Groglass’ Sustainability Report 2024 has been prepared with reference to the ESRS (Delegated Regulation (EU) 2023/2772). Although the company is not in the scope for mandatory sustainability reporting under the CSRD, the ESRS were used as guidelines on a voluntary basis to align with stakeholder expectations and to be ahead of direct regulatory requirements. In some disclosures, the drafts of the simplifed ESRS were used as a guidance to gain more clarity about the requirements and which key data points are expected to be maintained in the simplified version.

The scope of the sustainability statement comprises primarily Groglass’ own operations that include two production facilities in Riga, Latvia, and the headquarters located on the same site as one of the production facilities. All the company’s activities associated with the production of anti-reflective and other high-performance glass coatings were considered in the double materiality assessment (DMA) and are fully covered in the sustainability statement. As to the company’s value chain, the focus of the first DMA was on the 1st tier of suppliers and direct customers.

2026-01-21

The time horizons set out in the ESRS 1 have been applied in this sustainability report: short-term <1 year, mid-term 1 to 5 years, long-term >5 years.

Database values from DEFRA and Ecoinvent 3.10 were used to calculate the Scope 3 GHG emissions.

This is the first Groglass’ sustainability report, so there were no changes in preparation and presentation of sustainability information compared to the previous periods.

The information and data on the Groglass’ GHG emissions have been compiled and calculated according to the GHG Protocol.

Groglass has implemented the following ISO standard-based management systems:

• ISO 9001 for quality management

• ISO 14001 for environmental management

• ISO 45001 for occupational health and safety management

• ISO 50001 for energy management

All the systems are externally audited and their compliance with the respective ISO standard is certified by Bureau Veritas.

In accordance with the Appendix C of ESRS 1, the company has omitted the information on the anticipated financial effects of sustainability-related risks and opportunities prescribed by ESRS E1-9, E2-6 and E5-6 for the first year of preparation of its sustainability statement.

In accordance with the Quick Fix Delegated Regulation (EU) 2025/1416, Wave 1 companies with up to 750 employees, may omit all information under ESRS S1 for FY 2024-2026. Based on this, S1-6 is partially disclosed and S1-7 is not disclosed.

Groglass is a limited liability company whose sole shareholder is SIA Alzette, a part of a private equity fund in the portfolio of the European asset manager Kartesia. The governing bodies of the company comprise Groglass’ Management Board and a Supervisory Board on the Alzette’s level. The Management Board consists of three executive members (CEO, CFO and COO), and it reports to the Supervisory Board. The Supervisory Board consists of six members.

A Sustainability Committee comprising seven members was established in 2024. It is chaired by a member of the Management Board (COO) to ensure continuous strategic attention to sustainability. The committee members represent key sustainability areas like HR and occupational health and safety, quality and environmental management, R&D, and others. The committee meets quarterly to follow up on the progress towards the targets set out in the Groglass’ Sustainability Roadmap. It also takes part in the development and coordination of sustainability-related documents and actions. Material matters are then reviewed and eventually approved by the Management Board.

The Sustainability Roadmap is fully integrated in the company’s business and budget, and thus reviewed quarterly by the Management Board. The Supervisory Board is semiannually informed about the progress on the roadmap. It also reviews and eventually approves sustainability-related initiatives and investments where such approval is needed according to the Groglass’ Articles of Association.

Employees are not directly represented on the Management Board, however, any employee can apply to participate in board meetings by filling out an application form before the meeting. Additionally, various channels exist for voicing concerns and suggestions.

The sustainability-related roles and responsibilities of the governing institutions are set out in the company’s Sustainability Policy: Groglass’ sustainability performance, company-wide commitment and coordination of initiatives across business units are overseen by the Management Board. It is responsible for meeting and fulfilling the sustainability goals and commitments of Groglass. The Sustainability Policy and its associated goals are reviewed annually with all the changes being approved by the Supervisory Board.

The CFO is responsible for the oversight of IRO at the governing body level. The IROs will be reviewed at least once every 3 years. The Supervisory Board will be informed of the IRO review results as necessary, particularly in the event of significant changes.

Target setting for significant IROs will take place within the Sustainability Steering Committee, which is overseen by the COO. The COO will also monitor target achievement during the committee’s quarterly meetings.

