Surteco Group SeXETR: SUR

Sustainability Report 2025 (Extract from Management Report) (2.29 MB)

· Issued by Surteco Group Se

Sustainable products. Sustainable business.

Sustainability Report 2025



Non-financial Statement*

ABOUT THIS NON-FINANCIAL STATEMENT

SURTECO GROUP SE is preparing and publishing the combined Non-financial Statement in accordance with

§315b and §315c German Commercial Code (HGB) and the Directive (EU) 2022/2464 of the European Parliament and the Council dated 14 December 2022 on the establishment of a framework to facilitate sustainable investments and Article 8 of the Delegated Regulation (EU) 2020/852 (EU Taxonomy Regulation).

CSRD AND ESRS AS A FOUNDATION FOR EUROPEAN SUSTAINABILITY REPORTING

The Corporate Sustainability Reporting Directive (CSRD) represents a substantial expansion of the previous EU Guidelines on non-financial reporting. The directive came into force on 5 January 2023 at EU level and has to be adopted in national law by the EU Member States. One of the aims is to oblige large companies oriented on the capital market in the EU to provide comprehensive disclosure as part of their sustainability reporting, highlighting the impacts of their business operations on sustainability aspects as well as pointing out the influences of sustainability aspects on the performance of their business, the results of operations and the situation of the company. With this purpose in mind, the EU has passed a number of European standards for sustainability reporting in the form of the European Sustainability Reporting Standards (ESRS), adopted as a delegated regulation, which is directly applicable in all EU Member States. The requirements of the current legal framework continue to apply to SURTECO because the national CSRD Implementation Act (CSRD-UmsG) did not come into force in Germany until 31 December 2025.

However, in the expectation of prompt implementation of the CSRD in German law, the SURTECO Group has made comprehensive preparations for first-time reporting in accordance with CSRD and ESRS respectively. The requirements of ESRS were largely implemented in this report on a voluntary basis for the 2025 business year.

STRUCTURE AND METHODOLOGY OF THE NON-FINANCIAL STATEMENT

SURTECO GROUP SE presents a Non-financial Statement at company level and a non-financial group statement jointly as a combined Non-financial Statement. The Non-financial Statement is an integrated element within the management report and complements the management section. In compliance with the requirements of the ESRS, the material topics were selected on the basis of their impact, their relevance and the assessment of their potential financial impacts. Material aspects and circumstances relating to environmental concerns, employee concerns, social concerns, business ethics and compliance, including combatting corruption and bribery, respect for human rights and sustainability in the supply chain are summarized and the content is divided into four sections on the basis of the structural requirements of the ESRS: general disclosures, environmental information, social information and company information.

The individual sections of the Non-financial Statement are based on the structure of the ESRS.

Reconciliation of sustainability matters between HGB requirements and the ESRS framework and contextu-alisation of the matters.

Sustainability matters ESRS-framework

Environmental concerns E1 Climate change E2 Pollution

E5 Resource use and circular economy EU-Taxonomy

Employee concerns S1 Own workforce

Social concerns* S1 Own workforce

G1 Business conduct

Respect of human rights* S1 Own workforce G1 Business conduct

Fighting corruption and bribery G1 Business conduct

* Reporting on S2 ("Workers in the Value Chain") and S3 ("Affected Communities") is not yet included in this reporting year. Explanations regarding human rights are provided in Chapter G1. The SURTECO Group maintains an ongoing dialogue with regional and local stakeholders at its sites.

The phase-in provisions provided for by the ESRS were not utilized during the reporting year.

General information

ESRS 2 GENERAL DISCLOSURES

This sustainability statement is a consolidated report about the material ESG topics of the SURTECO Group and forms part of the management report. The structure of the report and its disclosures are based on the framework of the Corporate Sustainability Reporting Directive (CSRD).

The group of consolidated companies governed by the sustainability statement corresponds to the companies consolidated in the company's consolidated financial statements, and the reporting period is the financial year and calendar year 2025. The base year for the achievement of the sustainability goals is the business year 2019. The financial information was denominated in the reporting currency of the euro (€). This sustainability statement also takes into account upstream and downstream activities of the value chain within the course of the reporting year. Information about the intellectual property, know-how and innovations of the SURTECO Group are not disclosed in this report. This reporting makes use of the time horizons defined in ESRS 1 for short-term (< 1y), medium-term (1-5 y) and long-term (> 5 y).

The preparation of the sustainability statement requires to a certain extent decisions of judgement, estimates and assumptions. The material facts that are affected by such decisions of judgement and estimates relate to the definition of the risks and opportunities associated with sustainability. The quantitative disclosures are the result of a consolidated, regular survey of the individual units within the Group. These data were prepared with due care and attention and following a comprehensive review. When the surveys are carried

out by the individual subsidiary companies, there may be unintentional misrepresentation when questions are answered. One example from the past relates to information having been provided in the wrong unit of measurement. If a mistake of this nature was discovered, the corresponding prior-year value was corrected in the report and appropriately identified. If omissions or exceptions to the disclosure of developments were identified, these are also assessed and reported in accordance with the circumstances.

A comprehensive risk assessment in connection with sustainability reporting is included under DR GOV-5 of this section. The data quality here is treated as an important aspect. This evaluation highlights the potential risks and their impacts and outlines the mitigation strategies directed towards continuously improving the quality of the information disclosed in this report.

Governance

DR GOV-1: The role of the administrative, management and supervisory bodies

The composition of the Supervisory Board is based on § 95 Sentence 2 Stock Corporation Act (Aktiengesetz, AktG) in conjunction with Article 8 Section (1) of the Articles of Association and the rules of the contract pursuant to §§ 13 Section (1) Sentence 1, 21 SE Participation Act (SE-Mitwirkungsgesetz) (Law on the Involvement of Employees in a European Company, SEBG) between the special negotiating committee and the executive management of SURTECO AKTIENGESELLSCHAFT about the participation of the employees of SURTECO GROUP SE dated 13 February 2007. According to these requirements, the company's Supervisory Board is made up of nine members. Six members are elected by the Annual General Meeting. All these six members are independent pursuant to the German Corporate Governance Code (DCGK). Three members are appointed as employee representatives to the Supervisory Board in accordance with the provisions of the above-mentioned agreement by the works councils of the three German companies of the SURTECO GROUP with the most employees. Since employees cannot be regarded as independent, as a matter of principle, the proportion of independent members of the Supervisory Board is 66.7 %. The Supervisory Board has defined a target for one female seat on the Supervisory Board by 2030. Up to now, it has not been possible to appoint an appropriately qualified women to the Supervisory Board of SURTECO GROUP SE. The proportion of women on the Supervisory Board during the reporting year 2025 is therefore 0 %.

In order to assess impacts, risks and opportunities in an evidence-based approach, the expertise of the Supervisory Board covers the following areas: paper and paper refinement, production and plastics technology, digital printing, occupational health and safety, human resources and climate economy. The Supervisory Board has appointed Mr. Jörg Wissemann as the contact person for sustainability issues in the Management Board. Mr. Wissemann holds a leading position in the area of sustainability consulting and therefore has extensive expertise in sustainability topics that are important for the company. Together with three other members of the Supervisory Board, Mr. Wissemann is a member of the Audit Committee of the SURTECO Group and is therefore responsible for the review and approval of the sustainability report. The definition of the sustainability targets of the SURTECO Group is carried out in consultation with the Management Board and Supervisory Board and is adopted by these bodies.

The Management Board (Executive Board) currently consists of two members. The Members of the Management Board are appointed and dismissed by the Supervisory Board. Rules of Procedure govern the allocation of business and the cooperation within the Management Board. The Members of the Management Board are not intended to work for the company beyond the statutory retirement age. In addition to the Management

Board, there are two other administrative and management bodies: the Senior Management Team (SMT) and the Executive Management Team (EMT, C Level 1). The proportion of women there was 12 % and 9 % respectively.

The Management Board of SURTECO GROUP SE manages the company with the objective of generating organic economic value added over the long term. The Management Board carries out its functions independently and in the interests of the company, while taking into account the needs of its shareholders, its employees and the groups associated with the company (stakeholders). The Members of the Management Board are jointly responsible for the executive management of the company. The Chairman of the Management Board coordinates the activities of the Management Board. The Management Board develops the com-pany's strategic direction, coordinates it with the Supervisory Board and implements the strategy. The Board ensures compliance with the statutory regulations and internal company guidelines and guarantees that the Group companies comply with these requirements.

The Board of Management has implemented a group-wide Internal Controlling System (ICS), a Risk Management System (RMS) and a Compliance Management System (CMS). The ICS and the RMS also deal with targets related to sustainability. The Management Board is responsible for the risk policy within the SURTECO Group. The identification of risks is carried out by the Management Board on the basis of group-wide guidelines. This is carried out together with the management of the subsidiary companies, Group controlling and the specialist departments. The results are regularly reported to the Management Board, which in turn submits a report to the Audit Committee of the Supervisory Board. The executive management of the subsidiary companies receives the instructions of the Management Board and in this connection is re-sponsible for the risks that it enters into its business activity. The management integrates the employees within the framework of their governance functions into the risk management. Binding rules for the risk management processes are defined within the group-wide Risk Management Manual.

The governance bodies of the SURTECO Group ensured that they possess or have access to the necessary skills and expertise in order to effectively monitor and manage sustainability aspects. In addition to the personal expertise, the governance bodies have access to internal experts who cover a wide range of sustainability aspects:

  • Corporate Function Sustainability

  • Environmental and Energy Managers

  • Occupational Safety Specialists

  • HR Specialists

  • Compliance and Internal Auditing Teams

  • Experts for Supply Chain Management

  • Specialists for Operational Excellence

    Furthermore, external advisors and specialist committees are available in order to regularly provide information on legal developments and best practices. The sustainability competencies available are directly related to the company's material ESG risks and opportunities. As a result of the structured access to internal experts and external specialists, the company ensures that its management bodies are in a position to take informed decisions directed towards creating long-term values for the company and its stakeholders. A

    complete overview of the management bodies of the SURTECO Group can be found in the notes to the financial statements in the section "Executive Officers of the Company".

