BP-2

Disclosures in relation to specific circumstances

The time perspective applied in the Sustainability Report is, unless otherwise stated, retrospective. In general, the time horizons short, medium, and long term are used. Short term refers to the reporting period, medium term refers to the reporting period up to five years, and long term refers to more than five years. During the reporting period, the Group has implemented structural changes and cost‑efficiency measures in parallel with the transition to a new enterprise system. In certain cases, these circumstances have limited the ability to collect and validate data to the desired extent, as reflected under the respective disclosure requirements. With respect to E2‑4, the available data sources consist of periodic control measurements carried out in accordance with the requirements of supervisory authorities. These measurements are not considered to provide a reliable basis for estimating annual total quantities, and in light of the circumstances described above, additional efforts to bridge this uncertainty have not been deemed an appropriate use of the company’s resources. Furthermore, uncertainty regarding regulatory developments at the EU level has affected the conditions for long‑term resource planning related to sustainability reporting. The company is monitoring regulatory developments and continuously evaluating their implications for the company’s future sustainability reporting.

The company has chosen to apply the transitional reliefs and several of the reporting simplifications in accordance with the European Sustainability Reporting Standards “quick‑fix” delegated act, which entered into force on July 11, 2025. These are specified in each respective section. A number of disclosure requirements are reported in other sections outside this Sustainability Report. In such cases, cross‑references are provided.

BE Group is continuously working to improve processes and data quality for reporting purposes. Calculation methods, including calculation factors and accounting principles, are described in connection with the reported information.

GOV-1

The role of the administrative, management and supervisory bodies

Board composition and independence

BE Group’s Board of Directors consists of six members, of whom five are elected by the General Meeting and one is an employee representative. All members elected by the General Meeting are non‑executive. The Group’s CEO is not a member of the Board. Of the members elected by the General Meeting, three are considered independent in relation to the company and its management and also in relation to major shareholders.

Board diversity at the end of 2025

Function	Area of responsibility
Board member’s term (year)	1–5 (4) / 11–15 (1) / 16–20 (1)
Independent directors	60% of elected by the General Meeting
Age structure (year)	35–39 (1) / 40–44 (1) / 50–54 (2) / 60–64 (2)
Distribution by gender	Women 2 (33%) / Men 4 (67%)
Level of education	Executive MBA, M.Sc. in Business and Economics, M.Sc. Mechanical Engineering

The members of the Board bring experience from the engineering industry, trade and distribution, as well as international business operations, all of which are relevant to BE Group’s business as a trading and service company within the steel sector. The employee representative contributes perspectives from operational activities.

Responsibility for sustainability matters

Board of Directors’ responsibilities

The Board of Directors holds the ultimate responsibility for BE Group’s sustainability work, including the oversight of material impacts, risks and opportunities related to sustainability. The Board approves the company’s sustainability strategy, key policies and the sustainability statement in the Annual Report. Sustainability matters are addressed by the Board at least twice per year and additionally as needed when material issues arise. As part of the annual strategy process, the Board reviews sustainability‑related risks and opportunities and their connection to the business strategy. The Board is continuously informed about sustainability matters through reporting from Group Management on material impacts, risks and opportunities.

CEO’s responsibilities

The CEO (who also serves as Managing Director of BE Group Sverige AB) has the overall operational responsibility for implementing the sustainability strategy, setting and working towards sustainability targets and ensuring compliance with policies at Group level. The CEO reports to the Board on sustainability matters and ensures that the necessary resources and mandates are in place to execute the sustainability work. The CEO is ultimately responsible for setting and following up on targets related to identified material impacts, together with the rest of Group Management. The Managing Directors of the subsidiaries are responsible for implementing sustainability activities within their respective units, in accordance with Group policies, guidelines and targets related to material impacts, risks and opportunities.