Significant IROs and targets will be integrated into the company’s strategy, implementation, and risk management processes. These processes will be incorporated into the ISO management system documentation and management reviews.

Sustainability matters, incl. material impacts, risks and opportunities identified in the double materiality assessment, are overseen by the COO of the company. On an operational level, sustainability-related IROs are coordinated by the Quality Management System Manager.

Groglass developed its Sustainability Roadmap in 2024. The document contains 19 targets set in the areas of Governance, Product, People and Planet. The document was approved by the Management Board and the Supervisory Board. The progress towards the sustainability targets set in it is regularly followed up by both governing bodies.

In addition to the competencies listed above, the Management Board Members can leverage the expertise of the Sustainability Committee members that represent key sustainability areas like HR and occupational health and safety, quality and environmental management, R&D, and others.

The Sustainability Roadmap is fully integrated in the company’s business and budget, and thus reviewed quarterly by the Management Board. The Supervisory Board is semiannually informed about the progress on the roadmap. It also reviews and eventually approves sustainability-related initiatives and investments where such approval is needed according to the Groglass’ Articles of Association.

The main sustainability-related matters that on the agenda of the Management and Supervisory Boards in 2024:

·       review of the external assessment of the company’s sustainability performance

·       review and approval of the Sustainability Policy and Sustainability Roadmap

·       establishment of the Sustainability Committee

The first full ESRS-based double materiality assessment, including IRO identification and assessment, was carried out in 2025.

No formal assessment of risks related to sustainability reporting was carried out in 2024. To ensure accuracy of the reported information and data the four-eye principle is applied internally in the process of report preparation.

Groglass is one of the world’s leading developer and manufacturer of anti-reflective and other high-performance coatings on glass and acrylic serving diverse industries such as picture framing, museum showcases, high-end electronics displays, and other applications.

Groglass has a global customer base and serves primarily two markets: framing and technical glass segments.

In March 2024, Groglass approved and published its Sustainability Policy that is built around three areas: Product, People, and Planet. The policy lays out the overall objectives and levers for each of these areas and sets the basic principles and roles for the policy implementation.

Innovation:

Groglass’ objective is to develop high-performance products that meet customer needs while maintaining exceptional environmental performance. Groglass is working to further integrate sustainability into internal design processes and identify innovations that continue to make Groglass products and manufacturing processes more sustainable.

• Increase investment in R&D to support the development of new coatings.

• Collaborate with research institutions annually to explore new coating technologies and sustainable materials.

• Enhance innovation in manufacturing processes, with a focus on energy efficiency, emissions reduction, and production efficiency.

Supply chain:

All key materials are sourced responsibly according to social and environmental standards.

• Implement a comprehensive ethical sourcing program that includes a supplier code of conduct, risk assessments, a supplier rating program, and training to ensure that suppliers meet social and environmental standards.

• Implement a supplier code of conduct that includes social and environmental criteria and require all suppliers to comply with it.

• Enhance supply chain transparency by collecting and analysing data from suppliers to better understand their ESG practices and impacts.

• Set targets for reducing carbon emissions in the supply chain by promoting energy efficiency, renewable energy, and other sustainable practices.

• Revise and improve transportation and logistics management to reduce the environmental impact of internal logistics.

Environmental performance:

Groglass aims to enhance its product stewardship approach based on the results of Life Cycle Assessments (LCA) of its products, as well as the measurement of corporate carbon emissions, also known as the company’s Carbon Footprint.

• Expand the Groglass EPD (Environmental Product Declaration) and Life Cycle Assessment program to new products to recognise their environmental impact, understand the impact of company inputs, and track the company’s value chain and resource efficiency.

• Ensure compliance with environmental regulations and implement voluntary environmental standards.

Diversity & well-being:

Create an inclusive and empowering workplace that embraces diversity, promotes well-being, and values the contributions of every employee. Groglass is committed to providing equal opportunities for professional growth, fostering a culture of respect and belonging, and prioritising the physical, mental, and emotional health of its employees.

• Through comprehensive programs and a positive work environment, Groglass aims to nurture personal and professional development, enabling employees to flourish and succeed.

