Own workforce

Material impacts, risks, and opportunities and their interaction with strategy and business model (SBM-3)

NORMA Group’s own employees represent a material sustainability issue for the Company’s own operations. The actual positive and negative impacts as well as risks in the context of NORMA Group’s own workforce identified in the materiality assessment are linked to the Company’s strategy and business model. In addition, these impacts and risks are of crucial importance for the adjustment of the strategy, as NORMA Group wants to remain an attractive employer in the future, and the success and quality of its products and services depend largely on the skills, motivation, and stability of its workforce. Current and future employees should develop a stronger identification with NORMA Group and build a long-term relationship with the Company. Their commitment is the basis for achieving the Company’s goals and enabling sustainable success. The Company has the ambition to strengthen its employer brand in order to increase its attractiveness in an external context, particularly for potential new employees.

NORMA Group takes into account all of its own employees as well as temporary workers who could be significantly affected by the Company’s impact. The employees concerned are differentiated, for example, according to the type of work activity, such as production and administration. This includes all of our own employees with fixed-term and permanent employment contracts as well as students, interns, and trainees.

As part of the materiality assessment, positive impacts were identified in connection with the Company’s own workforce. These include strengthening co-determination and employee rights, promoting equal opportunities and diversity, and supporting professional development. Such aspects are in line with NORMA Group’s principles and standards and reflect the importance of fair working conditions and equal treatment for all of our own workforce. All employees who fall under the definition of the Company’s own workforce can benefit from these impacts.

NORMA Group recognizes various negative impacts that can directly affect employees. Employment uncertainties arise in particular as a result of market distortions, which can lead to increased concerns with regard to job stability and financial security. In addition, there is a risk of work-related accidents that cannot be completely ruled out despite comprehensive safety actions and that endanger the health of employees. Another key issue is the lack of transparency in salary structures between men and women, which can lead to perceived unequal treatment. These challenges require continuous action to improve working conditions and promote equal treatment.

The identified material financial risks and negative impacts in relation to the Company’s own workforce are directly related to its strategic alignment and business model, as maintaining a healthy, stable, and qualified workforce and ensuring compliance with labor and human rights are key prerequisites for sustaining operational performance and implementing the growth strategy. Work-related accidents can not only endanger the health of employees, but can also lead to financial risk through a loss of trust in NORMA Group. Failure to respect labor and human rights also entails the risk of legal violations and reputational damage. In addition, failure to fill critical positions, such as expert roles and key roles in production, can impair the stability of processes and the implementation of strategic projects. Inadequate management of these risks could significantly impair the value chain, jeopardize the Company’s reputation, and reduce its competitiveness in the long term.

NORMA Group does not record any material impacts on its own workforce as a result of transition plans to reduce negative environmental impacts and achieve greener and climate-neutral operations. The Company wants to ensure that its measures to improve environmental sustainability do not adversely affect the working conditions of its employees.

NORMA Group has not identified any significant risks related to forced labor and child labor in the course of its operations. NORMA Group is committed to preventing forced and child labor by introducing Group-wide standards for working conditions, and establishing measures to comply with global regulations.

Policies related to own workforce (S1-1)

NORMA Group has adopted policies and statements to effectively manage the material impacts and risks associated with its own workforce. At the heart of these efforts are the Code of Conduct, the Human Rights Commitment Statement, and the policies on Human Rights, Diversity, and Inclusion as well as the Health and Safety Policy. These policies address the needs and rights of the Company’s employees and apply in principle to all employees. As NORMA Group has identified both material positive and negative impacts and risks in connection with its own workforce, it remains a central task of Human Resources to identify, assess, and actively manage negative impacts and potential risks.

Human Rights Policy

With a clear focus on employees, NORMA Group introduced a Human Rights Policy in financial year 2024, creating a framework for all employees and external partners to respect and promote human rights in accordance with global standards and ethical practices. It is intended to ensure that potential human rights risks within the Company’s operations are identified and mitigated, while also promoting a positive working environment that contributes to greater employee satisfaction, stronger retention, and fair treatment for all involved.

