GOVERNANCE INFORMATION

Business conduct

Material impacts, risks, and opportunities and their relation to strategy and business model
The majority of AddLife's sustainability impact occurs indirectly through business relationships within the supply chain. Risks related to labor rights and human rights can arise in raw material extraction, processing, and manufacturing. AddLife actively work to understand and mitigate these risks through structured supplier monitoring and control mechanisms. For a more detailed review of supplier-related impacts, risks, and opportunities, see Workers in the Value Chain.

In parallel, corruption and bribery represent a significant business risk, particularly in procurement and raw material extraction in regions with weak business conduct regulations. Unethical influence can lead to market distortion, legal repercussions, and disruptions in our supply chain.

To address challenges related to corruption and responsible supplier relationships, AddLife have implemented:

• An updated Supplier Code of Conduct, which imposes stricter requirements on business conduct, anti-corruption, and labor conditions.
• Sustainability due diligence processes, including risk-based screening of business partners and monitoring of regulatory compliance.
• Anti-corruption training for employees in high-risk areas.
• A whistleblower system through WhistleB, an anonymous reporting channel to detect potential irregularities within the business and supply chain.

These initiatives enhance our ability to identify business conduct risks and ensure transparency in AddLife's global supply network.

Corruption can undermine supply chain transparency, increasing the risk of human rights and labor law violations. To prevent this, we conduct extensive due diligence efforts to identify and manage business ethics risks associated with AddLife's business model.

Failure to manage corruption-related risks can have financial consequences, including:

• Risk of legal sanctions or fines due to non-compliance.
• Costs for internal investigations and subsequent corrective measures in suspected corruption cases.
• Reputational consequences, which may affect business opportunities and financing.

Through systematic anti-corruption measures, AddLife minimize these financial risks and strengthen the Group's business security.

In the short term, stricter anti-corruption requirements result in increased administrative costs. In the long term, these initiatives establish a more robust business conduct framework and reduced risk exposure, reinforcing our position in the market. We continuously work to enhance our business conduct risk management systems, where due diligence, the whistleblower system, and internal audits are key tools to ensure compliance with sustainability standards.

During 2023 and 2024, AddLife has further developed procedures to mitigate corruption risks and strengthened supplier evaluations through improved monitoring and increased compliance requirements.

This report covers business conduct and sustainable supplier governance in alignment with ESRS standards.

Governance

Responsibility of governance, supervisory, and management bodies
AddLife promotes a high standard of business conduct through governance by the Board of Directors and Group Management. The Board of Directors has overall responsibility for corporate governance, sustainability strategy, and monitoring of business conduct issues. It decides annually on updates to the Code of Conduct, which is a central part of the work on business conduct and supplier responsibility.

The Group Management is responsible for ensuring that business conduct guidelines are followed within all subsidiaries. During 2023, several subsidiaries joined the group-wide whistleblower channel, enabling employees to report suspected corruption or other breaches of the Code of Conduct anonymously. The Board monitors reported cases and ensures that action is taken where necessary.

All employees, including at management level, undergo annual training in business conduct principles via AddLife Academy. By the end of 2024, 92 percent of employees had completed the training. The Board and Group Management also receive regular updates on legislative changes and new business conduct requirements.

AddLife has zero tolerance for corruption and works actively to ensure that business conduct guidelines are followed in both internal processes and the supply chain.

Management of Impacts, Risks, and Opportunities

Business conduct policies and corporate culture
AddLife’s business conduct work is governed by a group-wide Code of Conduct, which addresses material impacts, risks, and opportunities related to business practices, human rights, working conditions, workplace safety, and anti-corruption. The Code of Conduct aims to promote ethics, transparency, and accountability throughout the business and regulates how AddLife expects employees and business partners to act.

The Code of Conduct applies to all employees, business partners, and suppliers. It extends to all subsidiaries globally and is adapted to local legal requirements in different regions. Suppliers are indirectly covered through a separate Supplier Code of Conduct, where AddLife sets requirements related to sustainability and business conduct.

The Board of Directors has overall responsibility for the Code of Conduct, while the Group CEO and Group Management are responsible for its implementation throughout the organization. At the subsidiary level, each subsidiary’s Managing Director ensures compliance within their operations.