Group Sustainability Coordinator

The Sustainability Coordinator coordinates the Group’s sustainability work and reports to the CEO. The role includes:

• Coordination of sustainability activities across business units and functions
• Preparation of documentation for decisions by the Board and Group Management
• Follow‑up of sustainability targets and key performance indicators
• Coordination of external sustainability reporting, including ESRS reporting
• Monitoring of regulatory developments and industry trends

Operational Responsibility at Company Level

The operational responsibility for sustainability matters is allocated among functions within the subsidiaries as follows:

Function	Area of responsibility
Operations	Environmental impacts in the company’s own operations (E1–E5), occupational health and safety (S1)
HR	Employee‑related matters, diversity, competence development and other personnel‑related topics (S1)
Sourcing	Value chain aspects (upstream E1–E5), workers in the value chain (S2), affected communities (S3)
Finance	Business ethics and anti‑corruption (G1), sustainability‑related financial reporting

Governance processes and internal controls

Reporting lines

The Sustainability Coordinator reports to the CEO. Sustainability information is aggregated from the subsidiaries’ functions (Operations, HR, Sourcing and Finance) and reported to Group Management for consolidation and subsequent reporting to the Board of Directors.

Integration with other governance processes

Sustainability matters are integrated into existing governance processes:

• Risk management: Sustainability‑related risks are included in the annual risk assessment reported to the Board.
• Strategy process: Material sustainability matters are taken into account in the annual strategy review.

Internal control over sustainability reporting

The framework for internal control over sustainability reporting is under development. During 2025, the focus has been on establishing processes for data collection and quality assurance of sustainability information. Work to formalize control structures and clarify roles and responsibilities in the reporting process will continue in the upcoming period.

Competence and expertise

The members of the Board collectively possess experience from industrial operations, trade and distribution, as well as international business management. This experience is relevant for assessing sustainability matters connected to BE Group’s operations as a steel distributor. Specific expertise in sustainability‑related areas such as climate, environmental legislation and EU regulatory frameworks is provided through:

• The Sustainability Coordinator’s preparation of analyses and supporting materials
• External advisory support when needed, for example regarding regulatory requirements
• Review and feedback from the auditors

The Board continuously evaluates the need for additional sustainability‑related competence as part of the annual Board evaluation.

GOV-2

Information provided to, and sustainability matters addressed by, the undertaking’s administrative, management and supervisory bodies

Sustainability matters are addressed by the Board of Directors at least twice per year and additionally whenever issues arise concerning material impacts. As part of the annual strategy process, the Board considers sustainability‑related risks and opportunities and how they relate to the business strategy. Furthermore, the Board receives information on risk management, internal control and sustainability reporting from the company’s Sustainability Coordinator as well as from the auditors through the Audit Committee. As part of the annual strategy update, the Board takes into account the impacts, risks and opportunities associated with the company’s material sustainability matters.

GOV-3

Integration of sustainability-related performance in the incentive schemes

In accordance with BE Group’s remuneration policy for senior executives, the company shall offer competitive and market‑based remuneration to attract, motivate and retain competent and skilled employees. Variable cash remuneration shall be based on predetermined, well‑defined and measurable financial targets for the Group and the relevant business area. The targets for variable cash remuneration shall primarily relate to the Group’s operating margin or operating result, and the underlying operating margin or operating result of the respective business area. In addition, individual targets may also be established. Currently, the variable cash remuneration for senior executives is not linked to any sustainability‑related objectives beyond the financial targets. Further information is available in the remuneration report on the company’s website: www.begroup.com.

GOV–4

Statement on due dilligence

BE Group does not have a unified, formalized due diligence process. The activities that constitute the company’s due diligence are integrated into existing policies, risk processes, and operational procedures rather than consolidated into a dedicated framework. Below is a description of how each step of the due diligence process is managed.

1. Embedding due diligence in governance, strategy and the business model

The company’s Code of Conduct, Code of Conduct for suppliers, Environmental Policy, Safety First Policy and Anti‑Corruption Policy form the policy framework within which due diligence is carried out. The Code of Conduct for suppliers refers to the ILO Core Conventions, the UN Global Compact, the OECD Guidelines for Multinational Enterprises, and the UN Universal Declaration of Human Rights. The Board of Directors holds the ultimate responsibility for sustainability matters, while the CEO carries the operational responsibility. The Sustainability Coordinator coordinates the work and prepares analyses and documentation to support decision‑making by the Board and Management.