The Management Board and local management bear overall responsibility for the topic of human rights and support the implementation of the policy and the measures derived from it.

The publication of the policy is intended to ensure that all potentially affected interest groups and those involved in its implementation are informed transparently.

Diversity & Inclusion Policy

The Diversity & Inclusion policy underlines the belief that diverse teams bring different perspectives and ideas to the table, thus promoting creativity and innovation. NORMA Group strives for active inclusive environments to foster diverse viewpoints and make effective decisions.

The Management Board and local management bear overall responsibility for the topic of diversity and inclusion and support the implementation of the policy and the actions derived from it.

The publication of the policy is intended to ensure that all potentially affected interest groups and those involved in its implementation are informed transparently.

The Code of Conduct is explained in detail in the following section CORPORATE CULTURE AND VALUES (G1).

The Human Rights and Diversity & Inclusion policies introduced by NORMA Group focus on the observance and protection of human rights, the promotion of equal opportunities, diversity and inclusion, as well as the labor rights of all employees. The Code of Conduct, the Human Rights Commitment Statement, and the policies on Human Rights and Diversity & Inclusion set out NORMA Group’s position on these issues, particularly with regard to its own employees.

NORMA Group underlines its commitment by firmly rejecting any form of human rights violations and maintaining zero tolerance for any breaches. The aim is to safeguard human rights and identify potential violations at an early stage in order to protect the rights of all employees, including their labor rights.

NORMA Group maintains a continuous dialogue with its own employees through direct contact or via the respective managers. This exchange is also promoted through employee surveys and close cooperation with employee representatives and trade unions. Its guidelines define clear actions and sanctions under labor law in order to exclude, minimize, or completely eliminate potential human rights violations as far as possible.

NORMA Group’s values are aligned with the ten principles of the UN Global Compact, the United Nations Guiding Principles on Business and Human Rights, and the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work. This is reflected, among other things, in efforts to uphold fair working conditions, eliminate discrimination, and combat corruption. NORMA Group strictly rejects human rights violations as described in the Universal Declaration of Human Rights and the Declaration of the International Labor Organization.

NORMA Group emphasizes in its policies that human trafficking, forced and compulsory labor, and child labor are not tolerated under any circumstances within its own workforce.

NORMA Group is currently developing a strategy to combat discrimination and harassment and to promote equal opportunities, diversity, and inclusion. These efforts are firmly anchored in the Code of Conduct, the Human Rights Commitment Statement, and the Human Rights and Diversity & Inclusion Guidelines. The content of these guidelines addresses aspects of discrimination, including harassment based on race, skin color, and gender, and the promotion of equal opportunity and diversity. They are intended to make it possible to express any form of political opinion, national affiliation, or social origin.

NORMA Group respects the respective national laws, but there are no specific Group-wide policies related to inclusion or positive actions for particularly vulnerable groups. As a signatory to the Diversity Charter since 2013, NORMA Group is committed to ensuring that all employees are valued – regardless of gender, nationality, ethnic origin, religion or belief, disability, age, sexual orientation and identity, or social background.

By complying with the requirements set out in the Human Rights and Diversity & Inclusion policies and providing voluntary training for employees, NORMA Group works to prevent and reduce discrimination and to act appropriately when incidents occur. In addition, the promotion of diversity and inclusion is to be actively supported in the future in order to establish an inclusive, respectful, and equal working environment in the long term. For example, mandatory diversity and inclusion training for all employees and managers were carried out in financial year 2025 on the basis of the newly introduced guidelines in order to raise awareness throughout the organization.

Human Rights Statement

NORMA Group recognizes the responsibility arising from its global operations and is committed to conducting its business in an ethical and socially responsible manner, while also taking responsibility for its own workforce.

