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continue doing so. The use of potentially hazardous substances is now strictly controlled within the framework of
current standards and regulations. Actions concerning the regeneration of ecosystems and the reduction of the use
of certain substances do not currently affect the strategic objectives or the business model. At the same time, it is
not ruled out that the strategy will in future incorporate objectives to minimise the use of potentially hazardous
substances by investing in safe alternatives and risk management systems.
E2-1 Pollution-related policies
[E2-1 14, 15] [MDR-P 65] In 2025 the Arctic Paper Group does not have a separate policy on pollution, including
mitigation of adverse effects or avoidance of pollution incidents and emergencies. The Group does not currently
identify a need for such a policy. The main principles regarding the use of chemicals are contained in the
Sustainable Development Policy. The Group is committed to limiting the use of such substances. The policy does
not refer to specific agents or chemicals. In line with the stipulations of this policy, as well as based on legislation
and environmental management systems, the Arctic Paper Group strives to introduce actions in the production
process that reduce the generation of pollutants and continuously monitors emissions to water and air.
Another document indirectly governing the approach to pollution is the Arctic Paper Group Code of Conduct for
the value chain. The document commits the production facilities to operate in accordance with the ISO 14001 and
EMAS environmental management system, and the Grycksbo and Munkedal mills additionally to have an ISO
50001 certified energy management system. These certificates introduce specific environmental and energy criteria
for the Group's suppliers and require them to undergo environmental audits, hence the impact also applies to the
supply chain.
The scope of the policies covers the operations of the Arctic Paper Group, excluding the Rottneros Group. The
Group Management is responsible for implementing the provisions of the policies. The policies adopted refer to the
Sustainable Development Goals 2030, the principles of the UN Global Compact, the Best Practices for WSE Listed
Companies. In preparing the content of the document, the interests and opinions of the Group’s stakeholders were
taken into account. The Group makes the adopted regulations available by posting them on the website and on the
internal communication channels of the various organisational units.
The Rottneros Group does not have a policy dedicated to pollution, including mitigating its negative effects,
replacing potentially hazardous substances and phasing out substances of particular concern, and avoiding
pollution-related incidents and emergencies. In its Sustainability Policy, the Group refers to minimising
environmental impact, operating in accordance with environmental certifications such as ISO 14001 and ISO
50001, and monitoring the pollution generated.
The scope of the policy covers the activities of the Rottneros Group. The Management Board of the Rottneros
Group is responsible for implementing the provisions of the policy. The adopted policy does not refer to third-party
standards or initiatives. In preparing the content of the document, the interests and opinions of the Group’s
stakeholders were taken into account. The Group makes the regulations available by posting them on its website
and on the internal communication channels of each organisational unit.
E2-2 Pollution-related activities and resources
[E2-2 18, AR 13] [MDR- 68].
At the Arctic Paper Group, key pollution-related activities focus primarily on upgrading and investing in new, less
polluting production infrastructure:
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Name of the action Description of the action
Modernisation of the
aeration system at the
wastewater treatment
plant
In 2024, a project began at the Kostrzyn plant to retrofit the wastewater treatment plant with a new air supply system to imp rove
the efficiency of the treatment processes. In 2025, the activities continued and were completed with the upgrade of the blowe r
station, enabling a more stable and efficient operation of the plant. The solutions used support more efficient removal of po llutants
from wastewater and improved performance of the treatment plant. In addition, the new blower has been adapted to be power ed
by a generator, which increases the reliability of the plant’s operation in the event of power cuts. Modernisation contribute s to
reducing the risk of disruption to treatment processes and strengthens the environmental safety of operations.
Installation of an EGSB
reactor in a wastewater
treatment plant
In 2024, a project to install a new EGSB (Expanded Granular Sludge Bed) reactor in the anaerobic section of the wastewater
treatment plant began at the Rottneros mill. Installation work was carried out in 2025, while commissioning and start -up of the
plant is scheduled for early 2026. The reactor used enables the production of biogas, which will be used in the pulp drying process
in flash dryers, thus reducing chemical oxygen demand and air pollution such as suspended solids, nitrogen and phosphorus. Th e
implementation of EGSB technology supports improvements in wastewater treatment efficiency by reducing the organic pollutant
load and reducing air emissions associated with suspended solids, nitrogen and phosphorus. The project contributes to a more
integrated approach to water, energy and emissions management in plant operations.
Upgrading the waste
water tank at the
bleaching plant
In 2025, a project was implemented at the Vallviks plant to rebuild the wastewater tank at the bleaching plant, aimed at impr oving
control over process wastewater parameters. The scope of activities included upgrading infrastructure to reduce chlorate
emissions to water. The solutions used support a more stable operation of the plant and a reduction in the pressure associated
with the discharge of pollutants into the water environment.
Biomass boiler
modernisation at a pulp
plant
A biomass boiler upgrade was carried out at the Rottneros plant in 2024 to improve the energy efficiency of the unit. The sol utions
used have enabled more efficient combustion of fuel and reduced emissions of selected air pollutants, including carbon monox ide
(CO) and nitrogen oxides (NOx). The project has contributed to increasing the stability of energy processes and improving
environmental parameters related to air pollutant emissions.
The effects of the modernisation can be seen in the emissions data: CO₂ emissions from stationary combustion fell from 1,915
tonnes per year in 2024 to 235 tonnes per year in 2025, while CO emissions decreased from 24.1 to 21.5 tonnes per year and
NOx emissions from 31.9 to 25.1 tonnes per year.
Planned actions
Modernisation of the
fresh water treatment
plant
An upgrade of the freshwater treatment plant at the Munkedals plant is planned for 2026, aimed at improving control of the qu ality
of water discharged into the environment. The scope of the project includes reducing sediment losses and stabilising flows in the
river, which will reduce the variability of water parameters. The planned actions aim to reduce water pollution pressures and
improve environmental conditions in the area of influence of the installation.
The investment in the project to upgrade the wastewater tank at the Vallviks plant amounted to MSEK 1.3,
which the Group considers to be a significant capital expenditure. The remaining activities do not involve
the need for significant investment or operational expenditure.
E2-3 Pollution targets
[E2-3 22] [MDR-T 81] The Arctic Paper Group has not set quantitative targets for water, air and soil pollution. To
date, no such need has been identified either in a regulatory or strategic context. The emission levels of the
individual compounds do not exceed the permitted values set out in the integrated permits in force for the individual
production facilities. Monitoring of the progress and effectiveness of the actions undertaken in this area is done
through the monitoring systems in place at the production facilities for emissions to air, water and soil.
E2-4 Contamination of air, water and soil.
[E2-4 30 b, AR 27] [E2-4 30 c] The following are emissions of polluting agents from facilities for which the relevant
threshold value specified in Annex II to Regulation (EC) No. 166/2006 of the European Parliament and of the
Council is exceeded, excluding greenhouse gas emissions, which are disclosed in Part E1-6 GHG Emissions of
Bands 1, 2 and 3 gross and total GHG emissions. These data were based primarily on direct measurements from
automated systems and, where this was not possible, on periodic measurements or calculations based on location-
specific data. Where automated measurement systems are used, calibration studies have been carried out. In the
case of Arctic Paper Kostrzyn, pollution measurements are carried out on the basis of the undertaking’s integrated
permit.
The Arctic Paper Group does not identify changes in the production process that may result in the appearance
of new pollutants or the disappearance of existing ones.
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Emissions of pollutants to air Unit
Arctic Paper
Munkedals
Arctic Paper
Grycksbo
Arctic Paper
Kostrzyn Rottneros Vallvik Total in 2025 Total in 2024
Carbon monoxide (CO)1 kg 246.85 62 823.00 30 988.40 1 713.28 374 272.91 470 044,43 484 385,17
Hydrofluorocarbons (HFCs) kg 17.50 16.70 34.20 67.80
Ammonia (NH3) kg 1 027.97 67 841.93 68 869.90 64 840,98
Non-methane volatile organic
compounds (NMVOCs)
kg 286.22 6 853.10 464 941.77 472 081.09 444 471.80
Nitrogen oxides (NOx/NO2)2 kg 2 040.00 20 038.00 133 979.30 25 125.00 312 078.54 493 260.84 479 840.74
Sulphur oxides (SOx/SO2)2 kg 15.00 2 051.11 6 006.54 43 604.94 51 677.58 67 997.55
Hydrochlorofluorocarbons (HCFCs) kg 10.00 10.00 4.60
Arsenic and its compounds (as As) kg 0.07 5.22 5.29 4.98
Cadmium and its compounds (as
Cd)
kg 0.17 3.26 3.43 3.26
Chromium and its compounds (as
Cr)
kg 0.51 8.16 8.67 8.24
Copper and its compounds (as Cu) kg 3.43 18,65 22.08 21.35
Mercury and its compounds (as Hg) kg 0.07 0.56 0.63 0.60
Nickel and its compounds (as Ni) kg 1.71 18.65 20,36 19.42
Lead and its compounds (as Pb) kg 3.43 18.65 22.08 21.35
Zinc and its compounds (as Zn) kg 34.27 74.64 108.90 108.39
Chlorine and inorganic compounds
(as HCl)
kg 2 104.87 2 104.87 2 046.68
Particulate matter (PM10) 2 kg 13.00 651.07 2 195.10 46 088.42 48 947.59 46 608.30
1 The measurement was verified by an accredited laboratory.
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Emissions of pollutants to water Unit
Arctic Paper
Munkedals
Arctic Paper
Grycksbo
Arctic Paper
Kostrzyn Rottneros Vallvik Total in 2025 Total in 2024
Nitrogen2 kg 2 582.00 7 690.00 21 322.90 15 501.00 24 126.00 71 221.90 71 956.28
Phosphorus2 kg 312.00 87.00 1 328.20 311.15 6 349.56 8 387.91 7 506.59
Arsenic and its compounds (as As)
2.
kg 0.09 1.91 9.20 11.20 11.65
Cadmium and its compounds (as
Cd) 2.
kg 0.01 0.32 9.78 10.11 7.15
Chromium and its compounds (as
Cr) 2.
kg 0.48 70.90 30.75 20.76 122.89 63.39
Copper and its compounds (as Cu)
2.
kg 3.37 126.40 36.60 54.82 221.19 173.34
Mercury and its compounds (as Hg)
2.
kg 0.04 0.20 0.00 0.24 0.43
Nickel and its compounds (as Ni) 2. kg 1.47 24.80 141.54 16.88 184.69 159.71
Lead and its compounds (as Pb) 2. kg 0.40 27.10 3.20 10.27 40.97 43.86
Zinc and its compounds (as Zn) 2. kg 16.86 121.50 463.66 897.75 1 499.77 1 744.39
Halogenated organic compounds
(as AOX) 2
kg 240.00 244.00 11 265.96 11 749.96 9 372.60
Total organic carbon (TOC) (as
total C or COD/3) 2
kg 21 998.00 20 367.00 22 045.70 911 010.00 851 322.75 1 826 743.45 1 535 890.70
Chlorides (as total Cl) kg 525 392.00 571 032.54 1 181 928.73 2 278 353.26 1 761 875.12
The Group identifies no material emissions of pollutants to soil.
E2-5 Substances of concern and substances of very high concern
The table below shows the quantities of potentially hazardous substances produced, purchased, used, and sold on
their own and as part of a product in 2025. This information is presented by class, according to the highest hazard
category of the substance. As a result of the double materiality analysis described in ESRS General Section 2, the
general disclosure of quantities of substances of very high concern was considered to be insignificant.
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Hazard class Unit Produced Purchased Applied
Sold as its
own
Sold as part of a
product
They left the
Group in the
form of waste
Carcinogenicity category 1 kg 0,00 1 106 067.97 1 105 907.71 0.00 0.00 148.26
Reproductive toxicity category 1 kg 0,00 44,30 44.30 0.00 0.00 0.00
Carcinogenicity category 2 kg 0,00 108 693.60 108 693.60 0.00 0.00 0.00
Reproductive toxicity category 2 kg 0,00 2 430,16 2 430.16 0.00 0.00 0.00
Toxic effects on target organs,
repeated exposure category 1
kg 0,00 27 257,00 0.00 0.00 0.00 23 525.00
Toxic effects on target organs, single
exposure category 1
kg 1 643 390,00 317 014,50 1 960 404.50 0.00 0.00 0.00
Toxic effects on target organs,
repeated exposure category 2
kg 0,00 267,21 267.21 0.00 0.00 0.00
Respiratory sensitisation category 1 kg 0,00 3 500.90 3 500.90 0.00 0.00 0.00
Skin sensitisation category 1 kg 975 337,50 2 177 273.92 2 210 466.90 846 214.00 58 533.60 15 644.40
Long-term hazard to aquatic
environment category 1
kg 46 954,00 365 747.48 386 834.78 0.00 0.00 875.60
Long-term hazard to aquatic
environment category 2
kg 0,00 2 989 299,56 2 989 243.06 0.00 13.20 0.00
Long-term hazard to aquatic
environment category 3
kg 0,00 187 111.39 174 220.79 0.00 0.00 12 890.60
Total for 2025 kg 2 665 681.50 7 284 708.00 8 942 013.91 846 214.00 58 546.80 53 083.86
Total for 2024(corrected values) kg 2 624 166.00 5 769 584.96 6 822 120.33 942 246.00 558 523.06 39 939.94
During the analytical work, discrepancies were identified in the presentation of data on the quantities of hazardous
substances. These involved the incorrect assignment of some volumes to specific hazard classes. As a result, the
table structure did not fully reflect the actual material flows, which affected the level of some aggregate values.
After verifying the source data, corrections to the classification and conversions were made, and the corrected data
were included in the current E2-5 disclosure.
The correction concerned hazard classes because, according to the ESRS, hazardous substances and
substances of very high concern are subject to disclosure by hazard class. Changes were also made to the stages
(i.e., manufactured, purchased, used, and sold); however, these changes are not material, as confirmed by the
structure of the ESRS requirements, which do not consider the stage as a factor determining the scope of required
disclosures. The table below presents the reported and corrected values for each substance class for 2024. The
error correction was described in BP-2.
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Hazard class Unit Produced Purchased Applied Sold as its own
Sold as part of a
product
They left the
Group in the form
of waste
Respiratory
sensitisation
category
1 (reported 2024)
kg 0.00 957 665.20 360.20 0.00 955 205.00 2 100.0
Respiratory
sensitisation
category 1
(corrected 2024)
kg
3 460.20 360.20 3 100.00 0.00
Skin sensitisation
category
1 (reported 2024)
kg 942 246.00 1 622 395.68 823 628.89 942 246.00 859 097.21 56 469.57
Skin sensitisation
category 1
(corrected 2024)
kg
942 246.00 371 348.68 11 468.89 942 246.00 355 319.21 4 560.57
Long-term hazard
to aquatic
environment
category
1 (reported 2024)
kg 58 400.00 63 954.59 89 494.74 32 840.80 19.05
Long-term hazard
to aquatic
environment
category 1
(corrected 2024)
kg
46 720.00 352 222.09 365 314.74 32 840.80 786.55
Total for 2024
(reported)
kg 2 635 846.00 7 405 939.84 7 241 660.33 942 246.00 2 014 406.06 190 473.44
Total for 2024
(corrected
values)
kg 2 624 166.00 5 769 584.96 6 822 120.33 942 246.00 558 523.06 39 939.94
The data on substances of concern come from purchasing data, sales data and safety data sheets of purchased
products, as well as information related to the nature of the production processes at each undertaking. The data
from Vallvik, Rottneros, Arctic Paper Grycksbo and Arctic Paper Munkedals, as well as Arctic Paper Kostrzyn, are
of high quality and include the CAS number (Chemical Abstracts Service – a numerical designation to identify a
chemical) and the annual consumption of the substance. As the concentration of substances of concern in
preparations containing such substances is not reported at Arctic Paper Kostrzyn, the full weight of the
preparations was used for the calculation. The use of potentially hazardous substances is based on estimates,
except when substances are incinerated, for which the data are very accurate. Many substances are reactants that
will undergo a chemical reaction and will not be detectable in the product or emissions. The simple inorganic salts
and acids used will be completely dissociated in the process and will not exist in the added form, thus remaining
undetectable.
E2-6 Anticipated financial impacts arising from material risks and opportunities associated with pollution
The Arctic Paper Group benefits from the possibility to omit the information set out in ESRS E2-6 in the first three
years of the Sustainability Statement on the basis of the “List of phased-in disclosure requirements” (Appendix C in
ESRS 1) and the Commission Delegated Regulation (EU) 2025/1416 of 11 July 2025 amending Delegated
Regulation (EU) 2023/2772 as regards the deferral of the start date of application of the disclosure requirements for
certain companies (“Quick fix”).
ESRS E3 Water and marine resources
SBM-3 Linking Material sustainability impacts and risks to the strategy and business model
[SBM-3 48b, c, d, f] The material water resource impacts and risks described stem from the specific nature of AP’s
business model based on pulp and paper production, which are highly water-intensive processes. The high reliance
on water as a key raw material means possible operational risks, as droughts or limited water availability can lead
to temporary production stoppages. High water consumption generates significant costs for water abstraction,
treatment and disposal, and increases in water prices and environmental charges can affect the profitability of
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operations. The limited availability of water in water-scarce regions can also increase the price of raw materials,
such as pulp and paper pulp, and force modifications to the supply chain, including the search for alternative
suppliers in regions with greater water availability. Water pollution associated with the maritime transport of pulp is
an additional aspect of risk linked to the business model. Increasing regulatory requirements and market pressure
for sustainable production are prompting the Group to further invest in water-saving technologies, water recycling
and treatment, and process optimisation. The Arctic Paper Group continuously monitors the quality of water
discharged into the environment, focusing on discharging water of high quality. In the future, it is possible to
implement sustainable transport strategies, including cooperation with suppliers using ballast water treatment
systems, which may affect logistics costs. These actions increase operational resilience to water shortages,
mitigate financial and reputational risks and support the Group’s long-term financial sustainability.
