Due diligence, control mechanisms, and risk management

The role of the administrative, management, and supervisory bodies (GOV-1)

The Management Board of NORMA Group consists of three members, while the Supervisory Board consists of six members. As NORMA Group is not subject to co-determination, there are no employee representatives on the Supervisory Board.

In the opinion of the Supervisory Board, the members of the Management Board have the necessary experience and expertise to manage the Company and conduct its business independently. The CFO is responsible for monitoring the sustainability-related impacts, risks, and opportunities of the Company’s activities on the Management Board and performs this task as part of the Sustainability Steering Committee.

In its own estimation, the Supervisory Board as a whole has in-depth knowledge in all sectors defined by the Supervisory Board in its competency profile and considered relevant to the proper performance of its oversight function.

Thanks to the special expertise of individual members, the Supervisory Board covers the relevant knowledge and experience in the areas of sustainability and ESG (“Environmental, Social, Governance”) in particular.

The current composition of the Management Board and Supervisory Board reflects gender diversity. At the end of financial year 2025, NORMA Group’s three-member Management Board consisted of two thirds women and one third men. At the end of financial year 2025, the Supervisory Board had a gender distribution of 50% female and 50% male.

All members of the Supervisory Board are independent within the meaning of the German Corporate Governance Code (GCGK). According to the GCGC, a Supervisory Board member is independent if there are no material and lasting personal or business relationships with the Company, its Management Board, or a controlling shareholder.

Due to the growing importance of corporate responsibility and ESG, these topics are becoming increasingly important in the work of the Supervisory Board, Management Board, and employees. Within the Supervisory Board, the Strategy Committee deals with the impact of climate change on the Company’s activities on an ad hoc basis during the financial year. The development of NORMA Group’s GHG emissions is discussed regularly, at least quarterly, in both the Supervisory Board and Management Board meetings.

Under the leadership of the Management Board member responsible for Corporate Responsibility and ESG, the Sustainability Steering Committee was established to deal with sustainability-related topics within NORMA Group. Chairing of the Steering Committee meetings is the responsibility of the CFO as a member of the Management Board, and the Vice President (VP) Investor Relations and Corporate Social Responsibility. Other members of the Steering Committee include Executive Vice President Group Finance & Tax, Executive Vice President Human Resources, Executive Vice President Group Legal and Compliance & Integrity, Vice President Quality & EHS, and Executive Vice President Group Purchasing & Supply Chain Management. The Steering Committee meets every six weeks. It manages and assumes responsibility for sustainability matters in line with the targets and measures defined by the Management Board within topic-specific working groups. The Steering Committee also makes management decisions, sets targets, and defines future-oriented strategies. The members of the operational working groups meet regularly during the financial year to drive forward the issues within their departments. The Corporate Responsibility team provides advice and support to the departments and promotes the sustainability-related guidelines of the Management Board and the Steering Committee. The Corporate Responsibility Team reports regularly to the Steering Committee within the financial year on the current status of the project plan and provides decision-making support. In addition, the respective departments monitor the impacts, risks, and opportunities.

Currently, NORMA Group has only partially implemented specific controls and procedures to manage and monitor sustainability impacts, risks, and opportunities. The Group-wide risk management tool has so far only been used to manage risks. Further information on integration into risk management is described in the section RISK MANAGEMENT AND INTERNAL CONTROLS FOR SUSTAINABILITY REPORTING (GOV-5). The Company is still in the early stages of this process. The first step was to identify the impacts, risks, and opportunities. In the coming financial years, the subsequent processes will be developed and implemented on an ongoing basis. In the future, the impacts, risks, and opportunities will be reviewed once a year and reassessed if necessary. In addition, a materiality assessment is carried out every three to five years or as required due to changes in the business model, for example, in order to take a holistic view of the impacts, risks, and opportunities and adjust them if necessary. Further information on the materiality assessment process can be found in the section IDENTIFICATION OF MATERIAL IMPACTS, RISKS, AND OPPORTUNITIES (IRO-1)

The responsible Management Board members monitor the implementation of the defined targets with regard to material impacts, risks, and opportunities of the operational working groups. NORMA Group’s departments report regularly to the respective Management Board department during the financial year. For example, there is continuous reporting to the responsible COO of NORMA Group in the areas of environment, health and safety, and quality. The departments are responsible for documenting the progress of their work over the course of the financial year. The Corporate Responsibility team also regularly, at least quarterly, informs the Sustainability Steering Committee about the progress made in implementing the CSRD and the EU taxonomy during the financial year.

NORMA Group’s Management Board and Supervisory Board have the necessary expertise to monitor sustainability matters effectively according to their own assessment. The Supervisory Board evaluates its work annually as part of a self-assessment, in which an external consultant may also be consulted. The presentation of the expertise required for sustainability matters can be found in the matrix SUSTAINABILITY EXPERTISE ON THE SUPERVISORY BOARD (GOV-1-21). The evaluation process includes a systematic analysis of existing skills and experience gained during the financial year. Possible gaps in knowledge can be closed through targeted training and the use of external experts. In financial year 2024, the Supervisory Board took part in specialized ESG training. The Integrity department is also responsible for corporate governance and is assigned to the Chief Executive Officer’s area of responsibility. The Executive Vice President Group Legal and Compliance & Integrity reports directly to the Chief Executive Officer of NORMA Group. The expertise of the Supervisory Board with regard to aspects of corporate governance is described in the matrix SUSTAINABILITY EXPERTISE ON THE SUPERVISORY BOARD (GOV-1-21). The sustainability-related expertise of the Management Board and Supervisory Board is also relevant for assessing the material impacts, risks, and opportunities within NORMA Group. Within the Sustainability Steering Committee, the CFO and chairpersons of the relevant departments are assigned to various working groups according to their respective areas of expertise. For example, the Executive Vice President Human Resources is responsible for “Own Workforce” and all matters relating to human rights. This structured division is intended to ensure focused and competent handling of the respective subject areas.