In the Human Rights Commitment Statement, NORMA Group points out that any form of violation of human rights is categorically rejected. NORMA Group is committed to the prevention of slavery and human trafficking within its own business activities and requires all business partners to refrain from violating human rights and to work toward this in their own value chain. If NORMA Group becomes aware of any violations, it gives its business partners the opportunity to remedy them as quickly as possible. The business relationship is then reassessed and termination of the contract is considered, if applicable.

Responsibility for implementing the requirements set out in the statement lies with the relevant departments and all members of NORMA Group.

With this statement, NORMA Group commits to complying with the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015, the Universal Declaration of Human Rights and the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work.

The publication of the statement is intended to ensure that NORMA Group transparently informs all potentially affected stakeholders and those involved in the implementation.

Policies related to health and safety (S1-1)

NORMA Group pursues a Group-wide approach to health and safety policy. All production sites are required to have a management system certified in accordance with ISO 45001:2018. In addition, NORMA Group has implemented an Occupational Health and Safety Policy, which was updated in financial year 2025. This policy provides the framework for managers to create a safe working environment for all employees and all other stakeholders.

The Chief Operations Officer of NORMA Group and the Vice President Quality and Environment, Health, and Safety are responsible for implementing the policy.

The policy takes all employees into account. Moreover, by publishing the policy, NORMA Group wants to ensure that all potentially affected stakeholders and those involved in its implementation are informed transparently.

Processes for engaging with own workers and workers’ representatives about impacts (S1-2)

NORMA Group takes the perspectives of its employees into account by actively incorporating their insights and opinions into the decision-making process. Engagement is measured every three years as part of the global employee survey. Employee engagement reflects the involvement and enthusiasm of employees in their work and workplace. Some of the key metrics monitored include the participation rate, overall average, engagement percentage, and approval percentage. In addition to employee engagement, NORMA Group aims to understand employee needs, identify opportunities for improvement, and translate feedback into feasible action plans at the global, regional, and local levels.

Based on the results, improvement actions are required in the areas that are below average or below what is expected, which are determined by the managers at department and company level in a workshop. Workshops and training courses are conducted by providers and employees of the HR department.

The defined action points are monitored, analyzed, and evaluated. The last employee survey took place in financial year 2023. The original plan was to carry out the employee survey every two years – previously it was carried out every three years. Due to the ongoing transformation program and the associated necessary redistribution of capacities, NORMA Group plans to conduct the next survey in the course of financial year 2026.

The operational responsibility for ensuring that employees are involved in the survey and that the results are actively incorporated into NORMA Group’s approach lies with Human Resources.

NORMA Group is also actively committed to occupational health and safety, including through safety committees in which local managers, non-executive employees, and production employees working on an hourly basis participate. This exchange is intended to ensure that the knowledge gained is directly integrated into NORMA Group’s working methods. In addition, regular safety training and awareness campaigns are carried out during the financial year to further raise awareness of safety issues.

Processes to remediate negative impacts and channels for own workers to raise concerns (S1-3)

During the reporting period, NORMA Group did not identify any confirmed negative impacts related to working conditions, equal treatment and equal opportunities, or other labor-related rights within its own workforce through its whistleblower system.

Nevertheless, NORMA Group remains focused on minimizing potentially fatal and high-risk incidents involving employees and external workers, particularly in the area of occupational health and safety. In the event of such incidents, detailed root cause analyses are carried out on site and immediate remedial actions are initiated and followed up in order to eliminate the underlying risk factors in the long term. Thanks to these safety precautions, the frequency of such incidents has already been reduced. Nevertheless, NORMA Group continues to focus increasingly on high-risk sites and uses the Safety Top Focus Program to further minimize negative impacts on the workforce.

In addition, each NORMA Group production site has implemented a value-based monitoring program that actively involves workers in identifying and resolving potential safety issues that could lead to injury or illness. As soon as risks are identified, actions are immediately taken and implemented to minimize the identified safety risks for employees and external workers.

