Quarterly Report (Tallink Grupp Sustainability Report 2025 ENG)

CONSOLIDATED SUSTAINABILITY STATEMENT 2025

AS TALLINK GRUPP

Beginning of the financial year 1 January 2025

End of the financial year 31 December 2025

Contact Information

Commercial Registry no. 10238429

Address Sadama 5

10111, Tallinn Republic of Estonia

Phone +372 6 409 800

Fax +372 6 409 810

Website https://www.tallink.com

Main activity maritime transport

(passenger G cargo transport)

CONTENTS

BASIS FOR PREPARATION 5

INCORPORATION BY REFERENCE 6

Disclosure Requirements Covered by AS Tallink Grupp's Annual Report 2025 7

List of datapoints deriving from other EU legislation 11

SUSTAINABILITY STRATEGY AND GOVERNANCE 14

Climate Change Mitigation Strategy 15

Governance System 16

DOUBLE MATERIALITY ASSESSMENT 18

Methodology 18

OVERVIEW OF MATERIAL IMPACTS, RISKS, AND OPPORTUNITIES 25

Climate Change and Air Pollution 25

Own Employees' Working Conditions and Equal Treatment 26

Human Rights in the Value Chain 26

Customer Safety 27

Protection of Customer Data 27

Management of Business Relationships in the Supply Chain 28

ENVIRONMENTAL INFORMATION 30

EU Taxonomy Reporting 30

Climate Change 38

Pollution 46

SOCIAL INFORMATION 49

Employees 49

Workers in the Value Chain 57

Consumers and End-Users 57

GOVERNANCE INFORMATION 61

Whistleblowing 61

Supplier Relationships 62

‌BASIS FOR PREPARATION

The Sustainability Statement of AS Tallink Grupp for the financial year of 2025 covers the material environmental, social, and governance (ESG) activities, policies, and governance structures of the Group and its subsidiaries in the same boundaries as the Annual Report of the Group for the financial year of 2025. The sustainability reporting obligation arises from Section 31, section 4 of the Estonian Accounting Act. The statement has been prepared in accordance with the Corporate Sustainability Reporting Directive (CSRD), the European Sustainability Reporting Standards (ESRS) and the European Union's Taxonomy Regulation. Any financial information presented in this Sustainability Statement has been prepared in accordance with International Financial Reporting Standards (IFRS).

This Sustainability Statement provides a description of the Group's value chain, incorporating a double materiality assessment (DMA) that considers both upstream and downstream actors in the value chain, as well as input from internal and external stakeholders. The results of the DMA have determined the content of this Sustainability Statement. The statement maps the Group's value chain, focusing on key sustainability impact areas across maritime transport, hospitality, retail, and support services. Sustainability efforts are integrated across operational areas such as fleet management, logistics, and procurement to ensure alignment with the Group's overall strategy.

The current statement covers the Group's own operations (including all operations and employees across all markets), the upstream value chain (consisting of suppliers and business partners providing goods and services to the Group), and the downstream value chain (including customers using the Group's products or services). The data, objectives and action plans presented focus primarily on the Group's own operations due to the better availability and quality of data in this area.

AS Tallink Grupp has exercised the right to omit certain information according to targeted amendments to ESRS adopted by the European Commission in July 2025. The preparation of sustainability data involves making estimates in certain areas, such as the calculation of gross Scope 1-3 GHG data, which may impact reported figures. These estimates are formed based on historical experience, independent advice, external data, and other relevant information deemed reasonable under the circumstances. Unless stated otherwise, all calculations and methodologies follow the guidance provided within the ESRS framework. The Group's vessels' greenhouse gas emissions related to fuel consumption have been validated by an independent third party as required by the EU-MRV Regulation. Other metrics reported have not been validated by any external body other than the assurance provider. Further details on limitations and accounting principles are provided in the Accounting Policies section of the relevant chapters.

The Group has defined the following time horizons for itself for the purposes of the DMA, KPI-setting, action plans and the current statement: short-term: 2024-2027, medium-term: 2028-2035, and longterm: 2036-2050. The timeline was established based on the Group's action plans and schedules, and is aligned with capital allocation cycles, as well as the expected lifetime of its key assets (see page 121 of the Annual Report) and, existing project deadlines. It also takes into account international sustainability goal timelines, such as those outlined in the Paris Climate Agreement and the International Maritime Organization (IMO) targets. In 2024, the Group set several KPIs and targets to be achieved within the next few years, defining this period as the short-term timeframe. Many key industry medium-term targets have been set for the period 2030-2035, prompting the Group to align with these and define a similar range as its medium-term timeframe. International goals often designate 2050 as a key date for achieving significant environmental milestones, making it a logical endpoint for the Group's long-term timeframe.

‌INCORPORATION BY REFERENCE

The following table outlines the locations of ESRS disclosures that have been incorporated by reference and presented outside the Sustainability Statement, appearing in other sections of the Annual Report of AS Tallink Grupp for the financial year 2025.

DISCLOSURE REQUIREMENTS INCORPORATED BY REFERENCE

Disclosure requirement Data point(s) Section Page*

GOV-1 §21a Number of executive and non-executive members of

the Supervisory and Management Board

Corporate Governance Report

95-102

GOV-1

G1. GOV-1

§23a-b,

§5b,

§21c, §17

Members of the Supervisory and Management Board, roles of the different levels and types of governance bodies in the Group

Corporate Governance 97-102

Report

SBM-1 §42,

§42a-b

SBM-1 §40a i-ii,

40e-g

Business model and value chain The Group

Business strategy and products/services The Group Strategy

5-7

5-7

8

SBM-1 §40b Total revenue by significant ESRS sectors Management Report 15

*See more in the Annual Report

‌Disclosure Requirements Covered by AS Tallink Grupp's Annual Report 2025

The tables below provide an overview of ESRS datapoints that derive from other EU legislation and where this information can be found if deemed material.

GENERAL DISCLOSURES

General Disclosures

Disclosure requirement Section Page

BP-1 General basis for preparation of the sustainability statement Basis for Preparation 5

BP-2 Disclosures in relation to specific circumstances Basis for Preparation 5

GOV-1

The role of the administrative, management, and supervisory bodies Employee representatives on the Supervisory and Management Board

Percentage of independent Board members

Information provided to and sustainability matters addressed by

Corporate Governance Report Governance System Governance System

93-104*

16

16

GOV-2

the undertaking's administrative, management and supervisory bodies

Governance System 16-17

GOV-3 Integration of sustainability-related performance in incentive schemes

Governance System 16-17

GOV-4 Statement on due diligence Governance System 16-17

GOV-5 Risk management and internal controls over sustainability reporting Governance System 16-17

SBM-1 Strategy, business model and value chain

SBM-2 Interests and views of stakeholders

Material impacts, risks and opportunities and their interaction with

The Group Strategy

Management Report Sustainability Strategy and Governance

Stakeholder Engagement Stakeholder Priorities and Evaluations

Sustainability Strategy and Governance

5-7*

8*

14-15*

14-15

20

20-21

14-15

SBM-3

strategy and business model

Double Materiality Assessment 18-24

Overview of Material Impacts, 25-28

Risks, and Opportunities

IRO-1 Description of the process to identify and assess material impacts, risks and opportunities

IRO-2 Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Double Materiality Assessment 18-24 Incorporation by Reference 6-13

*See more in the Annual Report

ENVIRONMENT

Climate Change

Disclosure requirement Section Page

E1-1 Transition plan for climate change mitigation Sustainability Strategy and Governance

14-15

E1.GOV-3 Integration of sustainability-related performance in incentive schemes

Climate Change 38-41

Double Materiality Assessment 18-24

E1.SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model

Overview of Material Impacts,

Risks, and Opportunities Climate Change

25-28

38-41

E1.IRO-1 Description of the processes to identify and assess material climate-related impacts, risks and opportunities

Double Materiality Assessment 18-24

Pollution

Disclosure requirement Section Page

E2.IRO-1

Description of the processes to identify and assess material pollution-related impacts, risks and opportunities