• Provide training and resources to managers and employees to support diversity and inclusion, including unconscious bias training, cultural competency training, and employee resource groups.

• Continue to focus on and implement initiatives to enhance workplace safety and prevent occupational hazards, ensuring the health and well-being of all employees.

• Foster a positive and inclusive work environment that promotes employee engagement, satisfaction, and overall well-being.

• Establish a comprehensive employee well-being program that includes initiatives focused on physical, mental, and emotional health.

Health & safety:

Health and safety are non-negotiable for Groglass. Groglass is committed to ensuring the safety and well-being of all employees to the highest possible standard by:

• Implementing comprehensive health and safety policies.

• Promoting a culture of safety.

• Providing ongoing training and education.

• Continuously monitoring and improving health and safety performance.

Development & training:

Create a high-performing and highly engaged workforce that embraces ongoing growth and development opportunities, empowered by an inclusive and innovative workplace culture.

• Increase participation in growth and development opportunities for employees at all levels.

• Ensure all managers and those in senior positions have participated in leadership development opportunities.

• Create a culture of innovation where all employees feel empowered to share their ideas, feedback, and unique perspectives, take reasonable risks, and experiment, contributing to greater business results.

• Constantly train and upskill Groglass employees to ensure the sustainable growth of both people and the company. Educate employees on sustainable choices within their professional and daily lives and encourage sustainable behaviour.

Circularity:

Groglass’ mission is to manufacture coatings using circular economy principles, achieving zero waste to landfill and working with partners to create a sustainable value chain.

• Develop a waste reduction program that includes a goal to reduce the amount of waste generated during production.

• Achieve zero waste to landfill in production.

• Conduct regular assessments of company waste streams to identify new opportunities for recycling or reuse, and implement changes to internal processes accordingly.

• Collaborate with suppliers and customers to implement circular economy principles throughout the entire value chain, from raw materials to end-of-life products.

Energy efficiency:

Groglass’ mission is to reduce its environmental impact and promote sustainable energy practices by increasing renewable energy usage, improving energy efficiency, and implementing energy recovery projects.

• Reduce electricity intensity per square metre of output across manufacturing facilities by increasing operational efficiency.

• Where possible, improve energy efficiency by switching to energy-efficient manufacturing devices and technologies.

• Conduct regular energy audits to identify opportunities for energy efficiency improvements.

Reducing emissions:

Groglass is dedicated to implementing measures that reduce its carbon footprint, focusing on GHG emissions to identify further reduction opportunities and increase climate resilience.

• Establish a carbon accounting system and define targets for CO2 reduction.

• Implement a strategy to reduce Scope 3 GHG emissions, including engagement with key suppliers.

• Identify key climate risks, analyse potential impacts, and incorporate preventive and responsive action plans into relevant decision-making processes to improve the company’s climate resilience.

Based on this policy, a more specific and detailed document, the Sustainability Roadmap, was developed, laying out specific targets for the mentioned areas. In addition, the Roadmap includes several governance-related targets aimed at strengthening corporate culture and alignment between sustainability matters and business strategy and operations.

Both documents were developed considering the entire company and all of its activities. A significant portion of the targets set in the Roadmap relates to key stakeholder groups: employees, suppliers, and customers.

Strengthening sustainability through improved operational efficiency

The company’s strategy for 2026-2030 is primarily focused on growing financial indicators through increasing product manufacturing volume, ensuring a high-quality product for end-users, and improving production efficiency. Non-productive time reduction, yield improvement and process robotisation.

Employee engagement

The business strategy also includes employee engagement monitoring through surveys and the quarterly eNPS (Employee Net Promoter Score). Measures for strengthening employee engagement include:

1. Structural units (departments) are encouraged to create action plans within their units, discussing the results within teams and seeking solutions within their sphere of influence. To promote successful and professional leadership, a manager development program has been implemented. A 360-degree survey has also been conducted to strengthen the feedback culture and individual development.

2. In quarterly employee meetings, the Management Board regularly presents the company’s goals and the status of achieved results.

3. A KPI poster has been created and displayed in a location visible to employees.

4. To promote work efficiency and digitalisation.

Employee health and environmental safety

Significant attention is paid to employee health and environmental safety achieved through:

1. Tracking critical occupational safety indicators (investigation of accidents and near-misses, and defining corrective/preventive actions).