    The sustainability team appointed by the Management Board is the office with central responsibility for sustainability at the SURTECO Group. It coordinates and manages the sustainability strategy of the Group and makes recommendations for targets and measures. Process owners and sustainability managers at the global locations ensure operational implementation of the sustainability targets. They take over responsibility for the sustainable organization in their area and coordinate activities. The sustainability team communicates with the Management Board through regular reporting and coordinates ongoing action with the Board. As part of strategic controlling for the Group, the Management Board keeps the Supervisory Board, and the Audit Committee informed by providing regular, comprehensive and prompt reports about issues related to sustainability and attainment of targets.

    DR GOV-2: Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

    Sustainability management and governance structure

    The sustainability management encompasses all entrepreneurial activities that safeguard the sustainable, long-term development of the company in line with the requirements of corporate governance, the environment and social concerns.

    The role of the administrative, management and supervisory bodies is clearly defined as set out below:

  • The Management Board bears overall responsibility for the sustainability strategy and takes final decisions in regard to measures and investments relating to sustainability.

  • A Sustainability Team appointed by the Management Board acts as a central body for coordination and controlling of the sustainability strategy. It develops proposals for targets and measures, monitors their implementation and ensures knowledge transfer within the company.

  • Sustainability managers and process owners at locations across the world ensure operational implementation and assume strategic responsibility for environmental, social and economic sustainability aspects in their respective areas.

  • The Sustainability Team communicates on a monthly basis with the Management Board and agrees strategic decisions within the scope of Executive Management Meetings and Strategy Meetings.

  • The Supervisory Board promptly receives comprehensive information and updates about sustainability topics in the context of Supervisory Board Meetings.

  • The Audit Committee of the Supervisory Board deals with sustainability reporting annually and reports its findings to the plenary session.

    Employees, process owners and sustainability managers are kept regularly informed through the group-wide management system and the Intranet. People in the public domain receive appropriate information in the Sustainability Report and on the company's website.

    Material sustainability topics during the reporting period under review

    During the reporting period under review, the administrative, management and supervisory bodies ad-dressed the following key sustainability issues:

  • Reduction of emissions: Development and implementation of CO₂ reduction strategies.

  • Use of secondary raw materials: Evaluation of the feasibility and integration of recycling materials into the production process.

  • Autonomy in energy supply: Analysis and investments in renewable energies in order to safeguard energy supply.

  • Alternative production technologies: Testing and implementation of sustainable manufacturing processes.

  • Occupational health and safety: improvement of occupational safety and company healthcare promotion.

  • Waste management: Measures for waste avoidance and optimization of disposal processes.

  • Circular economy: Development and promotion of closed material cycles.

  • Diversity: Implementation and monitoring of measures to promote diversity in the workforce.

    These topics were addressed in decisions taken by the Management Board, in strategy meetings and committee meetings. Concrete measures were adopted and directed towards minimizing risks and exploiting opportunities.

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

    The SURTECO Group has recognized the key role played by sustainability in promoting long-term value creation and responsible business practices, and the Group has implemented sustainability targets within the incentive systems used for the Management Board.

    The compensation system for the Management Board provides for a share of 10 % of variable remuneration to be determined by the achievement of sustainability targets. These sustainability targets are established by the Supervisory Board in consultation with the Management Board for each business year.

    The SURTECO Group publishes a Compensation Report every year in order to give stakeholders insights into the performance of and benefits to our Management Board, including the progress made in attaining sustainability targets. You can find these Compensation Reports under Financial Reports of the SURTECO Group on the Internet Portal of SURTECO (https://www.surteco.com, Investor Relations, Financial Reports).

    DR GOV-4: Statement on due diligence

    The SURTECO Group has established a comprehensive due diligence approach to ensure that all risks and opportunities relevant to sustainability are systematically identified, assessed and addressed across all business units, supply chains and stakeholders. A key factor here is setting up a robust due diligence process that encompasses the following key elements:

  • Evaluation and identification of potential sustainability risks in all business operations.

  • Use of Key Performance Indicators (KPIs) aligned with sustainability-related targets to measure progress and identify potential for improvement at an early stage.

  • Close communication and collaboration with stakeholders - including suppliers, employees, investors and local communities - in order to ensure transparency and accountability.

  • Continuous review and adaptation of the due diligence process in response to changing regulatory requirements, market trends and stakeholder expectations.

    The Sustainability Team at the SURTECO Group is working on further developing this process in order to manage the company's sustainability initiatives effectively and integrate them successfully within the strategy across the company.

    The following table provides an overview of how the core elements of due diligence are presented in the sustainability statement:

    Core elements of the duty of care

    Sections in the sustainability declaration

    Relevant stakeholders / responsible parties

    Integration of due diligence into

    Section DR SBM-1 & DR GOV 1: Sus-

    Management Board, Supervisory

    governance, strategy and business model

    tainability strategy & governance structure

    Board, Sustainability Team

    Involvement of affected stakehold-

    Section DR SBM-2: Stakeholder en-

    Suppliers, customers, investors,

    ers in all key due diligence steps

    gagement & dialog mechanisms

    NGOs, employee representatives

    Identification and assessment of

    Section DR IRO-1 & DR SBM-3: Mate-

    Environmental organizations, em-

    negative impacts

    riality analysis & risk identification

    ployees, local communities

    Measures to counter negative

    Section DR GOV-5: ESG manage-

    Sustainability managers, compli-

    effects

    ment systems & action plans

    ance, internal audit, works councils

    Tracking the effectiveness of efforts

    Section DR GOV-5: Monitoring, KPIs

    Internal audit, external auditors, rat-

    and communication

    & Reporting

    ing agencies

  • Integration into corporate governance: Due diligence is firmly anchored in the governance structure. The Management Board bears ultimate responsibility while the Sustainability Team as an operational committee develops concrete measures and coordinates their implementation.

  • Stakeholder integration: Regular dialogues and reporting proactively involves internal and external stakeholders in the due diligence process. This approach promotes transparency and strengthens the trust and confidence in the decisions taken by the company relating to sustainability.

  • Measurement and continuous improvement: Clearly defined KPIs provide assistance in measuring progress and identify specific areas where improvements are necessary. Continuous review and adaptation of the process ensures that the company can respond flexibly to new challenges and regulatory changes.

    DR GOV-5: Risk management and internal controls over sustainability reporting

    The SURTECO Group has established a structured system for identification, assessment and management of risks within sustainability reporting. This system is integrated within risk management through-out the company and comprises the following:

  • A central Sustainability Management System that defines the guidelines and procedures for data collection, data analysis and data reporting.

  • Internal controlling mechanisms that ensure the quality and accuracy of the sustainability data collected.

  • Regular review and auditing by Internal Audit and external auditors in order to ensure compliance with regulatory requirements.

    The SURTECO Group uses a risk-based assessment methodology in order to identify and prioritize potential risks in sustainability reporting:

  • Identification of risks: Analysis of potential risks, e.g. data gaps, inconsistent reporting or inadequate data sources.

  • Assessment of the risks: Each risk is assessed on the basis of its probability and impact on reporting.

  • Prioritization of the risks: Risks with high priority are addressed with targeted measures in order to safeguard the quality and reliability of reporting.

    The following risks were identified as material and are addressed thorough specific measures:

    Risk

    Effects

    Reduction strategy

    Data gaps or missing data

    Incomplete or distorted reporting

    Automated data collection systems, close cooperation with relevant specialist departments

    Incorrect data entry or calculations

    Inaccuracies in the sustainability indicators

    Standardized control mechanisms, internal plausibility checks

    Delayed or untimely data collection

    Failure to comply with reporting obligations in a timely manner

    Implementation of a clear schedule for data collection and validation

    Insufficient transparency and trace-

    Stakeholder confidence in reporting

    Regular audits and documentation

    ability

    could be impaired

    of all process steps

    Strategy

    DR SBM-1: Strategy, business model and value chain

    SURTECO GROUP SE (Societas Europaea) is a company listed on the stock exchange under European law and is based in Buttenwiesen, Germany. The company is the ultimate parent company of the Group and is registered in the Company Register of the Local Augsburg Court (Amtsgericht Augsburg) under HRB 23000. The purpose of the companies consolidated in the SURTECO Group is the development, production and sale of coated surface materials based on paper and plastic.

    Business areas

    The SURTECO Group produces a wide range of products for domestic use, for the trade sector and for the public arena. SURTECO products are used in virtually all areas of daily life. For example, they are applied on furniture, flooring and doors in homes, in caravans and on cruise ships. The products manufactured by the Group companies are primarily processed by the international flooring, wood-based and furniture industries. They are also used by cabinetmakers and artisan craft businesses. This involves coatings being used for

    wood-based materials such as chipboard and fibreboard. The coating gives these boards their final surface with appropriate visual, haptic and functional attributes. The most important sales markets for the Group include Germany, the rest of Europe, and North and South America.

    Edgebandings based on plastic and paper are the SURTECO Group's product with the highest sales. Plastic edgings are made from the plastics ABS, PMMA, PP and PVC in a wide range of different dimensions and strengths to meet specific customer requirements. Melamine edgings are manufactured on the basis of printed lightfast specialist papers.

    Finish foils made of plastic or paper are used in a wide variety of applications. The paper-based foils are used to create furniture surfaces with different design and haptic feels. The SURTECO Group offers plastic foils for furniture surfaces, as well as for further processing into carpets and for industrial applications.

    Decor papers are applied to provide materials with decorative elements in order to refine wood-based surfaces, for use in the furniture and floor industries and in interior design. The development of wood, stone and fantasy decors is carried out in cooperation with the Group's in-house design studios.

    The SURTECO Group offers products and solutions for flooring wholesalers and for professional floor-layers. The product range covers skirtings, stair edges, transition rails and all the accessories required for laying floors.

    Release papers from the SURTECO Group are widely used in the wood-based material industry. The product lends the surface its final visual look and creates an appealing haptic feel. Release papers are also used to give texture to other materials such as leatherette.

    Technical extrusions made of all common plastics manufactured for the construction sector and many other industrial sectors complete the product portfolio.