Double Materiality Assessment 18-24 Overview of Material Impacts,

Risks, and Opportunities 25-28

E2-1 Policies related to pollution Pollution 46-48

E2-2 Actions and resources related to pollution Pollution 46-48

E2-3 Targets related to pollution Pollution 46-48

E2-4 Pollution of air, water and soil Pollution 46-48

Water and Marine Resources

Disclosure requirement Section Page

E3.IRO-1

Description of the processes to identify and assess material water and marine resources-related impacts, risks and opportunities

Double Materiality Assessment 18-24 Overview of Material Impacts,

Biodiversity

Risks, and Opportunities

25-28

Disclosure requirement Section Page

E4.IRO-1

Description of the processes to identify and assess material biodiversity and ecosystem-related impacts, risks and opportunities

Double Materiality Assessment 18-24 Overview of Material Impacts,

Risks, and Opportunities 25-28

E4.SBM-3

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

Double Materiality Assessment 18-24 Overview of Material Impacts,

Circular Economy

Risks, and Opportunities

25-28

Disclosure requirement Section Page

E5.IRO-1

Description of the processes to identify and assess material resource use and circular economy-related impacts, risks and

Double Materiality Assessment 18-24 Overview of Material Impacts,

opportunities

Risks, and Opportunities

25-28

SOCIAL

Own Workforce

Disclosure requirement Section Page

S1.SBM-2 Interests and views of stakeholders

Stakeholder Engagement Stakeholder Priorities and Evaluations

20

20-21

S1.SBM-3

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

Double Materiality Assessment 18-24 Overview of Material Impacts,

Risks, and Opportunities 25-28

S1-1 Policies related to own workforce Employees 49-56

S1-2 Processes for engaging with own workforce and workers' representatives about impacts

S1-3 Processes to remediate negative impacts and channels for own workforce to raise concerns

Taking action on material impacts on own workforce, approaches

Employees 49-56

Employees 49-56

S1-4

to managing material risks pursuing material opportunities related to own workforce, and effectiveness of those actions

Employees 49-56

S1-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Employees 49-56

S1-6 Characteristics of the undertaking's employees Employees 49-56

S1-9 Diversity metrics Employees 49-56

S1-10 Adequate wages Employees 54-56

S1-14 Health and safety metrics Employees 52-53

S1-16 Remuneration metrics (pay gap and total remuneration) Employees 54-56

Workers in the Value Chain

Disclosure requirement Section Page

S2.SBM-2 Interests and views of stakeholders

Stakeholder Engagement Stakeholder Priorities and Evaluations

20

20-21

S2.SBM-3

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

Double Materiality Assessment 18-24 Overview of Material Impacts,

Risks, and Opportunities 25-28

S2-1 Policies related to workers in the value chain Workers in the Value Chain Governance

57

61-64

S2-2 Processes for engaging with workers in the value chain and workers' representatives about impacts

S2-3 Processes to remediate negative impacts and channels for workers in the value chain to raise concerns

Taking action on material impacts on workers in the value chain,

Workers in the Value Chain Governance

Workers in the Value Chain Governance

57

61-64

57

61-64

S2-4

approaches to managing material risks pursuing material opportunities related to workers in the value chain, and effectiveness of those actions

Workers in the Value Chain Governance

57

61-64

S2-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Workers in the Value Chain Governance

57

61-64

SOCIAL

Affected Communities

Disclosure requirement Section Page

S3.SBM-2 Interests and views of stakeholders

Stakeholder Engagement Stakeholder Priorities and Evaluations

20

20-21

S3.SBM-3

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

Double Materiality Assessment 18-24 Overview of Material Impacts,

Consumers and End-Users

Risks, and Opportunities

25-28

Disclosure requirement Section Page

S4.SBM-2 Interests and views of stakeholders

Stakeholder Engagement Stakeholder Priorities and Evaluations

20

20-21

S4.SBM-3

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

Double Materiality Assessment 18-24 Overview of Material Impacts,

Risks, and Opportunities 25-28

S4-1 Policies related to consumers and end-users Consumers and End-Users 57-60

S4-2 Processes for engaging with consumers and end-users about impacts

S4-3 Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Taking action on material impacts on consumers and end-users,

Consumers and End-Users 57-60

Consumers and End-Users 57-60

S4-4

approaches to managing material risks pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Consumers and End-Users 57-60

S4-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Consumers and End-Users 57-60

GOVERNANCE

Business Conduct

Disclosure requirement Section Page

G1.GOV-1

The role of the administrative, supervisory, and management bodies

Stakeholder Engagement Stakeholder Priorities and Evaluations

20

20-21

G1.IRO-1

Description of the processes to identify and assess material impacts, risks, and opportunities

Double Materiality Assessment 18-24 Overview of Material Impacts,

Risks, and Opportunities 25-28

G1-1 Business conduct policies and corporate culture Governance 61-64

G1-2 Management of relationships with suppliers Governance 61-64

G1-3 Prevention and detection of corruption and bribery Governance 61-64

G1-4 Incidents of corruption or bribery Governance 61-64

‌List of datapoints deriving from other EU legislation

O material X not material -- phased in

The tables below provide an overview of ESRS datapoints that derive from other EU legislation, cf. ESRS 2 Appendix B and where this information can be found if deemed material.

GENERAL DISCLOSURES

General Disclosures

Disclosure requirement and related datapoint Regulation Page

SBM-1 X 40 (d) ii - Activity in chemical, controversial weapons, and/or tobacco

SFDR N/A

40 (d) iv industry

ENVIRONMENT

Climate Change

Pillar 3, Benchmark regulation

SFDR, Pillar 3, Benchmark regulation

N/A*

38-40

E1-5 O 37 Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors)

SFDR 45

E1-5 O 38 Energy consumption and mix SFDR 45

E1-5 O 40-43 Energy consumption and intensity from activities in high-climate-impact sectors

SFDR 45

E1-6 O 44 Gross Scope 1, 2, 3 and Total GHG emissions SFDR, Pillar 3, 44

Benchmark regulation

E1-6 O 53-55 Gross GHG emissions intensity SFDR, Pillar 3, 45

Benchmark regulation

E1-7 X 56 GHG removals and carbon credits EU Climate Law N/A

E1-9 -- 66 Exposure of the benchmark portfolio to climate-related physical risks

Benchmark regulation Phased in

E1-9 -- 66 (a) 66 (c)

Disaggregation of monetary amounts by acute and chronic physical risk

Location of significant assets at material physical risk

Pillar 3 Phased in

E1-9 -- 67 (c) Financial opportunities (cost savings, market size and changes to net revenue) from climate change actions

E1-9 -- 69 Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors)

* Not excluded from EU Paris-aligned Benchmarks

Pillar 3 Phased in Benchmark regulation Phased in

ENVIRONMENT

Pollution

Disclosure requirement and related datapoint Regulation Page

E2-4 O 28 Emissions to air, water, and soil SFDR 46-48

Water and Marine Resources

Disclosure requirement and related datapoint Regulation Page

E3-1 E3-4

X 9, 13, 14,

28 (c), 29

All disclosures SFDR N/A

Biodiversity

Disclosure requirement and related datapoint Regulation Page

E4-2 X 24 All disclosures SFDR N/A

Circular Economy

Disclosure requirement and related datapoint Regulation Page

E5-5 X 37, 39 All disclosures SFDR N/A

SOCIAL

Own Workforce

Disclosure requirement and related datapoint Regulation Page

S1-16 --

97 (a)

97 (b)

Unadjusted gender pay gap Excessive CEO pay ratio

SFDR, 55

Benchmark regulation 56

SFDR

S1-17 O

103 (a)

104 (a)

Incidents of discrimination

Severe human rights issues and incidents

SFDR

SFDR, 56

Benchmark regulation

SOCIAL

Workers in the Value Chain

Disclosure requirement and related datapoint Regulation Page

S2.SBM-3 O 11 (b) Significant risk of child labour or forced labour in the value chain