2. Zero environmental incidents (registration and investigation of emergency situations, and defining corrective/preventive actions).

3. Conducting monthly 6S audits.

4. Organising regular training sessions.

Groglass also aims to reduce its GHG emissions.

The most important elements of the Groglass’ value chain are illustrated below. The value chain shows the key inputs, key downstream and upstream actors, as well as the elements that are material in the entire value chain.

For the double materiality assessment, the value chain was mapped on a detailed level; the detailed version, however, is not disclosed in the report.

According to the risk profiles of the CountryRisk.io, significant Groglass suppliers are not located in countries with high risk, and 99% are located in low or very low-risk countries.

Inputs identified, together with the Groglass’ technologies and competencies, enable the company to produce coated glass products of superior performance and high durability that benefit society at large through preservation of culture and art, as well as through enhanced technical glass properties for digital displays used in public spaces like stations and airports, medical equipment, and other applications.

Stakeholder inquiries and feedback received via the ongoing regular communication and interactions are considered by respective departments on a regular basis and included in the company’s development plans and activities, if relevant. Responses from the stakeholder survey of 2025 were used as an informative input by the internal experts assigning quantitative values to the potentially material IROs.

Identification of potentially material IROs started by selecting environmental, social, and governance topics that are relevant to Groglass’ operations. First, in accordance with the requirements set out in ESRS 1 and EFRAG Implementation Guidance 1 Materiality Assessment, universal sustainability topics and subtopics were selected from the list given in the ESRS 1 AR16. The selection was done based on the previously mapped value chain. No company-specific topics were identified at this point.

Once the relevant topics were determined, potentially material IROs were identified in cooperation with an external consultant and internal discussions based on the definitions given in the ESRS Annex II. The impact materiality looked at the impacts that Groglass’ own activities and its value chain have or could have on the environment and people. The financial materiality dealt with sustainability-related risks and opportunities that could have financial effects on the company.

During the IRO identification, one company-specific subtopic (availability of workfoce) was identified. In addition to that, data protection and security is relevant to both customer and employee data, therefore these two were grouped as one and further treated as a company-specific subtopic under ESRS G1.

See also “Sources and inputs used in the DMA” below.

See above “Description of double materiality assessment process”, subsection “Methodology.”

In the stakeholder survey of 2025, stakeholders were asked how important various sustainability topics are to them. Further consultations deep-diving into effects of specific impacts might be considered in the future.

For more information on stakeholders, see ESRS 2 SBM-2 “Interests and views of stakeholders.”

See above “Description of double materiality assessment process”, subsection “Methodology.”

• Corporate Sustainability Reporting Directive (CSRD) transposed into the national laws of Latvia by the Law on on Sustainability Disclosures

• European Sustainability Reporting Standards (ESRS) and the related guidance and explanatory documents, primarily, EFRAG Implementation Guidance 1 Materiality Assessment and Implementation Guidance 2 Value Chain

• Groglass’ internal documentation directly or indirectly related to sustainability matters (for example, Sustainability Policy, Sustainability Roadmap, documention for the quality, environmental, occupational health and safety, and energy management management systems, etc.)

• internal expert knowledge and opinions

• stakeholder input gathered through the survey of 2025 and regular communication with various stakeholder groups

• sustainability information on the websites of other glass coating manufacturers

16/10/2025

See the Appendix “Disclosure requirements and incorporation by reference” at the end of the report.

First, material IROs were selected according to the materiality thresholds defined in the DMA methology. These were then linked to the corresponding ESRS subtopics. If a topical standard contains several subtopics, only those relevant to the material IROs of the company are disclosed. The ESRS 2 is fully disclosed.

For the list of the material ESRS and their subtopics, see above “Description of double materiality assessment process”, subsection “Identification of Material Topics.”

No climate-related considerations are factored into remuneration of members of the governing bodies.

Groglass has not yet developed a transition plan for climate change mitigation. A general, qualitative objective to reduce GHG emissions is included in the business strategy for 2026-2030. According to the company’s Sustainability Roadmap, feasibility of reduction measures like purchasing electricity from renewable sources and buying certified wood for packaging are evaluated annually.