NORMA Group has also implemented processes and procedures that enable employees to report their concerns, worries, or needs. This also includes the possibility of addressing them directly or submitting complaints anonymously via the whistleblower system. Further information on the whistleblower system is provided in the section CORPORATE CULTURE AND VALUES (G1). Another way of directly addressing issues is for employees to take part in the Employee Engagement Survey, which is usually conducted every three years.

These channels are established by NORMA Group itself and through participation in third-party mechanisms.

As part of its whistleblower system, NORMA Group has established a procedure to ensure that complaints related to employee matters are handled carefully and that issues raised are followed up and monitored. For NORMA, the use of channels and structures is an indicator that they are known and trusted. However, NORMA Group does not systematically survey relevant stakeholders on effectiveness and awareness. NORMA Group has set itself strict guidelines designed to prevent any form of retaliation against individuals, including employee representatives, who use the whistleblower system. Further detailed information on the procedures and monitoring can be found in the section CORPORATE CULTURE AND VALUES (G1).

Internal training and various communication actions such as the intranet, posters, and additional information materials ensure that these channels are known and accessible in the workplace.

Taking action on material impacts on own workforce, and approaches to mitigating material impacts and risks and pursuing material opportunities related to own workforce, and effectiveness of those actions (S1-4)

In the area of occupational health and safety, a wide range of actions are implemented with the aim of effectively countering negative impacts and managing and minimizing risks.

NORMA Group has implemented various actions to strengthen health and safety in the workplace. NORMA Group strives to ensure that adequate human and organizational resources are allocated to manage its material impacts. Global and local EHS teams are responsible for occupational safety. In addition, NORMA Group has a global HR team as well as local HR units that take care of the organization of and compliance with working conditions. Among other things, these teams manage diversity and inclusion actions, employee training, and other programs to promote a safe working environment.

Safety committees, which consist of local managers, non-executive employees, and production employees working on an hourly basis, regularly coordinate safety training, awareness campaigns, and safety toolbox topics during the financial year. As part of job safety analyses carried out by the environment, health, and safety managers at the respective local sites, risks are also identified and assessed and, if necessary, actions are implemented and monitored according to the risk level of the workplace. In addition, managers operate a value-based safety program that actively engages workers in identifying and reporting safety issues that could potentially lead to injury or illness. As soon as risks are identified, actions are immediately taken and implemented to minimize the identified safety risks for employees and external workers. These preventive actions make it possible to invest specifically in new safety technologies in order to avoid work-related accidents. The scope of the actions described includes legal entities where there is a higher risk of work-related accidents.

NORMA Group continuously conducts analyses and assessments to ensure the effectiveness of its actions to promote the health and safety of workers. This is achieved by continuously monitoring internal safety metrics, which include both leading and lagging indicators. Examples of lagging indicators include reportable accidents and near misses, while leading indicators include the results of VBS audits and safety training. A key component is obtaining and maintaining ongoing ISO 45001 certification and conducting internal and external ISO 45001 audits to ensure compliance with and the effectiveness of safety standards. Regular ISO certifications in accordance with 45001 are carried out at 92% of the production sites. After each reportable incident, NORMA Group reviews the corrective actions through analysis and practically implements the lessons learned. These processes form the framework to identify and implement targeted actions to promote positive impacts on the workforce.

To further strengthen global standards and ensure uniform implementation, clear responsibilities were defined at global level in financial year 2025 in order to sharpen roles and increase accountability within the organization. To underscore the importance of occupational safety at the strategic level, the accident rate was introduced as a remuneration-relevant metric for the Management Board.