Human rights policy commitments

SFDR 26-27

26-28

Policies related to workers in the value chain

SFDR,

61-64

S2-1 O 17-19

Non-respect of UNGPs on Business and Human Rights, and

OECD guidelines

Due diligence policies

Benchmark regulation 61-64

17

S2-4 O 36 Human rights issues and incidents connected to its upstream and downstream value chain

Affected Communities

SFDR 62-63

Disclosure requirement and related datapoint Regulation Page

S3-1 S3-4

X 16, 17, 36 All disclosures SFDR,

Benchmark regulation

N/A

Consumers and End-users

Disclosure requirement and related datapoint Regulation Page

S4-1 O 16 Policies related to consumers and end-users SFDR 57-60

S4-1 O 17 Non-respect of UNGPs on Business and Human Rights, and OECD guidelines

SFDR,

Benchmark regulation

57-60

S4-4 O 35 Human rights issues and incidents SFDR 57-60

GOVERNANCE

Business Conduct

Disclosure requirement and related datapoint Regulation Page

G1-4 O 21 (a) Fines for violation of anti-corruption and anti-bribery laws SFDR,

Benchmark regulation

63-64

G1-4 O 24 (b) Standards of anti-corruption and anti-bribery SFDR 63-64

‌SUSTAINABILITY STRATEGY AND GOVERNANCE

The Group's sustainability objectives are aligned with its overall business strategy, reflecting the integration of key sustainability matters into its strategic framework. Information on the Group's strategy, a description of its services, markets and segments, and the number of its employees can be found in the Annual Report on pages 5-7 and 22. This section focuses on how sustainability matters are integrated into the Group's strategy, business model, and value chain. The Group's strategic cornerstones, as outlined in the Annual Report on page 8, inherently support sustainability principles without altering the Group's established objectives. These connections are reflected in the following areas:

→ Achieving the highest levels of customer satisfaction is directly linked to sustainability areas such as customer safety, data protection, and human rights. This strengthens customer trust and loyalty while upholding ethical business practices.

→ The Group's strategy to develop a wide range of high-quality services for a broad customer base is closely tied to fostering sustainable business relationships within the supply chain and implementing environmental practices that promote greener and more sustainable service delivery. The Group also recognises the importance of ensuring good working conditions for employees, as their well-being is essential for delivering quality services.

→ Improving profitability and strengthening market leadership are directly linked to tackling climate change and reducing air pollution, as protecting the environment and operating in a more environmentally friendly manner enhance competitiveness. The Group leverages energy-efficient technologies and green innovations, which have proven to deliver cost savings and contribute to both economic performance and environmental responsibility.

The description of the Group's value chain (see pages 18-19) takes into account the outcomes of the DMA, which identified the key stages where the Group's operations have the most significant environmental, social, and economic impacts. This analysis guided the integration of sustainability matters into the Group's strategic frameworks, ensuring that both the financial risks and opportunities associated with sustainability, as well as the Group's broader responsibilities towards stakeholders and the environment are addressed.

→ The Group requires energy and materials for its operations and, therefore, monitors advancements in sustainable fuel and renewable energy technologies.

→ Operational activities prioritise energy efficiency and adherence to regulatory requirements, supported by continuous investment in innovative technologies.

→ Services delivered to customers reflect the Group's commitment to quality and environmental

responsibility, as well as reducing emissions and meeting stakeholder expectations.

The Group engaged with stakeholders (see page 20-21) primarily as part of the DMA and their perspectives were integrated into the analysis to identify and prioritise material impacts, risks, and opportunities.

‌Climate Change Mitigation Strategy

AS Tallink Grupp has identified climate change mitigation as a material and strategic issue, given the significant role of its shipping operations in global greenhouse gas (GHG) emissions and the regulatory landscape. The development, approval, and execution of the transition plan for climate change mitigation is the responsibility of the Group's Management Board, who will collaborate with relevant experts and departments, as well as external experts and business partners. The Group is currently in the process of developing its transition plan, having conducted an initial workshop on the potential activities and framework in 2025. However, that the key levers for achieving the ambitious climate targets set for shipping remain unclear, and there is no definitive solution to the industry's challenge of identifying more sustainable and future-proof shipping fuels. Until a global consensus is reached on whether the next fuel for passenger vessels will be ammonia, hydrogen, green ammonia, biofuel, nuclear power, or some other option, the transition plans will remain indicative rather than prescriptive. The Group continuously monitors technical developments and trends in fuel and other technologies by participating in international industry and sector events, and by maintaining close contact with technology developers and relevant authorities.

The Group aims to reduce its absolute CO2 emissions within Scope 1 and Scope 2 in line with EU medium- and long-term targets, such as the FuelEU Maritime Regulation, as well as the objectives set by the International Maritime Organization (IMO). The EU Taxonomy Reporting containing financial data related to climate change mitigation can be found on pages 30-37.

Strategic principles for achieving the Group's KPIs and targets include the following:

→ AS Tallink Grupp will focus its main activities and investments on reducing GHG emissions from its shipping operations, as these account for the majority (2025: 68%, 2024: 63%) of its Scope 1 and Scope 2 emissions.

→ In addition to CO2 emissions, the Group will take action to reduce other harmful GHG emissions (e.g., methane, nitrous oxide). Thus, the Group refers to the strategy as GHG Emissions Reduction Strategy (and not decarbonisation strategy).

→ The Group's current focus is on achieving real GHG emission reductions from its own operations

and it only undertakes GHG offsetting initiatives that demonstrate proven environmental results.

The Group's implementation strategy is structured across short-, medium-, and long-term horizons:

→ Short-term (2024-2027) tactics for achieving GHG emission reductions mainly include sourcing and implementing technological solutions on board the Group's vessels to reduce fuel consumption and increase energy efficiency.

→ Medium-term (2028-2035) tactics for achieving GHG emission reductions also include implementing technological advances that enable vessels to increase energy efficiency and reduce fuel consumption, as well as collaborating with providers of carbon capture solutions.

→ The Group's measures for achieving medium-term onshore GHG emission reductions on a smaller scale include gradually transitioning to using renewable shore power during longer port stays, provided that the supply of such green energy is sufficient and the cost is not higher than that of other available energy solutions.

→ Long-term (2036-2050) tactics for achieving GHG emission reductions are based on the expectation and assumption that a sustainable alternative shipping fuel will be developed and made available to shipping companies within the next 5-10 years.

→ Medium- to long-term achievement of GHG emissions reductions additionally include sourcing and utilising viable biofuels, provided that they are available, legally permitted, cost-effective, and proven to deliver environmental benefits.

‌Governance System

The Corporate Governance Report of AS Tallink Grupp, prepared in accordance with the Estonian Accounting Act, provides information on the Group's organisational structure and governance, the members of its Supervisory Board and Management Board, and the roles of its governing bodies. See pages 95-102 of the Annual Report for further information.

Gender Ratio of the Supervisory Board Gender Ratio of the Management Board

Supervisory and Management Board

The Supervisory Board of AS Tallink Grupp comprises six members, all of whom receive remuneration from the Group. 16.7% of Supervisory Board members are independent (i.e., one out of six). There is no representation of employees or other workers on the Management or Supervisory Boards.

All five members of the Group's Management Board are wage-earning employees of the Group. Incentive schemes and remuneration policies for management and supervisory bodies are currently not linked to any sustainability matters, including emission reduction targets. Each member of the AS Tallink Grupp Management Board has clear responsibility for specific areas of the organisation's operations, governance, and policies.

Sustainability Management and Oversight

Sustainability action plans are led by the Group's Sustainability Reporting Manager (previously by the Group Head of ESG), who reports directly to a Management Board member. Sustainability topics are added to the Management Board's agenda on a regular basis, with an average frequency of at least once a quarter. The identification of the Group's impacts, risks and opportunities (IROs) is a continuous shared responsibility by the entire Management Board, which also oversees related action plans and KPI achievement, with support from the Group's Sustainability Reporting Manager.