Preliminary analysis of potential decarbonisation levers identify the following measures for Scope 1 and 2 emission reduction:

• purchasing electricity from renewable sources (partially or fully);

• further increasing energy and operational efficiency;

• buying certified wood for packaging;

• minimise shipping orders by air.

In 2024, the energy efficiency projects were implemented. The projects overall energy savings is estimated at 45 MWh/year.

No formal resilience analysis has been conducted. As part of the double materiality assessment, climate-related physical risks (both acute and chronic) and their potential impacts on the Groglass’ operations were assessed as non-material. Thus, a more detailed analysis, incl. climate scenario analysis, was considered currently unfeasible.

As to increased carbon pricing through mechanisms like the EU Emission Trading Scheme 2 and Carbon Border Adjustment Mechanism (CBAM), Groglass is not directly affected by these. Such mechanisms may apply to the company’s carbon-intensive suppliers, however, the financial effects of potential increase in the cost of raw materials and electricity in the future due to these mechanisms is estimated as minimal.

The material risk of increased stakeholder scrutiny for GHG emissions and climate impacts can be considered a transition risk. The first step towards addressing it and drafting potential mitigation measures and targets is calculating and disclosing GHG emissions.

Climate-related IROs were identified as an integral part of the DMA process and assessed according to its IRO assessment methodology and materiality thresholds; no separate process was developed for these IROs. The IROs below the current materiality threshold are not further analysed.

Energy consumption and measures for energy efficiency are also analysed and monitored as an important aspect of the company’s ISO 14001-based environmental management system and ISO 50001-based energy management system.

See also E1.SBM-3.

All policies listed above encompass the entire company (own operations).

Since risks associated with climate change adaptation have been assessed as minimal, this is not further addressed in the report. As to the climate change mitigation, Groglass has included its commitment to emission reduction both in its business strategy for 2026-2030 and the policies listed above. The next steps to be taken include definition of a base year and setting of quantative targets, along with development of a more detailed plan on how to achieve them.

See “Decarbonisation levers identified and key actions planned” under ESRS E1-1.

Organisational boundaries: all Groglass activities.

Operational boundaries include:

• All Scope 1 direct emissions (e.g., fuel used in company vehicles, refrigerant, natural gas use for chemical production facilities).

• All Scope 2 indirect emissions (from purchased electricity and heat, purchased cooling).

• Key Scope 3 emissions related to purchased goods and services, water use, fuel and energy related activities, upstream and downstream transporting and distribution, end-of-life treatment of sold products, employee commuting and business travel.

Calculation methodology by GHG Protocol Corporate Accounting and Reporting Standard.

Location- and market-based Scope 2 emissions were calculated using publicly available emission factors. Location-based emission factors are available on the website of the Ministry of Climate and Energy, and market-based emission factors: on the website of the Latvian transmission system operator AST.

The most significant Scope 3 categories were selected based on their impact and emission volume. These emissions were calculated using publicly available emission factors, as no primary data was obtained from suppliers or other value chain partners

No.

No.

Pollution-related IROs were identified as an integral part of the DMA process and assessed according to its IRO assessment methodology and materiality thresholds. Pollution and pollutants are also thoroughly analysed and monitored as an important aspect of the company’s ISO 14001-based environmental management system.

See also ESRS 2 IRO-1 and ESRS 2 SMB-1.

The DMA was carried out for all Groglass’ activities and considered also upstream and downstream transportation and logistics. Within the environmental management system processes, both production facilities are screened for environmental aspects, incl. pollution and pollutants.

The Sustainability Policy states that Groglass aims to minimise envirommental impacts of their products based on the results of life cycle assessments. The Environmental Policy lays out the following directions for pollution-related matters:

·       to reduce the emission of pollutants into the environment, the amount of waste generated, as well as the level of noise and vibration

·       to reduce the chemical consumption by substituting hazardous chemicals with less hazardous ones

·       to develop plans for containment and utilisation of chemicals in emergency situations.

Within the environmental management system, measures are taken to fundamentally prevent the occurrence of such emergency situations. This involves developing an emergency response plan and guidelines for handling chemical spills, monitoring waste indicators, defining annual goals, and identifying suitable waste recycling opportunities. Furthermore, attempts are made to substitute particularly hazardous substances with less hazardous alternatives; if substitution is not possible, special attention is paid to the use of PPE (Personal Protective Equipment).