    Laminates have a multilayer structure and offer long-life and cost-effective surfaces for living environments and commercial spaces. Performance foils offer a variety of final applications as rigid, semi-rigid and flexible foils. Coated fabrics are vinyl-coated materials and they are used in cushioning for seats and coverings, for example in the automobile industry or in marine settings on ships.

    Focuses of sustainable business

    By adopting the Sustainable Development Goals (SDGs) of the UN, the community of nations has made a commitment to work together and contribute jointly to improving economic, environmental and social development by 2030. The SDG Agenda is intended to decisively drive forward global activities with 17 Global Goals and 169 targets. The individual goals are closely linked together and exert an influence on each other in a variety of different ways.

    Achieving these goals is the shared responsibility of all societal players, including commercial enterprises. They provide the framework for what companies have to achieve in order to continue to be able to do business successfully in the future. Without neglecting the perspective of a holistic approach to the goals, the SURTECO Group analyses the priorities for developing its sustainability strategy in a continuous process. The SURTECO Group evaluated its business activities in the course of this procedure. On this basis, eight SDGs from the UN sustainability goals were identified that the SURTECO Group can exert a major influence on. Partnerships for achieving the goals (SGD 17) complement the strategy. The defined goals were included in the strategy of the SURTECO Group. The measures derived from this analysis are presented in the table below.

    Target number

    Sustainable Development Goal (SDG)

    SURTECO Group Measure for implementation

    3

    Health and well-being

    5

    Gender equality

    6

    Clean water

    8

    Decent work and economic growth

    9

    Industry, innovation and infrastructure

    12

    Sustainable consumption and production

    13

    Climate protection measures

    17

    Partnerships to achieve all goals

    • Occupational health and safety

    • Compatibility of work and family

    • Diversity

    • Women in management positions

    • Reduction of water consumption

    • Wastewater management

    • Working conditions

    • Code of conduct for suppliers

    • State-of-the-art technology

    • Product and process innovations

    • Minimizing the use of resources and energy

    • Process optimization

    • Emission minimization

    • Waste management

    • Emission minimization

    • Waste management

    Sustainability targets have been agreed for all products in the SURTECO Group. This involves using raw materials that are already bio-based or renewable through the application of materials based on wood fibre such as paper and wood-based materials. We aim to base our products on the following criteria:

  • Resource conservation

    Reduction of the use of fossil-based raw materials through the application of recycled or bio-based materials.

  • Energy efficiency

    Optimization of production processes to reduce energy consumption and to make use of renewable energy.

  • Waste management

    Minimization of production waste and promotion of recycling and reuse.

  • Circular economy

    Establishment of circular and recycling processes which promote recovery.

  • Transparent supply chains

    Safeguarding sustainable procurement of raw materials and other materials.

  • Product design

Design of products that are easier to recycle and have fewer environmental impacts.

The sustainability targets listed above relate to all product groups of the SURTECO Group and there is no prioritization by geographical regions. During the reporting period, there were no significant changes in the product offering, or the markets and customer groups.

A material component for tracking and implementation of targets is the ISO certification to various standards of our locations.

The following table provides an overview of the certified locations.

Certified production locations

Country

Site

Quality

Environment

Energy

Occupational

Other certifi-

(ISO 9001)

(ISO 14001)

(ISO 50001)

Safety

cation

(ISO 45001)

Buttenwiesen • • • • * FSC, PEFC

Greenguard,

Bönen • • •

Dunningen • • •

FSC, PEFC,

Blauer Engel

Greenguard, FSC, PEFC

Blauer Engel

Germany

Gladbeck • • Greenguard Greenguard,

Grammetal • • •

Halle (Saale)

FSC, PEFC

Blauer Engel

USA

United Kingdom

Heroldstatt • • FSC, PEFC

Hüllhorst • • • FSC, PEFC

Laichingen • • • FSC, PEFC Sassenberg • • • • * FSC, PEFC

Willich Agawam

Auburn Vantage Vinyl

Greensboro

Jeannette Vantage Vinyl

Monroe Vantage Vinyl

Myrtle Beach

Ashbourne • •

Stourport-on-

Severn • •

Canada Brampton

Brazil

São José dos Pinhais

•

Portugal

Mindelo

• •

Sweden

Gislaved

• •

Indonesia

Batam

Greenguard

Thailand

Rayong

• •

Australia

Sydney

Greenguard

*Principle of the procedure. Includes requirements from DIN ISO 4500

Wherever possible the SURTECO Group joins forces with its customers to carry out development projects in order to find solutions for circular processes in the packaging sector and for recycling processes concerning plastic products.

All the products of the SURTECO Group can be subsumed under the category "Building products and furnishings".

Business (product) 2024 2025

€ million

Edgebands

260.7

239.5

Finish foils

137.2

128.3

Decorative printing

88.2

93.5

Impregnates / Release papers

48.6

31.5

Skirtings and related products

73.8

76.9

Technical extrusions

47.0

46.8

Laminates

98.3

95.1

Performance Films

31.6

34.3

Coated Fabrics

39.6

41.9

Other

31.6

33.4

856.6

821.2

Global presence

Being close to our customers is important for the SURTECO Group. Proximity guarantees short delivery pathways that save resources and permit individual bespoke responses to differing regional preferences and trends. The SURTECO Group operates in virtually all the countries of the world and maintains 26 production locations in Germany, the United Kingdom, Sweden, Portugal, Canada, USA, Brazil, Indonesia, Thailand and Australia. At the same time, the company's global presence and comprehensive product range make it less vulnerable to the volatility of sales fluctuations in individual countries and sectors.

Geographical breakdown of SURTECO Group

Sales in € million Employees at 31/12 2024 2025 2024 2025

Germany

160.6

156.3

1,490

1,499

Europe (without Germany)

315.5

303.9

641

646

America

297.1

280.3

1,043

1,001

Asia / Australia

75.1

71.6

558

549

Other

8.3

9.1

0

0

856.6

821.2 3,732 3,695

Value chain

Sustainable business practices encompass not only the organization itself but also upstream and downstream sectors throughout the entire value chain.

The SURTECO Group procures raw materials, packaging materials, production goods, services and other inputs such as energy worldwide. Generally speaking, the SURTECO Group purchases directly from several manufacturers and is not dependent on an individual supplier. The cost of materials ratio was 49 % in 2025 and this indicates that the procurement of raw materials constitutes the biggest expense item for the SURTECO Group. Around 75 % of the total cost of materials is attributable to the three most important raw materials paper, plastics and chemical additives. Consequently, plastics manufacturers, paper producers and the chemicals industry are the most important groups of suppliers.

In order to uphold its social and environmental responsibility in the framework of a holistic approach the SURTECO Group has defined its values in a Code of Conduct for suppliers - Sustainable Procurement ("Code of Conduct") with 17 principles based on ethical business conduct, social standards and environmental standards. The Code is based on international conventions such as the United Nations Human Rights Declaration, the guidelines on children's rights and entrepreneurship, business conduct and human rights, labour standards and the United Nations Global Compact.

End customers are dominated by the wood-based materials industry, the wholesale trade, the home-im-provement market and the furniture industry. End consumers only purchase skirtings through the home-improvement sector as a finished product manufactured by the SURTECO Group. Surface materials are incorporated into the production process at customers of the SURTECO Group in order to make other products like furniture, doors and laminate flooring. Most end products can be disposed of through house-hold waste collection or recycling centres. Some furniture parts can be recycled and returned to the wood-based materials industry.

The need for living and office space is constantly increasing as the global population rises, together with the consequent expansion of purchasing power. This is leading to a spiralling demand for furniture, flooring and interior installations. It is particularly relevant for the demographic and economic development taking place in the emerging economies. In addition, the global trend towards urbanization and individualization is generating an accelerated demand for attractive interior architecture and fittings.

The company and its products need to become more sustainable over the entire value chain in order to meet this challenge without jeopardizing the company's principles.



Strategy and business model

The strategy of the group of companies with its seven pillars of Product Leadership, Operational Excellence, Commercial Excellence, Digitalization, Focused Internationalization, Sustainability and a Corporate Culture under the slogan of "Company I like to work for" is single-mindedly focused on the overarching goal: "We make rooms worth living in".

The business model of the SURTECO Group is based on the claim that we manufacture outstanding surfaces, edgings and extrusions (profiles). However, excellent products in themselves are not sufficient to guarantee sustainable success over the long term. This offering is supplemented by bespoke solutions that are tailor-made to suit the needs of our customers and this is augmented by comprehensive service. Our strategy rises to this challenge by encompassing all stages of the value chain, with a particular focus on providing the best possible service for all our customers.

DR SBM-2: Interests and views of stakeholders

The SURTECO Group absolutely needs to understand the impacts that stakeholders may exercise on our business activities. But also understand the interests and views of stakeholders and embedded it into the business strategy.

The SURTECO Group communicates continuously and promptly with the most important stakeholders in a form that is relevant to the individual target group. The most important stakeholders are listed below. They were identified in the SURTECO Group's activities and business relationships as well as its engagement initiatives in order to identify their interests and views.