Additionally, AS Tallink Grupp has an Internal Audit department, whose role is to provide independent and objective assurance that the organisation's risk management, governance, and internal control processes are operating effectively. As of 2025, this includes the implementation of controls over sustainability reporting procedures. During Q4 2025, the Group's Internal Audit department conducted an assessment of the organisation's governance practices and the management of sustainability risks, including leadership structures, business ethics, risk management processes, and the quality of sustainability reporting. All activities were carried out in line with the annual audit plan and findings were reported to the Management Board to ensure that identified risks were addressed. The fieldwork was led by the Group's Senior Specialist from the Internal Audit department in cooperation with the Group's Sustainability Reporting Manager.

The Group works with external experts and consultants where additional knowledge or expertise in certain areas is needed. In 2025, external support was used for the DMA review process and the development of new data collection and calculation processes for Scope 1, 2, and 3 GHG emissions. AS Tallink Grupp relies exclusively on established consultancy firms for advisory services. Additionally, the expertise of climate, ESRS, and CSRD specialists has been utilised to complement the Group's in-house knowledge in GHG emissions methodologies and calculations. Data collection methodologies are developed and implemented in collaboration with the finance team and controllers, and data quality is verified by internal experts, to ensure accuracy and consistency.

Risk Management and Sustainability Reporting

The Group does not have a formalised risk management framework dedicated specifically to IRO-related matters. Nevertheless, risks related to sustainability matters are regularly reported to the Management Board by department heads and specialists. These risks are addressed on a case-by-case basis, without separate prioritisation, and are managed on the same basis as other business risks. The key risks relating to sustainability matters raised during the reporting period were associated with preparations for CSRD-compliant reporting and policy updates in key IRO and legal areas, such as carbon emission reductions, the European Commission's Omnibus proposal, and supply chain governance, as well as carbon reduction strategies and action plans. For major strategic decisions, such as fuel procurement, sustainability matters are considered, including the environmental impact and implications for employees. To ensure proactive risk management and compliance with applicable requirements, regular meetings are held with key stakeholders to identify sustainability reporting risks, and these risks are regularly discussed at board meetings.

As part of its commitment to responsible business conduct, AS Tallink Grupp has implemented a due diligence process to identify, assess, prevent, mitigate, and remediate actual and potential impacts on people and the environment. This approach aligns with internationally recognised frameworks, including the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises. Below is a mapping of the core elements of due diligence that are structurally linked to the relevant disclosures in this Sustainability Statement.

Responsible business conduct inoperations

Engaging with affectedstakeholders

Identifying and assessing adverseimpacts

Cease, prevent, or mitigateimpact

Track implementation andresults

‌DOUBLE MATERIALITY ASSESSMENT

‌Methodology

During the financial year, the Group conducted a review of its 2024 DMA process, results, and conclusions to assess their validity. This involved evaluating the relevance of the established KPIs and confirming the continued applicability of the 2024 conclusions. The results of the 2025 review confirmed that the 2024 conclusions were still accurate and applicable, as the Group's business activities and external environment had not changed significantly.

The DMA review was based on the Group's internal expert assessment. Stakeholder expectations were considered indirectly by drawing on regulatory requirements and insights derived from regular interactions with stakeholders, including direct communication. In total, four workshops were held, with the involvement of department managers and/or specialists responsible for each sustainability topic. The IROs of each topical standard were addressed in separate workshops to assess the relevance of the topics identified as material in 2024, taking into account the developments that had occurred during the reporting year. The results were confirmed by the Management Board at regular board meetings.

Regular stakeholder engagement takes place through various channels, including in-person meetings, quarterly coffee mornings with the CEO, scheduled meetings with business partners, supplier seminars, and customer interactions via e-communication and Group-owned channels. Regular surveys and other forms of feedback also provide valuable insights that are reviewed at management meetings and incorporated into the Group's decision-making processes.

The following sections provide an overview of the Group's 2024 double materiality assessment process,

including its scope, methodology, and key outcomes.

Business Process and Mapping of Impacts, Risks, and Opportunities

AS Tallink Grupp began its double materiality assessment by analysing its economic activities and supply chain based on data from previous annual reports. This business process analysis identified how the Group affects the broader environment and society, and conversely, how external factors influence the Group. The analysis was conducted during a structured workshop with the Management Board, key department heads, and internal experts. The outcomes were then used to identify and assess the Group's IROs.

Before the assessment, the Group compiled a preliminary list of potential IROs derived from its main sustainability impacts and stakeholder feedback. The mapping process included reviewing relevant sustainability standards and regulations, analysing the results of stakeholder engagement activities, and identifying areas where the Group's operations have, or are affected by, environmental, social, or governance impacts. The list was then refined and validated through an internal workshop where employees from relevant departments completed structured assessment tables, guided by standardised materials. External experts reviewed the results to ensure consistency and objectivity. The final IROs were approved by the Management Board after further discussions and adjustments.

‌The Group's Value Chain

The primary stakeholders in the Group's value chain include employees, suppliers (fuel, technology), business partners (ports, financing partners, investors), customers (tour operators, loyal customers), investors, and authorities. The secondary stakeholders include the wider supplier and business partner network, communities, NGOs, and the media.

Although these groups were invited to participate in the stakeholder survey, their involvement remained limited. As primary stakeholders are directly linked to the Group's operations, they were prioritised during the first DMA cycle in 2024. While secondary and tertiary stakeholders were also identified during the process, they were not included in the assessment for 2024 and 2025. The Group intends to expand engagement with these groups in future DMA cycles.

Inbound Logistics

Sourcing more sustainable marine fuels (LNG, biofuels) and traditional fuels from suppliers. Procuring vessels from shipbuilders and retrofitting older vessels to enhance fuel efficiency.

Operations

PRIMARY ACTIVITY

Providing ferry and cruise services across the Baltic Sea (Estonia, Finland, Sweden). Optimising routes to reduce fuel consumption, managing waste responsibly on vessels, and implementing energy-efficient practices. Offering dining, shopping (travel retail), and entertainment services onboard. Sourcing local and sustainable products where possible, reducing single-use plastics, and improving energy efficiency (e.g., lighting, HVAC systems).

Outbound logistics

Delivering cargo to ports and managing logistics for efficient loading/unloading. Collaboration with green logistics partners and using electric vehicles where reasonable.

Marketing S Sales

Managing ticket sales (both online and through agencies), conducting marketing campaigns, and enhancing the onboard customer experience. Offering digital tickets and promoting sustainability initiatives. Providing travel retail services both onboard ferries and in onshore shops, as well as through online platforms. Focusing on sustainable product offerings.

Services

Providing hospitality services at onshore hotels and restaurants, with a focus on sustainability (e.g., sourcing local food, reducing waste, improving energy efficiency). Decommissioning vessels responsibly, in accordance with EU regulations. Recycling ship materials and components, promoting circular economy practices.

Governance S Compliance

Ensuring compliance with EU regulations, including CSRD and ESRS.

Human Resources

SUPPORT ACTIVITY

Providing training and development for staff, with a focus on customer service, sustainability practices, and safety. Supporting continuous learning, especially in environmental and safety protocols.

Technology S Innovation

Investing in advanced technologies like emission control technologies and digital tools for optimising routes and fuel consumption. Implementing innovative solutions to reduce environmental impacts.

Procurement

Engaging with suppliers and stakeholders to source eco-friendly materials, products, and services across all operations, from fuel procurement to retail goods. Preferring local, sustainable, and fair-trade products.

‌Stakeholder Engagement

During the 2023-2024 double materiality assessment process, the Group engaged with its primary stakeholders. A structured online questionnaire was distributed to employees, customers, suppliers (including their workers in the value chain), investors, and other business partners to evaluate the relevance and significance of sustainability topics. Stakeholders were invited to share their perspectives on the importance of various sustainability areas. They were also asked to evaluate AS Tallink Grupp's impacts and associated risks in these areas. Additionally, all respondents were given the opportunity to elaborate on their views through open-ended questions, which many utilised to provide deeper insights. The survey was complemented by focus group discussions and interviews to validate and expand upon the initial results.

While specific affected communities were not directly engaged in the survey, all other stakeholder groups acted as representatives of communities' interests regarding sustainability matters. Although outreach efforts were made to engage key customers and authorities, this proved less successful. Nevertheless, the insights gathered from other stakeholders provided a solid basis for identifying material topics and understanding which sustainability topics were most relevant to the Group's operations and value chain. The results of all engagement activities were reviewed and discussed by the Management Board at regular board meetings.

