Legal basis
In accordance with Sections 315b und 315c HGB, NORMA Group is obliged to prepare a Consolidated Non-financial Statement for NORMA Group in the Condensed Management Report. The following contents represent the Consolidated Non-financial Statement of NORMA Group for fiscal year 2025. In this section, all disclosures refer to ESRS 2 unless otherwise specified.
The Consolidated Non-financial Statement relates to the period from January 1 to December 31 2025.
9 All figures include Water Management
In accordance with Section 315c (3) in conjunction with Section 289d HGB, the Consolidated Non-financial Statement was prepared based in part on the first set of the European Sustainability Reporting Standards (ESRS) as a framework.
The following information, which would be reportable according to the result of the double materiality assessment, was not included in the consolidated non-financial reporting due to limited data availability:
Resource inflows – Products and materials (E5-4)
Appropriate remuneration (S1-10)
Compensation metrics – Pay gap and total compensation (S1-16)
NORMA Group voluntarily reports on the current status of data collection for the topics of “resource utilization” and “salary-related information” outside of the Consolidated Non-financial Statement and the Management Report. These disclosures can be found in the following section: ADDITIONAL VOLUNTARY SUSTAINABILITY DISCLOSURES
Scope of consolidation
The basis for the preparation of non-financial reporting is the scope of consolidation of NORMA Group SE, i.e., all domestic and foreign companies, so that production sites as well as distribution, sales and competence centers, and administrative buildings are included in the reporting. Where individual sections deviate from this approach for certain facts and data, this is explicitly disclosed in the relevant sections.
In contrast to the disclosures in the financial report in accordance with IFRS, the ESRS does not require separate reporting on the water management companies.
General basis for preparation of the Consolidated Non-financial Statement (BP-1)
The Consolidated Non-financial Statement of NORMA Group SE (“NORMA Group”, “the Company”) for fiscal year 2025 is made for the entire scope of consolidation. NORMA Group’s Consolidated Non-financial Statement is based on the scope of consolidation used for the consolidated financial statements (see NOTE 4 – SCOPE OF CONSOLIDATION). The Consolidated Non-financial Statement also includes information on the upstream and downstream value chain. As part of the materiality assessment, material impacts, risks, and opportunities in the value chain were identified. The policies, measures, and targets defined by NORMA Group cover various areas:
Various stakeholders were taken into account. Employees of NORMA Group suppliers are considered in the upstream value chain, among others. Customers, consumers, and end users are considered stakeholders in the downstream value chain. The own workforce includes NORMA Group employees and temporary agency workers and employees of service providers who carry out activities on the Company’s premises. Affected communities and municipalities, especially those close to the production sites, are also taken into account. By taking this approach, NORMA Group wants to ensure that sustainable principles are integrated and implemented and that all relevant stakeholders are analyzed. When disclosing metrics, NORMA Group refers to its own operations for fiscal year 2025. No information on intellectual property, know-how, or the results of innovations in orientation with European Sustainability Reporting Standards (ESRS) 1 Section 7.7 has been omitted from the Consolidated Non-financial Statement. The exemption from disclosure of pending developments or matters under negotiation in accordance with Articles 19a (3) and 29a (3) of Directive 2013/34/EU was not used.
Disclosures related to estimation and earnings uncertainties and other requirements (BP-2)
Assessment of the value chain: Descriptions of the disclosed data on NORMA Group’s upstream and downstream value chain can be found in the topic-specific sections reporting on metrics. The parameters used to estimate the individual value chain data are also disclosed and described there in detail, along with information on estimation uncertainty, planned measures to improve accuracy in the future,
the sources used for each estimate, and the resulting uncertainties. This makes it transparent which factors contribute to the uncertainties in the quantitative metrics and monetary amounts. In addition, the assumptions and judgments made in assessing the sources of the estimates and the uncertainty of the results are defined. Information on the sources of measurement uncertainty for each applicable quantitative metric and material monetary amounts is also disclosed in the respective topic-specific section. The assumptions and assessments made when measuring each quantitative metric and each monetary amount are also presented there. In reporting year 2025, mainly estimation methods were used as part of the Scope 3 calculation.
As NORMA Group has further developed some of its data collection processes and introduced new metrics, comparability with the previous sustainability reporting, which was based on Sections 315b and 315c in conjunction with Sections 289c HGB, is difficult in some cases. The following table provides an overview of the relevant metrics. Further information can be found in the respective topic-specific sections.
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Difficult comparability of data collection compared to the previous year
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Metric
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Reason
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Scope 2 – market-based (E1-6)
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Calculation methodology was adjusted
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Scope 3 (E1-6)
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Data collection process has been changed
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Characteristics of the Company’s employees (S1-6)
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Metric newly introduced
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Diversity metrics (S1-9)
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Metric newly introduced
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Completion rate of the “Information Security” training course
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Training program has been revised
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Compliance with the requirements of the ESRS is in line with NORMA Group’s self-image of ensuring precise and future-oriented sustainability reporting. It offers an opportunity for further development and ensures future comparability.
NORMA Group has not included any information from additional reporting standards in the Consolidated Non-financial Statement. However, NORMA Group has included additional voluntary sustainability disclosures that are not part of the Consolidated Non-financial Statement. In detail, the following standards were used: Sustainable Development Goals (SDG) and UN Global Compact (UNGC).
NORMA Group has incorporated information by reference. For a number of topics, the following list of ESRS requirements and the specific data points mandated by a disclosure requirement is provided, incorporated by reference.
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References to the Management Report and Remuneration Report
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Disclosure obligation
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Reference
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REMUNERATION REPORT
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ESRS [GOV-3-29a-e]
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WORKFORCE BY REGION
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ESRS [SBM-1-40aiii]
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BUSINESS MODEL
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ESRS [SBM-1-42a] [SBM-1-42b]
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In addition to the assurance by the appointed auditor, the metrics reported for financial year 2025 are not validated by any other external body responsible for quality assurance. If validation is carried out in individual cases, this will be reported at the appropriate point. In addition, NORMA Group is making use of all phase-in options in its second voluntary year of applying the CSRD, with the exception of the health and safety metrics according to ESRS S1-14.
References to other EU legislation (IRO-2)
An index of all disclosure requirements that NORMA Group has followed in preparing this statement can be found in the section REFERENCES TO THE MANAGEMENT REPORT AND REMUNERATION REPORT (BP-2). The table for DATA POINTS RELATING TO EU LEGISLATION (IRO-2) lists all data points resulting from other EU legislation and indicates where they can be found in this Consolidated Non-financial Statement and whether they have been identified as material by NORMA Group.
The regulatory requirements, as described below, were implemented taking into account the required due diligence, control mechanisms, and risk management.
Links to external websites contained in this report are not part of the non-financial statement.
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These contents are part of the Non-financial Group Report and were subject to a separate limited assurance examination.