Key stakeholders of the SURTECO Group

Stakeholder

Communication

Interests and

views

Implementation in the

SURTECO strategy -Pursuit of the UN goal

Consideration

of stakeholder interests

Investors

Annual General Meeting

Sustainable corporate

SDG 8 Decent work and

Reporting on ESG key

Capital market conferences

value

economic growth

figures

Individual meetings

Profitability

Integration into sustain-

Profitable and competitive

ability decisions

business models

Supervisory

Supervisory Board meeting

Sustainability strategy

SDG 8 Decent work and

Integration of sustaina-

Board

Sustainable corporate

economic growth

bility goals into the cor-

value

SDG 13 Climate action

porate strategy

Leadership role in sustain-

Regular sustainability

able developments

reports

ESG-supported remu-

neration models for the

Management Board

Management

Executive Management Meet-

Sustainability strategy

SDG 3 Good health and

Anchoring sustainability

Board

ing

Sustainable management

well-being

in corporate manage-

Strategy meeting

Environmental and health

SDG 8 Decent work and

ment

Board meeting

protection

economic growth

Setting and monitoring

Corporate governance

SDG 13 Climate action

climate targets

Promotion of a sustain-

able corporate culture

Employees

Works meetings

Secure employment

SDG 3 Good health and

Training on sustainable

Appraisal interviews

Equal opportunities

well-being

working practices

Employee surveys

Equal pay

SDG 8 Decent work and

Involvement in deci-

Intranet

Further development

economic growth

sion-making processes,

Work / life balance

Promotion of diversity

Suppliers

Purchasing discussions

Sustainable supply chain

SDG 9 Industry, innovation

Supplier audits

Supplier evaluation

Health and safety

and infrastructure

Promoting joint re-

Trade fairs

Working conditions and

SDG 13 Climate action

source conservation

rights

and circular economy

Climate change

projects

Circular economy

Customers

Sales meetings

Sustainable products and

SDG 12 Sustainable con-

Transparency about

Customer events

production

sumption and production.

sustainable products

Customer satisfaction

Sustainable supply chain

SDG 13 Climate action

Recycling and take-

analysis

Health and safety

back concepts

Conferences

Working conditions and

Sustainable packaging

rights

solutions

Climate change

Circular economy

Inhabitants /

Press

Sustainable production

SDG 6 Clean water and

Participation in local en-

Communities

Open day

Informal contacts

sites in harmony with qual-

ity of life

sanitation

SDG 13 Climate action

vironmental and social

projects

Reduction of local emis-

sions

Authorities and

Press

Corporate Governance

SDG 13 Climate action

Compliance with legal

associations

Communication via specialist

Environmental protection

SDG 17 Partnerships to

requirements

departments

achieve the goals

Involvement in sustain-

ability initiatives

The administrative, management and supervisory bodies have a special role within the scope of stakeholder reporting. This relates to the Management Board, the Supervisory Board and the operational management team. These bodies are kept regularly informed by the Sustainability Officer during the course of Management Board and Supervisory Board Meetings, or in the case of operational management as part of the Management Review Meetings. The latter meetings in particular also gather information within the Business Units about stakeholder opinions along the supply chain.

More robust integration of stakeholders increases acceptance and legitimacy because a range of interests is taken into account. This also promotes innovations because suppliers, customers and NGOs can contribute sustainable solutions. Risks such as environmental or social problems can be identified and avoided at an early stage. Active stakeholder involvement means that sustainability will be more credible and make a contribution to wealth creation over the long term. Investors prefer companies with clearly defined ESG strategies and this facilitates financing. Over the long term, close stakeholder involvement therefore enhances economic stability and reduces regulatory risks.

The SURTECO Group has therefore adapted its business model to have a greater focus on sustainable material innovations, recyclability and less resource-intensive production processes This approach takes account of stakeholder interests and regulatory requirements. The business model is being adapted in accordance with the existing structures and framework conditions of stakeholder relationships.

The methodology applied by the SURTECO Group to identify and assess material impacts, risks and opportunities is described in DR IRO-1 under the section Impacts, Risk and Opportunity Management of this reported standard.

DR SBM-3: Material impacts, risks and opportunities and their interaction with strategy and business model Sustainability in the SURTECO Group is a pillar of the corporate strategy that is networked with all areas of activity. This approach is adopted because we are aware that while it is our responsibility to pursue the economic interests of the shareholders, we also have a responsibility to preserve the planet's resources and contribute to the well-being of society.

The company culture and the employees are the foundation underpinning the SURTECO strategy. The SURTECO Group is committed to the principles for sustainable development and improvement of living standards and intends to be a sustainable company and a role model for ESG practices.

The SURTECO Group identified its material topics on the basis of the materiality analysis methodology described in DR IRO-1. This can be found under the section Impact, Risk and Opportunity Management in this reporting standard.

The SURTECO Group consolidates its impacts, risks and opportunities taking into account the relevant sustainability aspects in order to provide a better overview. The topics and results of the materiality analysis are provided in the following matrix.

The material impacts, risks and opportunities are the result of the interaction between the environment and society with the activities and business relationships of the SURTECO Group.

Material

E1 Climate

change - Energy

E5 Circular Economy -

Resources inflows and outflows

E1 Climate change -

Climate change

E2 Pollution - Air

G1 Business conduct

S1 Own workforce -

Working conditions

E5 Circular

Economy - Waste

S1 Own workforce - Equal

treatment and opportunities

E2 Pollution -

Microplastics

Non-material

E2 Pollution - SC

and SVHC



Impact on society and environment

Very Low

Low

Medium

Highl

Very High

Very Low

Low

Medium

High

Very High

Impact on company

ESRS E1 - Climate change

The dependence on energy resources, the necessity to increase efficiency and the proportion of renewable energy make energy a relevant topic for the SURTECO Group. This is not simply on account of the impacts that result from the use of non-renewable energy sources. It also relates to the financial impacts that the energy transition can exert on the company. Additional material impacts result from the release of greenhouse gases (GHG) and their potential impact on climate change. Changes in the regulations, restrictions on the use of fossil-based energies, charges for emissions of greenhouse gases and the costs of decarboniza-tion can also all impact negatively on the business. Impacts, risks and opportunities arising from energy consumption and the release of greenhouse gases have a higher incidence in the supply chain, material transport and the SURTECO Group's own operations.

ESRS E2 - Pollution

The materiality of pollution depends on the type of materials used by the SURTECO Group. Air pollution is a material topic for the SURTECO Group because it uses materials containing solvents and these can potentially cause harm when released into the air. In spite of the existing treatment systems and mitigation measures, the release of solvent emissions is relevant for the SURTECO Group. However, significant risks may also arise from changes in legal requirements when using materials of this nature. Similarly, changes in emission limits may lead to restrictions on the selection of materials, processes or treatment technologies.

The manufacture of plastics and the use of raw materials which are classified as microplastics are also material for the SURTECO Group. This is not only the case on account of the potential impacts owing to contamination but also due to the mandatory requirements for their application.

ESRS E5 - Resource use and circular economy

The type of business activity of the SURTECO Group, its dependence and the impacts of its use make resource use and the circular economy a key issue in their in-house business activities and also in up-stream activities. The volume of waste and the proportion of disposal processes are also relevant topics for the efficient use of resources and the circularity of materials.

ESRS S1 - Own Workforce

Our slogan "A company I like to work for" is one of the pillars of SURTECO's strategy, and occupational health and safety, social security and the right work-life balance are absolutely essential for this. Loyalty, stability and commitment are some of the key effects of this topic. But the other side of the coin is the way the workforce, their absenteeism and lack of commitment can impact negatively on the company.

ESRS G1 - Business Conduct

Violations of human rights principles have been identified as a material topic for the SURTECO Group not because of the probability of occurrence, since the probability of their occurring is very low, but because of the magnitude of their impact. The corporate culture at the SURTECO Group is based on people and their rights. Protection of these rights is supremely important over the entire value chain.

Every single material matter is disclosed in this sustainability statement in accordance with the relevant thematic standard.

Impacts,

risks and opportunities

Measures

Positive Negative Financial Effects Consideration of

Effects Effects the value chain

ESRS E1

Reduction of en-

Reduction of green- Investment costs Long-term cost Energy efficiency

Climate Change

ergy consumption,

use of renewable

house gas emis- for energy effi- savings through and decarboniza-

sions, reduction of ciency measures energy efficiency tion in the supply

energies, invest-

energy costs, ful- and reduced CO2 chain, material

ment in energy effi-

fillment of regula- costs transport and own

ciency technologies

tory requirements operations

ESRS E2

Use of alternative,

Reduction of emis- Customization Cost savings Use and emissions

Environmental pollution

less environmen-

sions, protection of costs for new ma- through reduction of solvents in the

tally harmful mate-

the environment, terials, production of environmental supply chain, plas-

rials, improvement

material efficiency processes penalties tic production and

of wastewater

micro-plastic risks

treatment pro-

cesses

ESRS E5

Promotion of circu-

Greater resource Initial investment in Reduction in mate- Waste generation,

Resource utilization and

lar economy prac-

efficiency, material recycling initiatives rial and waste man- material transpor-

circular economy

tices, increased re-

availability, lower agement costs tation and raw ma-

cycling, use of sec-

waste costs terial consumption,

ondary materials

circular economy

initiatives in the

supply chain

ESRS S1

Health and safety

Improved employee Costs for training Lower sickness Workplace culture,

Own workforce

programs, training

initiatives, promo-

retention, higher programs and com- rates, reduced fluc- health protection

productivity pany health initia- tuation rates and commitment in

tion of work-life

tives the value chain

balance, diversity

and inclusion

ESRS G1

Implementation of

Strengthening rep- Expenses for com- Reduction of repu- Human rights and

Business conduct

guidelines for com-

utation, reducing pliance and moni- tational damage ethics throughout

pliance with human

risks in the area of toring and compliance the value chain,

rights, transpar-

human rights fines supplier manage-

ency initiatives

ment and compli-

ance monitoring

Impact, risk and opportunity management

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

The SURTECO Group has implemented a structured procedure in order to identify and assess systematically material sustainability topics, risks and opportunities. The starting point for this procedure is the comprehensive determination of potentially relevant topics arising from the areas of Environment, Social and Governance (ESG). The company is guided by the requirements of the European Sustainability Reporting Standards (ESRS) and the regulatory requirements, industry-specific developments and global sustainability goals such as the Sustainable Development Goals (SDGs) of the United Nations.

A key component of the process is identification of the relevant stakeholder groups. This includes customers, employees, suppliers, investors, local communities and organizations of civil society. The perspectives and expectations of these stakeholders are integrated systematically in the process by means of surveys, workshops and dialogue formats. In order to ensure that all relevant topics are taken into account.

The company uses internal and external information sources to identify the topics and the underlying data. Internal sources encompass e.g. indicators from environmental management, social indicators and risk reports. External sources comprise regulatory requirements, scientific studies, market analyses and sector reports. This information is brought together and serves as the foundation for additional analysis.

The assessment of the identified topics is carried out in the context of a materiality analysis, which is based on the concept of double materiality. Two perspectives are taken into account. On the one hand, the impact dimension, which describes the impacts that the company has on the environment and society, such as the emission of greenhouse gases, the use of resources or social concerns such as diversity and inclusion. On the other hand, the financial dimension, which examines the impacts of sustainability topics on the com-pany's business activities and financial situation. Examples of the latter dimension include climate risks, regulatory changes or access to financing opportunities.