The Group recognises that its impact on society and the environment extends beyond its direct operations and that its long-term success depends on maintaining positive and constructive relationships with all key stakeholders. Continuous and substantive dialogue helps align business activities with social and environmental expectations, strengthens collaboration, improves service quality, and mitigates risks.

Stakeholder expectations and suggestions were gathered through meetings, surveys, and feedback forms. These activities were an integral part of the DMA process, in which sustainability-related information was exchanged, and stakeholder expectations were mapped. An additional survey was conducted to understand which sustainability topics stakeholders consider most significant and where the Group's operations have the strongest impact. The results were validated through in-depth interviews and focus group meetings with representatives of several key stakeholder groups.

The Group aims to continue and enhance its stakeholder engagement, expand information exchange, and further refine its mapping of expectations and impact assessments during the future reporting periods.

Stakeholder Priorities and Evaluations

The survey results reflected strong interest across all key sustainability areas, with nearly all topics receiving an average rating of above 4 on a 0-5 scale. However, the Group acknowledges that survey results alone are insufficient for prioritising activities, as resources must be allocated to areas with the most significant actual or potential impacts. Consequently, the Group's list of material topics does not align directly with the survey results but also considers other factors. Some topics, such as marine pollution from ships, are tightly governed by International Maritime Organisation (IMO) conventions, reducing the need for additional prioritisation.

The interviews generated concrete suggestions and expectations specific to each stakeholder group, many of which will inform ongoing cooperation even if they do not appear explicitly in this report. Expectations of policymakers were not surveyed separately, as they are reflected in evolving legislation and international agreements. Compliance and alignment with these regulations remain fundamental to the Group's operations.

A recurring message across all stakeholder groups was the need for continuous and transparent communication on sustainability-related topics. This report responds to that expectation by presenting consolidated findings and outlining the Group's future commitments. Based on current feedback, the Group has not modified its business model or strategic direction but will continue to review stakeholder expectations.

Stakeholders' assessments of topic materiality: average scores on a scale from 0 (immaterial) to 5 (highly material)

Key topics highlighted by stakeholder groups

Double Materiality Assessment 2024

The stakeholder and value chain analysis described above provided the foundation for the double materiality methodology. The following section outlines the detailed assessment framework and criteria applied to identify and prioritise the Group's impacts, risks, and opportunities.

The IROs identified and assessed for AS Tallink Grupp and its value chain have been aligned with, and mapped against, the sustainability matters outlined in the topical ESRS standards. The identification followed a top-down approach, guided by strategic-level decision-making. For material IROs covered by a topical standard, the required ESRS disclosures are provided. For entity-specific topics, the minimum disclosure requirements serve as the basis for reporting on policies, actions, targets, and metrics. For a detailed index of information covered in this Sustainability Statement, see pages 6-13. The analysis was carried out on a consolidated basis, encompassing all entities within AS Tallink Grupp and its subsidiaries.

All sustainability matters where the Group both influences and is influenced by the external environment were identified through an analysis of the business model and value chain. This process defined specific impacts, risks, and opportunities over short-, medium-, and long-term time horizons. Of the defined IROs only negative impacts and risks were considered relevant. This reflects prevailing geopolitical and economic challenges, which currently constrain the potential for positive development. Although potential opportunities and positive impacts were also considered, none were identified as material at the time of the analysis.

The assessment distinguished between actual impacts, which have already occurred or are certain to occur, and potential impacts, which may develop over time. The materiality of actual impacts was evaluated based on their severity, while emerging impacts were assessed by considering both their likelihood and severity. Severity assessments factored in the scale, scope, and irremediability of consequences. The risk assessment included an evaluation of both the magnitude of the risk and its likelihood of occurrence.

AS Tallink Grupp assessed climate-related impacts using historical GHG data as an input. The assessment of GHG emissions was based on the GHG Protocol methodology. Additionally, the analysis of the impact of climate change on the Group's activities, conducted within the framework of the EU Taxonomy for Sustainable Activities, was used as an input. In analysing both climate change and other thematic areas, key sources of information included assessments from the Group's in-house subject matter experts, as well as research and survey findings and reports such as the Eurobarometer on Climate Change, EU Climate Strategies and Targets, EU Progress on Climate Action, and the Estonian Climate Change Adaptation Development Plan until 2030.

The methodology for AS Tallink Grupp's double materiality assessment was developed by the Estonian Center for Applied Sciences CentAR. Based on sustainability topics aligned with the classification outline in the ESRS, it integrates stakeholder input gathered through an anonymous online survey, focus group discussions, and interviews with key partners. Specific sustainability impacts were identified through a filtering process that combined the Group's preliminary internal mapping with stakeholder feedback and interview insights. Explanatory notes were prepared to clarify the key aspects and context of each identified impact. To ensure a fact-based evaluation of material impacts, the data collection covered recent operational data, internal rules and procedures, as well as relevant international agreements and national regulations applicable to AS Tallink Grupp. The likelihood of impacts was assessed for the short, medium, and long term, and expressed as a percentage estimate.

In assessing the Group's potential impacts on the natural environment and people across all ESRS sustainability matters, three additional criteria were evaluated alongside likelihood: the scale, scope, and irremediability of the impact. Each was rated on a 0-5 scale, where higher values indicate broader, more severe, and less reversible impacts.

In assessing the risks and opportunities associated with all ESRS sustainability matters, the evaluation covered factors arising from the natural (including physical), business, social, and regulatory (including transition) environments. These risks and opportunities may also result from previously identified impacts and dependencies. The assessment considered their potential effects on the Group's development, financial position, performance, cash flows, and cost of capital over the short, medium, and long term. The assessment was conducted on a 0-5 scale, reflecting the potential financial impact, which is typically measured through estimated profit reduction or the ratio of additional costs to net profit. Scores ranged from 0, indicating no material effect on profitability, to 5, representing either a profit reduction exceeding 50%, or a scenario in which business continuity is at risk.

The overall evaluation reflected the Group's consolidated assessment of whether its impact on the environment and people, or the surrounding environment's impact on the Group, is considered material. When an issue is identified as material, a detailed overview of its current status, plans, objectives, and related information is included in AS Tallink Grupp's Sustainability Statement. Materiality is determined based on a scoring matrix, where a total score of 4 or higher indicates a material impact. In the case of a negative impact on human rights, the severity score of the impact determines the final materiality score. In such cases, the probability of the impact occurring is irrelevant.

Materiality assessment matrix of an IRO

‌OVERVIEW OF MATERIAL IMPACTS, RISKS, AND OPPORTUNITIES

Based on stakeholder assessments and expectations, as well as an evaluation of all potential impacts, risks, and opportunities identified, in 2024 the Group's ESG working group focused primarily on identifying material impacts and risks. AS Tallink Grupp identified six key impact areas, encompassing a total of nine specific issues that will receive heightened attention in the coming years. The 2025 DMA review confirmed that no changes had occurred in these IROs compared with the 2024 assessment, indicating that these impact areas remained accurate and applicable.

‌Climate Change and Air Pollution

AS Tallink Grupp's GHG emissions primarily originate from shipping, with additional emissions arising from shore-based operations and hotel services. The Group manages its emissions to ensure they align with the goal of mitigating climate change by focusing on improving energy efficiency, reducing fuel consumption, and meeting emerging regulatory requirements. The table below outlines the emission sources, related IROs, and the objectives set for the reporting period.