To support the review of implemented actions and the demonstration of continuous improvement, various ISO 45001 certifications were renewed by carrying out on-site audits, underlining the Company’s commitment to systematic occupational health and safety management. The Safety Top Focus Program continued to be implemented in order to provide targeted support to underperforming sites, strengthen the safety culture there, and reduce incidents. In addition, regional EHS workshops were held in Malaysia, the USA, and Poland to promote the exchange of knowledge, disseminate best practices, and address site-specific challenges.

In the APAC region, the lock-out tag-out procedures were revised and improved in order to prevent unintentional commissioning of systems and make maintenance work safer. In addition, standardized training documents on occupational safety were developed and introduced at all APAC sites, accompanied by site-specific training to ensure a uniform understanding and correct application. Finally, each site carried out its annual EHS campaign and related activities or initiatives to raise employee awareness, strengthen the safety mindset, and promote a proactive safety culture throughout the Company.

In financial year 2025, actions will be initiated to implement the adopted guidelines in the areas of “Human Rights” and “Diversity and Inclusion,” such as mandatory training and awareness programs for all employees and managers.

In order to promote fair and transparent remuneration, NORMA Group carried out a classification of top management and a regional pilot cascading of these classifications, as no global evaluation or remuneration structure was previously in place. This was the first step toward creating a harmonized global structure that serves as the basis for implementing remuneration benchmarks and developing corresponding guidelines. Due to changes in the Company structure and the scope of the project, the process was postponed and will be continued next year.

The range of training and development courses has been significantly expanded – including new management development programs, targeted upskilling initiatives and individual learning modules.

The recruiting process was also revised: A policy has been drawn up and diversity & inclusion is integrated into job advertisements.

A Human Rights Committee was established in the area of human rights and discrimination in relation to the Company’s own workforce. Further information on this can be found in the section CORPORATE CULTURE AND VALUES (G1).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (S1-5)

As NORMA Group is aware of its responsibility for all employees, it is pursuing a steady reduction in occupational accidents and the resulting accident rate. This is in line with the commitment to a safety-first culture enshrined in the H&S guidelines. NORMA Group is pursuing the goal of a rate of reportable occupational accidents of less than 6.1 in financial year 2025. The rates represent the number of work-related accidents per one million hours worked. This target applies throughout the Group. NORMA Group has involved the Supervisory Board in setting this target for occupational health and safety. This target is based on the forecast number of reportable accidents with a 5% improvement on the previous year compared to the forecast working hours. Final approval of the targets was given by the Management Board and Supervisory Board.

Progress and developments in the accident rate are monitored by the global H&S team and reported to the Management Board on a monthly basis and to the Supervisory Board on a quarterly basis. In order to achieve the Group-wide goal for occupational health and safety, this was transferred to the regional organizations and implemented there on a binding basis.

Thanks to the actions implemented, the goal was achieved and the accident rate in financial year 2025 was 4.70. This target is also an incentive and part of the Management Board remuneration. Further information on this can be found in the REMUNERATION REPORT.

The aim for the 2026 financial year is to continue to reduce the rate of reportable occupational accidents and ensure a maximum value of 3.8 at Group level.

Metrics related to the Company’s own workforce (S1-6, S1-8, S1-14, S1-17)

The reporting for the Company’s own workforce is based on all employees with fixed-term and permanent employment contracts. Students, interns, and trainees are included and are defined as core employees. Only the data for this group of people is provided in the report. The information is always given in the employee headcount. Temporary agency workers are defined as non-employees in NORMA Group’s own workforce in accordance with ESRS requirements. In the context of NORMA Group, these are defined as temporary agency workers and, in accordance with ESRS requirements, are only included in the health and safety metrics under S1-14.

If there is a deviation from this definition or if the information is stated differently, this will be disclosed.

In addition, only employees who have an active employment status as of December 31, 2025, i.e., are not on parental leave, maternity leave, or comparable long-term absences, are included in the reporting.

S1-6 Characteristics of the Company’s employees

The tables below provide an overview of the total number of employees, broken down by gender and country. The calculation of the data is generally based on the country-specific definitions and specifications. The breakdown shows the countries in which at least 50 employees are employed and which account for at least 10% of the total workforce.