E3-1 Policies related to water and marine resources
[E3-1 11, 12, 14] [MDR-P 65] In 2025 the Arctic Paper Group did not have a separate water, marine and ocean
resources policy. The Group currently manages the water and marine resources topic based on the provisions of
the Sustainable Development Policy. In line with this policy, Group companies make efforts to reduce water
consumption and wastewater discharge, and to reuse water used in the production process. The policy also
represents the Arctic Paper Group’s commitment to strive to ensure that the water used is treated first and only
then reintroduced into the environment. The policy notes that the quality of water abstracted and discharged is
monitored. The monitoring requirement also stems from the water permits in both Poland and Sweden (Swedish:
Vattendom). The document refers to the use and supply of water within its own operations, water treatment and a
commitment to reduce water consumption. It also applies to value chain operations that may be carried out in areas
at risk of water scarcity.
The scope of the policy covers the operations of the Arctic Paper Group. The Group Management is responsible
for implementing the provisions of the policy. The adopted policy does not refer to third-party standards or
initiatives. In preparing the content of the document, the interests and opinions of the Group’s stakeholders were
taken into account. The Group makes the regulations available by posting them on its website and on the internal
communication channels of each organisational unit.
E3-2 Activities and resources related to water and marine resources
[E3-2 17, 19] [MDR-A 68] Key water resource activities focus at Arctic Paper Group on optimising water
consumption:
Name of the action Description of the action
Optimisation of water
and wastewater
management, reduction
of water consumption in
production processes
In 2024, the Arctic Paper Group continued its efforts to minimise water use in its production processes, increase water reuse and
reduce the load of pollutants discharged with wastewater. A key element of these activities was the modernisation of the
wastewater treatment infrastructure at Arctic Paper Kostrzyn, which included equipping the plant with a new air supply system,
resulting in improved efficiency of the treatment processes. The upgrade of the blower station was completed in 2025 and was a
continuation of the work started earlier. The initiatives undertaken support more efficient management of water resources and
reduce pressure from water discharges, which is important in the context of the high water intensity of paper and pulp produc tion
processes and the increasing physical risks associated with water availability.
Installation of a water
metering system
In 2024, the infrastructure at the Rottneros plant was upgraded with the installation of a metering system at the water intak e. This
solution allowed for more accurate monitoring of the amount of water abstracted and better control of its use in operationa l
processes in 2025. The measure supports more efficient management of water resources and the identification of potential area s
for further optimisation of water use.
Regulation of water
resources
In 2025, Arctic Paper Munkedals obtained a permit enabling more efficient and economical use of the existing water storage
capacity and the introduction of new rules for its regulation and retention in connection with the hydropower plant. This act ion will
allow better management of water resources in the future, particularly during dry summer periods, reducing the risk of water
shortages. The new conditions will allow more rational management of water abstraction and storage, increasing the plant’s
resilience to climatic variability.
The above activities did not require significant capital or operating expenditure.
The Group will consider the next steps and the resources needed to implement them.
E3-3 Water and marine resources objectives
[E2-3 22] [MDR-T 81] Arctic Paper Group has not currently set quantitative targets for water and marine resources
due to a lack of identified need. Monitoring the progress and effectiveness of the actions undertaken in this area is
done by monitoring water consumption, reuse and recycling. Water consumption levels do not exceed the
permitted values set out in the integrated permits in force for the individual production facilities.
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E3-4 Water consumption
[E3-4 28] The table below shows the water consumption of the Arctic Paper Group’s own operations, the amount of
water recycled and reused and the Group’s water intensity.
Water consumption Unit 2025 2024
Total water consumption m3 1 322 510.77 1 337 498.51
Water abstraction m3 32 256 987.56 34 150 489.32
Water discharge m3 30 933 576.79 32 812 990.811
Total water consumption in areas at
risk of water scarcity, including areas
with significant water scarcity2
m3 0 0
Total amount of water recycled and
reused
m3 48 060 751.88 47 541 104.99
Total amount of water stored3 m3 0 0
Changes in water storage m3 0 0
Water absorption EUR m3/1million 4 net revenue 1 764.69 1 676.95
The value of total water consumption consists of:
• Steam from the drying process of the main product
• Vapours from drying in side operations (causticizing and regeneration boiler)
• Water in the product
• Water in waste, such as sludge from sewage treatment.
The water intake value consists of water taken into the factory through the factory’s own preparation of fresh water
from the river on the basis of water licences issued in Poland and Sweden (Vatttendom) and water purchased from
an external supplier (city water).
The water discharge value consists of two streams:
• Wastewater treated at the factory’s wastewater treatment plant. Volume is measured using a built-in
continuous flow meter. The values shown in the table do not include rainwater.
• Unpolluted cooling water returning to the river. This flow is calculated as a residual value for the entire
factory, except for Vallvik, where it is measured.
TOTAL AMOUNT OF WATER RECYCLED AND REUSED
Water recycling in paper mills involves returning water from the paper machines to the pulp preparation
department. Recycling is calculated on the basis of the dry content in the raw material stream. Water recycling at
the fibre line pulp mill consists of water used in counter current from screening to bleaching to washing. In the pulp
mill’s chemical recovery system (Vallvik only), the condensation water from the evaporation plant is used as wash
water on the white liqour lime sludge filter. The lime-mud filter filtrate is used as solvent water for the soda melt. All
volumes are measured using in-line flowmeters.
E3-5 Anticipated financial impacts arising from impacts, risks and opportunities related to water and
marine resources
The Group benefits from the possibility to omit the information set out in ESRS E3-5 in the first three years of the
Sustainability Statement on the basis of the “List of phased-in disclosure requirements” (Appendix C in ESRS 1)
and the Commission Delegated Regulation (EU) 2025/1416 of 11 July 2025 amending Delegated Regulation (EU)
1 Corrected value for 2024. During the preparation of the 2025 Sustainability Statement, an issue was identified regarding incorrect reporting of wastewater discharges for 2024. This
error resulted from an incorrect formula reference in the source Excel file. Instead of including the value "Discharge of treated wastewater to river," the line item reported for Arctic Paper
Kostrzyn used data from the previous year referring to the category "Sludge from wastewater treatment plant." Consequently, the volume of wastewater discharged at the Kostrzyn mill
was incorrectly reported. Additionally, the volume of uncontaminated cooling water discharged to the river was not included in the reported water discharges. The total wastewater
discharge reported for fiscal year 2024 was 23,078,936.75 m³, while the corrected value is 32,812,990.81 m³. The correction of the error is described in BP-2.
2 According to the WRI Aqueduct Water Risk Atlas tool, none of the Group’s locations are situated in a region of high baseline water stress.
3 The Group does not store water.
4 According to the euro exchange rate in 2025 – 4,2267; 2024 – PLN 4.3064. Source: NBP.
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2023/2772 as regards the deferral of the date of application of the disclosure requirements for certain companies
(“Quick fix”).
ESRS E5 Resource use and the circular economy
SBM-3 Linking Material sustainability impacts to strategy and business model
[SBM-3 48b, c, d, f] The material impacts described in the area of resource use and the circular economy are linked
to Arctic Paper’s business model through the manufacturing nature of its operations and its high dependence on
raw materials, including non-renewable resources. These issues are partly linked to the Group’s strategy through
the Packaging Pillar, which includes the development of renewable resource-based and recyclable packaging as
an alternative to plastic packaging. These actions provide opportunities to reduce the consumption of primary raw
materials, reduce waste and adapt the offering to growing customer expectations and regulatory requirements. The
use of recycled materials and the efficient recovery of raw materials can contribute to lower production costs and
improved resource efficiency in the long term. At the same time, production processes produce a percentage of
non-reusable or recyclable waste. These wastes require specialised disposal methods, which generate costs for
transport, storage or incineration and may incur additional environmental charges. Rising raw material prices and
waste management costs can increase operating costs. Increasing regulatory requirements and market pressures
may require the further development of circular economy solutions. In the future, it is possible to incorporate waste
minimisation targets into the strategy and gradually redefine the business model towards less dependence on non-
renewable resources. Growing environmental awareness among consumers is encouraging demand for products in
more sustainable packaging, supporting the development of new business areas.
E5-1 Policies related to resource use and the circular economy
[E5-1 14, 15] [MDR-P 65] In 2025, the Arctic Paper Group did not have a separate policy on resource use or the
circular economy. The Group currently manages this related topic on the basis of the provisions of the
Sustainability Policy. In this policy, the Arctic Paper Group emphasises the organisation’s co-creation of a
sustainable, closed-loop production system. The Group declares the use of renewable resources such as pulp fibre
– these resources are reused and recycled with little or no waste generation. Another document governing the
approach to managing the resource topic is the Environmental Policy. It obliges the Group to buy pulp from certified
and controlled sources and to check the origin of the wood raw material used in its production. The Group declares
its efforts to purchase pulp from sustainably managed forests. This commitment is also enshrined in the
Sustainable Development Policy as part of responsible sourcing,
The scope of the policies covers the operations of the Arctic Paper Group. The Group Management is
responsible for implementing the provisions of the policies. The policies adopted do not refer to third-party
standards or initiatives. In preparing the content of the documents, the interests and opinions of the Group’s
stakeholders were taken into account. The Group makes the regulations available by posting them on its website
and on the internal communication channels of each organisational unit.
The Rottneros Group has adopted a Resource Policy in which it declares actions to exclude wood from:
• Illegal sources;
• Forests whose protected natural values are threatened by logging. In Sweden, this concerns all wood
originating from key forest habitats harvested contrary to the recommendations of the Swedish Forest
Agency.
• Forests that have been substantially converted to plantations or other land uses;
• Forest management using genetically modified trees;
• Forest management that violates any of the ILO core conventions on forced or child labour, freedom of
association, collective bargaining, discrimination and harassment;
• Forests that are being cut down in violation of human rights;
• Sources which do not comply with the EU Timber Regulation
The Rottneros Group has certification to international FSC® and PEFC standards for its supply chain.
The raw materials policy applies throughout the Rottneros Group, and the parent company’s Board of Directors
is responsible for implementing and complying with its provisions. The provisions of the Policy refer, inter alia, to
International Labour Organisation standards. In preparing the content of the document, the Rottneros Group took
into account the opinions and interests of its stakeholders. The Group makes the contents of the Policy available by
posting them on the website and in the internal communication channels of each organisational unit.
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E5-2 Activities and resources related to resource use and the circular economy
[E5-2 19] [MDR-A 68] Key activities related to resource utilisation and the circular economy focus on raw material
certification or waste segregation in the Arctic Paper Group:
Name of the action Description of the action
Maintaining FSC®
certification for paper
trays
In both 2024 and 2025, the Rottneros Group maintained FSC ® certification and food contact compliance for paper trays produced
in Sweden. This action confirms responsible sourcing of wood raw materials and compliance with high safety standards for
products intended for food contact. Maintaining certification suppo rts sustainable forest management and reinforces a circular
approach to packaging design and production.
Supervision of certified
pulp sourcing
In 2024 and 2025, the Arctic Paper Group used mainly FSC ® or PEFC certified wood pulp in the production process at all paper
mills in Poland and Sweden. This approach aims to ensure that the wood raw material comes from sustainably managed forests.
In 2025, these actions continued through ongoing supply chain ov ersight and systematic verification of FSC ® and PEFC
certifications, maintaining a 100% share of certified pulp in raw material purchases. In addition, at the Arctic Paper Grycks bo mill,
the pulp used must meet the Nordic Ecolabel (Nordic Swan), which confirms the efficient use of resources, including lower
consumption of raw materials and energy in the production process.
Construction of a
thallium oil production
facility
In 2024, a new thallium oil plant was commissioned at the Vallvik mill. The project makes it possible to obtain cleaner and m ore
useful fractions of by-products from the pulp production process. This measure increases the efficiency of raw material use and
promotes the reuse of materials that previously had a lower use value. Following the commissioning of the new plant, a major
customer of talc oil confirmed in 2025 that the quality of the supply had improved – the moisture content is significantly lower and
the resin content and acid index are higher, resulting in a better use value of the product.
Cooperation on fly ash
recycling
In 2025, Arctic Paper Grycksbo has partnered with the municipality -owned company Falu Energi to recycle fly ash from the steam
boiler by reusing it on forest land as fertiliser. This action allows the by -product of the energy process to be managed in a way that
supports a closed loop, contributes to reducing the amount of waste sent for disposal.
Extension of the waste
separation system
In 2025, Arctic Paper Munkedals implemented an extended waste separation system, including municipal waste fractions. This
action improves the separation of waste streams at the waste generation stage and increases opportunities for further waste
management.
The activities did not involve significant investment or operational expenditure.
Further activities and the resources needed to implement them are currently being planned. These activities
primarily involve internal stakeholders (employees) as well as upstream stakeholders in the value chain (suppliers)
and will continue to do so.
E5-3 Objectives related to resource use and the circular economy
[E5-3 24, 25, 27] [MDR-T 80] The Arctic Paper Group’s resource use and circular economy (resource impact) goal
is to source pulp for paper production from FSC® or PEFC certified suppliers at 100%. The objective relates to the
sustainable extraction and use of renewable resources.
As of 2017, the Group declares to source almost 100% of the raw material with the indicated certificates. This
was 98% in 2025 (98% in 2024).
The target is measured on the basis of completed orders for FSC® or PEFC certified pulp, in the same way
since the beginning of its implementation. The metric is not linked to scientific evidence or validated by an external
body other than the assurance provider.
The purpose of supply chain verification is to gain assurance that:
• the wood does not originate from illegal sources,
• the wood does not originate from endangered areas or areas of high conservation value,
• the wood does not originate from genetically modified trees,
• indigenous peoples’ traditions and rights are not violated in the harvesting of timber.
The Group’s internal stakeholders were involved in setting the adopted target. The objective is linked to the policies
described earlier but is not driven by external regulatory obligations. A description of the methodology for
measuring the achievement of the objective is provided in the next subsection (E5-4 Resources introduced).
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E5-4 Input resources
[E5-4 32, AR 24] Material resources introduced to the Arctic Paper Group used in the production of paper and pulp
are outlined below.
Resources introduced into the organisation Unit 2025 2024
Total weight of products entering the organisation t 0 0
Total weight of technical material entering the organisation t 259 653.45 266 007.36
Total mass of biological materials entering the organisation t 1 533 165.70 1 526 617.19
including materials from sustainable sources t 1 502 875.92 1 497 073.57
Total mass of products, technical and biological materials introduced into the organisation t 1 792 819.79 1 792 624.69
Percentage of biological materials used to provide services and manufacture products (including
packaging) from sustainable sources
% 98% 98%
Percentage of biological materials used in the production of pulp from sustainable sources % 100% 100%
Percentage of biological materials used in paper production from sustainable sources*
*Including starch, wrapping paper, pallets
% 92% 92%
Total weight of products, materials, components reused or recycled in the manufacture of products
(including packaging) or services
t 0 0
Percentage of products, materials, components reused or recycled in the manufacture of products
(including packaging) or services
% 0 0
The weight was estimated on the basis of purchase invoices and product sheets.
TOTAL WEIGHT OF TECHNICAL MATERIAL ENTERING THE ORGANISATION
The technical materials assessed in this disclosure are:
• Filling and coating pigments,
• Process chemicals used in processing,
• Packaging materials except those listed under biological material.
TOTAL MASS OF BIOLOGICAL MATERIALS ENTERING THE ORGANISATION
The following biological/compostable materials are included in this category:
• Wood raw material,
• Starch,
• Paper material.
SUSTAINABLY SOURCED MATERIALS
The materials whose mass is included in this category are FSC® and PEFC-certified wood and pulp.
TOTAL WEIGHT OF PRODUCTS ENTERING THE ORGANISATION
The reported mass of input resources is limited to raw materials and related process materials, mainly process
chemicals consumed in the manufacturing process and packaging materials for finished goods leaving the
production facilities, due to the lack of relevant data (kg/year). The following consumed resources are not included
in this statement:
• IT equipment,
• Textiles such as workwear and machine clothing,
• Furniture,
• Building materials,
• Storage and transport equipment and facilities,
• Spare parts and consumables.
E5-5 Resources discharged
[E5-5 35] The key recyclable and degradable products offered by the Arctic Paper Group are:
• Sheets and scrolls,
• Coated and uncoated, wood-free and wood-based paper,
• CTMP pulp from the Rottneros Mill,
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• ECF and UKP pulp from the Vallvik Mill,
• Injection-moulded packaging products from Rottneros Packaging.
[E5-5 36] The Arctic Paper Group’s products are primarily intended for printers, paper distributors, book and
magazine publishers, the advertising industry and packaging manufacturers, so the expected durability of end
products, repairability or recyclable content ratios cannot be precisely determined. The sustainability of the final
products depends primarily on how they are stored and the method of further processing and handling by
customers, as part of their own business operations and production processes.
Arctic Paper products are manufactured with the development of a circular economy in mind. The Group draws
on the methodology and experience of third parties to develop new ways of producing different types of paper,
based on the identification of chemical risks and the impact of particular solutions on product quality, taking into
account both the manufacturing process and the use and end-of-life of the product. Selected Arctic Paper products
have been tested and approved for use in Nordic Ecolabel-certified products. Products from the Arctic Paper
Kostrzyn mill are EU Ecolabel certified.
In 2025, the total volume of waste in the Arctic Paper Group was 63,435.98 tonnes, of which approx. 69% was
prepared for reuse, recycling or other recovery processes. Details of the waste are included in the table below.
Resources drained from the organisation Unit 2025 2024
Waste for which disposal has been avoided t 43 978.53 57 306.85
Hazardous waste, including: t 326.80 231.01
prepared for re-use t 0 0
recyclable t 244.29 87.24
subject to other recovery processes t 82.51 143.76
Non-hazardous waste, including: t 43 651.73 57 075.84
prepared for re-use t 1 978.25 2 262.09
recyclable t 29 074.35 43 768.52
subject to other recovery processes t 12 599.13 11 045.24
Waste sent for disposal t 19 457.45 21 073.92
Hazardous waste, including: t 54.60 7.76
burnt t 1.52 3.65
stored t 42,88 0.19
subjected to other disposal processes t 10.20 3.91
Non-hazardous waste, including: t 19 402.85 21 066.16
burnt t 1 381.99 1 482
stored t 17 970.73 19 546.38
subjected to other disposal processes t 50.13 37.78
Total amount of radioactive waste t 0 0
Total waste generated t 63 435.98 78 323.77
Total quantity of hazardous waste t 381.40 238.76
Total amount of non-recycled waste t 34 117.34 34 468.01
Percentage of waste not recycled % 53.78% 44.01%
Total non-hazardous waste t 63 054.58 78 085.01
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The main waste streams for the Group are packaging waste, production waste, pallet waste and municipal waste
from office operations. The Group’s waste structure is dominated by biomass (pulp fibres), wood and plastics
(packaging tape, stretch film). The Group does not generate radioactive waste.