2. Engaging with affected stakeholders across all main steps of due diligence

BE Group engages with key stakeholders through personal meetings, customer and employee surveys, supplier meetings, investor interactions and union collaboration. During the 2023-2024 materiality assessment, interviews were conducted with selected internal and external stakeholders including shareholders, trade unions, a bank, an insurance company, customers and suppliers. However, the company has no established procedures for engaging with affected communities or workers in the value chain beyond the first tier of suppliers.

3. Identifying and assessing negative impacts

Identification of negative impacts takes place through the double materiality assessment, the annual risk assessment, and ongoing work within the ISO 14001 and ISO 45001 certified management systems. The materiality assessment was updated in 2025. Sustainability‑related risks are included in the annual risk analysis reported to the Board. Insight into impacts beyond the first tier of suppliers is limited.

4. Taking action to address negative impacts

Actions within the company’s own operations are described under each topical standard and include, among others: energy efficiency measures (E1–E3), systematic occupational health and safety practices and the Safety First programme (S1), chemical management and environmental certification (E2). In the value chain, negative impacts are primarily addressed through the requirements set out in the Code of Conduct for suppliers, as well as through the geographical sourcing strategy that prioritises European producers.

5. Tracking the effectiveness of measures and communicating results

Follow‑up is carried out through key performance indicators related to health and safety, energy consumption and emissions, which are reported to Group Management and the Board of Directors. External communication takes place through this sustainability statement. The company has not conducted a systematic evaluation of policy effectiveness during the reporting period.

6. Enabling remediation

BE Group’s whistleblowing service (“Trumpet”) enables anonymous reporting of suspected misconduct and is administered by an independent third party. Employees, suppliers and other stakeholders can report via the company’s website. With respect to the value chain, remediation is primarily expected to be handled by each actor within the supplier chain. BE Group has no dedicated channels for workers in the value chain or affected communities to raise complaints directly with the company.

Steps in the due dilligence process	Page references in the sustainability statement
1. Embedding due diligence in governance, strategy and the business model	p. 17 (GOV-1), p. 19 (GOV-4), p. 20 (SBM-1), p. 24 (E1-2), p. 43 (Safety First Policy, Code of Conduct), p. 51 (G1-1)
2. Engaging with affected stakeholders across all main steps of due diligence	p. 20 (SBM-2), p. 21 (IRO-1)
3. Identifying and assessing negative impacts	p. 18 (Risk Management), p. 21 (IRO-1), p. 23–48 (SBM-3 for each topical standard)
4. Taking action to address negative impacts	p. 25 (E1-3), p. 29 (E2-2), p. 31 (E3-2), p. 36 (E5-2), p. 43 (S1 MDR-A), p. 46 (S2 MDR-A), p. 48 (S3-4)
5. Tracking the effectiveness of measures and communicating results	p. 25 (E1-4), p. 26 (E1-5, E1-6), p. 37 (E5-5), p. 44 (S1 MDR-T/M), p. 46 (S2 MDR-T), p. 48 (S3-5)
6. Enabling remediation	p. 19 (GOV-4), p. 43 (Whistleblower Policy), p. 46 (S2 grievance mechanisms), p. 48 (S3-3)

GOV–5

Risk management and internal controls over sustainability reporting

BE Group has not established a formalised framework for internal control over sustainability reporting for the 2025 financial year. Sustainability information has been collected from operational functions and quality‑assured by the Sustainability Coordinator. No systematic risk assessment of the reporting process has been carried out. The company intends to evaluate the need for formalised control structures for sustainability reporting during the upcoming period.

SBM-1

Strategy, business model and value chain

BE Group is a leading trading and service company within steel, stainless steel and aluminium. The company’s ambition is to be the most profitable and growing steel distributor in the markets in which it operates. In 2025, total net sales amounted to SEK 3,934 M. At the end of the year, the total number of employees was 513, distributed as follows:

Parent company	9
Sweden	247
Finland	257

The average number of employees during the year amounted to 555.

