Social responsibility information

S1 Own workforce

BE Group’s employees work in warehouse and production environments where handling heavy materials and exposure to dust particles pose occupational health and safety risks. The company applies a zero‑accident vision through its Safety First programme. Health and safety has been identified as the most material topic concerning the own workforce.

Material impacts, risks and opportunities Position in the value chain Potential/actual impacts Time horizon
Negative impact
Health and safety in the workplace
Own operations Actual

SBM-3

Material impacts, risks and opportunities and their relationship to strategy and business model

BE Group has, through the double materiality assessment, concluded that ESRS S1 Own Workforce is material. In accordance with ESRS 1 Appendix C, the company applies transitional provisions for S1 Own Workforce, primarily regarding quantitative metrics, with the aim of expanding disclosures in the coming years.

The segment of the own workforce that BE Group has assessed as being materially impacted includes full‑time and part‑time employees, temporary employees, and contracted labour such as consultants and personnel from staffing agencies.

The potential impacts identified by the company are mainly linked to health and safety, where the working environment may pose risks due to airborne dust particles and occasionally cold facilities. BE Group takes active measures to prevent and evaluate these risks, and regular health examinations are carried out for staff at the production facilities.

Another potential impact relates to production activities and the handling of heavy materials. A policy is in place, and units work locally to assess and mitigate risks in the operations to prevent accidents. Governance documents have been established, and regular follow‑ups, workplace meetings, safety inspections and training sessions are conducted. Every incident and risk observation is reported, evaluated, addressed and followed up. The largest warehouse and production facility in Sweden is certified according to ISO 45001, but at present there are no plans to implement the certification at the facilities in Finland.

The company has not identified any risks or incidents related to forced labour or child labour within its own operations.

MDR-P

Adopted policies for managing material sustainability matters

BE Group’s Code of Conduct applies to all operations and employees within the company. The ethical guidelines provide direction for daily work to achieve the Group’s objectives and clarify everyone’s responsibility toward business partners, shareholders, employees and society. Respect for human rights is a key factor in contributing to the UN Sustainable Development Goals.

Internal guidelines are included in the company’s Code of Conduct, which outlines the rights of employees, such as:

  • the right to be represented by a trade union in negotiations
  • fair employment and wage conditions
  • a workplace free from discrimination and harassment
  • zero tolerance for child labour

There is also a policy based on a zero‑accident vision called Safety First, which is founded on the principle that all accidents can be prevented and that safety must always come first. Governance documents have been established, and regular follow‑ups, workplace meetings, safety inspections and training sessions are conducted.

All policies are approved by management and available to employees. They form part of the onboarding program for new hires.

Policy Description Management Owner
Code of Conduct BE Group’s Code of Conduct sets out the expectations for employee behavior in areas such as human rights, workplace environment, business ethics, anti‑corruption, and the environment. The policy is based on the UN Global Compact. The policy applies to all employees across the Group. Ultimate responsibility for the policy lies with the President and CEO. The current version of the policy was approved by the Board of Directors in April 2018. The policy is communicated to employees at the start of their employment and is available on the company intranet. Employees are required to acknowledge that they have read and understood the policy. The policy was developed internally, and as documentation is not available, the company assumes that no stakeholder dialogue was conducted during its initial development. President and CEO
Privacy Policy BE Group’s Privacy Policy provides information on the collection, processing, storage, and sharing of personal data concerning individually identifiable employees. The policy applies to current, former, and future employees regardless of employment type, as well as to contracted personnel. The policy was adopted in 2022 and was developed internally. As documentation from the development process is not available, the company assumes that no stakeholder dialogue was conducted during the policy’s initial formulation. CFO
Safety First Policy BE Group’s Safety First Policy establishes that safety must always be the highest priority. The policy is based on a zero‑accident vision and the conviction that all workplace accidents are preventable. It encompasses systematic occupational health and safety management, including risk assessments, follow‑up procedures, training, and continuous improvement. The company also applies behaviour‑based safety methods to strengthen the conditions for a safe working environment. Leadership within the health and safety area is guided by BE Group’s leadership principles (‘BE A LEADER – 8 Principles’). The policy applies to all employees, subcontractors, and contracted personnel across the Group. Ultimate responsibility for the policy lies with the CEO and Group President. The policy was adopted in 2019. It is communicated through the company intranet, during onboarding of new employees, and through regular safety activities and safety training. In line with the policy, one site in Sweden (Barlastgatan) has obtained ISO 45001 certification for occupational health and safety management. The policy was developed internally, and as documentation from the development process is not available, the company assumes that no stakeholder dialogue was conducted during its initial formulation. President and CEO
Whistleblowing Policy BE Group’s Whistleblowing Policy sets out the procedures for reporting serious irregularities within the Group. The policy covers the reporting of suspected criminal activity, corruption, severe environmental misconduct, significant safety deficiencies, and serious discrimination. Reporting is carried out through an external whistleblowing service called Trumpet, which is administered by an independent third party. The policy applies to all individuals engaged in work‑related contexts within BE Group, including members of the Board of Directors, employees, interns, contracted personnel, as well as shareholders and auditors. Ultimate responsibility for the policy lies with the CFO. Reports are handled under strict confidentiality by a limited group consisting of the external service administrator and BE Group’s internal Whistleblowing Committee. Reports may be submitted anonymously. Individuals who report in good faith are protected against retaliation, a protection that also extends to colleagues and union representatives who assist in the reporting process. The policy is communicated through the company’s website, where the whistleblowing service is accessible. The policy was adopted in July 2022. It was developed internally with consideration of the EU Whistleblowing Directive and Swedish whistleblowing legislation. CFO