The TOC-target is based on the national legislative requirements (a Category B polluting activity permit), which are established to ensure air quality and protect the environment. The other above-mentioned targets are set voluntarily.

The (TOC) target applies only to the chemical plant. The other targets apply to both plants together.

MS Dynamics Ax handles chemical substance tracking. Usage can be tracked after the chemicals are written off. Water pollution is very difficult to measure directly. Wastewater quality is regularly controlled by the supplier. If the analysis results are within limits, measurements are taken once every two years. If results are outside the norms, then the measurements are repeated once a quarter.

Groglass’s wastewater measurements are within permitted limits.

Air pollution: Measurements are conducted by the independent LEGMC (Latvian Environment, Geology and Meteorology Centre) laboratory.

A few SCs are used in the chemical coating process and for equipment cleaning and maintenance. These have STOT SE 1, 2 properties (presumed to be toxic to specific organs or organ systems in the body following a single exposure), Aquatic Chronic 1, 2, 3 and 4 properties (substances that are toxic or harmful to aquatic life, with long-lasting effects), Skin Sens. 1, 1A (skin sensitisation category 1) and STOT RE 1, 2 (specific target organ toxicity, repeated exposure categories 1 and 2). Negligible amounts of SCs are used in the research testing processes.

To lower the potential impacts and risks associated with the use of SCs, in 2024,a technical substance with the hazard classification Carc. 1B; Muta. 1B; Aquatic Chronic 2 was replaced with a less hazardous substance classified as Aquatic Chronic 2.

No SVHCs are used in the company’s operations.

IROs related to circular economy were identified as an integral part of the DMA process and assessed according to its IRO assessment methodology and materiality thresholds. Flows of materials, incl. waste streams, are also thoroughly analysed and monitored as an important aspect of the company’s ISO 14001-based environmental management system.

See also ESRS 2 IRO-1 and ESRS 2 SMB-1.

The DMA was carried out for all Groglass’ activities and considered also upstream and downstream transportation and logistics. Within the environmental management system processes, both production facilities are screened for environmental aspects, incl. flows of materials and waste.

No formal consultations have been conducted on matters related to circular economy.

The most resource- and impact-intensive stages of the value chain are upstream and own operations where significant amounts of energy and raw materials (incl. virgin materials in the upstream processes) are used. While cutting and preparing of the glass products still require certain amounts of energy, the use phase of the Groglass’s products have low material and energy needs. When the products reach their end-of-life stage, high recyclability of glass allows diverting them towards waste recovery operations, mostly recycling.

While the Sustainability Policy lays out the overarching approach to all sustainability matters, the Environmental Policy sets the main directions for environmental matters, incl. effective and sparing use of resources and materials, and responsible waste management. In addition to that, the ISO 14001-based environmental management system (EMS) plays a significant role in matters relating to resource use and circular economy. One of the main principles of the EMS is to take into account the recyclability of materials for production and packaging upon their selection.

While Groglass recycles its own glass waste to a large degree, production of high-performance coated glass requires superior quality of raw materials, and only virgin glass suits these quality requirements. The suitability of recycled glass has been tested by the company; the results, however, were not acceptable in terms of the product quality. Likewise, the fragility of the product requires significant amounts of high-quality packaging materials, limiting the options for the use of recycled materials.

Although not explicitly stated in the policies, Groglass applies the waste hierarchy principles in its waste management:

·       prevention of waste (through effective and sparing use of resources and materials)

·       reuse (through reusable metal frames for transportation of flat glass)

·       recycyling (through high recycling rates of own glass waste and high recyclability of materials used for packaging)

Glass sheets that do not pass the pre-production quality check are downcycled and used for setting up and calibrating the equipment before being diverted to recycling. Disposal is seen as the least favourable option for managing the company’s waste. Currently, Groglass does not actively engage in sustainable sourcing.

All targets related to resource use and circular economy are set voluntarily.

Two of the targets described above relate to waste management, primarily prevention of waste and recycling. The target on zero environmental complaints is a general target covering all environmental matters.