The SURTECO Group has established a structured decision-making process to ensure that significant impacts, risks and opportunities are systematically identified, assessed and monitored. This process is carried out by an interdisciplinary team, which is made up of representatives from the executive management, the sustainability management team, the risk management team and relevant specialist departments. The internal controlling procedures include regular review and approval by the Management Board along with implementation of a double-checking (four-eyes) principle relating to materially important key decisions.

The assessment process for impacts, risks and opportunities is integrated within the existing Risk Management System and permits a complementary analysis of financial and operational risks. The Risk Management System (RMS) is disclosed in the management report and does not place any special focus on risks related to sustainability.

The results of the impacts, risk and opportunity assessments flow directly into strategic planning and decision-making at the company and departmental levels. For example, the findings are used to guide investment decisions, product development strategies and measures for compliance with statutory regulations. In addition, the results are communicated regularly at board meetings and workplace meetings.

DR IRO-2: Disclosure Requirements in ESRS covered by the undertaking's sustainability statement

The DRs in the ESRS are listed in the following table as a result of the material analysis. These were identified by the SURTECO Group as material and they were included in this Sustainability Statement.

DRs covered in the sustainability statement

Standard Chapter Disclosure Requirement Paragraph

ESRS 2 Governance DR GOV-1: The role of the administrative, management and supervi- 1

sory bodies

DR GOV-2: Information provided to and sustainability matters ad- 2

dressed by the undertaking's administrative, management and supervisory bodies

DR GOV-3: Integration of sustainability-related performance in in- 3

centive schemes

DR GOV-4: Statement on due diligence 4

DR GOV-5: Risk management and internal controls over sustainabil- 5

ity reporting

Strategy DR SBM-1: Strategy, business model and value chain 1

DR SBM-2: Interests and views of stakeholders 2

DRs covered in the sustainability statement

Standard

Chapter

Disclosure Requirement

Paragraph

DR SBM-3: Material impacts, risks and opportunities and their inter-

action with strategy and business model

3

Impact, risk and

opportunity management

DR IRO-1: Description of the process to identify and assess material

impacts, risks and opportunities

1

DR IRO-2: Disclosure Requirements in ESRS covered by the under-

taking's sustainability statement

2

MDR-P: Policies adopted to manage material sustainability matters

3

MDR-A: Actions and resources in relation to material sustainability

matters

4

Metrics and tar-

gets

MDR-M: Metrics in relation to material sustainability matters

1

MDR-T: Tracking effectiveness of policies and actions through

targets

2

ESRS E1

Governance

DR related to ESRS 2 GOV-3: Integration of sustainability-related performance in incentive schemes

1

Strategy

DR E1-1: Transition plan for climate change mitigation

1

DR related to ESRS 2 SBM-3: Material impacts, risks and opportuni-

ties and their interaction with strategy and business model

2

Impact, risk and

opportunity management

DR related to ESRS 2 IRO-1: Description of the process to identify

and assess material impacts, risks and opportunities

1

DR E1-2: Policies related to climate change mitigation and

adaptation

2

DR E1-3: Actions and resources in relation to climate change

policies

3

Metrics and tar-

gets

DR E1-4: Targets related to climate change mitigation and

adaptation

1

DR E1-5: Energy consumption and mix

2

DR E1-6: Gross Scopes 1, 2, 3 and Total GHG emissions

3

DR E1-7: GHG removals and GHG mitigation projects financed

through carbon credits

4

DR E1-8: Internal carbon pricing

5

DR E1-9: Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

6

ESRS E2

Impact, risk and

opportunity management

DR related to ESRS 2 IRO-1: Description of the process to identify

and assess material impacts, risks and opportunities

1

DR E2-1: Policies related to pollution

2

DR E2-2: Actions and resources related to pollution

3

Metrics and targets

DR E2-3: Targets related to pollution

1

DR E2-4: Pollution of air, water and soil

2

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

concern

3

DRs covered in the sustainability statement

Standard Chapter Disclosure Requirement Paragraph

DR E2-6: Anticipated financial effects from material pollution-re- 4

lated risks and opportunities

ESRS E3 Water and marine resources standard not covered in the sustainability statement - under the materiality assessment no topics were identified as material. Most of the water is used for cooling or cleaning purposes and discharged back into the public drainage system or even rivers after appropriate treatment and processing. Only a very small proportion of the volume of water withdrawn is associated with the manufacture of inks and varnishes. The assessment took into account the amount of water used by each SURTECO site, the purpose of its use and total annually consumption. The level of water stress at each location was also analysed.

ESRS E4 Biodiversity and ecosystems standard not covered in the sustainability statement - under the materiality assessment no topics were identified as material. The majority of SURTECO's production sites are in industrial areas or other business parks, although SURTECO also has some operational premises close to protected nature conservation areas. No relevant impacts were identified on biodiversity or ecosystem. SURTECO defines strict rules for plants located near flowing bodies of water so that production does not lead to any recordable impacts on the surrounding fauna and flora. The assessment also took in consideration the impact in value chain, especially due to the use of paper raw materials. All paper raw material used by SURTECO are certified accordingly with FSC or PEFC, meaning that materials come from sustainable sources.

ESRS E5 Impact, risk and

opportunity management

DR related to ESRS 2 IRO-1: Description of the processes to identify 1

and assess material resource use and circular economy-related impacts, risks and opportunities

DR E5-1: Policies related to resource use and circular economy 2

DR E5-2: Actions and resources related to resource use and circular 3

economy

Metrics and targets

DR E5-3: Targets related to resource use and circular economy 1

DR E5-4: Resource inflows 2

DR E5-5: Resource outflows 3

DR E5-6: Anticipated financial effects from material resource use 4

and circular economy-related risks and opportunities

ESRS S1 Strategy DR related to ESRS 2 SBM-2: Interests and views of stakeholders 1

DR related to ESRS 2 SBM-3: Material impacts, risks and opportuni- 2

ties and their interaction with strategy and business model

Impact, risk and opportunity management

DR S1-1: Policies related to own workforce 1

DR S1-2: Processes for engaging with own workforce and workers' 2

representatives about impacts

DR S1-3: Processes to remediate negative impacts and channels for 3

own workforce to raise concerns

DR S1-4: Taking action on material impacts on own workforce, and 4

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

Metrics and targets

DR S1-5: Targets related to managing material negative impacts, 1

advancing positive impacts, and managing material risks and opportunities

DR S1-6: Characteristics of the undertaking's employees 2

DR S1-7: Characteristics of non-employees in the undertaking's own 3

workforce

DRs covered in the sustainability statement

Standard

Chapter

Disclosure Requirement

Paragraph

DR S1-8: Collective bargaining coverage and social dialogue

4

DR S1-9: Diversity metrics

5

DR S1-10: Adequate wages

6

DR S1-11: Social protection

7

DR S1-12: Persons with disabilities

8

DR S1-13: Training and skills development metrics

9

DR S1-14: Health and safety metrics

10

DR S1-15: Work-life balance metrics

11

DR S1-16: Remuneration metrics (pay gap and total remuneration)

12

DR S1-17: Incidents, complains and severe human rights impacts

13

ESRS S2 Workers in the value chain standard not covered in the sustainability statement - under the materiality assessment no topics were identified as material. The assessment considered SURTECO main suppliers' location and areas at risk. Is in motion a worldwide screening analysis within the scope of the Supply Chain Act that will improve completeness and accuracy of the assessment.

ESRS S3 Affected communities standard not covered in the sustainability statement - under the materiality assessment no topics were identified as material. The assessment took in consideration the location of SURTECO plants and its proximity to communities, with the majority being in industrial areas. For the value chain, in particular suppliers of paper raw materials, SURTECO use materials certified accordingly with FSC and PEFC.

ESRS S4 Consumers and end-user's standard not covered in the sustainability statement - under the materiality assessment no topics were identified as material. Given the characteristics of SURTECO products, classified as articles, and its business-to-business model, no relevant risks are expected to occur from its use.

ESRS G1 Governance DR related to ESRS 2 GOV-1: The role of the administrative, supervi- 1

sory and management bodies

Impact, risk and opportunity management

DR related to ESRS 2 IRO-1: Description of the processes to identify 1

and assess material impacts, risks and opportunities

DR G1-1: Corporate culture and business conduct policies and cor- 2

porate culture

DR G1-2: Management of relationships with suppliers

The Disclosure requirement Management of relationships with suppliers is not covered in the sustainability statement. Under the materiality assessment these topics were identified as not material. Because The group-wide Corporate Centre "Group Procurement" defines the framework conditions for procurement and coordinates the relationships with suppliers. The avoidance of payment delays, particularly in the case of small and medium-sized companies, is ensured through defined processes for incoming invoices within the relevant Enterprise Resource Planning systems. The Group has its own Supplier Code containing detailed guidelines for ethical, social and environmental standards that is covered under the disclosure requirement G1-1.

DR G1-3: Prevention and detection of corruption and bribery 4

Metrics and targets

DR G1-4: Confirmed incidents of corruption or bribery 1

DRs covered in the sustainability statement

Standard Chapter Disclosure Requirement Paragraph

DR G1-5: Political influence and lobbying activities

The Disclosure requirement Political influence and lobbying activities is not covered in the sustainability statement. Under the materiality assessment these topics were identified as not material because no company of the SURTECO Group has been entered in the EU Transparency Register or in the local Transparency Registers of the relevant governments and our code of conduct prohibit any financial and in-kind political contribution

DR G1-6: Payment practices

The Disclosure requirement Payment practices is not covered in the sustainability statement. Under the materiality assessment these topics were identified as not material, as referred in G1-2

MDR-P: Policies adopted to manage material sustainability matters

The SURTECO Group has implemented a Group Sustainability and Risk Management Policy. The results of our risk assessments are being included in our group-wide risk controlling, analysed for urgency and relevance, and the appropriate measures will be implemented where possible. The inspection of operational facilities will be carried out at regular intervales in accordance with local circumstances and take into account changes that have occurred at local level.