The total number of employees reported in Section S1-6 corresponds to the core workforce reported in the consolidated financial statements. The consolidated financial statements also include the number of temporary workers. However, this is not disclosed in this Consolidated Non-financial Statement, as temporary workers can be reported as “phase-in” in accordance with ESRS. NORMA Group uses this phase-in option in financial year 2025, so the metrics for temporary workers is not reported.

The following table illustrates the key characteristics of the workforce in terms of employment relationships. This data is based on the number of employees at the end of the year and includes a detailed breakdown by gender.

In the reporting period, a total of 856 employees left NORMA Group. The fluctuation rate during this period was 14.50%.

Fluctuation describes the percentage ratio of voluntary and involuntary departures to the total number of employees within a certain period of time. This percentage is calculated by setting the number of departures in relation to the total number of employees in the respective month. Various contract types are taken into account when calculating fluctuation, including employees with fixed-term employment contracts and employees with permanent employment contracts. Students, interns, and trainees are excluded from this calculation.

Collective bargaining coverage and social dialogue (S1-8)

NORMA Group recognizes the important role of collective bargaining agreements in shaping the working and employment conditions of its employees. 47.6% of temporary and permanent employees are covered by collective agreements, which corresponds to 2,716 employees worldwide. The collective agreements are negotiated locally and therefore vary according to country-specific requirements.

Collective bargaining agreements have been negotiated for 637 employees in the European Economic Area, which corresponds to 11.0%. As this information is only to be reported for countries in which NORMA Group has significant employment, defined as countries with at least 50 employees covering at least 10% of the total workforce, only the collective agreements for Germany can be reported in this context.

With regard to social dialogue, 12.6% of NORMA Group employees worldwide are represented by workers’ representatives. This figure is given for the countries in the European Economic Area in which NORMA Group employs at least 50 employees who make up at least 10% of the total workforce.

NORMA Group has an agreement with its employees regarding representation by a European Works Council, a Societas Europaea Works Council, or a Societas Cooperativa Europaea Works Council.

Diversity metrics (S1-9)

NORMA Group presents the gender distribution in top management and the age structure of employees in the following tables.

The aim of this disclosure is to transparently present the gender diversity at the top management level as well as the age structure within NORMA Group’s workforce. NORMA Group defines the top management level as executives who report directly to the CEO, CFO, or COO.

In addition to the reported metrics in accordance with the ESRS, NORMA Group also provides salary-related information. As the reporting requirements in the context of ESRS S1-10 and ESRS S1-16 cannot yet be fully met, NORMA Group provides additional information on a voluntary basis. They are not currently the subject of an external audit. These disclosures can be found in the following section: ADDITIONAL VOLUNTARY SUSTAINABILITY DISCLOSURES THAT ARE NOT PART OF THE CONSOLIDATED NON-FINANCIAL STATEMENT OR THE MANAGEMENT REPORT

Health and safety metrics (S1-14)

All of the following metrics and information in the area of health protection and occupational safety relate to both permanent NORMA Group employees and temporary agency workers. This comprehensive approach ensures a holistic assessment of working conditions and risks at all sites and reflects the company-wide sense of responsibility toward all employees.

NORMA Group is committed to maintaining a robust health and safety management system to ensure the well-being of its workforce. At the end of the financial year, 87.0% of employees were covered by the health and safety management system in accordance with ISO 45001, based on the total number of employees at that time.

In addition, 98.4% of employees in the manufacturing plants are covered by the ISO 45001 management system.

NORMA Group recorded 0 fatalities as a result of work-related injuries last year.

This figure includes all reported fatalities at all NORMA sites worldwide. In addition to employees and temporary agency workers, external workers such as individual contractors or other persons working on the Company’s premises under the supervision of the Company are also included.