[E5-5 40, AR 33] Waste data are obtained from waste recipients and collected at the level of production
facilities. Waste volumes from the production facilities are monitored on an ongoing basis and their weight is
reported in the respective reporting systems – BDO (Polish Waste Database) for Arctic Paper Kostrzyn and
Naturvårdsverket for the other production facilities. Most of the waste generated is waste associated with the paper
and pulp production process – sewage sludge from on-site treatment plants. Paper and cardboard packaging and
wooden packaging also represent significant amounts of waste.
E5-6 Anticipated financial impacts from material risks and opportunities related to resource use and the
circular economy
The Arctic Paper Group benefits from the possibility to omit the information set out in ESRS E5-6 in the first three
years of the Sustainability Statement on the basis of the “List of phased-in disclosure requirements” (Appendix C in
ESRS 1) and the Commission Delegated Regulation (EU) 2025/1416 of 11 July 2025 amending Delegated
Regulation (EU) 2023/2772 as regards the deferral of the start date of application of the disclosure requirements for
certain companies (“Quick fix”).
Taxonomy
The EU Taxonomy is a classification system that establishes criteria for environmentally sustainable economic
activities. It plays an important role in helping to scale up sustainable investments and implement the European
Green Deal. The EU taxonomy provides businesses, investors and policymakers with the relevant definitions of
how an economic activity can be considered environmentally sustainable. In this way, it provides security for
investors, protects private investors, and helps companies become more climate-friendly.
Regulation 2020/852 of the European Parliament and of the Council on the EU taxonomy was published in the
Official Journal of the European Union on 22 June 2020 and entered into force on 12 July 2020.
It lays the foundations for the EU Taxonomy by setting out 4 overarching conditions that an economic activity
must meet in order to qualify as environmentally sustainable. An economic activity qualifies as environmentally
sustainable if it:
a) it makes a substantial contribution to one or more of the environmental objectives;
b) does not cause significant harm to any of the environmental objectives;
c) it is carried out in accordance with minimum guarantees;
d) meets the technical qualification criteria.
The Taxonomy Regulation sets out the following environmental objectives:
a) climate change mitigation;
b) adaptation to climate change;
c) the sustainable use and protection of water and marine resources;
d) the transition to a circular economy;
e) pollution prevention and control;
f) protecting and restoring biodiversity and ecosystems.
In accordance with the Taxonomy Regulation, the Arctic Paper Group discloses in its annual report:
• the percentage of turnover derived from products or services related to environmentally sustainable
activities;
• the percentage of capital expenditures (CapEx) corresponding to assets or processes related to
environmentally sustainable activities;
• the percentage of operating expenditure (OpEx) corresponding to the assets or processes associated with
environmentally sustainable activities.
In this Sustainability Statement 2025, the Arctic Paper Group discloses the percentage of turnover, capital
expenditure and operating expenditure eligible for the EU taxonomy and reviews the criteria for environmentally
sustainable economic activities set out in Article 3 of Regulation 2020/852 of the European Parliament and of the
Council to determine what percentage of these three values are related to environmentally sustainable activities.
The core business of the Arctic Paper Group is the production and sale of paper and pulp. These activities are
not covered by the EU Taxonomy.
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1. Qualification and Taxonomy Compliance Assessment Process
We have divided the evaluation process into 4 stages:
1. Identification - an overview of all activities carried out by all Arctic Paper Group entities and determining whether
and which activities qualify as Taxonomy-compliant activities. The review covered Arctic Paper Group's revenues,
capital expenditures and operating expenses. The basis for considering a given activity as eligible was a
comparison of the actual activity with the description of the activity detailed under Annex I or Annex II to the
Commission Delegated Regulation (EU) 2021/2139, taking into account the Commission Delegated Regulation
(EU) 2023/2485 of 27 June 2023 amending the above Regulation and with the description of the activities
contained in the Commission Delegated Regulation (EU) 2023/2486
2. Allocation – assigning the value of turnover, capital expenditures and operating expenditures to specific
activities, identified in the first stage.
3. Verification – examination of the criteria of significant contribution and non-significant harm for all identified
activities, using the technical screening criteria referred to in the Annexes to Commission Delegated Regulation
(EU) 2021/2139.
Verification of compliance with the technical screening criteria was carried out for activities eligible for the EU
Taxonomy. and consisted of an analysis of the different criteria for significant contribution and non-significant harm
and checking to what extent the activity complies with the technical screening criteria set out in Annexes I and II to
Commission Delegated Regulation (EU) 2021/2139, as extended by Commission Delegated Regulation (EU)
2022/1214, Commission Delegated Regulation (EU) 2023/2485 and 2023/2486.
According to the analysis, none of the activities qualified in 2025 meet the technical qualification criteria. Given
that the taxonomy does not cover its main activities, the Group does not have documentation confirming the
compliance of its other activities. Arctic Paper Group carried out a climate risk analysis for all production facilities
located in Poland and Sweden, which is part of the DNSH principle for most eligible activities.
4. The next step was to assess whether the Minimum Guarantees were met.
According to Article 18 of Regulation (EU) 2020/852 of the European Parliament and of the Council: "minimum
safeguards, (...), are the procedures applied by an enterprise conducting business activities to ensure compliance
with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human
Rights, including the principles and rights set out in the eight fundamental conventions set out in the International
Labour Organization's Declaration on Fundamental Principles and rights at work and the principles and rights set
out in the International Bill of Human Rights."
The test of compliance with minimum safeguards was carried out in accordance with the recommendations
included in the Final Report on Minimum Safeguards prepared by the Platform on Sustainable Finance.
According to the recommendations, failure to meet the minimum guarantees is at least one of the following four
conditions:
• insufficient or non-existent human rights due diligence processes, including labour rights, corruption, taxation
and fair competition;
• the company or its top management has been found guilty of violations of labor law or human rights laws in
certain types of labor law or human rights court cases;
• lack of cooperation with the OECD National Contact Point (OECD NCP; NCP OECD) on the notification
received by the OECD NCP;
• The Business and Human Rights Resource Center (BHRRC) made an allegation against the company,
which the company did not respond to within 3 months.
During the verification process at Arctic Paper Group, non-compliance with the above premises was tested as
follows:
1. as a result of the internal analysis, it was determined that the Arctic Paper Group has a due diligence process in
place and in place.
• Arctic Paper Group has a whistleblowing system in place;
• mandatory training for all employees in the field of anti-corruption and anti-competitive practices;
• Arctic Paper Group implements a supplier sustainability assessment system;
• The Arctic Paper Group's Code of Conduct in the value chain, the Sustainability Policy and the Diversity
Policy were implemented.
2. as a result of verification whether no final convictions were issued in relation to the persons mentioned in the
content of the premise, in the period to which the verification relates.
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3. A review of the OECD NCP (National Contact Point) notification database was carried out, which showed that
there were no notifications concerning the Arctic Paper Group during the review period –
https://mneguidelines.oecd.org/database/.
4. A verification of the Business and Human Rights Resource Center (BHRRC) application database was carried
out, which showed no notifications regarding the Arctic Paper Group during the verification period -
https://www.business-humanrights.org/en/companies/.
5. Calculation – using the information obtained in the second and third stages to prepare tables containing the
required information and to develop supplementary information in accordance with the requirements of Annexes I
and II to Commission Delegated Regulation (EU) 2021/2178, as amended by Annex V of Commission Delegated
Regulation (EU) 2023/2486.
The process was led by a team of representatives of Arctic Paper Group companies, coordinated by the
Sustainability Team.
The eligibility assessment found that the Arctic Paper Group carries out the following activities:
• CCM 1.3 – Forest management – services in the field of wood management provided by Rottneros;
• CCM 4.1 Energy production with the use of photovoltaic energy – production of electricity from photovoltaic
farms located in Poland and Sweden;
• CCM 4.5 Hydropower Generation – at the Munkedals Hydroelectric Power Plant;
• CCM 4.8 Production of electricity from bioenergy – expenditures on pellet energy generation installations at
the factory in Grycksbo;
• CCM 4.10 Energy storage – turnover and capital expenditure related to the installation of battery storage
facilities in Rottneros;
• CCM 4.13 Production of biogas and biofuels for transport and bioliquids – revenues, capital expenditures
and operating expenditures from the production of tall oil by the Rottneros plant;
• CCM 4.20 Cogeneration of heat/cooling energy and electricity from bioenergy – capital expenditures related
to the investment in a boiler based on cogeneration from bioenergy at the plant in Vallvik and turbine in a
boiler in Grycksbo;;
• CCM 4.24 Generation of heat/cooling energy from bioenergy – capital expenditure on the renovation of the
heat recovery boiler and turbine at the Vallvik plant;
• CCM 5.1 Construction, expansion and operation of water abstraction, treatment and supply systems –
expenditures related to the modernization and expansion of water intake infrastructure in Grycksbo;
• CCM 5.3 Modernization of wastewater collection and treatment systems in Grycksbo;
• CCM 5.9 Recovery of materials from hazardous waste;
• CCM 6.5 Transport by motorcycles, passenger cars and light commercial vehicles, which evaluates vehicles
belonging to the Arctic Paper Group's own and leased fleets used in Arctic Paper's own operations;
• CCM 6.14 Infrastructure for rail transport – capital expenditures and operating costs of maintenance of the
section of railway infrastructure for the transport of raw materials in the factories in Kostrzyn and Rottneros;
• CCM 7.2 Renovation of existing buildings – capital expenditures incurred for the renovation of buildings
belonging to mills;
• CCM 7.3 Installation, maintenance and repair of energy efficiency equipment;
• CCM 7.4 Installation, maintenance and repair of electric vehicle charging stations in the Group's buildings
(and car parks);
• WTR 1.1 Manufacturing, installation and related services of leak control technologies to reduce and prevent
leakage in water supply systems;
• BIO 1.1 conservation, including the restoration of habitats, ecosystems and species as part of the restocking
of the Munkedals River.
2. Accounting policies
The requirements of Delegated Regulation 2021/2178 were applied to the calculation of individual key
indicators.
At the stage of identifying Taxonomy-eligible activities and accompanying activities, it was ensured that none of
them qualifies for more than one activity, i.e. for example, no investment project meets the definition of more than
one activity. In practice, the different activities eligible for the Taxonomy and the related activities relate to separate
areas, which eliminates the risk of double inclusion in them.
At the stage of preparation for the process of identifying types of activity, and then allocation and verification,
persons responsible for individual business areas were informed about such theoretical risk and instructed that if a
given activity meets more than one definition of activity, they should assign it to the definition of this type of activity,
which best reflects the specificity and nature of a given activity.
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In the reported 2025, no changes were made to the accounting policy.
The following rules are used to calculate the percentage of turnover, CapEx and OpEx eligible for the
Taxonomy:
Turnover – in terms of turnover, the basis was the total consolidated revenues of the Arctic Paper Group in
2025, disclosed in the consolidated financial statements under "Revenue from sales of paper and pulp" described
in Note 4.1. The numerator for turnover KPIs in the field of eligible activities consists entirely of the values derived
from revenues from contracts with customersP. Revenues from Taxonomy-eligible activities are assigned to the
numerator.
In 2025, the Arctic Paper Group identified 9 activities from which revenues qualify for the taxonomy.
In 2025, Arctic Paper generated Taxonomy-eligible revenues mainly from the services provided by Rottneros in
the areas of timber management services (activity 1.3) and and tall oil production (activity 4.13) at the Vallvik pulp
mill.
Arctic Paper derives from its own electricity production as indicated in the eligible descriptions of activities 4.1
CCM, 4.5 CCM, 4.8 CCM, 7.6 CCM and biogas/biofuels produced by activities 4.13 CCM. The corresponding
amounts were accordingly excluded from taxonomic reporting. In the course of the analysis, no other cases of self-
consumption were found that would require disclosure.
in thousand PLN December 31, 2025
Revenues from Taxonomy-eligible activities 116 283
Consolidated revenues 3 197 594
Revenue indicator of Taxonomy-eligible activities 3.64%
The percentage of revenues related to Taxonomy-eligible activities is 3.64%.
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Percentage of turnover from products or services related to economic activities in accordance with the taxonomy
Substantial contribution criteria
DNSH criteria
('Does Not Significantly Harm')
Economic activities (1)
Code(s) (2)
Absolute turnover (3)
Proportion of turnover (4)
Climate change mitigation
(5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change
mitigation (11)
Climate change
adaptation (12)
Water and marine
resources (13)
Pollution (14)
Circular
economy (15)
Biodiversity (16)
Minimum
safeguards (17)
Proportion
of
Taxonomy
- aligned
(A.1.) or -
eligible
(A.2.)
turnover,
2024 (18)
Category (enabling
activity) (19)
Category (transitional
activity) (20)
ths zł % Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T
A. Taxonomy eligible activities
A.1. Environmentally sustainable activities
(Taxonomy-aligned)
0 0%
Turnover of environmentally sustainable
activities (Taxonomy-aligned) (A.1)
0 0,00% 0,00
%
0,00
%
0,00
%
0,00
%
0,00% 0,00
%
0,00%
Of which enabling
0 0,00% 0,00
%
0,00
%
0,00
%
0,00
%
0,00% 0,00
%
0,000% E
Of which transitional
0 0,00% 0,00
%
0,00
%
0,00
%
0,00
%
0,00% 0,00
%
T
A.2 Taxonomy-Eligible, but not
environmentally sustainable activities (not
Taxonomy-aligned activities)
EL;
N/EL
EL;
N/EL
EL;
N/EL
EL;
N/EL
EL;
N/EL
EL;
N/EL
Forest management CCM
1.3
87 837 2.75% EL N/EL N/EL N/EL N/EL N/EL
2.28%
Electricity generation using solar photovoltaic
technology
CCM
4.1
2 159 0.07% EL N/EL N/EL N/EL N/EL N/EL
0.00%
Electricity generation from hydropower CCM
4.5
2 348 0.07% EL N/EL N/EL N/EL N/EL N/EL
0.00%
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Substantial contribution criteria
DNSH criteria
('Does Not Significantly Harm')
Economic activities (1)
Code(s) (2)
Absolute turnover (3)
Proportion of turnover (4)
Climate change mitigation
(5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change
mitigation (11)
Climate change
adaptation (12)
Water and marine
resources (13)
Pollution (14)
Circular
economy (15)
Biodiversity (16)
Minimum
safeguards (17)
Proportion
of
Taxonomy
- aligned
(A.1.) or -
eligible
(A.2.)
turnover,
2024 (18)
Category (enabling
activity) (19)
Category (transitional
activity) (20)
Electricity generation from bioenergy CCM
4.8
115 0.00% EL N/EL N/EL N/EL N/EL N/EL
0,00%
Storage of electricity CCM
4.10
1 295 0.04% EL N/EL N/EL N/EL N/EL N/EL
0.00%
Manufacture of biogas and biofuels for use in
transport and of bioliquids
CCM
4.13
22 411 0.70% EL N/EL N/EL N/EL N/EL N/EL
0.94%
Construction, extension and operation of water
collection, treatment and supply systems
CCM
5.1
45 0.00% EL N/EL N/EL N/EL N/EL N/EL
0.00%
Construction, extension and operation of waste
water collection and treatment
CCM
5.3
61 0.00% EL N/EL N/EL N/EL N/EL N/EL
0.00%
Installation, maintenance and repair of charging
stations for electric vehicles in buildings (and
parking spaces attached to buildings)
CCM
7.4
13 0.00% EL N/EL N/EL N/EL N/EL N/EL
0.00%
Turnover of Taxonomy-eligible, but not
environmentally sustainable activities (not
Taxonomy-aligned activities) (a.2)
116 283 3.64% 3.64
%
0.00
%
0.00
%
0,00
%
0.00% 0.00
%
3.33%
Turnover of taxonomy-eligible activities (A.1
+ A.2)
116 283 3.64% 3.64
%
0.00
%
0.00
%
0.00
%
0.00% 0.00
%
3.33%
B. Taxonomy-non-eligible activities
Turnover of Taxonomy-non-eligible
activities (B)
3 081 312 96.4%
Total (A+B)
3 197 594 100.0%
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The Code constitutes the abbreviation of the relevant objective to which the economic activity is eligible to make a substantial
contribution, as well as the section number of the activity in the relevant Annex covering the objective, i.e.:
CCM — Climate Change Mitigation
CCA — Climate Change Adaptation
WTR — Water and Marine Resources
CE — Circular Economy
PPC — Pollution Prevention and Control
BIO — Biodiversity and ecosystems
Y – Yes, Taxonomy-eligible and Taxonomy-aligned activity with the relevant environmental objective
N – No, Taxonomy-eligible but not Taxonomy-aligned activity with the relevant environmental objective
N/EL – Not eligible, Taxonomy-non-eligible activity for the relevant environmental objective.
Non-financial undertakings shall also report the extent of eligibility and alignment per environmental objective, that includes alignment with each of environmental objectives for activities contributing
substantially to several objectives:
Proportion of turnover/Total turnover
Taxonomy aligned per objective Taxonomy eligible per objective
CCM 0,00% 3.64%
CCA 0,00% 0,00%
WTR 0,00% 0,00%
CE 0,00% 0,00%
PPC 0,00% 0,00%
BIO 0,00% 0,00%
EL – Taxonomy-eligible activity for the relevant objective
N/EL – Taxonomy-non-eligible activity for the relevant objective.
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CapEx – with respect to capital expenditures (CapEx), the basis was capital expenditures settled in the Arctic
Paper Group in individual factories and at the headquarters, which consisted of increases in intangible assets of
PLN 47,448 thousand, rights of use of PLN 3,963 thousand and increase in fixed assets of PLN 269,742 thousand.
The denominator includes an increase in property, plant and equipment and intangible assets during a given
financial year before depreciation, amortisation and any revaluation, including those resulting from revaluation and
impairment, for a given financial year, excluding changes in fair value.
in thousand PLN December 31, 2025
CapEx related to Taxonomy-eligible activities 120 799
Total capital expenditure 321 153
CapEx ratio of Taxonomy-eligible activities 37.61%
The percentage of capital expenditures related to eligible activities is 37.61%.