The Code of Conduct is based on international guidelines such as the UN Global Compact, the Universal Declaration of Human Rights, the ILO Core Conventions, and the OECD Guidelines for Multinational Enterprises. AddLife’s anti-corruption policy is based on the UN Global Compact’s Tenth Principle on anti-corruption, and in the next major revision of the Code of Conduct in 2025, the connection to the UN Convention Against Corruption will be further clarified.

As part of this update, stakeholder perspectives are taken into account through dialogues with business partners and employee surveys. The purpose of the update is to strengthen alignment with international guidelines and clarify AddLife’s commitment to combat issues such as human trafficking.

To ensure accessibility and understanding, the Code of Conduct is communicated to all employees through AddLife Academy, where training is provided. It is also available to business partners and is integrated into supplier agreements.

AddLife actively works to establish, develop, promote, and evaluate its corporate culture. This is achieved through several initiatives:

• AddLife Academy offers training in business conduct guidelines, leadership, and corporate values through both digital and in-person courses.
• Leadership and decentralized governance strengthen the corporate culture by allowing subsidiaries to operate independently within a clear framework of shared values and principles.
• Annual employee surveys are used to evaluate the corporate culture, and the results serve as a basis for improvement measures.
• Ethical guidelines and the whistleblower system contribute to an open and transparent culture where employees can report any violations anonymously.

To enable the early detection of potential irregularities, the group has a whistleblower system provided by an external partner, WhistleB Whistleblowing Centre.

REPORTING CHANNELS:

• Direct reporting to the CFO or immediate manager.
• Anonymous reporting via the WhistleB platform, which accepts reports from both internal and external stakeholders.
• External reporting to relevant authorities.

All reports are handled confidentially, and anonymity is ensured through encryption and metadata removal.

INVESTIGATION PROCESS AND WHISTLEBLOWER PROTECTION:

• All reports are handled confidentially, and anonymity is ensured through encryption and metadata removal.
• Confirmation of receipt of a report is sent within seven days.
• An in-depth investigation is conducted as needed by a specialized team.
• Feedback is provided to the whistleblower within three months.
• Full anonymity is guaranteed to whistleblowers to ensure that no one is subjected to retaliation, in accordance with EU Directive 2019/1937.

Suspected cases of corruption are handled according to the same process to ensure objective and independent review. The area of business with the highest risk for corruption and bribery is public procurement.

At present, AddLife does not have an established policy on animal welfare, but this issue will be included in the Code of Conduct in the next major update in 2025. AddLife does not conduct animal testing within its operations.

Management of supplier relationships
AddLife collaborates with a broad network of suppliers and strives for long-term, responsible business relationships. Supplier management is based on the Code of Conduct and the Supplier Code of Conduct, which establish guidelines for business conduct, human rights, and sustainability. These requirements were previously implemented at the subsidiary level and were further formalized in 2024 through a group-wide due diligence process.

In 2024, AddLife, in cooperation with selected subsidiaries, conducted a pilot project to develop a framework for identifying and managing supplier risks, with a particular focus on human rights.The process includes:

• Risk assessment of supplier relationships, analyzing geographical, operational, and sustainability factors.
• Supply chain reviews to ensure material supply and reduce risks related to regulatory compliance and sustainability.
• Integration of systematic sustainability due diligence tools, such as EcoVadis, to enhance transparency in the supply chain

The group-wide process aims to ensure a long-term and consistent risk management methodology across the entire supply chain. Implementation will take place gradually from 2025 to 2028 to ensure responsible and sustainable procurement.

As part of the new due diligence process, AddLife has strengthened its efforts to evaluate suppliers based on social and environmental criteria, which include:

• Compliance with international guidelines, such as the UN Global Compact, ILO Core Conventions, and OECD Guidelines for Multinational Enterprises.
• Labor conditions and human rights, with requirements for suppliers to respect working conditions, non-discrimination, and prohibition of child and forced labor.
• Environmental impact, assessing climate impact, chemical use, and resource consumption.
• Supplier follow-up and audits, where EcoVadis is used to identify high-risk suppliers and take corrective action when necessary.