Handling of information and sustainability aspects within the administrative, management, and supervisory bodies (GOV-2)

Under the leadership of NORMA Group’s CFO, a Steering Committee meets every six weeks to discuss sustainability matters, among other things. The committee is informed by the Corporate Responsibility department about material sustainability-related impacts, risks, and opportunities, as well as the implementation of due diligence, and the results and effectiveness of concepts, measures, and defined targets. Based on this, the Steering Committee makes all necessary sustainability-related decisions. The Corporate Responsibility department also reports regularly to the Supervisory Board of NORMA Group on sustainability matters during the financial year. This also includes information on the material impacts, risks, and opportunities. The Audit Committee is informed about ESG issues at least twice a year by the Vice President Corporate Social Responsibility. The Management Board and Supervisory Board also consider the impacts, risks, and opportunities with regard to the Company’s sustainable business strategy and when making decisions on material transactions. Compromises in connection with these impacts, risks, and opportunities have not yet been taken into account in financial year 2025.

In financial year 2025, the Steering Committee dealt with the material impacts, risks, and opportunities. A summarized overview can be found in the section MATERIAL IMPACTS, RISKS, AND OPPORTUNITIES AND THEIR INTERACTION WITH STRATEGY AND BUSINESS MODEL (SBM-3).

Inclusion of sustainability criteria in remuneration (GOV-3)

A detailed overview of the inclusion of sustainability criteria in remuneration can be found in the REMUNERATION REPORT.

Statement on due diligence (GOV-4)

The following overview explains how and where the application of the key aspects and steps of the due diligence process is reflected in the Consolidated Non-financial Statement:

Risk management and internal controls over sustainability reporting (GOV-5)

Risk management at NORMA Group is an integral part of corporate governance, both at Group management level and in the individual companies and functional areas. NORMA Group also has a Group-wide internal control system that partially covers non-financial processes and Group-wide activities. Due to the heterogeneous process landscape and the rapid pace of change in the requirements for non-financial information in the area of sustainability, the maturity level of the non-financial internal control system does not yet correspond to that of the Group-wide internal control system. It aims to ensure the integrity and reliability of sustainability reporting and compliance with all legal requirements and internal guidelines. The Management Board of NORMA Group is responsible for maintaining an effective risk and opportunity management system. The Supervisory Board is responsible for monitoring the effectiveness of the Group’s risk management system.

The procedures and methods for preparing the Consolidated Non-financial Statement are integrated into NORMA Group’s risk management process. The risks associated with sustainability reporting are identified by Corporate Responsibility as the responsible specialist department and described within the risk management system. Corporate Responsibility has also developed internal controls and measures to minimize these risks. The identified risks and controls/measures are described in more detail below. As part of the risk-oriented business audit conducted by the external auditing firm, the Consolidated Non-financial Statement is also audited with limited assurance.

The identified impacts, risks, and opportunities are currently not integrated into the general risk management process and the assessment of NORMA Group’s overall risk profile. The Company reviews the integration of impacts, risks, and opportunities into the existing risk management system annually and as required. The identified sustainability-related risks are not prioritized in comparison to other risks.

The approach of the internal control and risk management system in with regard to the Group accounting process is explained in detail in the RISK AND OPPORTUNITY REPORT. The sustainability reporting process is based on the existing approach to risk assessment as part of the risk management system. Risks that arise in the context of sustainability reporting are recorded within the risk management system and follow the methodology of the entire risk management process.

The following main risks relating to sustainability reporting were identified as part of the financial risk assessment carried out:

•Reporting does not fully comply with regulatory requirements and standards (e.g., EU taxonomy, CSRD)

•Incompleteness and accuracy of the data

•Time of availability of the information

Internal controls and measures have been developed to minimize these risks:

As part of sustainability reporting, checklists developed by NORMA Group must be completed to ensure a complete and consistent Consolidated Non-financial Statement. In order to avoid errors, the process for preparing sustainability reporting texts is based on the separation of responsibilities and functions or competencies as well as plausibility checks as part of the reporting process. The individual text sections of the report are prepared by the Corporate Responsibility department and checked and consolidated by the responsible specialist department in accordance with the dual-control principle.

The results of the risk assessment and internal controls throughout the sustainability reporting process are integrated into the relevant internal functions and procedures by the responsible departments. For example, Corporate Responsibility conducts a final review to ensure that all material data points required by the ESRS have been considered in both reporting and data collection.

The CFO is responsible for preparing the Consolidated Non-financial Statement. The CFO and the relevant departments are regularly informed about the content and progress of the report every six weeks as part of the Steering Committee. If material risks arise or if the internal controls reveal potential risks, the Steering Committee is

informed at an early stage. The Audit Committee and Supervisory Board also deal with of the Consolidated Non-financial Statement for NORMA Group. The Supervisory Board is informed of the contents of the Consolidated Non-financial Statement by the Management Board and reviews it. The final report is submitted to the Audit Committee and the Supervisory Board of NORMA Group for review. If the Supervisory Board has no further adjustment requests or queries following its review, approval is granted.

Within the described responsibilities and control mechanisms, the following assumptions and findings regarding NORMA Group’s business model, value chain, corporate strategy and material impacts, risks, and opportunities were confirmed.