Topic IRO type Origin Time horizon

GHG emissions from vessels and other equipment and sources

GHG emissions as a result of purchased energy

Actual impact (negative) Own operations Short- and medium-term

Actual impact (negative) Upstream value chain Short- and medium-term

Objective Baseline (2023) Reporting year (2025) Target (2030)

Reduce the Group's Scope 1 and Scope 2 emissions

Meet the requirements of FuelEU Maritime Regulation

423 211 tCO₂e 443 057 tCO₂e Per annum reduction of at

least 2% (in absolute terms)

91.6 grams CO₂e per MJ 91.6 grams CO₂e per MJ In line with FuelEU Maritime

regulation

The Group's commitment to reducing GHG emissions and meeting the requirements of the FuelEU Maritime regulation enhances its resilience to changing regulations and market expectations, supporting financial stability and operational continuity over the medium term. The Group recognises that Scope 1 and Scope 2 GHG emissions represent its most material environmental impact and have direct financial implications. By achieving a 2% annual reduction in those emissions, the Group expects to mitigate the impact of potential carbon taxes and improve operational efficiency. While the exact financial impacts are subject to carbon market fluctuations, detailed disclosures will be provided in subsequent reports as more data becomes available. The DMA confirms that the Group's business activities do not have any material impacts, risks or opportunities relating to water and marine resources, biodiversity and ecosystems, or circular economy and resource use that are not already sufficiently covered by disclosures under other topical standards. Additionally, as the Group has no operational sites in or near biodiversity-sensitive areas, it has concluded that there is no need for any special mitigation measures. Although water pollution was not identified as a material matter, the Group has still decided to report on its initiatives in this area due to high stakeholder interest and to maintain historical continuity.

‌Own Employees' Working Conditions and Equal Treatment

No material issues were identified regarding own employees' working conditions. However, ensuring the health and safety of its employees remains a priority for the Group. Workplace accidents and health risks can affect employee well-being and may result in financial implications related to compensation claims, regulatory non-compliance, and operational disruptions.

The Group prioritises the prevention of workplace injuries and fatalities through continuous safety monitoring, training, and risk management. Maintaining a low Lost Time Injury Frequency Rate (LTIFR) and preventing fatal accidents supports a reliable and efficient working environment, which in turn reinforces the Group's resilience and long-term operational stability.

Topic IRO type Origin Time horizon

Maintain the number of workplace accidents at the current level or reduce further

Risk Own operations

Short-, medium-, and longterm

Own workers' health and safety at work

Risk Own operations Short-, medium-, and longterm

Objective Baseline (2023) Reporting year (2025) Target (2030)

Maintain the LTIFR level at or below

the baseline across the Group in the short term and reduce the LTIFR level in the long term

Maintain a 0 fatal work accident level

LTIFR baseline: 13.3 6.3 Maintain a low LTIFR level

across the Group (excl. fatal incidents resulting from underlying health issues)

Number of fatal work accidents: 0

0 Number of fatal work

accidents: 0

‌Human Rights in the Value Chain

The Group acknowledges the importance of identifying and addressing human rights risks concerning workers in its supply chain, particularly those relating to child labour and unsafe working conditions. While no specific violations have been identified to date, these risks remain material due to the complexity of global supply chains. The Group addresses these risks through a due diligence process that protects workers' rights and mitigates financial risks such as legal penalties and supply chain disruptions. Strengthening human rights in the supply chain supports the Group's long-term resilience and aligns with stakeholder expectations for ethical business practices. For the purposes of this Sustainability Statement, the Group's supply chain is defined as consisting of Tier I suppliers.

The following strategic goals and objectives are interconnected with those described in the supply chain and management of business relations sections. In line with ESRS reporting requirements, the focus is on material upstream and downstream value chain matters rather than a full mapping of all supply chain actors. Human rights considerations related to other parts of the value chain, such as the Group's own workforce, consumers, and end-users, are addressed in the respective chapters of this Sustainability Statement.

Topic IRO type Origin Time horizon

Ensuring that human rights are

protected across the value chain, with a particular focus on the supply chain

Risk Upstream value chain Short-, medium-, and long- term

Objective Baseline (2023) Reporting year (2025) Target (2030)

Improve the effectiveness of the due diligence process in the supply chain that is part of the Group's regular supplier audits

All large and strategic suppliers

The Group carries out 10-15 general supplier audits per annum according

to its annual audit plan. No ESG 9

related violations have been identified during those audits

Maintain level of zero ESG related violations identified during regular supplier audits

comply with the Group's Supplier Code of Conduct

Compliance level: 100% 100% Maintain baseline level

‌Customer Safety

Passenger safety remains a high priority for AS Tallink Grupp, as identified by stakeholders and internal assessments. Ensuring safety across all operations is essential for maintaining customer trust and satisfaction, as well as for mitigating the risk of financial loss and reputational harm. The Group's proactive safety management, supported by comprehensive protocols and regular training programmes, strengthens operational resilience and fosters long-term stability.

Topic IRO type Origin Time horizon

Ensure customer safety across operations, with a particular focus on safety in maritime transport

Risk Own operations

Short-, medium-, and longterm

Objective Baseline (2023) Reporting year (2025) Target (2030)

Prevent serious incidents leading

to significant losses (human, financial, data, or other)

Number of serious incidents: 0 0 Number of serious incidents: 0

‌Protection of Customer Data

The Group prioritises protecting customer data to prevent breaches, ensure compliance with data protection regulations, and maintain customer trust. Effective data protection practices mitigate the risk of potential financial loss, such as fines under the General Data Protection Regulation (GDPR), and safeguard against reputational harm. The Group's strategy includes regular risk assessments, and employee training programmes. These measures ensure resilience against emerging threats and support the Group's long-term commitment to operational excellence and customer satisfaction.

‌Management of Business Relationships in the Supply Chain

The Group has identified supply chain transparency and due diligence as material topics due to their relevance to workers' rights and environmental sustainability. Compliance with the Supplier Code of Conduct is monitored through regular supplier audits, which help mitigate the risk of non-compliance and ensure adherence to sustainability requirements. These measures safeguard the Group's reputation and reduce financial risks associated with supply chain disruptions and regulatory penalties. Strengthening the due diligence process further enhances the Group's resilience against evolving sustainability risks and supports long-term operational stability.

No significant governance related issues were identified during the DMA. However, the analysis indicated an increased level of risk related to supply chain disruptions. The Group recognises the need to enhance its understanding of the activities within its value chain.

Topic IRO type Origin Time horizon

Supplier and supply chain transparency and due diligence

Risk Upstream value chain Short-, medium-, and long- term

Objective Baseline (2023) Reporting year (2025) Target (2030)

100% of the Group's strategic and

All large suppliers meet the requirements set out in the Group's Supplier Code of Conduct

Improve the effectiveness of the

large suppliers are familiar with and committed to the Group's Supplier Code of Conduct (contracts in excess of EUR 50 000)

The Group carries out 10-15

100% Maintain baseline level

due diligence process in the supply chain that is part of the Group's regular supplier audits

general supplier audits per annum according to its annual audit plan. No ESG related violations have been identified during those audits

No ESG violations have been identified.

Maintain level of zero ESG related violations identified during regular supplier audits

Double materiality matrix 2024

‌ENVIRONMENTAL INFORMATION

‌EU Taxonomy Reporting‌

In accordance with Article 8 (1) of the Taxonomy Regulation (EU) 2020/852, the Group is required to report how and to what extent its economic activities are aligned with environmentally sustainable economic activities as defined in the EU taxonomy. For this purpose, the Group has followed the relevant delegated acts, including the Delegated Regulation (EU) 2021/2178, Delegated Regulation (EU) 2021/2139, and Delegated Regulation (EU) 2023/2486, together with the amendments introduced by Delegated Regulation (EU) 2026/73 of 4 July 2025. The Taxonomy Regulation covers economic activities that can contribute to six environmental objectives:

→ Climate change mitigation

→ Climate change adaptation

→ Sustainable use and protection of water and marine resources

→ Transition to a circular economy

→ Pollution prevention and control

→ Protection and restoration of biodiversity and ecosystems

Under Article 8 (2), the Group, as a non-financial undertaking, is required to disclose key performance indicators relating to turnover, capital expenditure and operating expenses. In 2025, two (2024: three) of the Group's economic activities were taxonomy-eligible:

→ transportation of freight by sea and coastal waters (CCM S CCA 6.10) and

→ transportation of passengers by sea and coastal waters (CCM S CCA 6.11).