Environment information

DISCLOSURE IN ACCORDANCE WITH ARTICLE 8 (2) OF DIRECTIVE (EU) 2020/852

As part of the European Union action plan "Financing Sustainable Growth", the Taxonomy Regulation came into force in 2020. It forms the foundation for the assessment criteria defining business activities as environmentally sustainable and lays down the regulations for reporting by the companies subject to reporting requirements. SURTECO has been subject to the reporting requirements under the Taxonomy Directive since 2021.

In 2025, the EU Commission issued a delegated act to streamline the reporting requirements of the EU taxonomy. This act took effect upon publication in the Official Journal on January 8, 2026, and can be applied to reporting for the 2025 financial year. This act gives companies the option omit assessing whether some of their economic activities are taxonomy-eligible or taxonomy-aligned where the cumulative capital expenditure related to those economic activities is below 10% of the denominator of the CapEx KPI. Furthermore the company may omit assessing whether operational expenditure related to all their economic activities is taxonomy-eligible or taxonomy-aligned, where the operational expenditure is not material for the business model of the Company, provided that the total value of the OpEx KPI denominator is disclosed and an explanation, why the operational expenditure is not material for the business model is disclosed. SURTECO takes advantage of these opportunities with the following explanation.

SURTECO's business model is based on the manufacture of materials for the wood-based materials, furniture, and caravan industries, as well as for interior design. None of these products are included in the activities related to the environmental objectives of the EU taxonomy. As a result, no taxonomy-eligible revenues have been identified in recent years, only taxonomy-eligible investment and operating expenses on a small scale. This mainly concerned the company's vehicle fleet, as well as investments in and operation of charging stations for electric cars, PV systems, and various energy-efficient devices. The SURTECO Group's business model also works without these activities, as business trips can be made using public transport, for example, and the power supply is also secured without the company's own PV systems. These activities therefore fall below the materiality threshold of 10% of total investment expenditure. In this respect, further determination of taxonomy compliance for the CapEx KPI can be waived for materiality reasons in accordance with the provisions of the EU taxonomy. The company's taxonomy-eligible but financially immaterial CapEx activities amount to € 1.5 million in the 2025 financial year, or 3.8 % of total CapEx. In 2024 taxonomy-eligible CapEx activities of € 2.2 million were identified.

As a manufacturing company, operating expenses are a necessity for SURTECO but are not essential to its business model. Operating expenses at SURTECO never directly generate revenue. The fact that there is no taxonomy-eligible revenue within the group also correlates with the immateriality of operating expenses. Research and development expenses can also be considered irrelevant to the implementation of the business model simply because of their very low amount. The company tries to reduce operating expenses to a minimum and could theoretically maintain its business model without these expenses altogether. In addition, taxonomy-eligible operating expenses fell below the newly introduced materiality threshold of 10 % in the last fiscal year. Since no structural changes in potentially taxonomy-eligible business expenses were

identified in the reporting period and, on the contrary, the company's leasing strategy for its vehicle fleet means that vehicle costs cannot be considered taxonomy-eligible (which was assumed in previous years), it can be assumed that the 10 % threshold will also be below the threshold in fiscal year 2025. In this respect, the company refrains from determining the taxonomy eligibility and taxonomy compliance of its operating expenses in accordance with the provisions of the EU taxonomy. Total operating expenses (OpEx KPI denominator) amounted to € 30.7 million in fiscal year 2025 after € 29,1 million in the previous fiscal year.

The following KPIs result for the business year:

Financial year

2025

Breakdown by environmental objectives of

Taxonomy aligned activities

KPI

Total

Proportion of Taxonomy eligible activities

Taxonomy aligned activities

Proportion of Taxonomy aligned activities

Climate Change Mitigation

Climate Change Adoption

Water

Circular Economy

Pollution

Biodiversity

Proportion of enabling activities

Proportion of transitional activities

Not assessed activities considered non-material

Taxonomy aligned activities in previous financial year 2024

Proportion of Taxonomy aligned activities in previous financial year 2024

€ mill.

%

€ mill.

%

%

%

%

%

%

%

%

%

%

€ mill.

%

Turnover

821.2

0

0

0

0

0

0

0

0

0

0

0

0

0

0

CapEx

38.7

0

0

0

0

0

0

0

0

0

0

0

3.8

0.6

0.2

OpEx

30.7

-

-

-

-

-

-

-

-

-

-

-

100

0.0

0.0

ESRS E1 CLIMATE CHANGE

Governance

DR related to ESRS 2 GOV-3: Integration of sustainability-related performance in incentive schemes

The mitigation of climate change constitutes a challenge for all companies. The goal of reducing CO2 emissions is integrated in the incentive systems of the Management Board of the SURTECO Group. Additional information on the SURTECO Group Incentive Schemes and their payment is included under DR GOV-3, which can be found in this statement in the section Governance of ESRS 2 General Disclosures Standard.

Strategy

DR E1-1: Transition plan for climate change mitigation

The SURTECO Group has set itself the goal of keeping our planet "worth living on". To this end, we are protecting our environment, using natural resources sparingly and avoiding or reducing the burden on people and nature. We have raised our goal of significantly reducing CO2 from 30 % to 50 % by 2030 [base year 2019: 95,915 tons of CO2 emissions]. Starting from the business year 2021, we have been sourcing green electricity at all locations in Germany and zero-emission electricity at some locations abroad. Our goal is to achieve the objective of becoming a climate-neutral company as early as the year 2045.

The short-term steps involve the conversion of all the production locations to the sourcing of electricity from renewable energy and the use of climate-friendly coolants. A group-wide, concerted transition plan is being drawn up and this plan is expected to be available by the business year 2027. The review of the transition plan is planned to be carried out by SBTi.

DR related to ESRS 2 SBM-3: Material impacts, risks and opportunities and their interaction with strategy and business model

The resilience analysis of the SURTECO Group carried out during the course of the business year assesses the adaptability of the business model and the strategy to meet the challenges of climate change with a timeframe of 5-10 years. In the context of the resilience analysis, the upstream value chain (upstream), including the procurement of raw materials and supplier dependencies, and the Group's own business activities were assessed. The analysis of the downstream value chain (downstream) in the scope of the double materiality analysis revealed impacts and opportunities which, however, are classified as insignificant. Future analyses could take greater account of this area provided that relevant information is available.

The resilience analysis is a component of strategic planning and sustainability strategy, and it is embedded in the Strategy Review Process. Climate scenarios drawn up by the Intergovernmental Panel on Climate Change (IPCC) and the International Energy Agency (IEA) form the basis for analysis, with particular focus on a 1.5 degree warming scenario. These agencies use top-down approaches, which assess the global impacts of climate risks on the market for surface materials, and bottom-up approaches, which investigate the specific risks and opportunities along the value chain. Customer and market data are also analysed in order to take account of the needs of customers and regulatory requirements in relevant markets. Internal workshops with the executive management, and experts on sustainability, procurement and production supplement the analysis.

The results of the scenario analyses demonstrate that the SURTECO GROUP has opportunities in the 1.5 degree scenario through the early integration of sustainable materials and climate-friendly production methods. Products with a reduced carbon footprint can be positioned within the marketplace as a unique selling proposition.

In the course of the analysis, physical risks were identified such as

  • shortage of raw materials and energy

  • interruptions to the supply chain

  • climate risks as a result of extreme weather events (storms, flooding, heat waves and cold snaps).

    The following risk was identified as a transition risk:

  • costs for the transition to climate-friendly technologies.

    Fundamentally, price increases for raw materials and energy are a material risk because uncertainties related to climate change in their production and logistics can make procurement more expensive. At the same time, the shortage of raw materials can lead to restrictions in material availability and price hikes.

    In addition, climate risks pose a direct threat for our production facilities, warehouses and transport pathways. Damage to infrastructure can trigger repair and insurance costs and/or make investments in resilient structures necessary. Furthermore, extreme weather conditions can exert an adverse effect on the working conditions for our employees and increase the chance of health risks.

    Another risk is posed by the potential costs for the transition to climate-friendly technology. The conversion to more sustainable processes, materials and production methods requires investments. Furthermore, stricter regulations such as increasing CO₂ pricing or stricter environmental regulations, can entail additional financial burdens.

    There is an opportunity in the expansion of the obligations and emission reporting as a result of new laws and directives. Potentially, this can lead to sharpening the sustainability strategy and a proactive response to future regulatory requirements, which can be seen as a strategic competitive advantage. The additional reporting obligations can promote the transparency and credibility of the SURTECO Group by demonstrating to investors, customers and other stakeholders that sustainability is firmly integrated into the corporate strategy.

    Responses to the challenges of climate change can be classified in three time horizons: Short-term adjustments (0-1 years)

  • Production optimization and energy efficiency

  • Use of materials and raw-material security through the use of recyclates and bio-based materials

    Medium-term adjustments (1-5 years)

  • Portfolio adjustment by means of development of new products with improved environmental footprint

  • Supply-chain resilience by means of diversification of the supplier structure

  • Training of employees

    Long-term adjustment (> 5 years)

  • Technological modernization by means of conversion to more environmentally friendly production procedures

  • Repurposing and modernization: Gradual conversion or shutdown of specific production lines may be possible if this becomes necessary due to regulatory or climate developments.

  • Decarbonization: Long-term investments in alternative materials and procedures for further reduction of the carbon footprint.

    The SURTECO Group therefore regards its business model as based on a sound foundation, since excessive dependence is avoided especially as a result of internationally positioned production sites, the avoidance of single sourcing and long supply routes, direct access to the capital markets and a broadly based product portfolio.

    Impact, risk and opportunity management

    DR related to ESRS 2 IRO-1: Description of the process to identify and assess material climate-related impacts, risks and opportunities

    The SURTECO Group identified its material IRO by applying the methodology for materiality analysis described in DR IRO-1, which can be found in the section Impacts, risk and opportunity management of the ESRS 2 General Disclosures standard contained in this statement.

    As part of the implementation of ESRS 2 IRO-1, a detailed assessment of the locations of the SURTECO Group was conducted in relation to extreme climate events. The focus was exclusively on river flooding and coastal flooding, while other climate extremes were not taken into account during the reporting year. Furthermore, the supply chain was not considered in this analysis. This assessment was based on the AQUEDUCT Water Risk Atlas published by the World Resources Institute (WRI). This provides an evidence-based methodology for recording water-related risks. RCP8.3 was used as a climate-scenario model. The assessment will gradually be expanded to the supply chain and to other climate hazards by 2030.