The systematized due diligence process ensures that risk areas are identified early and proactively managed. Between 2025 and 2028, further measures will be developed to improve supplier monitoring, expand risk analysis, and strengthen responsible sourcing strategies.

More details on AddLife's due diligence efforts, specific risk areas, and future initiatives in the supply chain are described on the page Workers in the Value Chain. 

Prevention and detection of corruption and bribery
AddLife has a zero-tolerance policy for corruption and bribery, which is set out in the group's Code of Conduct. To reduce the risk of irregularities and ensure regulatory compliance, AddLife has implemented the following measures:

• Clearly defined guidelines for ethical business conduct, outlined in the Code of Conduct and specific supplier guidelines.
• A whistleblower system administrated by an external partner (WhistleB) for confidential reporting of suspected corruption or other regulatory violations.
• Business conduct requirements integrated into supplier agreements, communicated through the Supplier Code of Conduct.

All reported cases are reviewed by AddLife’s whistleblower team, whose members have the authority to handle whistleblower cases. To ensure objectivity and confidentiality:

• The whistleblower channel is managed by WhistleB, an independent external party, which guarantees anonymity for the reporter.
• Reports are handled only by designated personnel, with access restricted according to confidentiality principles.
• No one potentially involved in the reported misconduct participates in the investigation.
• External legal expertise is included when necessary, particularly in cases of suspected criminal activity. 

The whistleblower investigation procedure includes:

• Confirmation of receipt of a report within seven days, if contact information is available.
• Internal investigation of the case by the whistleblower team, with potential inclusion of internal or external legal experts.
• Feedback to the whistleblower within three months, in accordance with EU Directive 2019/1937.

The reporting of investigation results is ensured through:

• Escalation of serious cases to Group Management and the Board when necessary.
• Communication of investigation decisions to relevant parties within the company.
• Possible reporting to external authorities in confirmed criminal cases.

To ensure that relevant parties have access to and understand the company’s anti-corruption and business conduct guidelines, the Code of Conduct is actively communicated to employees and business partners through existing business relationships and supplier dialogues. The policy is available to all employees and, in some cases, directly integrated into supplier agreements.

At present, training in business conduct guidelines, leadership, company values, and the Code of Conduct is offered, covering business conduct and ethical business practices. However, AddLife currently does not offer specific training on anti-corruption and bribery, but such training is planned for future implementation. Since no separate anti-corruption training program currently exists, there is no available data on the number of employees in risk functions covered by such training. Members of the company’s administrative, managerial, and supervisory bodies undergo training in the Code of Conduct, but a more specific focus on anti-corruption issues is an area for future training efforts.

Metrics and targets

Confirmed cases of corruption and bribery
Currently, AddLife lacks a group-wide action plan for anti-corruption, but some subsidiaries actively address the issue, as they operate in markets with higher corruption risks.

One of the group's subsidiaries operating in Eastern Europe has intensified its anti-corruption efforts in the past year by implementing an anti-bribery policy, training employees, and obtaining ISO 37001 certification. The focus is on ensuring transparency and ethical business practices, especially in high-risk markets.

To ensure compliance, internal risk assessments and audits have been conducted, with a focus on supplier relationships and key individuals within the healthcare sector. A whistleblower service has also been implemented to enable anonymous reporting of suspected cases.

The initiative covers the entire subsidiary’s operations and will be gradually expanded to more markets. Through clear guidelines, regular training, and improved control procedures, the company strengthens its position as an ethical and trustworthy player in the region. At the group level, we closely monitor developments and are considering new guidelines for subsidiaries to work more ambitiously on anti-corruption.

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The data on corruption and bribery is based on reporting from subsidiaries as well as a review of internal whistleblowing mechanisms and compliance systems. Incidents are reviewed and followed up according to our internal compliance and business conduct processes.

The reporting includes confirmed incidents as well as any disciplinary actions and business consequences related to violations. Differences in legislation and reporting requirements between countries may affect how incidents are defined and handled in different jurisdictions.

The data has not been externally validated. We continuously work to strengthen our control systems and ensure consistent and transparent reporting on issues related to corruption and bribery.

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