MDR-A

Actions and resources related to material sustainability matters

The potential impact identified by the company is primarily linked to health and safety, where the working environment may pose risks due to airborne dust particles and occasionally cold facilities. BE Group takes active measures to prevent and assess these risks, such as gradually replacing diesel forklifts with electric forklifts, conducting air measurements at selected production facilities, performing work environment assessments and carrying out regular health examinations for employees at the production sites.

The company has not identified any risks or incidents related to forced labour or child labour within its own operations.

The company works actively with occupational health and safety and uses different system supports in Sweden and Finland for data compilation. In 2025, the company initiated the implementation of a joint system to enable more harmonised reporting.

MDR-T

Monitoring the effectiveness of policies and actions through targets

The company has established overarching targets related to its own workforce and monitors, among other things:

  • the number of accidents and incidents in operations
  • sick leave
  • conducts pay equity assessments
  • measures employee turnover
  • ensures that all employees are offered regular performance development reviews

These activities are followed up annually by the local management teams.

MDR-M

Metrics related to material sustainability matters

The company reports the following key performance indicators for 2025.

Health and safety

During the year, 9 accidents resulting in more than one day of absence were reported, of which 6 occurred in Sweden and 3 in Finland.

Increasing the proportion of female employees

The average number of employees in BE Group during the year amounted to 555, of which 10% were women. Gender distribution remains a sector‑related challenge, and efforts continue to assess how the company can create conditions to attract more female employees and managers. The differences between the proportion of women in administrative roles and in production are substantial. As of 31 December 2025, the share of women among administrative staff was approximately 26%, while the share in production was around 3%.

S2 Workers in the value chain

BE Group’s upstream value chain includes raw material extraction and steel production, where working conditions and labour‑related rights may be associated with risks. The company’s procurement strategy, with a focus on European suppliers, serves as an indirect risk‑reducing factor. Visibility into working conditions beyond the first tier of suppliers is limited.

Material impacts, risks and opportunities Position in the value chain Potential/actual impacts Time horizon
Negative impact
Risks related to working conditions and labour‑related human rights in the mining sector
Upstream Potential Short-, medium-, long-term
Negative impact
The risk of accidents in production is an inherent characteristic of steel and aluminium production processes
Upstream Actual Short-, medium-, long-term

SBM-3

Material impacts, risks and opportunities and their relationship to strategy and business model

BE Group has considered the nature, scale and geographical context of its operations when assessing impacts on workers in the value chain. Material impacts on value chain workers have been assessed as assumed rather than verified, reflecting limited traceability beyond first‑tier suppliers. These assumed impacts cover all sub‑topics: working conditions, equal treatment and opportunities, and other work‑related rights.

BE Group’s upstream value chain includes virgin materials—iron ore, bauxite and alloying elements such as nickel and chromium—procured through global commodity markets via steel producers. The mining sector presents documented risks related to working conditions and labour‑related rights, particularly in jurisdictions with weaker regulatory frameworks.

The company’s sourcing strategy means that sourcing primarily takes place from suppliers within the European market, where regulatory frameworks governing labour conditions are generally more developed. This geographical focus serves as an indirect risk‑mitigating factor for labour‑related risks in the first tier of the supply chain. BE Group’s business model as a distributor results in limited control and visibility over working conditions beyond the first tier. Impacts are addressed through requirements in the Code of Conduct for suppliers and the geographical focus of the sourcing strategy.