Within NORMA Group, cases are recorded using a standardized local data collection system. This survey makes it possible to record all fatalities across all sites and consolidate them at Group level. In addition, the Environment, Health, and Safety department is obliged to report fatal accidents to the local authorities.

In addition, a total of 68 recordable work-related accidents were registered in the last financial year, which corresponds to a rate of 4.7.

NORMA Group takes both injuries and illnesses into account when documenting recordable accidents, as incidents that lead to an injury or illness are defined as accidents. Reporting is carried out separately for the rates of reportable injuries and reportable illnesses.

The rate of recordable work-related injuries in the last financial year was 4.7, while the rate of recordable illnesses was 0, as there are no known recordable illnesses subject to legal requirements.

This indicator includes all sites of the legal entities (subsidiaries) of NORMA Group. The number of reportable incidents refers to work-related injuries or illnesses that can lead to death, days lost, reduced ability to work, transfer to another job, medical treatment beyond first aid, or unconsciousness. This includes significant injuries or illnesses that are diagnosed by a physician or other licensed health care professional, even if they do not result in the above consequences.

The rate of recordable work-related injuries and illnesses is calculated by dividing the total number of recorded cases by the total working hours and then multiplying by one million.

NORMA Group also reports on the number of days lost by its employees due to work-related injuries and work-related illnesses as well as the number of days lost due to fatalities as a result of such incidents. A total of 2,277 lost days were counted in financial year 2025.

The calculation of days lost is based on the first and last full day of absence and includes calendar days. This means that days on which the person concerned is not scheduled to work, as well as weekends and public holidays, also count as days lost. The local health and safety authorities monitor, document, and report the days lost, taking into account the first and last full day of absence. In exceptional cases, the exact number of days lost for certain incidents may not be immediately known. If a preliminary estimate is necessary, this is carried out by the global team in the Health & Safety department.

Human rights-related incidents, complaints, and severe impacts (S1-17)

During the reporting period, NORMA Group registered one confirmed incidents of discrimination based on gender, race or ethnic origin, nationality, religion or belief, disability, age, sexual orientation or other grounds, including harassment, through its whistleblower system.

In addition, NORMA Group received 16 human rights-related complaints through internal grievance mechanisms that are independent of the above-mentioned incidents. Human rights grievances relate to complaints regarding labor rights, freedom of association, forced labor, child labor, working conditions, and occupational safety.

The Company has investigated the reported incidents in accordance with the internal guidelines within the framework of the Human Rights Committee that has been set up and has implemented appropriate remedial actions where necessary. The investigations revealed no evidence of systematic or structural causes.

NORMA Group identified zero confirmed cases of severe human rights violations in which the United Nations Guiding Principles, the International Labor Organization Declaration, or the OECD Guidelines were violated.

With regard to the number of incidents, all human rights violations reported by internal or external sources via NORMA Group’s whistleblower system and assessed by the Human Rights Committee as actual or severe human rights violations are taken into account. The Human Rights Committee categorizes and assesses the severity of the individual complaints on the basis of key questions. Since financial year 2024, NORMA Group Integrity has also obtained a confirmation of completeness from relevant departments to ensure that all relevant complaints have been submitted to the whistleblower system. The information received is processed within NORMA Group and can be examined by external bodies on a case-specific basis beyond the legal requirements.

NORMA Group’s legal counsels collect information from the CFOs of the regions who report on fines and convictions of each entity. This information is then combined by the legal department for the entire Group. Fines are allocated to the reporting year in which the decision became legally binding, although the possibility that reporting persons may conceal fines cannot be ruled out. The information received is processed exclusively within NORMA Group and is not validated by external bodies beyond the legal requirements.

In connection with the reported cases of human rights violations and discrimination, the fines, sanctions, and compensation for these incidents and complaints amounted to a total of EUR 0.

In connection with serious incidents relating to human rights violations, fines, penalties, and compensation totaled EUR 0.