The Group's other activities, which include onboard restaurant and sales services, onshore restaurant services, online shop, and other onshore business are classified as taxonomy non-eligible activities. This applies also to the operation of vessels that do not provide transportation services but are used to provide accommodation services to refugees. The Group is not involved in the construction, operation, or financing of nuclear energy or fossil gas facilities.

In line with the option provided by the legislation, starting from this reporting year the Group has decided to apply the 10% materiality threshold when assessing eligibility and alignment for activities that are not material from the Group's perspective, as set out in Commission Delegated Regulation (EU) 2026/73. Based on this, hotel services have been excluded from the 2025 statement, as their impact does not exceed the established materiality threshold. Since the change affects eligibility rather than alignment, the statement remains comparable with previous periods.

The Group has presented key performance indicators at the consolidated group level, and split these between different economic activities, to avoid double counting.

KPIs related to the EU taxonomy - summary (millions of euros)

KPIs related to the EU taxonomy - turnover (millions of euros)

KPIs related to the EU taxonomy - capital expenditure (millions of euros)

KPIs related to the EU taxonomy - operating expenses (millions of euros)

Accounting Policies: Eligibility

The KPIs presented in this statement have been calculated according to the Commission Delegated Regulations as follows:

→ Proportion of turnover = turnover of taxonomy-eligible activities / total turnover

→ Proportion of capital expenditure (CapEx) = CapEx of taxonomy-eligible activities / total CapEx

→ Proportion of operational expenditure (OpEx) = OpEx of taxonomy-eligible activities / total OpEx

The turnover from taxonomy-eligible activities includes vessels' ticket revenue, revenue from the chartering of vessels, and cargo revenue. The turnover from taxonomy-eligible activities does not include revenue from onboard and onshore restaurant and retail services, from hotel services, or the online shop. The total turnover used to calculate the proportion of taxonomy-eligible activities in the Group's turnover includes total turnover without exceptions.

Capital expenditure related to taxonomy-eligible activities consists of investments in the Group's sea-going vessels. Due to the nature of the Group's economic activities, its vessels carry both passengers and cargo, therefore investments in vessels contribute to both types of activities. Technical investments in the Group's vessels are divided equally between passenger and freight transport activities. Capital expenditure related to the public areas of the vessels are allocated between activities according to the share of passengers and cargo drivers among the total number of passengers. The capital expenditure used to calculate the proportion of taxonomy-eligible activities in the Group's capital expenditure includes total capital expenditure, excluding adjustments to lease agreements recognised in accordance with IFRS 16.

Operating expenses related to taxonomy-eligible activities include costs directly related to the maintenance of vessels to ensure their continued and efficient operation. Operating expenses are broken down between passenger and cargo transport as follows: the operating expenses of cruise vessels are equally split between passenger and freight transport activities, and the operating expenses of cargo vessels are fully allocated to freight transport. Total operating expenses for calculating the share of taxonomy-eligible activities in the Group's operating expenses include total costs related to maintenance of the Group's assets such as direct service and technical maintenance costs, personnel costs related to service and technical maintenance, the cost of external asset maintenance services, and the costs arising from the development and maintenance of the IT equipment of vessels.

Contextual (qualitative) Information

In accordance with Annex I to the Taxonomy Regulation, the Group is obliged to explain its key performance indicators and the reasons for any changes in these indicators during the reporting period. There were revisions to the methodology used to calculate eligibility figures:

→ The Group has decided to apply a materiality threshold of 10% when assessing eligibility and alignment for activities that are not material from the Group's perspective. Therefore, hotel services have been excluded from the 2025 statement.

Accounting Policies: Alignment Assessment

According to Article 3 of Regulation (EU) 2020/852, an activity is environmentally sustainable (i.e., taxonomy-aligned), if it:

→ contributes substantially to one or more of the environmental objectives,

→ does not significantly harm any of the environmental objectives,

→ is carried out in compliance with the minimum safeguards.

Substantial Contribution

The Group's substantial contribution to climate change mitigation through transportation of freight by sea and coastal waters (CCM 6.10) and transportation of passengers by sea and coastal waters (CCM 6.11) was assessed according to the technical criteria listed in Annex I to Delegated Regulation (EU) 2021/2139. The assessment was carried out vessel by vessel. First the Group calculated the EEXI (Energy Efficiency Existing Ship Index) value of a ship. In the case of passenger vessels, the EEXI value was compared to the threshold provided by the technical screening criteria in Annex I 6.11 (c) 1 to Delegated Regulation (EU) 2021/2139. Where the value of EEXI was below the threshold, the taxonomy-eligible turnover, capital expenditure and operating expenses that were associated with that vessel were classified as substantially contributing to climate change mitigation. For cargo vessels, the Group used the threshold provided by the technical screening criteria in Annex I 6.10 (c) to Delegated Regulation (EU) 2021/2139. Due to methodological reasons, it was not possible to calculate the EEXI values for two of the Group's newest vessels (Megastar and MyStar). The indicators of these vessels were classified as not aligned with the EU taxonomy. In addition, the vessels for which the EEXI values exceeded the required criteria were considered as not aligned with the EU taxonomy.

To evaluate the Group's substantial contribution to climate change adaptation through transportation of freight by sea and coastal waters (CCA 6.10) and transportation of passengers by sea and coastal waters (CCA 6.11) a climate risk and vulnerability assessment (as foreseen in Delegated Regulation (EU) 2021/2139, Annex I, Appendix A) was conducted in 2022, which revealed minor negative impacts from climate risks, which have been addressed through appropriate adaptation measures. At the beginning of 2025, the risk assessment was reviewed and updated to ensure alignment with the most recent Intergovernmental Panel on Climate Change Assessment report (AR6). As no significant changes were identified in the Group's vulnerability to climate risk, it was concluded that the adaptation measures in place remain sufficient to mitigate identified risks. The same assessment also applies to the Do No Significant Harm (DNSH) criteria within activities contributing to climate change mitigation. Resilience to these risks is further described in the Climate Change section of this Sustainability Statement.

‌1 The screening criteria provide value for the EEDI (Energy Efficiency Design Index), however, the EEDI is calculated only for new ships and not for existing ones. As the calculation principle is the same and the Group's fleet consists of existing ships that have no EEDI value, EEXI is used instead of the EEDI.

Do No Significant Harm

Taxonomy-aligned services in the Baltic Sea are subject to stricter environmental criteria than those in the rest of the world and Europe, on average. The Do No Significant Harm (DNSH) principle is closely followed in daily operations and the Group's activities 6.10 and 6.11 are aligned with the DNSH principle according to the technical screening criteria established in Delegated Regulation (EU) 2021/2139 as described in the table below.

Environmental objective

Climate change

CCM 6.10

CCA 6.10

CCM 6.11

CCA 6.11

Compliance

The Group has no vessels dedicated to the transport of fossil

N/A N/A N/A

mitigation

fuels

Climate change adaptation

Water

Circular economy

Pollution prevention

Biodiversity

N/A N/A Climate risk and vulnerability assessment is carried out;

appropriate adaptation measures are in place

Risks have been identified, a zero-spill policy has been

Plans are applied across the Group's shipping operations

Measures are in place for waste prevention and handling;

Convention as well as relevant EU regulations

Proven compliance with Annexes VI and IV to the IMO

Regulation (EU) No 528/2012

Appropriate measures are in place to prevent the introduction of non-indigenous species;

Noise and vibrations are limited in line with the IMO guidance

Zero-spill policy is in place

Support for projects that aim to protect the Baltic Sea marine environment

Minimum Safeguards

An overview of the applied minimum safeguards is provided in the Governance chapter of this Sustainability Statement.

Alignment with the Taxonomy

In 2025, the decrease in the proportion of taxonomy-aligned operating expenses can be primarily attributed to a larger portion of the Group's economic activities being conducted by taxonomy non-aligned vessels. For example, for the Group's newer ships that are equipped with modern propulsion systems (such as MyStar and Megastar) the Energy Efficiency Design Index (EEDI) is not issued and the Energy Efficiency Existing Ship Index (EEXI) cannot be calculated. These indexes have been utilised by the Group to determine which ships are considered taxonomy-aligned, which in turn forms the basis for taxonomy alignment calculations. Despite the new ships being more environmentally friendly than the older ones, they have been categorised as not aligned due to the reasons mentioned above. The proportion of taxonomy-aligned capital expenditure increased compared to 2024 due to a higher proportion of investments in vessels that are considered taxonomy-aligned.