In 2025, Arctic Paper's key taxonomy-eligible capital expenditures were related to the installation of photovoltaic
farms (activity 4.1) at the Arctic Paper Group's paper mills and the investment in the construction of a pellet
production unit (activity 4.8) at Arctic Paper Grycksbo.
The entire CapEx is included in the consolidated financial statements under the following increase items:
• fixed assets – Note 5.1
• right-of-use assets - Note 5.2
• intangible assets – Note 5.4
The numerator is assigned the part of CapEx that relates to activities eligible for the taxonomy.
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The percentage of capital expenditure (Capex) for products or services related to business activities in accordance with the taxonomy.
Substantial contribution criteria DNSH criteria
('Does Not Significantly Harm')
Economic
activities
(1)
Code(s) (2)
Absolute Capex (3)
Proportion of CapEx (4)
Climate change mitigation
(5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change mitigation
(11)
Climate change
adaptation (12)
Water and marine
resources (13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum safeguards (17)
Proportio
n of
Taxonom
y- aligned
(A.1.) or -
eligible
(A.2.)
CapEx,
2024 (18)
Category (enabling
activity ) (19)
Category (transitional
activity) (20)
ths zł % Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T
A.
Taxono
my
eligible
activities
A.1.
Environ
mentally
sustaina
ble
activities
(Taxono
my-
aligned)
0 0%
CapEx of
environ
mentally
sustaina
ble
activities
(Taxono
my-
aligned)
(A.1)
0 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00%
Of which
enabling
0 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% E
Of which
transitio
nal
0 0,0% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% T
===== SIDA 131 =====
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Substantial contribution criteria DNSH criteria
('Does Not Significantly Harm')
Economic
activities
(1)
Code(s) (2)
Absolute Capex (3)
Proportion of CapEx (4)
Climate change mitigation
(5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change mitigation
(11)
Climate change
adaptation (12)
Water and marine
resources (13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum safeguards (17)
Proportio
n of
Taxonom
y- aligned
(A.1.) or -
eligible
(A.2.)
CapEx,
2024 (18)
Category (enabling
activity ) (19)
Category (transitional
activity) (20)
A.2
Taxono
my-
Eligible,
but not
environ
mentally
sustaina
ble
activities
(not
Taxono
my-
aligned
activities
)
EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL
Electricity
generatio
n using
solar
photovolt
aic
technolog
y
CCM 4.1 21 216 6,61% EL N/EL N/EL N/EL N/EL N/EL 9,73%
Electricity
generatio
n from
bioenergy
CCM 4.8 78 573 24,47% EL N/EL N/EL N/EL N/EL N/EL 8,84%
Storage
of
electricity
CCM 4.10 49 0,02% EL N/EL N/EL N/EL N/EL N/EL 4,09%
Manufact
ure of
biogas
and
biofuels
for use in
transport
CCM 4.13 2 754 0,86% EL N/EL N/EL N/EL N/EL N/EL 5,45%
===== SIDA 132 =====
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Substantial contribution criteria DNSH criteria
('Does Not Significantly Harm')
Economic
activities
(1)
Code(s) (2)
Absolute Capex (3)
Proportion of CapEx (4)
Climate change mitigation
(5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change mitigation
(11)
Climate change
adaptation (12)
Water and marine
resources (13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum safeguards (17)
Proportio
n of
Taxonom
y- aligned
(A.1.) or -
eligible
(A.2.)
CapEx,
2024 (18)
Category (enabling
activity ) (19)
Category (transitional
activity) (20)
and of
bioliquids
Cogenera
tion of
heat/cool
and
power
from
bioenergy
CCM 4.20 6 456 2,01% EL N/EL N/EL N/EL N/EL N/EL 1,50%
Productio
n of
heat/cool
from
bioenergy
CCM 4.24 367 0,11% EL N/EL N/EL N/EL N/EL N/EL 3,74%
Construct
ion,
extension
and
operation
of water
collection
,
treatment
and
supply
systems
CCM 5.1 2 582 0,80% EL N/EL N/EL N/EL N/EL N/EL 0,59%
Construct
ion,
extension
and
operation
of waste
water
collection
and
treatment
CCM 5.3 476 0,15% EL N/EL N/EL N/EL N/EL N/EL 0,43%
Transport
by
CCM 6.5 1 646 0,51% EL N/EL N/EL N/EL N/EL N/EL 0,16%
===== SIDA 133 =====
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Substantial contribution criteria DNSH criteria
('Does Not Significantly Harm')
Economic
activities
(1)
Code(s) (2)
Absolute Capex (3)
Proportion of CapEx (4)
Climate change mitigation
(5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change mitigation
(11)
Climate change
adaptation (12)
Water and marine
resources (13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum safeguards (17)
Proportio
n of
Taxonom
y- aligned
(A.1.) or -
eligible
(A.2.)
CapEx,
2024 (18)
Category (enabling
activity ) (19)
Category (transitional
activity) (20)
motorbike
s,
passenge
r cars
and light
commerci
al
vehicles
Infrastruc
ture for
rail
transport
CCM 6.14 572 0,18% EL N/EL N/EL N/EL N/EL N/EL 0,09%
Renovati
on of
existing
buildings
CCM 7.2 2 159 0,67% EL N/EL N/EL N/EL N/EL N/EL 2,24%
Installatio
n,
maintena
nce and
repair of
energy
efficiency
equipmen
t
CCM 7.3 3 472 1,08% EL N/EL N/EL N/EL N/EL N/EL 0,88%
Installatio
n,
maintena
nce and
repair of
charging
stations
for
electric
vehicles
in
buildings
(and
parking
CCM 7.4 442 0,14% EL N/EL N/EL N/EL N/EL N/EL 0,87%
===== SIDA 134 =====
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Substantial contribution criteria DNSH criteria
('Does Not Significantly Harm')
Economic
activities
(1)
Code(s) (2)
Absolute Capex (3)
Proportion of CapEx (4)
Climate change mitigation
(5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change mitigation
(11)
Climate change
adaptation (12)
Water and marine
resources (13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum safeguards (17)
Proportio
n of
Taxonom
y- aligned
(A.1.) or -
eligible
(A.2.)
CapEx,
2024 (18)
Category (enabling
activity ) (19)
Category (transitional
activity) (20)
spaces
attached
to
buildings)
Conserva
tion,
including
restoratio
n, of
habitats,
ecosyste
ms and
species
BIO 1.1 35 0,01% N/EL N/EL N/EL N/EL N/EL EL 0,00%
CapEx of
Taxono
my-
eligible,
but not
environ
mentally
sustaina
ble
activities
(not
Taxono
my-
aligned
activities
) (a.2)
120 799 37,61% 37,60% 0,00% 0,00% 0,00% 0,00% 0,01% 39,30%
CapEx of
taxonom
y-eligible
activities
(A.1 +
A.2)
120 799 37.61% 37.60% 0.00% 0.00% 0.00% 0.00% 0.01% 39,30%
B.
Taxono
my-non-
===== SIDA 135 =====
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Substantial contribution criteria DNSH criteria
('Does Not Significantly Harm')
Economic
activities
(1)
Code(s) (2)
Absolute Capex (3)
Proportion of CapEx (4)
Climate change mitigation
(5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change mitigation
(11)
Climate change
adaptation (12)
Water and marine
resources (13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum safeguards (17)
Proportio
n of
Taxonom
y- aligned
(A.1.) or -
eligible
(A.2.)
CapEx,
2024 (18)
Category (enabling
activity ) (19)
Category (transitional
activity) (20)
eligible
activities
CapEx of
Taxono
my-non-
eligible
activities
(B)
200 354 62.4%
Total
(A+B)
321 153 100.0%
===== SIDA 136 =====
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The Code constitutes the abbreviation of the relevant objective to which the economic activity is eligible to make a substantial contribution, as well as the section number of the activity in the relevant
Annex covering the objective, i.e.:
CCM — Climate Change Mitigation
CCA — Climate Change Adaptation
WTR — Water and Marine Resources
CE — Circular Economy
PPC — Pollution Prevention and Control
BIO — Biodiversity and ecosystems
Y – Yes, Taxonomy-eligible and Taxonomy-aligned activity with the relevant environmental objective
N – No, Taxonomy-eligible but not Taxonomy-aligned activity with the relevant environmental objective
N/EL – Not eligible, Taxonomy-non-eligible activity for the relevant environmental objective.
Non-financial undertakings shall also report the extent of eligibility and alignment per environmental objective, that includes alignment with each of environmental objectives for activities contributing
substantially to several objectives:
Proportion of CapEx/Total CapEx
Taxonomy aligned per objective Taxonomy eligible per objective
CCM 0,00% 37.60%
CCA 0,00% 0,00%
WTR 0,00% 0,00%
CE 0,00% 0,00%
PPC 0,00% 0,00%
BIO 0,00% 0.01%
EL – Taxonomy-eligible activity for the relevant objective
N/EL – Taxonomy-non-eligible activity for the relevant objective.
===== SIDA 137 =====
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OpEx – with respect to operating expenditure (OpEx), the basis was the costs of day-to-day servicing, repairs and
maintenance of the assets of the Group companies. They include such costs as: personnel costs of persons
responsible for maintenance and repairs, costs related to repairs and overhauls of equipment/installations,
operating leases and research and development costs. The part of OpEx that relates to activities eligible for
taxonomy has been assigned to the numerator. The OPEX numerator includes those denominator items that relate
to taxonomy-compliant or taxonomy-eligible activities. The vast majority were costs related to the ongoing
maintenance of property, plant and equipment (maintenance, repairs, conservation, etc.).
in thousand PLN December 31, 2025
Operational expenditure related to Taxonomy-eligible activities 42 336
Total operating expenses 219 317
Indicator of operational expenditure related to Taxonomy -eligible activities 19.30%
The percentage of operating expenses related to eligible activities is 19.30%.
In 2025, Arctic Paper's key Taxonomy-eligible operating expenditure was related to, m.in others, the
maintenance of the tall oil production facility at the pulp mill in Vallvik (activity 4.20).
The data used for the calculations came from the financial and accounting systems of the Arctic Paper Group's
operating units. Arctic Paper Group does not use estimates or allocations in the preparation of KPIs in accordance
with the EU Taxonomy.
The analysis showed that there is no need for a detailed disaggregation of KPIs among the operating units of
the Arctic Paper Group in accordance with point 1.2.2.3 of Annex I to Commission Delegated Regulation (EU)
2021/2178.
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Percentage of operating expenses (Opex) for products or services related to business activities in accordance with the taxono my
Substantial contribution criteria
DNSH criteria
('Does Not Significantly Harm')
Economic activities (1)
Code(s) (2)
Absolute OpEx
(3)
Proportion of
OpEx (4)
Climate change
mitigation (5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change
mitigation (11)
Climate change
adaptation (12)
Water and
marine
resources (13)
Pollution (14)
Circular
economy (15)
Biodiversity (16)
Minimum
safeguards (17) Proportion of
Taxonomy-
aligned (A.1.)
or -eligible
(A.2.) OpEx,
2024 (18)
Category
(enabling activity
) (19)
Category
(transitional
activity) (20)
ths
zł
% Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T
A. Taxonomy
eligible activities
A.1.
Environmentally
sustainable activities
(Taxonomy-aligned)
0 0%
OpEx of
environmentally
sustainable activities
(Taxonomy-aligned)
(A.1)
0 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00%
Of which enabling 0 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,000% E
Of which transitional 0 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% T
A.2 Taxonomy-
Eligible, but not
environmentally
sustainable activities
(not Taxonomy-
aligned activities)
EL; N/EL EL;
N/EL
EL;
N/EL
EL;
N/EL
EL; N/EL EL;
N/EL
Forest management CCM
1.3
2 132 0,97% EL N/EL N/EL N/EL N/EL N/EL 3,48%
Electricity generation
using solar
photovoltaic
technology
CCM
4.1
80 0,04% EL N/EL N/EL N/EL N/EL N/EL 0,00%
Electricity generation
from hydropower
CCM
4.5
216 0,10% EL N/EL N/EL N/EL N/EL N/EL 1,10%
===== SIDA 139 =====
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Substantial contribution criteria
DNSH criteria
('Does Not Significantly Harm')
Economic activities (1)
Code(s) (2)
Absolute OpEx
(3)
Proportion of
OpEx (4)
Climate change
mitigation (5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change
mitigation (11)
Climate change
adaptation (12)
Water and
marine
resources (13)
Pollution (14)
Circular
economy (15)
Biodiversity (16)
Minimum
safeguards (17) Proportion of
Taxonomy-
aligned (A.1.)
or -eligible
(A.2.) OpEx,
2024 (18)
Category
(enabling activity
) (19)
Category
(transitional
activity) (20)
Electricity generation
from bioenergy
CCM
4.8
172 0,08% EL N/EL N/EL N/EL N/EL N/EL 0,97%
Manufacture of biogas
and biofuels for use in
transport and of
bioliquids
CCM
4.13
524 0,24% EL N/EL N/EL N/EL N/EL N/EL 0,68%
Cogeneration of
heat/cool and power
from bioenergy
CCM
4.20
13
297
6,06% EL N/EL N/EL N/EL N/EL N/EL 19,62%
Production of
heat/cool from
bioenergy
CCM
4.24
1 840 0,84% EL N/EL N/EL N/EL N/EL N/EL 0,00%
Construction,
extension and
operation of water
collection, treatment
and supply systems
CCM
5.1
5 692 2,60% EL N/EL N/EL N/EL N/EL N/EL 9,30%
Construction,
extension and
operation of waste
water collection and
treatment
CCM
5.3
3 601 1,64% EL N/EL N/EL N/EL N/EL N/EL 5,55%
Material recovery from
non-hazardous waste
CCM
5.9
19 0,01% EL N/EL N/EL N/EL N/EL N/EL 0,00%
Transport by
motorbikes, passenger
cars and light
commercial vehicles
CCM
6.5
225 0,10% EL N/EL N/EL N/EL N/EL N/EL 0,91%
Infrastructure for rail
transport
CCM
6.14
70 0,03% EL N/EL N/EL N/EL N/EL N/EL 3,54%
Renovation of existing
buildings
CCM
7.2
2 973 1,36% EL N/EL N/EL N/EL N/EL N/EL 6,24%
===== SIDA 140 =====
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Substantial contribution criteria
DNSH criteria
('Does Not Significantly Harm')
Economic activities (1)
Code(s) (2)
Absolute OpEx
(3)
Proportion of
OpEx (4)
Climate change
mitigation (5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change
mitigation (11)
Climate change
adaptation (12)
Water and
marine
resources (13)
Pollution (14)
Circular
economy (15)
Biodiversity (16)
Minimum
safeguards (17) Proportion of
Taxonomy-
aligned (A.1.)
or -eligible
(A.2.) OpEx,
2024 (18)
Category
(enabling activity
) (19)
Category
(transitional
activity) (20)
Installation,
maintenance and
repair of energy
efficiency equipment
CCM
7.3
263 0,12% EL N/EL N/EL N/EL N/EL N/EL 0,70%
Installation,
maintenance and
repair of charging
stations for electric
vehicles in buildings
(and parking spaces
attached to buildings)
CCM
7.4
11
134
5,08% EL N/EL N/EL N/EL N/EL N/EL 0,02%
Manufacture,
installation and
associated services for
leakage control
technologies enabling
leakage reduction and
prevention in water
supply systems
WTR
1.1
82 0,04% N/EL N/EL EL N/EL N/EL N/EL 0,05%
Conservation,
including restoration,
of habitats,
ecosystems and
species
BIO
1.1
15 0,01% N/EL N/EL N/EL N/EL N/EL EL 0,00%
OpEx of Taxonomy-
eligible, but not
environmentally
sustainable activities
(not Taxonomy-
aligned activities)
(a.2)
42
336
19,30% 19,25% 0,00% 0,04% 0,00% 0,00% 0,01% 57,67%
OpEx of taxonomy-
eligible activities
(A.1 + A.2)
42
336
19,30% 19,25% 0,00% 0,04% 0,00% 0,00% 0,01% 57,67%
B. Taxonomy-non-
eligible activities
===== SIDA 141 =====
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Substantial contribution criteria
DNSH criteria
('Does Not Significantly Harm')
Economic activities (1)
Code(s) (2)
Absolute OpEx
(3)
Proportion of
OpEx (4)
Climate change
mitigation (5)
Climate change
adaptation (6)
Water (7)
Pollution (8)
Circular
economy (9)
Biodiversity (10)
Climate change
mitigation (11)
Climate change
adaptation (12)
Water and
marine
resources (13)
Pollution (14)
Circular
economy (15)
Biodiversity (16)
Minimum
safeguards (17) Proportion of
Taxonomy-
aligned (A.1.)
or -eligible
(A.2.) OpEx,
2024 (18)
Category
(enabling activity
) (19)
Category
(transitional
activity) (20)
OpEx of Taxonomy-
non-eligible activities
(B)
176
981
80.7%
Total (A+B) 219
317
100.00%
The Code constitutes the abbreviation of the relevant objective to which the economic activity is eligible to make a substantial
contribution, as well as the section number of the activity in the relevant Annex covering the objective, i.e.:
CCM — Climate Change Mitigation
CCA — Climate Change Adaptation
WTR — Water and Marine Resources
CE — Circular Economy
PPC — Pollution Prevention and Control
BIO — Biodiversity and ecosystems
Y – Yes, Taxonomy-eligible and Taxonomy-aligned activity with the relevant environmental objective
N – No, Taxonomy-eligible but not Taxonomy-aligned activity with the relevant environmental objective
N/EL – Not eligible, Taxonomy-non-eligible activity for the relevant environmental objective.
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Non-financial undertakings shall also report the extent of eligibility and alignment per environmental objective, that includes alignment with each of environmental objectives for activities contributing
substantially to several objectives:
Proportion of OpEx/Total OpEx
Taxonomy aligned per objective Taxonomy eligible per objective
CCM 0,00% 19.25%
CCA 0,00% 0,00%
WTR 0,00% 0.04%
CE 0,00% 0,00%
PPC 0,00% 0,00%
BIO 0,00% 0.01%
EL – Taxonomy-eligible activity for the relevant objective
N/EL – Taxonomy-non-eligible activity for the relevant objective.