Strategy, business model and value chain

BE Group’s strategy is based on creating value in each key activity and offering high‑quality materials and services at competitive prices. As an independent actor in the market, BE Group aims to use its influence to contribute to a low‑carbon society by offering a comprehensive range of products with a low CO₂ footprint. There is no uniform definition of “green/sustainable/low‑CO₂ steel.” BE Group considers these terms applicable to steel whose emissions are significantly below the global average. For internal classification, BE Group uses data from the World Steel Association. Read more at: https://worldsteel.org/steel-topics/sustainability/sustainability-indicators-2024-report/#co2-emissions-and-energy-intensity

The strategy focuses on increasing and deepening collaboration with customers, enhancing supply chain efficiency, and managing costs to achieve healthy margins across the business. The primary customer segments are within the construction and manufacturing industries in the main markets of Sweden and Finland.

Knowledge and experience have been fundamental strengths of BE Group since the company was founded. Going forward, a key strategic priority is to expand expertise in “sustainable steel” and to increase emphasis on traceability and transparency throughout the value chain, enabling customers to make informed purchasing decisions.

The strategic priorities are centred around strengthened focus in the following areas:

• Customer focus – Create clarity and deliver the best customer experience
• Purchasing focus – Optimize the balance between premium service and cost‑efficiency
• Operational focus – Achieve efficiency across the entire value chain

Customer focus

BE Group strives to deliver the best possible customer experience throughout the entire business transaction by working with structured sales management, moving toward a unified sales process, and clarifying the value drivers that differentiate the company. The aim is to make it easy for customers to make informed, sustainable choices when purchasing from BE Group.

Sourcing focus

A significant part of BE Group’s value proposition lies in effective inventory management, ensuring the right materials at the right price. The company aims to maintain high service levels for customers while ensuring profitability. BE Group seeks to use its market influence to contribute to a low‑carbon society by offering a comprehensive assortment of low‑CO2 products, with a strong focus on traceability and transparency in the value chain.

Operational focus

BE Group works internally to enhance employee competence and implement routines and processes to improve performance. The strategy aims to increase efficiency within production and strengthen collaboration across the business to optimize flows and ensure high delivery accuracy. The company continues to invest in digital tools that facilitate both the sales and purchasing processes.

IRO-1

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

At the end of 2023 and the beginning of 2024, BE Group conducted a materiality assessment together with an external consultancy, in accordance with the requirements of the European Sustainability Reporting Standards (ESRS). The project was carried out in four phases: preparation and scoping, mapping of impacts, risks and opportunities, materiality assessment, and validation. Throughout the process, the management teams in Sweden and Finland participated in workshops, and between these sessions the sustainability coordinator collaborated with consultants and smaller groups of department heads to drive the work forward.

During the preparation and scoping phase, the company’s business model was defined, value chains were mapped by product area, key stakeholders were identified, and thresholds for impact materiality and financial materiality were established. It was also decided during this phase to apply the recommended time horizons set out in the ESRS.

The mapping phase began with a workshop in which all ESRS topical standards were systematically reviewed at sub‑topic level to ensure that all potential impacts, risks and opportunities relevant to the company were identified. This was followed by subject‑specific follow‑ups with relevant departments to ensure that no issues had been overlooked. The results of this phase served as the basis for a series of interviews with selected internal and external stakeholders, aimed at validating that BE Group’s assessments did not significantly deviate from stakeholder expectations and perceptions of the company’s impacts, risks and opportunities. These interviews collected stakeholder views across all ESRS topical standards. Stakeholder groups participating in the interviews included shareholders, trade union organisations, banks, insurance companies, customers and suppliers.

The materiality assessment was conducted in a workshop with broad representation from the management teams of the business units, and the results were subsequently reviewed in more detail with each respective unit. The consolidated outcome was then validated by BE Group’s Group Management and presented to the Board of Directors.

During 2025, the materiality assessment was reviewed, and revisions were made in necessary areas. These revisions primarily concerned impacts and risks originating from the Polish and Baltic operations, which were largely divested before the reporting period. The impacts related mainly to energy use, driven by the energy mixes in those regions. The risk that was adjusted downward related to potential disruptions in the event of war. During the double materiality assessment, this risk had been classified as requiring entity‑specific disclosure. The risk is described in this report under the general risk section, see page 13.