MDR-P

Adopted policies for managing material sustainability matters

BE Group’s expectations on suppliers regarding working conditions, equal treatment and work‑related rights are governed by the company’s Code of Conduct for Suppliers, most recently revised in 2023. The Code sets out minimum requirements in the following areas:

Working Conditions

Compliance with working hour regulations (maximum 60 hours per week including overtime), minimum wages in line with applicable legislation, statutory benefits, accident insurance as well as transparent systems for time registration and wage management

Equal treatment and equal opportunities

Prohibition of discrimination based on race, colour, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, trade union membership, national origin or marital status. Requirement for a workplace free from harassment.

Other work‑related rights

Prohibition of forced labour, human trafficking and child labour. Respect for freedom of association and collective bargaining rights. Comprehensive requirements for occupational health and safety, including risk management, chemical handling, emergency preparedness and ergonomics

The Code of Conduct for suppliers requires suppliers to ensure that these principles are upheld within their own supply chains. BE Group, or a third party appointed by BE Group, reserves the right to conduct audits or on‑site visits to assess supplier compliance. Suppliers are expected to provide grievance mechanisms for employees and protections for whistleblowers in line with applicable legislation. BE Group aims for all suppliers to sign the company’s Code of Conduct for suppliers. In cases where suppliers do not sign it, this may be accepted provided the supplier can demonstrate its own Code of Conduct with equivalent or higher standards. This pragmatic approach reflects the fact that several of BE Group’s major suppliers are international steel producers with well‑established sustainability programs and Codes of Conduct.

Policy Description Management Owner
Code of Conduct for suppliers BE Group’s Code of Conduct for suppliers specifies minimum requirements for suppliers in areas such as legal compliance, labour rights and human rights, occupational health and safety, the environment, and business ethics. The policy references the ILO Core Conventions, the UN Global Compact, the OECD Guidelines for Multinational Enterprises, and the UN Universal Declaration of Human Rights. The policy applies to all suppliers to the Group. Suppliers are encouraged to apply equivalent requirements within their own supply chains. Ultimate responsibility for the policy lies with President ad CEO. The policy is communicated to suppliers during contractual processes. BE Group seeks to ensure that all suppliers sign the Code of Conduct for suppliers. In cases where suppliers do not sign BE Group’s Code, this may be accepted provided that the supplier can present its own code of conduct with equivalent or higher standards. The policy was developed internally with consideration of international frameworks. As documentation from the development process is not available, the company assumes that no stakeholder dialogue was conducted during the policy’s initial formulation. President and CEO

MDR-A

Actions and resources related to material sustainability matters

BE Group has no specific actions or strategies directed toward the identified impacts on workers in the value chain beyond the requirements established through the company’s Code of Conduct for suppliers.

The company’s sourcing strategy means that sourcing primarily takes place from suppliers within the European market, where regulatory frameworks for labour conditions, occupational health and safety, and labour rights are generally more developed than in other regions. This geographical focus serves as an indirect risk‑reducing factor related to labour‑related risks in the first tier of the supply chain.

Visibility into working conditions beyond the first tier, particularly in relation to raw material extraction, is limited due to the structure of the value chain and how commodity markets operate. No specific actions to address these risks were implemented during the reporting period.

MDR-T

Monitoring the effectiveness of policies and actions through targets

BE Group’s business model as a distributor results in limited control and visibility over working conditions beyond the first tier. Impacts are addressed through the requirements set out in the Code of Conduct for suppliers and through the geographical focus of the company’s procurement strategy.

BE Group has no dedicated channels or procedures for workers in the value chain to raise complaints or report concerns directly to the company. General contact channels are available via the company’s website.

According to BE Group’s Code of Conduct for suppliers, suppliers are expected to provide their own grievance mechanisms for workers and ensure whistleblower protection in accordance with applicable legislation. Remediation of any adverse impacts on workers in the value chain is therefore primarily expected to be managed by the respective employer within the supplier chain.

BE Group did not receive any complaints from workers in the value chain during the reporting period.

MDR-M

Metrics related to material sustainability matters

BE Group has not established specific targets relating to workers in the value chain. The development of measurable targets and indicators is being evaluated for future reporting periods.

S3 Affected communities

Material impacts, risks and opportunities Position in the value chain Potential/actual impacts Time horizon
Negative impact
Material impacts on indigenous peoples and local communities arising from raw material extraction
Upstream Potential Short-, medium-, long-term
Positive impact
Major employers, particularly in small or rural communities
Own operations Actual Short-, medium-, long-term

S4 Consumers and end-users