===== SIDA 143 =====
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Activities of the Arctic Paper SA Group related to nuclear energy and natural gas in the context of the EU Environmental
Taxonomy
Disclosure in accordance with Annex III of Commission Delegated Regulation (EU) 2022/1214, supplementing
Commission Delegated Regulation (EU) 2021/2178 with Annex XII on standard templates for the disclosure of
information referred to in Article 8(6) and (7). – i.e. for activities related to nuclear energy and natural gas.
Nuclear energy related activities
1 The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative elec tricity
generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle.
No
2 The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produc e
electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen producti on, as well as
their safety upgrades, using best available technologies.
No
3 The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electric ity or process
heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclea r energy, as well as
their safety upgrades.
No
Fossil gas related activities
1 The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that pr oduce
electricity using fossil gaseous fuels.
No
2 The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and p ower
generation facilities using fossil gaseous fuels.
No
3 The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilitie s that
produce heat/cool using fossil gaseous fuels.
No
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3. SOCIAL INFORMATION
ESRS S1 Own workforce
S1 SBM-3 material impacts and risks and their interrelationship with the strategy and with the business model
[SBM-3 48b, c, f] The material impacts and risks described in relation to the Group’s own employee resources
are linked to the Arctic Paper Group’s business model through the manufacturing nature of its operations and its
reliance on human capital. The Group focuses on building employee confidence, respecting diversity and providing
safe and stable working conditions, including shift work. These actions promote long-term employment, allow
knowledge and experience to accumulate in the organisation and translate into higher operational efficiency and
product quality. Attention to security, job stability and competitive salaries promotes employee retention. The need
to ensure safety and proper working conditions requires constant monitoring and investment in HR processes and
safety systems. These activities enable the development of human capital, which is a key element of the Group’s
business model. In the long term, maintaining a competent and committed workforce supports operational stability
and production quality. As a whole, the employee resource strategy supports both operational efficiency and the
attractiveness of the company in the labour market.
The positive impacts identified are the result of a trust-building approach that manifests itself in the provision of
good working conditions that take into account employment stability, competitive salaries, high safety standards
and dialogue with employees. The adverse impacts are mainly related to the specific nature of the Group’s
operations, i.e. manufacturing activities being an environment where there is a risk of accidents and potentially
more demanding conditions related to physical, shift and night work. In addition, due to the nature of the industry
and the location of its production plants, the Arctic Paper Group identifies the risk of a potential shortage of
employees with specific competencies in the region and the low proportion of women in managerial positions,
which the Group has addressed in the Diversity Policy of the Management Board and the Supervisory Board of
Arctic Paper, aiming to have a proportion of women in the bodies of no less than 30%. This aspect will be taken
into account in future recruitment processes.
[S1 SBM-3, 14, 15, 16] All persons who are owned employee resources of the Arctic Paper Group that may be
materially affected by it are included in the scope of disclosure under ESRS 2. These material impacts and risks
include impacts related to the Arctic Paper Group’s own operations and value chain, including through its products
or services and business relationships, to the extent that the Group has access to such information. The
predominant group of employees significantly affected by the Group’s activities are those employed directly by the
Arctic Paper Group, mainly in production and operational areas, including sales, logistics, finance, HR, among
others. The Group does little work with employees classified by the ESRS standard as non-owner employees. At
the time of publication of this Statement, the Arctic Paper Group has not yet developed a Climate Change
Mitigation Transition Plan and therefore cannot make a description of the material impact on employees that may
result from transition plans to reduce adverse environmental impacts and achieve climate-neutral operations. In the
course of the work on the double materiality analysis, the Arctic Paper Group did not identify the presence of
material risks of forced or compulsory labour or child labour in its business or value chain.
S1-1 Policies related to own workforce
[S1-1, 21, AR12, MDR-P, 65] The Arctic Paper Group manages its material impacts and risks on its own employee
resources based on the following policies:
• The Arctic Paper Group’s Value Chain Code of Conduct contains the Arctic Paper Group’s core principles of
conduct, ethics and values such as compliance with the law, reporting of potential violations, respect for
human rights including working conditions, health and safety rules, protection against discrimination, respect
for the environment. The Code addresses the following important issues: job security, working time,
adequate pay, social dialogue, health and safety at work, measures to prevent violence and harassment in
the workplace, work-life balance;
• Diversity policy; Management Board and Supervisory Board members and employees (promotes openness
to diversity and the provision of equal opportunities in recruitment and development, irrespective of
characteristics such as, inter alia, age, gender, nationality, disability). The policy addresses the following
important issues: training and skills development, diversity, gender equality and equal pay for work of equal
value, employment and integration of people with disabilities;
• Remuneration policy for Management Board and Supervisory Board members (principles for the
remuneration of top management employees in the Group, such as description of the components of
remuneration for Management Board and Supervisory Board members, general principles for the award of
variable remuneration for members of the Management Boards, prevention of conflicts of interest). In
addition Arctic Paper Group entities have in place remuneration regulations in accordance with the legal
provisions in force in a given country of specific entity;
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• Sustainability Policy (explains the approach to managing sustainability topics in the Arctic Paper Group,
including general principles for managing environmental, social and business impacts). It addresses the
following material issues: health and safety at work, measures to prevent violence and harassment in the
workplace;
• The Whistleblowing and Whistleblower Protection Policy describes the approach to business ethics and
explains the ways and channels for whistleblowing. Addresses the following important issue: measures to
prevent violence and harassment in the workplace.
The scope of the policies covers the operations of the Arctic Paper Group, excluding the Rottneros Group. The
Group Management is responsible for implementing the provisions of the policies. The policies adopted do not refer
to third-party standards or initiatives. In preparing the content of the documents, the interests and opinions of the
Group’s stakeholders were taken into account. The Group makes the regulations available by posting them on its
website and on the internal communication channels of each organisational unit.
The Rottneros Group manages its material impacts and risks on its own workforce on the basis of the following
policies:
• Code of Conduct (description of Rottneros’s key principles and values, including diversity among
employees). The Code addresses the following important issues: health and safety at work, gender equality
and equal pay for work of equal value, employment and integration of people with disabilities, social
dialogue;
• Sustainability policy (Rottneros’s principles of environmental and social responsibility). The policy addresses
the following important issues of training and skills development;
• Diversity policy of the Management Board (principles for maintaining diversity in the management and
supervisory bodies). The policy addresses the following important issues gender equality and equal pay for
work of equal value;
• The Whistleblowing and Whistleblower Protection Policy (anonymous whistleblowing). The policy addresses
the following material issues: measures to prevent violence and harassment in the workplace;
• Working environment policy (concerning working conditions). The policy addresses the following material
issues: health and safety, training and skills development,
Rottneros Group policies do not address the following important issues: job security, working time, adequate pay,
work-life balance.
The scope of the policies covers the activities of the Rottneros Group. The Group Management is responsible for
implementing the provisions of the policies. The policies adopted do not refer to third-party standards or initiatives.
In preparing the content of the documents, the interests and opinions of the Group’s stakeholders were taken into
account. The Group makes the regulations available by posting them on its website and on the internal
communication channels of each organisational unit.
[S1-1 19, 20] [MDR-P, 65] The Arctic Paper Group’s commitment to respecting human rights is reflected throughout
the Group’s operations and business relationships. We develop and implement our policies and internal regulations
while adhering to international standards and initiatives as well as local regulations, including but not limited to:
• UN Global Compact principles;
• OECD Guidelines for Multinational Enterprises;
• UN Guiding Principles on Business and Human Rights;
• UN Universal Declaration of Human Rights;
• Charter of Fundamental Rights of the European Union;
• International Labour Organisation Convention.
The Arctic Paper Group respects human rights, individual rights, and the dignity of employees and all third parties.
The Arctic Paper Group Value Chain Code of Conduct is based on laws and good business practices, which means
that any deviation from the principles described in this document may lead to both disciplinary action and legal
action against violators. If an employee notices violations of the Code of Conduct or any other Arctic Paper Group
policies, they must discuss their concerns with their superior or the relevant department within the company, i.e. the
HR or legal department. If an employee does not feel comfortable reporting the above violations to a supervisor,
they can use an anonymous whistleblowing service via a web form or dedicated phone line.
[S1-1, 22, 24] [AR 15, 16] The Arctic Paper Group’s policies and internal regulations, and in particular the Arctic
Paper Group Code of Conduct for the Value Chain, explicitly address the prohibition of human trafficking, forced or
compulsory labour and child labour. The principles expressed in the Arctic Paper Group Code of Conduct for the
value chain are intended to aim to eliminate discrimination (including harassment), promote equality of opportunity
and otherwise enhance diversity and inclusion. Any discrimination on the basis of racial and ethnic origin, gender,
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sexual orientation, gender identity, disability, age, religion, political opinion, national or social origin is stigmatised in
the Arctic Paper Group’s business and is not tolerated in our operations or those of our value chain entities.
[S1-1, 23] Each Arctic Paper Group organisational unit has implemented its own health and safety policy,
supplemented by appropriate policies and procedures..
[S1-1, 24] The aforementioned regulations focus on the inclusion of all groups of employees, do not formulate
specific inclusion obligations for people from vulnerable groups within their own workforce, and are implemented
with respect for the principles of diversity and inclusion.
The Arctic Paper Group reviews all policies, rules and guidelines at least once every two years.
S1-2 Procedures for working with own workforce and workers’ representatives on matters of impact
[S1-2 25, S1-4] The Arctic Paper Group actively and continuously engages and dialogues with its employees and
their representatives through various communication channels. Employees have the opportunity to express their
opinions and evaluations of the Group’s activities by, among other things, participating in surveys, during periodic
discussions with their superiors, by submitting proposals to the “Suggestion Boxes”, or anonymously by using the
whistleblowing service (whistleblower service). The Group assesses the effectiveness of cooperation with
employees through periodic employee satisfaction surveys and through ongoing communication with employees.
[S1-2, 27a-27e, 28, AR18-24] The Arctic Paper Group has a European Works Council (EWC) that meets twice a
year. The EWC covers all employees (excluding employees of Rottneros) in all EU and EEA member states. The
EWC is committed to creating the conditions for greater employee participation among all Arctic Paper employees.
Responsibility for organising and conducting employee engagement rests with the HR managers of each
organisational unit. The Group Management Board, supported by the managers of the Group’s various
organisational divisions, is responsible for implementing the results and conclusions of the communication with
employees.
S1-3 Processes for remediating the effects of adverse impacts and channels for raising concerns by own
workforce.
[S1-3 32, 33] If an employee observes a violation of the Code of Conduct or other Arctic Paper Group policies and
rules, he or she should discuss his or her concerns with his or her supervisor or the relevant department within the
unit, e.g. HR or Legal. If an employee does not feel comfortable reporting the above violations to a supervisor, they
can use the anonymous whistleblowing service. Through a publicly accessible whistleblowing system, via text or
voice message, anyone can report suspected serious wrongdoing that is inconsistent with the Arctic Paper Group’s
values. Reports can be submitted in one of three languages (Polish, English and Swedish) at: WhistleB,
Whistleblower Centre.
At the same time, the Arctic Paper Group conducts outreach activities to disseminate knowledge and raise
awareness among employees and contractors on the principles set out in the Whistleblowing and Whistleblower
Protection Policy by providing information on whistleblower protection. Every report, signal from an employee is
dealt with conscientiously and impartially.
All communications received are treated as fully confidential and those working on them shall be bound in
writing to maintain confidentiality. The employees responsible for receiving and processing reports keep track of the
inflow of applications by accessing the system. Receipt of the report is acknowledged within 7 days of receipt and
processed within 3 months, and the whistleblower is then informed of the outcome.
The Arctic Paper Group, together with all of its units, is committed to preventing and responding to retaliation
against whistleblowers including discrimination, mobbing and other undesirable behaviour in the work environment.
The Arctic Paper Group briefed employees on the implementation of channels for reporting violations and
conducted online training on reporting issues. The Arctic Paper Group has not assessed whether individuals within
its own workforce are aware of and trust the presence of these structures or processes as a means of raising their
concerns or needs and addressing them.
S1-4 Actions taken in relation to material impacts on own workforce and approaches applied to manage
material risks and to seize material opportunities related to own workforce, as well as the effectiveness of
those actions.
[S1-4, 37, 38, 40, AR 42] [MDR-A 68] The Management Board of the Arctic Paper Group and the managers of the
Group’s individual organisational units are responsible for taking action regarding material impacts on their own
employee resources.
The actions taken in 2025 mainly address the identified adverse real-world impacts and risks in the areas of
health and safety and diversity. For the other identified positive impacts, the Arctic Paper Group has continued with
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its existing efforts, including offering competitive remuneration, offering employment with permanent contracts and
ensuring a functioning whistleblowing channel.
WORKING TIME
In accordance with the applicable working time regulations and the Code of Conduct in the value chain, the Arctic
Paper Group pays particular attention to compliance with the applicable working hours and minimizes the amount
of overtime work, thus reducing the possibility of accidents caused by fatigue.
ADEQUATE PAY
The Arctic Paper Group awards salaries commensurate with the positions held and competencies held, in
accordance with the Group's remuneration policies and regulations. When determining salaries, HR departments
review the prevailing market rates for specific job categories and locations.
WORK-LIFE BALANCE
The Arctic Paper Group promotes the mental and physical well-being of its employees by subsidizing
comprehensive healthcare, which includes co-financing tests as part of preventive programs, including cancer
screenings. The Group offers hybrid work options for administrative employees living outside the locations where
the Group's organizational units are located.
OCCUPATIONAL HEALTH AND SAFETY.
In order to prevent occupational safety hazards, the following actions are being taken throughout the reporting
period to prevent accidents and incidents with the potential to result in actual adverse consequences:
Encouraging employees to report risky situations in order to identify and prevent potential hazards at production
facilities:
Observation of potential risks by employees and reporting them to a common system to strengthen cooperation
in risk mitigation across all Group production facilities (PIA system). In 2025, 1,035 observations were reported,
each subject to root cause analysis. All risk observations are investigated and addressed (959 observations in
2024). The extent of action taken depends on the level of risk identified. This could be a minor adjustment to
minimise risk or a more advanced action requiring an update of procedures;
Submission by employees of proposals to improve and serve to increase work safety to the “Suggestion Box”
(122 safety proposals registered in 2025, 160 proposals in 2024), which are then analysed and approved for
implementation by the managing directors of the various organisational units.
Take corrective action following reported risk situations to eliminate potential risks:
Meeting targets arising from identified potential safety risks – in 2025 50 safety-related improvements were
implemented at Arctic Paper Kostrzyn (61 in 2024); 470 corrective actions were implemented at Arctic Paper
Munkedals (204 in 2024) and 270 at Arctic Paper Grycksbo (610 in 2024);
Updating safety procedures – regular reviews of existing safety procedures take place at all Group production
facilities and updates are made where necessary; a new fire prevention procedure has been implemented at Arctic
Paper Grycksbo – management or designated personnel are required to check fire safety equipment and assess
risk areas four times a year, and report deficiencies and take action where necessary; in addition, a management
“walk-through” has been carried out to encourage employees to pay more attention to and improve safety issues in
the organisation.
Safety training for employees:
The Values-Based Leadership programme for managers covered issues related to creating a safety culture in
Group companies;
At Arctic Paper Kostrzyn, safety and fire protection training was conducted for all employees in the production
area, as well as competency-enhancing training for the company’s paramedics; emergency drills were conducted
for employees; and an instructional video on safety in the factory area was prepared for new employees and
visitors;
At Arctic Paper Grycksbo, in addition to standard training, training was provided on topics such as fire and
safety hazards and CPR;
At Arctic Paper Munkedals, as part of a programme to develop safety competencies in selected positions
including electricians, technicians, maintenance workers, machine operators and maintenance supervisors, Lock
Out Tag Out (LOTO) training was provided teaching how to safely cut off, lock out and tag out energy sources
before servicing machinery. As part of this training, workers practised how to avoid accidents by physically securing
and marking equipment, preventing it from accidentally starting up during repairs or maintenance.
DIVERSITY AND EMPLOYMENT STRUCTURE
Activities to activate and encourage younger people and women to apply for positions in the organisation to
mitigate the risk of underemployment, increasing employee turnover and lower diversity in the workforce – for
example, at Rottneros companies, all applicants are invited to job interviews.
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Competence mapping and structured development of competences as part of succession planning for individual
posts.
Participation in local job fairs as well as events organised by schools and colleges. The organisation of open
days in the Kostrzyn factory for school pupils, presentations in schools and the organisation of traineeships in the
factory The activities undertaken have resulted in the employment of women in management positions in areas
such as IT, maintenance.
Arctic Paper Kostrzyn promotes employee referral program that encourages and rewards current employees
who will recruit new employees.
TRAINING AND SKILLS DEVELOPMENT
The Group responds to the training needs of its employees by providing comprehensive training and development
opportunities through access to training.
FAVORABLE WORKING CONDITIONS FOR PEOPLE WITH DISABILITIES
Due to its operational profile involving the production of paper and pulp, the Arctic Paper Group has limited
opportunities to offer employment to people with disabilities. As part of the recruitment process for administrative
positions, hybrid or remote work options are offered, thus meeting the needs of people with disabilities.
[S1-4 38 43, AR 38, 39] The effectiveness of the measures is monitored through engagement and dialogue with
employees, e.g. through surveys, periodic interviews. None of the activities listed entail plans that would require
significant investment or operational expenditure.
[S1-4, AR 43] As at the date of publication of the Sustainability Statement, the Arctic Paper Group has not yet
developed a climate transition plan and, therefore, is not able to describe measures taken to mitigate any adverse
impacts that may arise from transition plans aimed at reducing adverse environmental impacts and achieving
greener and climate-neutral operations on its own workforce.
S1-5 Targets for managing material adverse impacts, enhancing positive impacts and managing material
risks and opportunities
DIVERSITY
[S1-5 46] [MDR-T 80] In the Management and Supervisory Board Diversity Policy adopted in 2021, the Arctic Paper
Group committed to strive to achieve and maintain the proportion of women on the Group’s Management and
Supervisory Boards at no less than 30% and to take this aspect into account in future recruitment processes. From
2022 the Arctic Paper Group has met this target and it is monitored at the end of each reporting period. At the end
of 2025, the ratio was 30%, as in 2024.
The proportion of women in management positions was calculated on the basis of the number of all members of
the Management Board, Supervisory Board and management team.