    CO₂ pricing is not included in the financial statements and no depreciation or impairments for fixed assets or buildings were undertaken. However, financial planning provides for investments in low-emission technologies or energy supply.

    DR E1-2: Policies related to climate change mitigation and adaptation

    The SURTECO Group is pursuing a strategic direction in order to manage climate-related impacts, risks and opportunities. The concepts are based on several strategic pillars, which are derived from the sustainability goals of the United Nations (SDGs). At the same time, they support the goals of the Paris Agreement and Germany's climate-neutrality strategy up to 2045.

    Climate protection

  • Innovations for improving the capability for product circularity (SDG 9).

  • Reduction of the specific energy use in production (SDG 12, 13).

  • Use of renewable or recycled raw materials to reduce the carbon footprint and to promote the circular economy (SDG 12).

  • Reduction of emissions beyond CO₂, particularly reduction of emissions of volatile organic compounds

    (VOC) (SDG 13).

    Adaptation to climate change

  • Assessment of the company locations in relation to flooding caused by rivers and coastal flooding.

    Energy efficiency

  • Reduction of the use of materials in the manufacture of products in order to save resources and energy (SDG 12).

  • Certification of our energy management systems in accordance with ISO 50001.

  • Measures for continuous optimization of energy-intensive processes.

    Use of renewable energy

  • Gradual increase in the use of renewable energy.

  • Investigation into materials along the upstream and downstream value chain with lower Product Car-bon Footprint (PCF).

    Other

  • Avoidance of transport pathways for reduction of indirect emissions (SDG 9).

  • Avoidance of waste (SDG 12).

  • Sustainability topics, including climate protection, are managed at Group level by a dedicated department.

DR E1-3: Actions and resources in relation to climate change policies

Measures in the reporting year Own business activities (OBA) / Value chain (VC)

Commision of a solar power system at the Agawam site (Pennsylvania, USA) OBA Increasing the recycling rate for plastic products OBA Establishment of a plastic edgeband product range with up to 100% secondary material OBA and VC Reduction of total energy consumption OBA

Reduction of GHG emissions compared to the previous year OBA

Screening of PCF-reduced materials VC

Reduction of hazardous waste OBA

Conversion of the vehicle fleet to electric vehicles OBA

Reduction of VOC emissions OBA

Commision of wastewater treatment at Rayong site OBA

Installation of charging infrastructure for electric vehicles OBA

Planned measures for the 2026 reporting year

Own business activities (OBA)/ Value chain (VC)

Time horizon

Commissioning of wastewater treatment at Sassenberg Site

OBA

In the 2026 reporting year

Increase the recycling rate for plastic products.

OBA

In the 2026 reporting year

Reduction of specific energy consumption

OBA

5-10 years

Reduction in GHG emissions

OBA

In the 2026 reporting year

Reduction of hazardous waste

OBA

In the 2026 reporting year

Implementation of the "Zero Pellet Loss" standard at all plastic

OBA

2026-2029

processing sites

No remedial measures were carried out during the year under review. The listed measures are managed and implemented by the Sustainability Department together with the cooperation of the BU Management Teams and with the involvement of the environmental and sustainability officers at the locations. The implementation of measures is linked with the budget process and the available financial and personnel resources. Decisions on projects with necessity for substantial CAPEX or OPEX are based on their effectiveness and considered on a case-by-case basis. A fixed budget for climate-neutrality measures is currently not envisaged.

An initial action plan for reduction of Scope 3 emissions is being prepared and is projected to be available by the reporting year 2026.

Metrics and targets

DR E1-4: Targets related to climate change mitigation and adaptation

The following disclosures must be provided in relation to the SURTECO Group's GHG targets:

Category Details

Base year 2019

Gross emissions in the base year (Scope 1 & 2) 95,915 tCO2e

GHG reduction target by 2030 -50% related to 2019

Reduction achieved to date (by 2025) -44% related to 2019

Annual reduction by 2030 5% of the previous year's figure in each case

Scope 1 & 2 emissions 60 % / 40 %

"Net Zero" (Scope 1, 2 & 3) 2045

GHG emissions from Scope 1 & 2 were recorded for the reporting year. An initial list of Scope 3 emissions is planned for the business year 2026.

All the locations belonging to the Group and relevant sources of emission are recorded for the identification of all direct and indirect GHG emissions in Scope 1 & 2. The base value for acquisitions and divestments is adjusted for the reference year. If there are any changes to the base value, the reduction target for 2030 remains unchanged.

The main decarbonisation lever for achieving the 2030 target is increasing the proportion of electricity purchased from renewable sources.

The SURTECO Group will set out it's detailed GHG emission reduction targets together with its climate-pro-tection measures in a graphical pathway representation after they have been submitted to the Science Based Targets Initiative (SBTi) and verified. The submission to the SBTi is planned by 2026. Comparison with a climate scenario is also planned in this connection.

DR E1-5: Energy consumption and mix

The reporting period for energy consumptions and GHG emissions corresponds to the reporting year. During this period, there were no material changes in the Group structure.

The figures presented were consolidated on the basis of information obtained from the individual subsidiary companies, with the main source of information being invoices from the energy utility companies.

During the reporting year, 338,561 MWh of energy were consumed by the SURTECO Group, which corresponds to a decrease of 2 % compared with 344,129MWh in 2024. This reduction is attributable to external market factors, as well as operational adjustments and shifts in the energy consumption profile.

Energy consumption and mix

MWh 2024 2025

Fuel consumption from coal and coal products

0

0

Fuel consumption from crude oil and petroleum products

13,821

10,950

Fuel consumption from natural gas

146,738

143,135

Fuel consumption from other fossil sources

0

0

Consumption of purchased or acquired electricity, heat, steam, and cooling from fossil sources

48,434

42,927

Total fossil energy consumption

208,993

197,012

Share of fossil sources in total energy consumption (%)

61

58

Consumption from nuclear sources

13,197

10,672

Share of consumption from nuclear sources 4

in total energy consumption (%)

3

Fuel consumption for renewable sources, including biomass (also comprising industrial and municipal waste of biologic origin, biogas, renewable hydrogen, etc.)

32,256

38,405

Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources

89,086

90,990

The consumption of self-generated non-fuel renewable energy

597

1,482

Total renewable energy consumption

121,939

130,877

Share of renewable sources in total energy consumption (%)

35

39

Total energy consumption

344,129

338,561

The energy consumption arises partly from the use of primary energy combustion fuels, such as natural gas or heating oil, and through the procurement of external energy, mainly in the form of electricity. In order to reduce possible environmental impacts, the SURTECO Group is pursuing an energy transition to renewable energy sources.

The share of renewable energy in the energy mix rose from 35 % in 2024 to 39 % in 2025.

The Group continues to pursue the sourcing of their electricity exclusively from renewable energy. In 2025, 68 % of the electricity consumed was generated from renewable sources, after 61 % in 2024.

A smaller proportion of the energy originates from own generation by means of photovoltaic systems. This energy is used almost entirely at the Group's own facilities. In the reporting year, 1,482 MWh of electricity consumed was generated by the SURTECO Group, after 597 MWh in the year 2024. In addition to the existing

installation in Portugal, Australia and Italy, this increase reflects the new photovoltaic system in the USA, which became operational in 2025.

The SURTECO Group is defined (Directive (EU) 2022/1288) as partly active in sectors (Sector C: Manufacturing Industry) that are classified as sectors with high climate impact. The SURTECO Group uses energy intensity as a Key Performance Indicator (KPI) in order to monitor energy efficiency at its operating facilities. The group-wide energy intensity for the business year 2025 amounts to sales of 412 MWh / € million, after 402 MWh / € million in fiscal year 2024. The total energy consumption decrease from 338,561 MWh in 2025 compared to 344,129 MWh in 2024. The decrease in sales of 4 % compared to the previous year was partially offset by the decrease in 2 % of the energy consumption.

Energy intensity per net revenue

MWh / € million 2024 2025 Variation

Total energy per net revenue 402

(Net revenue see ESRS 2; DR SBM1)

412

2.5%

DR E1-6: Gross Scopes 1, 2, 3 and Total GHG emissions

In spite of the efforts directed towards environmental protection, emissions into the atmosphere cannot be completely avoided. They also constitute side effects of production processes such as waste or consumption of resources and raw materials. Emissions are subject to limit values that are defined by operating licences for our plants issued by government agencies. The SURTECO Group monitors compliance with these limit values at individual locations through having measurements taken by independent third parties.

The direct emissions of CO2 equivalent (Scope 1) arise as a result of the combustion of fossil energy sources in the company's own power plants or by emissions caused within the organization, for example from heating energy or thermal exhaust-gas treatment. Emission values were calculated on the basis of the energy sources used, such as gas or heating oil, and the global warming potential (GWP) of the Feder-al Office for Economic Affairs and Export Control (BAFA).

The indirect Scope 2 emissions in the form of CO2 equivalents are caused mainly by external energy purchases in the form of electricity. Market-based and location-based GWPs were taken into account for the calculation. The market-based figures were taken directly from the individual energy suppliers of the SURTECO Group. Whenever information was not available, the values used correspond to the location-based values. The values were then determined on the basis of location-based GWPs, which were obtained from the International Energy Agency (IEA). Of the purchased electricity, 64% was bundled with Guarantees of Origin and Renewable Energy Certificates. The remaining 36 % came from the conventional electricity mix, of which 9 % was from renewable sources, 22 % from nuclear energy and 69 % from non-renewable sources.

As far as total GHG emissions are concerned, it can be assumed that the emissions in the upstream and downstream value chain, i.e. Scope 3 emissions, outweigh the total emissions from Scope 1 and 2. The Group is planning to submit figures on this matter in the coming reporting year.

The total volume of CO2 equivalents emitted by the SURTECO Group, which comprise the direct and indirect emissions from its business activities, amounted to 54,135 tons of CO2e in the reporting period 2025.

In 2025 there was a decrease in total CO2e emissions by 5%, from 57,202 tons of CO2e in 2024.