‌Climate Change

As shipping is recognised as a high-impact sector, climate change represents a key environmental and business concern for AS Tallink Grupp. The Group's DMA confirmed that its most significant impacts and risks are related to GHG emissions from shipping operations and purchased energy.

Emissions from shipping operations (Scope 1) have an actual negative impact in the short and medium term, with potential long-term risks. Emissions from purchased energy used by the Group (Scope 2) have an actual negative impact in the short and medium term, with potential medium- and long-term risks.

Climate Risk and Business Model Resilience

A climate-related risk assessment was conducted in line with the EU Taxonomy Regulation in 2024, with the assistance of an external environmental expert. The assessment focused on identifying climate-related IROs relevant to the Group's operations, while also informing the internal business model resilience analysis aimed at providing input for short-term decision-making and tactical activity planning.

The resilience analysis considered the full scope of the Group's operations and value chain in accordance with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). Two climate scenarios were applied to evaluate potential short-, medium-, and long-term effects on operations, assets, and financial performance.

1. Low-Carbon Transition Scenario (aligned with 1.5 °C or 2 °C warming limit)2

   This scenario assumes that governments and businesses implement stringent climate policies, leading to rapid decarbonisation and the widespread adoption of clean technologies. In the short term, AS Tallink Grupp will face increased capital expenditure for fleet modernisation and transition to cleaner fuels. In the medium to long term, however, these investments are expected to result in lower carbon costs, improved efficiency, and a stronger reputation as a sustainable operator.

2. High-Impact Climate Change Scenario (3 °C+ warming scenario)2

This scenario assumes limited or no global action on climate change, leading to higher global temperatures, increased extreme weather events, and greater disruption to ecosystems and economies. In the short term, the Group could face more frequent extreme weather events, sea ice variability, and operational disruptions. Over the medium and long term, adaptation measures such as resilient infrastructure and optimised logistics will be critical to maintaining operational continuity and controlling costs.

For both scenarios, the Group assessed transition and physical risks, including the risk of regulatory changes (such as the IMO decarbonisation strategy), market and technology risks (including sustainable fuel availability, capital requirements, and stranded assets), and reputational considerations linked to decarbonisation progress. The analysis confirmed that the efficiency improvements, decarbonisation investments, and fleet upgrades already undertaken provide a competitive advantage, particularly on the Tallinn-Helsinki route, and support alignment with the EU and the IMO climate objectives. Strengthening resilience through continued investment in cleaner technologies, operational efficiency, and adaptation measures remains central to the Group's longterm sustainability strategy.

‌2 IPCC's Fifth Assessment Report (AR5)

Policy and Targets

The Group operates within a regulatory framework defined by the EU's Fit for 55 package, which requires a 55% reduction in Union-wide GHG emissions by 2030 (compared with 1990). In parallel, the IMO has set specific targets for the shipping sector, including a 20% absolute GHG emissions reduction by 2030 and a 70% reduction by 2040 (relative to 2008)3. These objectives are legally binding for international shipping.

Although the Group has not yet formalised a climate policy or long-term transition plan, it has adopted strategic principles and near-term targets that align with the EU and the IMO requirements. Stakeholder feedback gathered during the DMA informed a review of the Group's GHG reduction priorities. The short-term action plan focuses on energy efficiency projects and technological improvements that lower fuel consumption and related emissions. These measures will extend the operational life of the existing fleet while ensuring compliance with current and foreseeable environmental regulations. Medium- and long-term actions will depend on the availability and commercial viability of sustainable marine fuels, which are still being developed. As the shipping sector is characterised by significant lead times for fleet development and construction, with vessel lifespans reaching up to 50 years, medium- to long-term plans are made only after thorough discussions and careful consideration. These plans will be developed when all relevant information is available to ensure well-informed decisions.

AS Tallink Grupp aims to reduce emissions from its Scope 1 and Scope 2 activities by 2% per year, using 2023 as the baseline. The targets will be reviewed and extended to medium- and long-term horizons before 2027. The target-setting process involved extensive discussions with the Group's Management Board and internal experts, including the Environmental Expert of the ship management function and the Chief Captain, who contributed technical knowledge of existing marine fuels, combustion processes, and expected emissions profiles, alongside forecasts of passenger and cargo traffic on the Baltic Sea within the short- and medium-term horizons. Baseline calculations incorporated historical reduction data dating back to 2008, while accounting for changes in fleet composition, routes, and operations during the COVID-19 pandemic. The baseline calculation for Scope 3 emissions is in progress and corresponding reduction targets will be set in the upcoming reporting periods once the baseline has been finalised.

The current short-term targets are not science-based or explicitly aligned with a 1.5 °C trajectory but rather reflect the best available operational and technological assumptions that are consistent with the IMO decarbonisation pathways. Because international shipping is a hard-to-abate sector, the feasibility of setting and achieving more science-based long-term targets will depend on future advances in low- and zero-carbon fuels and the supporting infrastructure. Investments therefore remain focused on reducing GHG emissions from shipping operations, which constitute the Group's largest emission source.

‌3 2023 IMO Strategy on Reduction of GHG Emissions from Ships

Actions and Achievements

AS Tallink Grupp has developed a GHG reduction plan for its existing fleet, which defines specific projects, performance indicators, and evaluation criteria. These projects include improvements to onboard energy consumption, hydrodynamics, and operational practices. Nine of the Group's vessels are already equipped to use shore power during extended port stays, further reducing emissions.

The majority of the planned activities for achieving further emissions reductions involve technological solutions.

→ Short-term: continued implementation of energy-efficiency projects and operational optimisations.

→ Medium-term: evaluation of carbon capture technologies, hybrid and battery solutions, and potential offsetting solutions.

→ Long-term: transition to sustainable fuels.

Successful implementation of the solutions depends on access to emerging technologies, technical data, and adequate financing. The Group's ship management function and executive teams continuously assess the feasibility and cost-effectiveness of new solutions before fleet-wide adoption. Regardless of whether future operations rely on fossil fuels or renewable energy sources, efficient use of energy remains essential. Improving energy efficiency reduces both environmental impact and resource demand, as even the production of renewable fuels requires substantial infrastructure and energy input. Therefore, the Group prioritises improving the energy efficiency of its existing vessels through technological and operational measures. These targets will be reviewed and adjusted as greater clarity emerges regarding the future fuel landscape for shipping.

During the reporting period, the Group continued to work on increasing the use of alternative fuels in its core operations. Preparations were made to replace the liquified natural gas (LNG) currently used by the shuttle vessels MyStar and Megastar with liquified biomethane (LBM) from 2026 onwards. The LBM supplied to the Group is certified to verify that it meets the EU's sustainability criteria. The shift towards alternative fuels complements the Group's broader energy-efficiency and emissions-reduction efforts.

In 2025, the Group invested EUR 0.8 million (2024: EUR 0.8 million) in climate change mitigation activities as part of its structured capital expenditure plan, which incorporates projects relating to energy efficiency and shore power usage on different vessels.

The Group recognises the financial risks arising from the EU Emissions Trading System (EU ETS), such as increases in carbon allowance prices, which could lead to higher operating costs and liabilities. The implementation of the Group's sustainability strategy is supported by a sustainability-linked loan with interest rates tied to sustainability KPIs, including GHG reduction targets. Non-compliance with the set conditions could result in higher interest expenses, impacting overall financial performance.

GHG emission reductions since 2008 have been achieved through fleet renewal and efficiency improvements to existing vessels. From 2008 to 2019, AS Tallink Grupp's CO2 emissions from the fleet were reduced by 39% in absolute terms. Since then, emissions have decreased further, with a reduction of 62% achieved by 2025 compared to 2008. In 2025, CO2 emissions amounted to 383 990 tonnes

(2024: 387 267 tonnes).