NUMBER OF ACCIDENTS AT WORK
The Arctic Paper Group (excluding Rottneros) has set an accident frequency rate target (Lost Time Injury Rate
“LTIR” per million working hours) of less than 4 in 2021 with a time horizon of 2025. This objective was monitored
on an ongoing basis when each accident event in the Group was recorded. The Arctic Paper Group will develop an
updated target for this area in the next reporting period.
[MDR-T 81] For the remaining identified material impacts and risks, the Arctic Paper Group has not introduced
additional targets to manage them.
The Arctic Paper Group will consider introducing the above targets as shared between Arctic Paper and
Rottneros in future years.
Own workforce or workers’ representatives were not directly involved in setting targets.
S1-6 Characteristics of the undertaking’s employees
[S1-6, 50] The majority of the Arctic Paper Group’s own employees are employed under a contract of employment
for an indefinite period. Fixed-term contracts are usually used during the probationary period of employment. Most
of the Arctic Paper Group’s own employees are employed full-time.
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Table – employment information by gender
Gender Number of employees in 2025 Number of employees in 2024
Men 1,122 1,198
Women 377 386
Other 0 0
Not reported 0 0
Total employees 1,499 1,584
Table – number of employees in countries where the company has at least 50 employees, representing at least
10% of its total workforce.
Country Number of employees in 2025 Number of employees in 2024
Sweden 941 1,045
Poland 520 500
Other 38 39
Total 1,499 1,584
The number of employees is given in terms of persons. Data on the number of employees is given as at the end of
the reporting period, including those employed as replacements. The number of employees stated is consistent
with the data presented in the financial statements.
In 2025, the number of employees in the Arctic Paper Group decreased by approx. 5% compared to the previous
year, mainly due to employee reductions at the Rottneros companies.
Table – information on employees by type of employment contract and working hours, broken down by gender
[S1-6, 50b, AR55]
Category Reporting period Women Men Other Not disclosed Total
Number of employees 2025 377 1,122 0 0 1,499
2024 386 1,198 0 0 1,584
Number of permanent
employees
2025 363 1,096 0 0 1,459
2024 349 1,099 0 0 1,448
Number of temporary
employees
2025 14 26 0 0 40
2024 37 88 0 0 125
Number of employees not
guaranteed working hours
2025 0 0 0 0 0
2024 0 11 0 0 11
Number of full-time
employees
2025 374 1,114 0 0 1,488
2024 383 1,182 0 0 1,565
Number of part-time
employees
2025 3 8 0 0 11
2024 3 16 0 0 19
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Table – total number of employees who left the company during the reporting period and employee turnover rate [S1-6, 50c, AR59].
Departures/turnover 2025 2024
Number of employees who left 145 144
Turnover rate 9.67% 9.1%
Turnover rate = (number of employees who left/ number of employees as at 31 December of the year in question) x 100%
S1-9 Diversity metrics
[S1-9, AR71] The diversity of our workforce is one of the factors contributing to the development of our
organisation. Different professional experience or backgrounds encourage the exchange of ideas that can
contribute to the improvement of our organisation.
The Arctic Paper Group includes in the definition of the category of top-level employees the members of the
Management Board (3 persons) and the members of the advisory team of the Management Board of the Arctic
Paper Group (7 persons, including 3 members of the Management Board).
Table – [S1-9, 66a, 66b]
Category Reporting period Women Men
Number of employees (number of
persons) at top management level
2025 1 6
2024 1 6
Percentage of employees at top
management level
2025 0.27% 0.53%
2024 0.26% 0.50%
Number of workers (persons) under 30
years of age
2025 52 153
Percentage of workers under 30 years of
age
13.79% 13.64%
Number of employees (number of
people) aged between 30 and 50
194 523
Percentage of employees aged between
30 and 50
51,46% 46.61%
Number of employees (number of
people) aged over 50
131 446
Percentage of employees aged over 50 34.7% 39.8%
Total employees 377 1122
Number of workers (persons) under 30
years of age
2024 51 166
Percentage of workers under 30 years of
age
13.21% 13.86%
Number of employees (number of
people) aged between 30 and 50
204 533
Percentage of employees aged between
30 and 50
52.85% 44.49%
Number of employees (number of
people) aged over 50
131 499
Percentage of employees aged over 50 33.9% 41.7%
Total employees 386 1198
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S1-10 Adequate wage
[S1-10, 69] All Arctic Paper Group employees, regardless of geographic location of employment, receive adequate
wages. An adequate wage is a wage that ensures that the needs of the worker and his or her family are met in the
light of national economic and social conditions.
S1-14 Health and safety metrics
[S1-14 88, AR 89-91] The Arctic Paper Group is pursuing a systemic approach to safety. We train our employees
every year and ensure that our management is well prepared to deal with emergencies in this area. We have
implemented programmes for risk assessment and reporting.
100% of the Arctic Paper Group’s own employees are covered by a health and safety management system
based on legal requirements and/or recognised standards or guidelines.
The most important tool for enhancing safety is the risk assessment carried out before the start-up of any new
machine or the implementation of a new working method.
If systemic problems are detected during the production process, we introduce targeted, continuous action
plans. In addition, trained rescue teams are in place at all our production facilities. We aim to minimise the number
of light and serious accidents at workplaces. Our paper mills have an occupational health service, as well as rescue
teams trained to respond to emergencies. Some of our employees also belong to local fire departments, where
they have been trained to respond to internal and external incidents and accidents. We carefully analyse all health
and safety incidents raised by our employees, and take actions to avoid serious consequences in the future.
In 2025, in spite of the preventive actions implemented, such as observing risk behaviour, monitoring it and
introducing corrective actions (described in S1-4), the number of accidents has increased. Injuries occur mainly due
to human error. Therefore, it is very important to change behaviour and create a culture of a safe workplace and to
create awareness among workers about possible hazards at production facilities.
2025 2024
Accidents and injuries among workers
Minor 40 32
Severe 2 2
Fatal 0 0
Total 42 34
Accidents and injuries among employees of subcontractors working on company premises
Minor 6 6
Severe 0 0
Fatal 0 0
Total 6 6
[S1-14, 88c, AR 89-91] The Lost Time Injury Rate (LTIR) for own employees in 2025 was 17.07, an increase
compared to 14.7 in 2024. The Lost Time Injury Rate (LTIR) is the number of lost time accidents per million hours
worked.
In order to improve internal risk monitoring, we use an additional classification of accidents distinguishing two
categories:
• Light accidents: Minor accidents: work-related incidents that did not result in temporary incapacity for work or
resulted in sick leave lasting up to 7 calendar days.
• Serious accidents: work-related incidents resulting in sick leave lasting more than 7 calendar days or leading
to permanent disability.
This classification is in addition to our standard reporting of lost time injuries (LTIs), which are defined as any work-
related injury that results in an employee being unable to return to work the day after the incident, according to
international standards such as ILO guidelines.
By integrating this approach, we aim to go beyond compliance and continuously improve health and safety at all
operational levels.
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S1-16 Remuneration metrics (pay gap and total remuneration)
The Arctic Paper Group remunerates employees according to their position, qualifications, experience and
performance, regardless of diversity factors.
2025 2024
Average level of gross hourly pay for men PLN 134 PLN 130 S1-16, 97a, AR 98 – AR 100
average level of gross hourly pay for
women
PLN 116.9 PLN 121 S1-16, 97a, AR 98 – AR 100
Gender pay gap – the pay gap 13% 7% S1-16, 97a, AR 98 – AR 100
Ratio of top earner’s salary to median
salary
17.81 10.48 S1-16, 97b, AR 101 – AR 102
THE WAGE GAP WAS CALCULATED USING THE FORMULA:
((Average level of gross hourly wage of male employees – average level of gross hourly wage of female
employees) / Average level of gross hourly wage of male employees)) *100.
The calculation takes into account average salary levels for men and women across the Arctic Paper Group.
The following factors have contributed to the increase in the wage gap in 2025:
• the start of the employment of women in lower positions in the packaging production company in Poland,
Kostrzyn Packaging;
• resignations of women in senior positions;
• use of the benchmark in the calculation for sales organisation positions for 2024.
RATIO OF TOP EARNER’S SALARY TO MEDIAN SALARY
Calculated as: Annual total remuneration of the highest paid person in the Arctic Paper Group divided by median
annual total employee remuneration (excluding the highest paid person).
In calculating the remuneration ratio, all employees were taken into account, regardless of the geographical
location of the individual units in the Arctic Paper Group where the employees are employed.
In order to determine the top earner, all salaries for the reporting period were reviewed. The full gross salaries of
the top earner, including base salary, bonuses and taxed benefits (such as car allowance) paid during the reporting
period were analysed.
The median salary was calculated based on the sum of the products of the hourly rate, the number of hours per
month and the number of months.
For Rottneros Latvia and the Arctic Paper sales organisations, available estimated data and market benchmarks
were used to calculate the median of total remuneration.
Remuneration values expressed in currencies other than PLN have been converted using the exchange rate
adopted in the balance sheet section of the financial statements.
S1-17 Incidents, complaints and serious impact on respect for human rights
In 2025, the Arctic Paper Group reported no incidents, labour-related complaints or serious human rights impacts
among its employees. The Arctic Paper Group was not a party to the proceedings in this regard.
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2025 2024
Number of cases of discrimination 0 0
Number of complaints made through channels to own employees to express concerns 0 5
Number of complaints submitted to OECD National Contact Points for Multinational
Enterprises
0 0
Number of serious human rights problems and incidents related to own workforce 0 0
Number of serious human rights issues and incidents related to own workforce that
constitute non-compliance with the UN Guiding Principles and the OECD Guidelines
for Multinational Enterprises
0 0
Number of serious human rights cases in which the company secured remedies for
those affected
0 0
Amount of significant fines, penalties and compensation for serious human rights
issues and incidents related to own workforce
0 0
Amount of material penalties, fines and reparations for damage caused by
infringements of social and human rights factors
0 0
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ESRS G1 Business conduct
The material impacts and opportunities described in terms of business conduct are linked to the Arctic Paper
Group’s business model through the Group’s ethics and values, which shape the way employees are managed and
the relationships with suppliers. A strong ethical culture and applicable codes of conduct support the selection of
partners that meet high ethical standards, the building of lasting relationships based on trust, the stable
development of the company and its competitive market position. An effective whistleblowing system and
whistleblower protection throughout the value chain ensures regulatory compliance and supports risk management.
G1-1 Business conduct policies and corporate culture
[G1-1, 7, 9] [MDR-P 65] We conduct our business in a stable, long-term and trustworthy manner, building on
established and trusted relationships with our stakeholders. Our core values include:
Transparency – We operate steadily, transparently and openly, following a long-term plan for how we operate,
how we think and how others perceive us. We ensure transparency across all our business operations are
transparent – from sustainable sourcing, the production and delivery of our products, to the communication of our
results to external stakeholders.
High-quality products and services – The Arctic Paper Group offers products and services that meet specific
quality requirements. These enable the implementation of client projects, including those with increased technical
requirements, using available technologies and operational solutions.
Respect for natural resources – We protect natural resources and continuously strive to create a healthy
balance between stakeholder needs, production and operational activities.
The Arctic Paper Group’s principles and values are outlined in the Code of Conduct in the value chain, which
applies to every stakeholder in the Group and all areas of its operations. It commits the entire Group and its
employees to ethical conduct as well as to acting in full compliance with the laws and regulations applicable to the
Group’s operations. Policies that complement the provisions of the Code ensure that the principles material to the
Group are duly understood and adhered to.
The Arctic Paper Group’s policies on business conduct:
• The Arctic Paper Group Value Chain Code of Conduct – sets out the Arctic Paper Group’s core principles of
conduct, ethics and values that apply to all employees, suppliers and associates of the Group;
• Sustainability Policy – sets out the general principles for approaching ESG issues;
• The Whistleblowing and Whistleblower Protection Policy – sets out the rules for reporting violations, dealing
with them and providing protection for whistleblowers.
Policies in place at Rottneros Group:
• Code of Conduct – sets out the basic principles of conduct, ethics and values;
• Anti-corruption and anti-competition policy – sets out rules related to the prevention of corruption and
promotes the principles of fair competition;
• The Whistleblowing and Whistleblower Protection Policy – sets out the rules for reporting violations, dealing
with them and providing protection for whistleblowers.
These policies address the important topic of corporate culture. They affect the entire value chain. They have been
adopted by the Management Board of the Group and they are responsible for their implementation. The contents of
the documents are available on the Group’s website. In addition, the Group expects suppliers and third parties to
sign the “Declaration of Suppliers and Third Parties on Acceptance of and Compliance with the Arctic Paper Group
Code of Conduct”.
[G1-1 7] We develop and implement our policies and internal regulations in accordance with international
standards and initiatives, as well as local regulations, including but not limited to:
• UN Global Compact principles;
• United Nations Convention against Corruption (UNCAC);
• OECD Guidelines for Multinational Enterprises;
• UN Guiding Principles on Business and Human Rights;
• UN Universal Declaration of Human Rights;
• Charter of Fundamental Rights of the European Union;
• International Labour Organisation Convention.
Every manager, employee and collaborator, as well as suppliers and other third parties working with the Arctic
Paper Group should be familiar with, understand, and adhere to the Arctic Paper Group Code of Conduct, as well
as similar regulations applicable within the Rottneros Group and other applicable regulations. Issues arising in
connection with the implementation of policies, as well as any comments or suggestions for improvements, must be
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reported to the Management Board of the Arctic Paper Group and the Management Board of the Rottneros Group,
whose responsibility is to monitor the functioning of corporate regulations in practice.
[G1-1 10a, 10e] Complaints regarding violations of the Code of Conduct and other regulations applicable to both
groups may be made directly to the Management Board of the Arctic Paper Group or the Management Board of the
Rottneros Group by all current and potential shareholders, customers, suppliers, contractors, as well as all
employees and managers of the company. All received complaints will be treated confidentially. The Management
Board of the Arctic Paper Group does not tolerate any illegal or unethical activities. Any violation of the Code of
Conduct may be punishable by disciplinary action.
[G1-1 10g] At the Arctic Paper Group, we are committed to ensuring that all our employees know and respect
the provisions of the Code of Conduct and other policies. To this end, nano-learning in the form of online training on
business ethics, among other topics, is provided to all employees. The Group provides voluntary access to training
by making computers available, which can also be used by employees in the production areas. It mainly covers the
topics of corruption and bribery, including how to recognise corrupt behaviour and how to behave in such
situations, along with information on how to report and how to respond to such situations. The Arctic Paper Group
does not have a training policy document and implements training based on current training plans and needs.
[G1-1 10h] The most vulnerable to incidents of corruption or bribery are employees involved in purchasing
processes.
BREACH REPORTING AND WHISTLEBLOWER PROTECTION
The Arctic Paper Group strives to maintain openness in its business operations and a high level of business ethics
by encouraging the reporting of any irregularities, abuses, and breaches of law, ethics, or internal company
regulations through the provision of various anonymous communication channels.
[G1-1 11] Under current legislation, the Arctic Paper Group is subject to legal requirements for whistleblower
protection and is required to provide stakeholders with channels to report violations of the law while ensuring
whistleblower protection. The existing Whistleblowing and Whistleblower Protection Policy is designed to enable
frank dialogue, without fear of potential retaliation. Unfavourable treatment or other retaliation for making an internal
or external report is not permitted under applicable law.
The Arctic Paper Group Code of Conduct in the value chain also commits the entire Group to preventing and
responding to retaliatory actions against whistleblowers including discrimination, mobbing and other undesirable
behaviour in the workplace. In addition, the Arctic Paper Group implements an informational policy aimed at
spreading knowledge and raising awareness among employees and contractors regarding the principles set out in
the Policy.
Every manager, employee, collaborator, and any person representing the Arctic Paper Group, as well as
suppliers and other third parties working with the Arctic Paper Group, should be familiar with, understand, and
adhere to the Arctic Paper Group Code of Conduct. Problems arising in connection with the implementation of the
Code, any comments, complaints relating to violations or suggestions for improvement may be reported directly to
the Management Board of the Arctic Paper Group. It is the responsibility of the Management Board to monitor the
operation of the Code of Conduct in practice and all complaints received are treated confidentially and with due
attention.
[G1-1 10c] In the event of a suspected or apparent violation of the Code of Conduct or other Arctic Paper Group
policies, employees are required to report it to their superiors or to HR or Legal. Both internal and external reports
can be made through the publicly available WhistleB platform, which is run by third-party provider Navex Global.
The platform guarantees the anonymity of reported cases and is available in several languages to ensure that
stakeholders have the widest possible access to this service. Whistleblower reports are anonymised.
[G1-1 10a] All violations are handled with due care and include taking all necessary actions to clarify the report.
Employees who act unethically or who breach the Code of Conduct or internal regulations of the Arctic Paper
Group or the Rottneros Group may be subject to disciplinary action. Depending on the circumstances and facts,
such conduct may lead to the termination of cooperation.
The Whistleblowing and Whistleblower Protection Policy requires the Management Board to appoint members
to the Whistleblowing Team. It is an impartial internal unit tasked with follow-up, including verification of the internal
report and further communication with the whistleblower. In addition, direct supervisors are obliged to inform
subordinate employees of the irregularity. Members of the Whistleblowing Team are subject to annual training on
whistleblowing management. The members of the Whistleblowing Teams in the various organisational units of the
group are individuals in the roles of HR directors and managers, legal and sustainability managers.
After the initial investigation of the case, the Team may decide whether to accept or reject the report. The
application process is conducted with confidentiality and impartiality, carefully listening to the parties involved. The
results of the ongoing investigation are presented in the form of a report. Proposals for further actions, including
corrective and preventive actions, are also prepared alongside the report. If deemed appropriate, changes to
internal operating procedures may be implemented.
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Business conduct-related activities and objectives
[G1-1 MDR-A 68] Business conduct activities that have been undertaken in the Arctic Paper Group include:
• promoting adherence to the Value Chain Code of Conduct among Arctic Paper employees and suppliers;
• conducting compliance and anti-corruption training.
These activities have not required significant funding and are ongoing. a
[G1-1 MDR-T] The Arctic Paper Group has not set measurable targets related to business conduct.
Considering the results of the double materiality analysis regarding business conduct, the Group has not identified
any such need. The Group regularly monitors the registers maintained by the OECD National Contact Points on
Responsible Business for notifications that may relate to its activities and the number of prosecutions or penalties
issued in cases involving, inter alia, unfair business practices, unfair competition, non-compliance with human
rights, including in the supply chain, corruption or bribery.