This decrease is primarily due to the ongoing conversion of locations to green electricity, particularly purchased green electricity (Scope 2), which led to a decrease by 5 % compared with the entire previous year. Furthermore, minor deviations are due to improvements in data quality, as work is continuously being done to improve the accuracy of measurement.

Retrospective Milestones and target years

t CO2eq Base year 2024 2025

Variation

in % 2026 2030 2045

Annual % target / Base year

Scope 1 GHG emissions

5 % (Scope 1 & 2) Previous year

50 % (Scope 1 & 2) Base year

Net Zero (Scope 1, 2 & 3) under assessment

Gross Scope 1 GHG emissions 39,597 34,412 32,462 -5.7 %

-18 %

Percentage of Scope 1 GHG emis-

sions from regulated emission 0 0 0 -trading schemes (%)

-

Scope 2 GHG emissions

Gross location-based Scope 2 GHG 52,870 46,581 40,642 -12.7 % emissions

-23 %

Gross market -based Scope 2 GHG 56,318 22,790 21,673 -4.9 % emissions

-62 %

Significant scope 3 GHG emissions

Total Gross indirect (Scope 3) GHG Under assessment emissions

-

Total GHG emissions

Total GHG emissions (location- 92,467 80,993 73,104 -9.7 % based)

-21 %

Total GHG emissions (market- 95,915 57,202 54,135 -5.4 % based)

-44 %

The use of natural gas by the SURTECO Group amounted to 54 % of the total greenhouse gas emissions in 2025. Electricity with a proportion of 37 % comes next. The remaining 9 % essentially result from the use of combustion fuels, district heating and the combustion of wood and waste, with a small proportion resulting from the release of harmful substances and gases.

The SURTECO Group releases biogenic emissions from the combustion of non-recyclable wood and paper waste, with a proportion of 1 % of total emissions (market-based GHG emissions in Scope 1 and 2) in 2025.

As noted, external market factors, operational adjustments, and changes in the energy consumption profile impacted overall energy use, which is reflected in greenhouse gas emissions, such as Scope 1.

For Scope 2, a significant difference is observed between location-based and market-based emissions. Location-based emission factors show a worldwide decrease, driven by a transformation of the electricity mix away from fossil fuels. Market-based emissions also trend downward. However, in certain high-demand facilities in USA, supplier emission factor increased compared with the previous reporting period, making the overall reduction less pronounced.

The group-wide emission intensity for the business year 2025 amounts to 66 t CO2e / € million sales for a total volume of CO2e emissions amounting to 54,135 tones.

Energy intensity per net revenue

t CO2eq / € million 2024 2025 Variation

Total GHG emissions (location-based) per net revenue 95

(Net revenue see ESRS 2; DR SBM1)

89

-6 %

Total GHG emissions (market-based) per net revenue 67

(Net revenue see ESRS 2; DR SBM1)

66

-1.5 %

Calculation of Scope 3 GHG emissions

No Scope 3 emissions data are available for the reporting year. The Group's diverse business areas and the wide variety of raw materials used make a reliable estimation complex, as any figure would depend on numerous assumptions and could be misleading. A robust assessment of Scope 3 emissions requires a tailored approach beyond standard calculation methods.

Quantitative disclosures are planned for the next reporting year, with data-collection and calculation methodologies currently being developed to ensure accuracy and reliability.

DR E1-7: GHG removals and GHG mitigation projects financed through carbon credits

The Group does not support any projects in own business or in the upstream or downstream value chain for the breakdown or storage of greenhouse gases.

DR E1-8: Internal carbon pricing

There is no internal CO2 pricing system within the company.

DR E1-9: Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

The SURTECO Group reviews the anticipated financial impacts arising from climate-related risks and opportunities. Currently, no strategies, measures or targets have been defined and there will therefore be no disclosure in the first year of the Sustainability Statement. The SURTECO Group is working towards defining the targets by 2029.

ESRS E2 POLLUTION

Impact, risk and opportunity management

DR related to ESRS 2 IRO-1: Description of the process to identify and assess material pollution-related impacts, risks and opportunities

Using the methodology for the materiality analysis described in DR IRO-1, which can be found in the section Impact, risk and opportunity management of the ESRS 2 General Disclosures standard, the SURTECO Group has identified its material impacts, opportunities and risks.

In addition to the process referred to, additional factors were taken into account for the assessment of the topics relating to the circular economy, for example:

  • screening of the most important pollutants for each manufacturing process and activities in the value chain,

  • potential receptors taking into account the type of pollutants, the handling conditions and the existing measures,

  • understanding of the composition of the raw materials used and their potential impacts on substances of concern and microplastics,

  • existing treatment systems and preventive measures,

  • Individual results from monitoring of pollutants,

  • Emission limit values.

Affected communities were not integrated in the reporting year.

Production locations where chemical raw materials are processed or stored have a higher risk in relation to environmental pollution than sites where exclusively sales or administrative activities take place. This difference was taken into account in the course of risk assessment, as production sites can cause potentially higher environmental impacts, for example through emissions, wastewater or handling hazardous substances. Risks arise here essentially during transport or delivery procedures by suppliers. Chemicals raw materials and subsidiary materials are stored in containers or on premises specially designed for this purpose. Finally, it is important to note that risk profiles can vary within the group of manufacturing locations depending on the production process and geographical location.

No incidents were registered during the reporting period that resulted in financial penalties or sanctions being levied by government authorities.

DR E2-1: Policies related to pollution

The SURTECO Group operates on the basis of the guiding principle of "avoidance before reduction before mitigation" and in the case of waste the principle "avoidance before reduction before recovery".

All questions relating to CO2 emissions were already addressed in the chapter Climate change E1 and will not be further discussed in the following sections. Where necessary, air control systems are installed.

Air pollution

Wherever possible, we use water as the solvent in our lacquers, paints or impregnations. For technological reasons, however, the use of organic solvents and the associated emissions cannot always be avoided. In all cases, the SURTECO Group complies with the statutory limit values, partly by the use of thermal afterburning of exhaust air.

SOC or SVHC

The SURTECO Group places a great importance on the responsible handling of chemicals and is actively working on avoiding substances that are classified as SOC (Substances of Concern) or SVHC (Substances of Very High Concern) in its formulations. Substances of this nature are only used if there are no alternatives in order to maintain the high requirements for product quality and functionality. Ensuring that these substances are only used in the quantities that are permitted under the statutory regulations.

Furthermore, we review the contents of our formulations regularly and carefully. The compositions are reviewed at fixed intervals and when relevant developments occur - for example changes in the statutory regulations or new scientific findings - and the formulations are modified as necessary. This approach underscores our commitment to the protection of people and the environment, along with our obligation to consistently comply with the statutory regulations.

Microplastics

Plastic granulate is used as raw material in the extrusion processes carried out by the SURTECO Group. All handling and further processing is carried out in closed systems in order to avoid pollution of the environment by microplastics. This prevents the release of microplastics. A high standard of cleanliness is absolutely essential here. The disclosures provided only relate to delivery and internal activities within the company.

DR E2-2: Actions and resources related to pollution

The measures implemented by the SURTECO Group follow the guidance in the EU Action Plan "Towards Zero Pollution for Air, Water and Soil" and the ISO guidelines for environmental management 14001.

Air pollution

The SURTECO Group complies with the statutory limit values, partly by using thermal exhaust air afterburning. This also applies to the limit values for exposure in the workplace. As appropriate, additional afterburning systems (RTO - Regenerative Thermal Oxidation) are installed. The SURTECO Group commissions external measurements in order to monitor the volume of emissions and has these carried out as part of environmental management.

SOC or SVHC

One of the subsidiary companies works with melamine impregnations. The free amounts of melamine in our products are below the prescribed limit values.

Furthermore, formaldehyde emissions arise in wastewater or in the air at some of our locations. Contaminated wastewater is collected and treated by specialized companies. If emissions are released into the air, biological or thermal after-treatment is carried out in order to avoid the release of formaldehyde into the atmosphere. Wherever substances of concern are used, the availability of less harmful substances is assessed on a regular basis.

Microplastics

Even though all processes related to the handling of plastic granulate have to be carried out in closed systems, accidental spillage cannot be avoided. In order to further reduce the entry of the plastic granulate into the environment, the SURTECO Group is targeting certification in accordance with the guidelines of the "Zero Pellet Loss Initiative" for all locations using plastic granulate within the next five years. This also includes training for employees and optimization of processes in order to avoid unintended spillage. The SURTECO Group is committed to minimizing potential risks by preventive measures.

Avoidance of incidents and emergency plans

The SURTECO Group has implemented a comprehensive risk management and emergency policy in order to systematically avoid potential environmental incidents and emergency situations, and to minimize impacts on people and the environment. These measures extend to our own activities.

  1. Avoidance of incidents and emergency situations

    The company implements the following measures for proactive prevention of environmental pollution and emergencies:

    • Regular risk analyses:

    • Identification of potential environmental risks by systematic location assessments and audits (in accordance with the ISO standard).

    • Assessment of hazardous substances.

    • Technical prevention measures:

    • Use of safety technology such as leakage and emission monitoring systems.

    • Automated shutdown systems.

    • Closed transfer and processing systems in order to avoid leakages.

    • Organizational measures:

    • Regular training sessions for employees in safety-critical processes and emergency measures

  2. Limiting the impacts of incidents and emergency situations

    If an incident occurs in spite of the preventive measures, comprehensive emergency and containment measures are available:

    • Immediate measures in the event of incidents:

    • Available emergency plans for various scenarios (e.g. chemical leakages, fires, major incidents).

    • Provision of emergency equipment (e.g. mobile absorbers, protective barriers, neutralization agents).

    • Rapid activation of internal emergency teams and crisis staffs.

    • Environmental and health measures:

    • Close exchange with local authorities and environmental protection organizations.

    • Immediate analysis and monitoring of environmental impact following an incident.

    • Medical protective measures for affected employees.

    • Learning processes and improvements:

Systematic follow-up after incidents to identify optimization potential.

Adjustment of safety and environmental policies on the basis of the findings gained.

This comprehensive approach enables the SURTECO Group to ensure that potential environmental pollution caused by incidents is largely avoided and the impacts are minimized.

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