G1-3 Prevention and detection of corruption and bribery.
[G1-3 18a] [AR5, AR6, AR7, AR8] In line with the Arctic Paper Group Code of Conduct for the Value Chain, any
form of corruption, bribery or anti-competitive activities are not subject to any tolerance. Neither the Arctic Paper
Group as a whole nor any person representing the Group (including third parties) are allowed to participate in or
support any corrupt practices. Employees are required to report any suspicions or signs of corruption to their
superiors, directly to members of the Management Board or through available whistleblowing channels.
The most vulnerable to incidents of corruption or bribery are employees involved in purchasing processes.
Therefore, to minimise the risk of corruption or bribery, a multi-step approach to purchasing has been developed
under the P06 procedure based on the ISO 9000 standard. All decisions made in the purchasing process are
based on the agreement of a dedicated group of people, not making the final decision dependent on one person.
As all decisions made during this process are never dependent on a single person, the risk of corruption is
reduced. For large investment projects, decisions regarding investment purchases are made by a dedicated
committee, and we are considering extending this practice to other large purchases. The logistics department has a
similar procurement system. The price lists are approved by our management and then passed on to our sales
team members. On the other hand, bonuses to members of the sales team are not tied exclusively to their
individual sales performance, but also to the overall financial performance of the company. We offer our clients
bonuses for six-month and annual periods, but these are linked to sales volumes, the ranges of which are carefully
monitored. Arctic Paper does not offer other types of bonuses (for example in-kind) to clients.
[G1-3 18b, 18c,] There are no separate investigative committees specifically dedicated to preventing and
detecting corruption or bribery in the Arctic Paper Group. Incidents or suspected corruption can also be reported by
external stakeholders through the WhistleB whistleblower platform. Reports are handled by the Whistleblowing
Team and other units within the company, if necessary, to ensure that those responsible for the investigation are
separate from the management structures involved.
[G1-3, 20] Arctic Paper’s Value Chain Code of Conduct and the analogous regulation in place at Rottneros are
publicly available documents, in addition also made available on the Group’s internal information channels.
[G1-3 21, AR 8] Members of management and supervisory bodies are not provided with additional training on
corruption beyond the publicly available training designed for all employees.
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Information on how policies are communicated to those to whom they are material (prevention and detection
of corruption or bribery)
Functions at risk Managers Administrative, management and
supervisory bodies
Other employees and collaborators
(contract of employment/B2B, contract
of mandate, etc.)
Reporting period 2025
Total number of people at
risk of corruption
62 16 33 13
Percentage of functions at
risk covered by training
programmes
79%
Number of people at risk of
corruption and trained to
deal with it
49 13 24 12
Reporting period 2024
Total number of people at
risk of corruption
66 15 40 11
Percentage of functions at
risk covered by training
programmes
94%
Number of people at risk of
corruption and trained to
deal with it
62 15 37 10
Delivery method and duration of training
Work shops NO NO NO NO
Online NO NO NO NO
Training platform YES YES YES YES
Topics covered
Definition of corruption YES YES YES YES
Suspicion/detection procedures YES YES YES YES
Policy YES YES YES YES
Frequency Once a year Once a year Once a year Once a year
Data comes from the Group’s training system, not validated by an external body other than the assurance
provider
G1-4 Incidents of corruption or bribery
[G1-4, 24a, 24b] No cases of corruption or bribery were identified in the current reporting year.
2024 2025
Number of convictions for violations of anti-corruption
laws
0 0
Level of fines for violations of anti-corruption legislation 0 0
Incidents 0 0
The data comes from the Group’s records and has not been validated by an external body other than the
assurance provider.
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[IRO -2.56, AR19] Index of disclosure requirements met in preparing the sustainability statement
Number
and title of
the
Standard
ESRS
number Name of disclosure Page in the report
ESRS 2
General
disclosures
BP-1 General basis for making sustainability statements 59
BP-2 Disclosure of information in relation to specific circumstances 59
GOV-1 Role of administrative, management and supervisory bodies (including G1.GOV -1). 61
GOV-2 Information provided to the undertaking’s administrative, management and supervisory bodies and the
sustainability issues they undertake
68
GOV-3 Inclusion of sustainability-related outcomes in incentive schemes (including E1.GOV -3). 69
GOV-4 Due diligence statement 69
GOV-5 Risk management and internal controls over sustainability reporting 70
SBM-1 Strategy, business model and value chain 71
SBM-2 Stakeholder interests and opinions (including S1-S3.SBM-2). 76
SBM-3 Important impacts, risks and opportunities and their interrelationship with the strategy and with the business
model (including E1.SBM-3, E4.SBM-3, S1-S3.SBM.3).
84
IRO-1 Description of the process to identify and assess material impacts, risks and opportunities (including E1 -
E5.IRO-1 and G1.IRO-1).
77
IRO-2 ESRS Disclosure Requirements covered by the undertaking’s sustainability statement 83
MDR-P Policies adopted to manage material sustainability issues
MDR-A Actions and resources related to material sustainability issues
MDR-M Metrics related to material sustainability issues
MDR-T Monitoring the effectiveness of policies and actions using targets
ESRS E1
Climate
change
E1-1 Transition plan for climate change mitigation 96
E1-2 Policies related to climate change mitigation and adaptation 96
E1-3 Actions and resources related to climate policiy 97
E1-4 Climate change mitigation and adaptation objectives 99
E1-5 Energy consumption and the energy mix 101
E1-6 Gross Scope 1, 2 and 3 GHG emissions and total GHG emissions 102
E1-7 GHG removal and mitigation projects financed through carbon credits 106
E1-8 Internal carbon pricing 106
ESRS E2
Pollution
E2-1 Policies related to pollution 107
E2-2 Pollution-related activities and resources 107
E2-3 Targets related to pollution 108
E2-4 Pollution of air, water and soil 108
E2-5 Substances of concern and substances of very high concern 110
ESRS E3
Water and
E3-1 Policies related to water and marine resources 113
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Number
and title of
the
Standard
ESRS
number Name of disclosure Page in the report
marine
resources E3-2 Actions and resources related to water and marine resources 113
E3-3 Targets related to water and marine resources 113
E3-4 Water consumption 113
ESRS E5
Resource
use and
the circular
economy
E5-1 Policies related to resource use and circular economy 115
E5-2 Actions and resources related to resource use and circular economy 116
E5-3 Targets related to resource use and circular economy 116
E5-4 Resources introduced 117
E5-5 Resources discharged 117
ESRS S1
Own
workforce
S1-1 Policies related to own workforce 136
S1-2 Procedures for working with own workforce and workers’ representatives on matters of impacts 138
S1-3 Processes for remediating the effects of adverse impacts and channels for raising concerns by own
workforce
138
S1-4 Addressing the material impacts on its own workforce and applying approaches to manage material risks
and opportunities related to its own workforce and the effectiveness of these actions
138
S1-5 Targets for managing material adverse impacts, enhancing positive impacts and managing material risks
and opportunities
140
S1-6 Characteristics of the undertaking’s employees 140
S1-9 Diversity metrics 142
S1-10 Adequate wage 143
S1-14 Health and safety metrics 143
S1-16 Remuneration metrics (pay gap and total remuneration) 144
S1-17 Incidents, complaints and serious impacts on respect for human rights 144
ESRS G1
Business
conduct
G1-1 Business conduct policies and corporate culture 146
G1-3 Prevention and detection of corruption and bribery 148
G1-4 Incidents of corruption or bribery 149
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The following is an index of all data points derived from other EU legislation used in this Sustainability Statement, based on
ESRS 2 Appendix B.
Disclosure
requirement and
associated data point
Reference to the
regulation on
disclosure of
information relating to
sustainable
development in the
financial services
sector
Reference to the third
pillar
Reference to the
Reference Indicators
Regulation
Reference to
European climate law
MATERIAL
TOPIC / NOT
MATERIAL
TOPIC
PAGE IN THE
STATEMENT
ESRS 2 GOV-1
Gender diversity of
board members para.
21(d)
Indicator No 13 in
Table 1 in Annex I
Annex II of
Commission
Delegated Regulation
(EU) 2020/1816 (5)
Material 61
ESRS 2 GOV-1
Percentage of body
members that are
independent para.
21(e)
Annex II of Delegated
Regulation (EU)
2020/1816
Material 61
ESRS 2 GOV-4 Due
diligence statement
para. 30
Indicator No 10 in
Table 3 in Annex I
Material 70
ESRS 2 SBM-1
Participation in fossil
fuel activities para.
40(d)(i)
Indicator No 4 in Table
1 in Annex I
Article 449a of
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453 (6), Table
1: Qualitative
information on
environmental risks
and Table 2:
Qualitative information
on social risks
Annex II of Delegated
Regulation (EU)
2020/1816
Not material
ESRS 2 SBM-1
Participation in
chemical production
activities para. 40(d)(ii)
Indicator No 9 in Table
2 in Annex I
Annex II of Delegated
Regulation (EU)
2020/1816
Material 76
ESRS 2 SBM-1
Participation in
controversial weapons
activities para.
40(d)(iii)
Indicator No 14 in
Table 1 in Annex I
Article 12(1) of
Delegated Regulation
(EU) 2020/1818 (7),
Annex II of Delegated
Regulation (EU)
2020/1816
Not material
ESRS 2 SBM-1
Participation in
tobacco cultivation and
production activities
para. 40(d)(iv)
Article 12(1) of
Delegated Regulation
(EU) 2020/1818,
Annex II of Delegated
Regulation (EU)
2020/1816
Not material
ESRS E1-1 Transition
plan to achieve climate
neutrality by 2050
para. 14
Article 2(1) of
Regulation (EU)
2021/1119
Material 96
ESRS E1-1 Units
excluded from the
scope of the Paris
Agreement-adapted
benchmarks para.
16(g)
Article 449a of
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453, Model 1:
Banking portfolio –
Climate change
transition risk: credit
quality of exposures
by sector, emision and
residual maturity
Article 12(1)(d) to (g)
and 12(2) of
Delegated Regulation
(EU) 2020/1818
Not material
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Disclosure
requirement and
associated data point
Reference to the
regulation on
disclosure of
information relating to
sustainable
development in the
financial services
sector
Reference to the third
pillar
Reference to the
Reference Indicators
Regulation
Reference to
European climate law
MATERIAL
TOPIC / NOT
MATERIAL
TOPIC
PAGE IN THE
STATEMENT
ESRS E1-4 GHG
emission reduction
targets para. 34
Indicator No 4 in Table
2 in Annex I
Article 449a of
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453, Model 3:
Banking portfolio –
Transition risks
associated with
climate change:
metrics of adaptation
Article 6 of Delegated
Regulation (EU)
2020/1818
Material 99
ESRS E1-5 Fossil
energy consumption
disaggregated by
source (only for
sectors with material
climate impacts) para.
38
Indicator No 5 in Table
1 and Indicator No 5 in
Table 2 in Annex I
Not material
ESRS E1-5 Energy
consumption and the
energy mix para. 37
Indicator No 5 in Table
1 in Annex I
Material 101
ESRS E1-5 Energy
intensity linked to
activities undertaken in
sectors with material
climate impact para.
40-43
Indicator No 6 in Table
1 in Annex I
Material 101
ESRS E1-6 Scope 1,
2, 3 gross GHG
emissions and total
GHG emissions para.
44
Indicators 1 and 2 in
Table 1 in Annex I
Article 449a of
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453, Model 1:
Banking portfolio –
Climate change
transition risk: credit
quality of exposures
by sector, emission
and residual maturity
Article 5(1), Article 6
and Article 8(1) of
Delegated Regulation
(EU) 2020/1818
Material 102
ESRS E1-6 Gross
GHG intensity para.
53-55
Indicator No 3 in Table
1 in Annex I
Article 449a of
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453, Model 3:
Banking portfolio –
Transition risks
associated with
climate change:
metrics of adaptation
Article 8(1) of
Delegated Regulation
(EU) 2020/1818
Material 106
ESRS E1-7 GHG
removal and carbon
credits para. 56
Article 2(1) of
Regulation (EU)
2021/1119
Not material
ESRS E1-9 Reference
portfolio exposure to
physical climate-
related risks para. 66
Annex II to Delegated
Regulation (EU)
2020/1818, Annex II
to Delegated
Regulation (EU)
2020/1816
Not material
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Disclosure
requirement and
associated data point
Reference to the
regulation on
disclosure of
information relating to
sustainable
development in the
financial services
sector
Reference to the third
pillar
Reference to the
Reference Indicators
Regulation
Reference to
European climate law
MATERIAL
TOPIC / NOT
MATERIAL
TOPIC
PAGE IN THE
STATEMENT
ESRS E1-9
Disaggregation of
monetary amounts
according to sudden
and prolonged
physical risk
paragraph 66(a) ESRS
E1-9 Location of
significant assets with
material physical risk
para. 66(c) Article
449a of Regulation
(EU) No 575/2013;
para. 46 and 47 of
Commission
Implementing
Regulation (EU)
2022/2453; Model 5:
Banking portfolio –
Physical risk related to
climate change:
exposures subject to
physical risk.
Not material
ESRS E1-9
Breakdown of the book
value of property by
energy efficiency class
para. 67(c)
Article 449a of
Regulation (EU) No
575/2013; para. 34 of
Commission
Implementing
Regulation (EU)
2022/2453; Model 2:
Banking portfolio –
Climate change
transition risk: loans
secured by real estate
– energy efficiency of
collateral
Not material
ESRS E1-9 Degree of
exposure of the
portfolio to climate-
related opportunities
para. 69
Annex II of Delegated
Regulation (EU)
2020/1818
Not material
ESRS E2-4 Amount of
each pollutant listed in
Annex II of the E-
PRTR (European
Pollutant Release and
Transfer Register)
Regulation emitted to
air, water and land,
para. 28
Indicator No 8 in
Annex I Table 1,
indicator No 2 in
Annex I Table 2,
indicator No 1 in
Annex I Table 2 and
indicator No 3 in
Annex I Table 2
Material 108
ESRS E3-1 Water and
marine resources
para. 9
Indicator No 7 in Table
2 in Annex I
Material 113
ESRS E3-1 Special
policy para. 13
Indicator No 8 in Table
2 in Annex I
Not material
ESRS E3-1
Sustainable seas and
oceans practices para.
14
Indicator No 12 in
Table 2 in Annex I
Not material
ESRS E3-4 Total
amount of water
recycled and reused
para. 28(c)
Indicator No 6.2 in
Table 2 in Annex I
Material 113
ESRS E3-4 Total
water consumption in
m3 per net income
from own operations
para. 29
Indicator No 6.1 in
Table 2 in Annex I
Material 113
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Disclosure
requirement and
associated data point
Reference to the
regulation on
disclosure of
information relating to
sustainable
development in the
financial services
sector
Reference to the third
pillar
Reference to the
Reference Indicators
Regulation
Reference to
European climate law
MATERIAL
TOPIC / NOT
MATERIAL
TOPIC
PAGE IN THE
STATEMENT
ESRS 2 SBM 3-E4
para. (16)(a)(i)
Indicator No 7 in Table
1 in Annex I
Material(Quick
fix)
ESRS 2 SBM 3-E4
para. 16(b)
Indicator No 10 in
Table 2 in Annex I
Material(Quick
fix)
ESRS 2 SBM 3-E4
para. 16(c)
Indicator No 14 in
Table 2 in Annex I
Material(Quick
fix)
ESRS E4-2
Sustainable
land/agriculture
practices or policies
para. 24(b).
Indicator No 11 in
Table 2 in Annex I
Material(Quick
fix)
ESRS E4-2
Sustainable ocean/sea
practices or policies
para. 24(c)
Indicator No 12 in
Table 2 in Annex I
Material(Quick
fix)
ESRS E4-2 Policies to
tackle deforestation
para. 24(d)
Indicator No 15 in
Table 2 in Annex I
Material(Quick
fix)
ESRS E5-5 Non-
recycled waste para.
37(d)
Indicator No 13 in
Table 2 in Annex I
Material 117
ESRS E5-5 Hazardous
waste and radioactive
waste para. 39
Indicator No 9 in Table
1 in Annex I
Material 117
ESRS 2 SBM-3-S1
Risk of incidents of
forced labour para.
14(f)
Indicator No 13 in
Table 3 in Annex I
Material
ESRS 2 SBM-3-S1
Risk of incidents of
child labour para.
14(g)
Indicator No 12 in
Table 3 in Annex I
Material
ESRS S1-1
Commitments on
human rights policy
para. 20
Indicator No. 9 in
Table 3 and Indicator
No. 11 in Table 1 in
Annex I
Material
ESRS S1-1 Due
diligence strategies for
issues covered by the
core Inter-National
Labour Organization
Conventions 1-8, para.
21
Annex II of Delegated
Regulation (EU)
2020/1816
Material
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ARCTIC PAPER SA SPRAWOZDANIE ZARZĄDU 2025 161
Disclosure
requirement and
associated data point
Reference to the
regulation on
disclosure of
information relating to
sustainable
development in the
financial services
sector
Reference to the third
pillar
Reference to the
Reference Indicators
Regulation
Reference to
European climate law
MATERIAL
TOPIC / NOT
MATERIAL
TOPIC
PAGE IN THE
STATEMENT
ESRS S1-1
Procedures and
measures to prevent
trafficking in human
beings para. 22
Indicator No 11 in
Table 3 in Annex I
Material
Indicator No. 11 in
Table 3 in Annex I
ESRS S1-1 Policy or
management system
for the prevention of
accidents at work
para. 23
Indicator No 1 in Table
3 in Annex I
Material
ESRS S1-3 Complaint
Mechanisms para.
32(c)
Indicator No 5 in Table
3 in Annex I
Material
ESRS S1-14 Number
of work-related deaths
and number and rate
of work-related
accidents para. 88(b)
and (c)
Indicator No 2 in Table
3 in Annex I
Annex II of Delegated
Regulation (EU)
2020/1816
Material
ESRS S1-14 Number
of days lost due to
injuries, accidents,
fatalities or illnesses
para. 88(e)
Indicator No 3 in Table
3 in Annex I
Material
ESRS S1-16
Unadjusted gender
pay gap para. 97(a)
Indicator No 12 in
Table 1 in Annex I
Annex II of Delegated
Regulation (EU)
2020/1816
Material
ESRS S1-16
Excessive level of
remuneration of the
General Director para.
97(b)
Indicator No 8 in Table
3 in Annex I
Material
ESRS S1-17 Cases of
discrimination para.
103(a)
Indicator No 7 in Table
3 in Annex I
Material
ESRS S1-17 Non-
compliance with the
UN Guiding Principles
on Business and
Human Rights and
OECD Guiding
Principles para. 104(a)
Indicator No. 10 in
Table 1 and Indicator
No. 14 in Table 3 in
Annex I
Annex II of Delegated
Regulation (EU)
2020/1816, Article
12(1) of Delegated
Regulation (EU)
2020/1818
Material
ESRS 2 SBM-3-S2
Material risk of
incidents of child or
forced labour in the
value chain para. 11(b)
Indicators No 12 and
No 13 in Table 3 in
Annex I
Not material
ESRS S2-1
Commitments on
human rights policy
para. 17
Indicator No. 9 in
Table 3 and Indicator
No. 11 in Table 1 in
Annex I
Material(Quick
fix)
===== SIDA 165 =====
ARCTIC PAPER SA SPRAWOZDANIE ZARZĄDU 2025 162
Disclosure
requirement and
associated data point
Reference to the
regulation on
disclosure of
information relating to
sustainable
development in the
financial services
sector
Reference to the third
pillar
Reference to the
Reference Indicators
Regulation
Reference to
European climate law
MATERIAL
TOPIC / NOT
MATERIAL
TOPIC
PAGE IN THE
STATEMENT
ESRS S2-1 Policies
related to persons
performing work in the
value chain para. 18
Indicator No 11 and
No 4 in Table 3 in
Annex I
Material(Quick
fix)
ESRS S2-1 Non-
compliance with the
UN Guiding Principles
on Business and
Human Rights and
OECD Guidelines
para. 19
Indicator No 10 in
Table 1 in Annex I
Annex II of Delegated
Regulation (EU)
2020/1816, Article
12(1) of Delegated
Regulation (EU)
2020/1818
Material(Quick
fix)
ESRS S2-1 Due
diligence strategies for
issues covered by the
core Inter-National
Labour Organization
Conventions 1-8, para.
19
Annex II of Delegated
Regulation (EU)
2020/1816
Material(Quick
fix)
ESRS S2-4 Human
rights issues and
incidents related to
upstream and
downstream value
chains para. 36
Indicator No 14 in
Table 3 in Annex I
Material(Quick
fix)
ESRS S3-1 Human
rights policy
commitments, para. 16
Indicator No 9 in Table
3 of Annex I and
indicator No 11 in
Table 1 of Annex I
Material(Quick
fix)
ESRS S3-1 Failure to
comply with UN
Guiding Principles on
Business and Human
Rights, ILO Principles
or OECD Guidelines
para. 17
Indicator No 10 in
Table 1 in Annex I
Annex II of Delegated
Regulation (EU)
2020/1816, Article
12(1) of Delegated
Regulation (EU)
2020/1818
Material(Quick
fix)
ESRS S3-4 Human
rights issues and
incidents para. 36
Indicator No 14 in
Table 3 in Annex I
Material(Quick
fix)
ESRS S4-1 Policy
relating to consumers
and end-users para.
16
Indicator No. 9 in
Table 3 and Indicator
No. 11 in Table 1 in
Annex I
Material(Quick
fix)
ESRS S4-1 Non-
compliance with the
UN Guiding Principles
on Business and
Human Rights and
OECD Guidelines
para. 17
Indicator No 10 in
Table 1 in Annex I
Annex II of Delegated
Regulation (EU)
2020/1816, Article
12(1) of Delegated
Regulation (EU)
2020/1818
Material(Quick
fix)
ESRS S4-4 Human
rights issues and
incidents paragraph 35
Indicator No 14 in
Table 3 in Annex I
Material(Quick
fix)
ESRS G1-1 United
Nations Convention
against Corruption
para. 10(b)
Indicator No 15 in
Table 3 in Annex I
Material
===== SIDA 166 =====
ARCTIC PAPER SA SPRAWOZDANIE ZARZĄDU 2025 163
Disclosure
requirement and
associated data point
Reference to the
regulation on
disclosure of
information relating to
sustainable
development in the
financial services
sector
Reference to the third
pillar
Reference to the
Reference Indicators
Regulation
Reference to
European climate law
MATERIAL
TOPIC / NOT
MATERIAL
TOPIC
PAGE IN THE
STATEMENT
ESRS G1-1 Protection
of whistleblowers para.
10(d)
Indicator No 6 in Table
3 in Annex I
Material
ESRS G1-4 Fines for
breaches of anti-
corruption and anti-
bribery legislation
para. 24(a)
Indicator No 17 in
Table 3 in Annex I
Annex II of Delegated
Regulation (EU)
2020/1816
Material
ESRS G1-4 Standards
Against Corruption and
Bribery para. 24(b)
Indicator No 16 in
Table 3 in Annex I
Material
===== SIDA 167 =====
ARCTIC PAPER SA SPRAWOZDANIE ZARZĄDU 2025 164
Signatures of the Members of the Management Board
Position First and last name Date Signature
President of the Management Board
CEO
Michał Jarczyński 21 April 2026 signed with a qualified
electronic signature
Member of the Management Board
CFO
Katarzyna Wojtkowiak 21 April 2026 signed with a qualified
electronic signature
Member of the Management Board
Vice-President for Sales and Marketing
Fabian Langenskiöld 21 April 2026 signed with a qualified
electronic signature
===== SIDA 168 =====
Translation note:
This version of our report is a translation from the original, which was prepared in Polish. All possible care
has been taken to ensure that the translation is an accurate representation of the original. However, in all
matters of interpretation of informa tion, views or opinions, the original language version of our report
takes precedence over this translation.
PricewaterhouseCoopers Polska spółka z ograniczoną
odpowiedzialnością Audyt sp. k.,
Nowy Rynek, ul. Wierzbięcice 1A, 61-569 Poznań, Polska
T: +48 (61) 851 1500, F: +48 (61) 851 1501, www.pwc.com
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt Sp. k.
is entered into the National Court Register maintained by the District Court for the Capital City
of Warsaw, under KRS number 0000750050, NIP 526-021-02-28. The seat of the Company is
in Warsaw at Polna 11
www.pwc.com
Independent Statutory Auditor’s Report
To the General Shareholders’ Meeting and the Supervisory Board of Arctic Paper S.A.
Report on the audit of annual consolidated financial statements
Our opinion
In our opinion, the annual consolidated financial statements:
• give a true and fair view of the consolidated financial position of Arctic Paper S.A (“Parent Company”)
and its subsidiaries (together the “Group”), as at 31 December 2025 and the Group’s consolidated
financial performance result on operation and consolidated cash flows for the year then ended in
accordance with the applicable International Financial Reporting Standards as adopted by the
European Union and the adopted accounting policies;
• comply in terms of form and content with the laws applicable to the Group and the Parent Company’s
articles of association;
Our opinion is consistent with our additional report to the Audit Committee of the Parent Company
issued on the date of this report.
What we have audited
We have audited the annual consolidated financial statements of Arctic Paper S.A. Group which
comprise:
• the consolidated statement of financial position as at 31 December 2025;
• the consolidated statement of profit or loss for the financial year then ended;
• the consolidated statement of comprehensive income for the financial year then ended;
• the consolidated statement of changes in equity for the financial year then ended;
• the consolidated statement of cash flows for the financial year then ended, and
• the additional information comprising the introduction to the consolidated financial statements and
additional notes and explanations.
===== SIDA 169 =====
2
Basis for opinion
We conducted our audit in accordance with the National Standards on Auditing in the wording of the
International Standards on Auditing as adopted by the resolutions of the National Council of Statutory
Auditors and the resolution of the Council of the Polish Agency for Audit Oversight (“NSA”) and
pursuant to the act of 11 May 2017 on Statutory Auditors, Audit Firms and Public Oversight (the “Act on
Statutory Auditors”) and the Regulation (EU) No. 537/2014 of 16 April 2014 on specific requirements
regarding the statutory audit of public interest entities and repealing Commission Decision 2005/909/EC
(the “EU Regulation”). Our responsibilities under NSA are further described in the Auditor’s
responsibilities for the audit of the consolidated financial statements section.
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for
our opinion.
Independence
We are independent of the Group in accordance with the ethical requirements of the EU Regulation that
are relevant to audits of financial statements of public interest entities, the ethical requirements of the
Act on Statutory auditors that are relevant to audits of financial statements in Poland and “the Handbook
of the International code of ethics for professional accountants (including International independence
standards) (the “Code of ethics”) as adopted by resolution of the National Council of Statutory Auditors
as applicable to audits of financial statements of public interest entities. We have also fulfilled our other
ethical responsibilities in accordance with ethical requirements of the EU Regulation, ethical
requirements of the Act on Statutory Auditors and the Code of ethics. During the audit, the key statutory
auditor and the audit firm remained independent of the Group in accordance with the independence
requirements set out in the Act on Statutory Auditors and in the EU Regulation.
===== SIDA 170 =====
3
Our audit approach
Overview
The overall materiality threshold adopted for our audit was set at PLN 25
580 thousand, which represents 0,8% of revenue from sale of paper and
pulp.
We performed the audit of the annual separate financial statements of
the Parent Company and the annual consolidation reporting package of
one subsidiary in Poland. In addition, we received audit reports for two
subsidiaries and one consolidated subgroup located within the European
Union. The audits of the reporting packages were carried out by
statutory auditors belonging to the PwC network, in accordance with our
instructions and under our supervision.
• Revenue recognition for the sale of paper and pulp
• Impairment of selected non‑current assets in the subsidiary
Rottneros AB
As part of designing our audit, we determined materiality and assessed the risks of material
misstatement in the consolidated financial statements. In particular, we considered where the Parent
Company’s Management Board made subjective judgements; for example, in respect of significant
accounting estimates that involved making assumptions and considering future events that are
inherently uncertain. As in all of our audits we also addressed the risk of management override of
internal controls, including among other matters, consideration of whether there was evidence of bias
that represented a risk of material misstatement due to fraud.
Materiality
The scope of our audit was influenced by our application of materiality. An audit is designed to obtain
reasonable assurance whether the consolidated financial statements are free from material
misstatement. Misstatements may arise due to fraud or error. They are considered material if,
individually or in aggregate, they could reasonably be expected to influence the economic decisions of
users taken on the basis of the consolidated financial statements.
Based on our professional judgement, we determined certain quantitative thresholds for materiality,
including the overall materiality for the consolidated financial statements as a whole , as set out in the
table below. These, together with qualitative considerations, helped us to determine the scope of our
audit and the nature, timing and extent of our audit procedures and to evaluate the effect of
misstatements, if any, both individually and in aggregate on the consolidated financial statements as a
whole.
Materiality
Group
scoping
Key audit
matters
===== SIDA 171 =====
4
Overall Group materiality PLN 25 580 thousand
How we determined it 0,8% revenues from sale of paper and pulp
Rationale for the materiality
benchmark applied
We determined materiality based on annual revenue from sale
of paper and pulp, as in our view this measure is appropriate
for assessing the Group’s performance from the perspective of
users of the financial statements and is a generally accepted
benchmark when the audited entity reports profit or loss before
tax close to zero. We set materiality at 0.8%, which, based on
our professional judgment, falls within an acceptable range of
quantitative materiality thresholds.
We agreed with the Audit Committee that we would report to them misstatements of the consolidated
financial statements identified during our audit above PLN 2 500 thousand, as well as misstatements
below that amount that, in our view, warranted reporting for qualitative reasons.
How we tailored our Group audit scope
We tailored the scope of our audit in order to perform sufficient work to enable us to provide an opinion
on the consolidated financial statements as a whole, taking into account the structure of the Group, the
accounting processes and controls, and the industry in which the Group operates.
We performed the audit of the annual separate financial statements of the Parent Company and the
annual consolidation reporting package of one subsidiary in Poland. In addition, we received audit
reports for two subsidiaries and one consolidated subgroup located within the European Union. The
audits of the reporting packages were carried out by statutory auditors belonging to the PwC network, in
accordance with our instructions and under our supervision.
Key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in our
audit of the consolidated financial statements of the current period. These matters were addressed in the
context of our audit of the consolidated financial statements as a whole, and in forming our opinion
thereon, and we do not provide a separate opinion on these matters.
===== SIDA 172 =====
5
Key audit matter How our audit addressed the key audit matter
Revenue recognition for the sale of paper
and pulp
The Group has presented its accounting
principles for the recognition of revenue from
the sale of paper and pulp in the notes, as
well as revenue-related disclosures in Notes
3 and 4.1 to the consolidated financial
statements. For the financial year ended 31
December 2025, the Group generated
revenue from sale of paper and pulp totalling
PLN 3,197.6 million (2024: PLN 3,434.7
million), arising from the following sources:
● sale of paper;
● sale of pulp.
This matter was an area of our particular
focus due to the fact that the application of
appropriate financial reporting principles
relating to the recognition, measurement and
presentation of revenue is complex and
requires management to make judgments,
including those related to the allocation of
transaction prices arising from sale of paper
and pulp to the respective performance
obligations. In addition, the correct
determination of revenue relies on the use of
complex IT systems for data processing.
Given the significance of revenue to the
consolidated financial statements, the need
for estimates and judgments, as well as the
potential risk of fraud, we determined this
matter to be a key audit matter.
Our audit procedures included, in particular:
● obtaining an understanding of and assessing the
internal control environment, including the IT
environment, relating to the recognition, measurement
and presentation of the different types of sales
revenue;
● assessing the compliance of the revenue recognition
accounting policies with the applicable financial
reporting standards, in particular those relating to
significant accounting estimates and judgments;
● reviewing significant sales agreements and related
contracts entered into by the Group;
● testing internal controls, on a sample basis, over the
correctness and accuracy of applied sales prices, as
well as the consistency of invoices with sales
orders/price lists and the consistency of invoices with
shipping documents;
● performing substantive procedures, on a sample
basis, including confirmations of selected aspects of
transactions with customers or reconciling issued sales
invoices, goods issue and delivery documents for sold
products and goods to the corresponding customer
contracts, applied sales prices and received payments;
● performing substantive procedures relating to the
appropriateness of the timing of revenue recognition
based on a selected sample;
● testing, on a sample basis, the accuracy and
completeness of the recognition of sales discounts and
marketing campaigns;
● analysing non‑standard journal entries in the
transaction journal for the audited year;
● incorporating an element of unpredictability in the
selection of the nature, timing and extent of audit
procedures;
● assessing the accuracy and completeness of
disclosures relating to revenue from sale of paper and
pulp in the consolidated financial statements.
===== SIDA 173 =====
6
Impairment of selected non‑current
assets in the subsidiary Rottneros AB
In Notes 5.1 to 5.8 to the consolidated
financial statements, the Group presented its
accounting policies, disclosures relating to
non‑current assets and the impairment tests
performed, including the results of these
tests, a description of the assumptions
adopted and sensitivity analyses. As at 31
December 2025, the balance of goodwill
recognised in the Group’s consolidated
financial statements amounted to PLN 8.2
million, the balance of intangible assets
amounted to PLN 78.5 million, while the
balance of property, plant and equipment
amounted to PLN 1,527.7 million (as at 31
December 2024, respectively: PLN 7.8
million, PLN 38.2 million, PLN 1,419.0
million).
Management performs impairment tests. As
at 30 June 2025, the Group’s Parent
Company, Rottneros, carried out impairment
tests of assets at the Rottneros Mill, which
identified the need to recognise an
impairment charge of PLN 53.7 million. This
amount was recognised in the financial
statements of the Rottneros Group and
included in the consolidation of the Arctic
Paper Group.
The impairment tests performed at the end
of the financial year did not indicate any
additional impairment of the
above‑mentioned assets, both in 2025 and
in the prior year. The recoverable amount of
the assets was determined as value in use.
Our audit procedures included, in particular:
● obtaining an understanding of and assessing the
process for identifying indicators of impairment of
non‑current assets and the appropriateness of
grouping assets into cash‑generating units in
accordance with the applicable financial reporting
standards;
● verifying the mathematical accuracy and
methodological consistency (with the involvement of
PwC internal valuation specialists) of the discounted
cash flow valuation model prepared by Management;
● critically evaluating the assumptions adopted and
estimates made by Management for the purpose of
determining the value in use of non‑current assets,
including, among others:
– the five‑year projection period of future cash flows
and the assumed levels of revenue, operating margin
and projected changes in net working capital;
– the discount rates applied (based on the weighted
average cost of capital), with the involvement of PwC
internal specialists;
– terminal growth rates applied beyond the forecast
period;
● assessing the sensitivity analysis performed by
Management regarding the impact of changes in key
assumptions on the valuation results;
● assessing the accuracy and completeness of
disclosures relating to impairment testing in the
consolidated financial statements.
===== SIDA 174 =====
7
Performing impairment tests requires
Management to adopt a number of
assumptions and make significant
judgments, including those relating to the
identification of cash‑generating units, the
Group’s strategy, financial plans and cash
flow forecasts for subsequent years,
including periods beyond the detailed
forecast horizon, as well as macroeconomic
and market assumptions.
Given the significance of these balances in
the consolidated financial statements, as
well as the level of judgment, estimates and
assumptions applied in the impairment
testing process, this matter was the subject
of our audit focus and was determined to be
a key audit matter.
Responsibility of the Management and Supervisory Board of the Parent Company for the
consolidated financial statements
The Management Board of the Parent Company is responsible for the preparation, based on the
properly maintained books of accounts of the annual consolidated financial statements that give a true
and fair view of the Group’s financial position and financial performance result on operation, in
accordance with International Financial Reporting Standards as adopted by the European Union, the
adopted accounting policies, the applicable laws and the Parent Company’s Articles of Association, and
for such internal control as the Parent Company’s Management Board determines is necessary to
enable the preparation of consolidated financial statements that are free from material misstatement,
whether due to fraud or error.
In preparing the consolidated financial statements, the Parent Company’s Management Board is
responsible for assessing the Group’s ability to continue as a going concern, disclosing, as applicable,
matters related to going concern and using the going concern basis of accounting unless the Parent
Company’s Management Board either intends to liquidate the Group or to cease operations, or has no
realistic alternative but to do so.
===== SIDA 175 =====