The two key groups of the company’s resource outflows towards the customers are:

1)      finished products – coated mineral and organic glass used for framing and in technical glass applications;

2)      outgoing packaging materials for product transportation (mostly wood frames, cardboard boxes and plastic film);

Additionally, there is an outflow of waste. The main waste fractions are glass (the largest fraction), incoming packaging materials, wastewater and municipal waste.

Reference service life: > 30 years.

Glass products are not reparable, if broken.
Mineral glass products are fully recyclable. The coatings make up a tiny fraction (0,01 %) of the final product and thus do not affect its recyclability for general purposes.
Coated organic glass products requires more sophisticated recycling methods. However, they are significantly less fragile and thus are the preferred option, for example, in the regions with increased risks of seismic activity

Outgoing packaging materials are highly recyclable, almost 100%. Declarations of packaging contents and recyclability are provided to customers upon request.

The amount of finished products is measured in m2. The amounts of packaging materials used are calculated based on a model that was developed internally, based on direct sample measurements of the amounts used for various types of packaging.

The main non-hazardous waste fractions are:

• glass – the largest fraction and highly recyclable; defective glass is used for equipment set up and calibration before recycling;

• incoming packaging materials – wood frames are resized and reused for outgoing packaging; most of other incoming packaging materials are sorted and recycled;

• wastewater – collected and treated by the local provider wastewater services who also takes regular measurements of the company’s wastewater quality;

• municipal and construction waste – the smallest fraction, unsorted and diverted to disposal.

Hazardous waste include organic solvents (waste class 080111), other organic solvents, washing liquids and desalting agents (070704, 070104), absorbents, filter materials (including oil filters not otherwise specified), wiping material and protective clothing contaminated with dangerous substances (150202,150203), packaging containing residues of or contaminated by dangerous substances (150110), other batteries and accumulators (160605).

Data on the amounts of waste and how it is further managed is received from the waste management providers.

Groglass does not take an active part in the product end-of-life waste management. As explained above, mineral glass products are highly recyclable, while coated organic glass products requires more sophisticated recycling methods.

Yes.

See the disclosures S1-6. Data on non-employees are not disclosed in this year’s report.

“Workplace with elevated OHS impacts” is an actual negative impact that was assessed as material for Groglass. Higher OHS risks and impacts are typical for manufacturing industry compared to other sectors. The workplace environment at Groglass includes various equipment, machinery, glass products, heavy weights, and certain amount of chemicals.

OHS matters are constantly monitored and managed through an ISO 45001-based and externally certified OHS management system that has been in place since 2018. Various measures are implemented both on a continuous basis and as one-time initiatives to prevent OHS incidents and to minimise the impacts that are constantly present in everyday working environment (for example, noise).

Two workforce-related risks were identified as material in the DMA of 2025:

·       risk of high-consequence OHS accidents; arising from the associated impact “Workplace with elevated OHS impacts”

·       availability of workforce, especially of relatively low qualified, but highly disciplined production workers and on short notice (for unplanned production peaks); arising from the dependency on workforce

Although relevant for all employees, both of the material risks under this topic relate to a greater degree to production workers.

IROs related to own workforce were identified as an integral part of the DMA process and assessed according to its IRO assessment methodology and materiality thresholds. Occupational health and safety matters are also thoroughly analysed and monitored through the company’s ISO 45001-based OHS management system. This system serves as a key tool for understanding risks and impacts associated with OHS, incl. which employee groups are affected by certain risks and impacts.

See also ESRS 2 IRO-1 and ESRS 2 SMB-2.

No such impacts are currently identified.

Not applicable.

Not applicable.

While there is no separate human rights policy at Groglass, the commitment to operate in accordance with the requirements of international and national laws relevant to the industry, as well as the principles of the UN Global Compact is laid out in the Code of Conduct. This document also commits to equal treatment of all employees and prohibits any form of discrimination, child labour and forced labour.

Matters like commencement and termination of employment, access to work resources, working time, remuneration, and vacation are reglamented in the Internal Rules of Procedure and several supporting procedures, thus ensuring equal treatment of all employees that in direct employment relationship with Groglass.

Human rights aspects related to the working environment are addressed in the OHS policy (see above). In addition to that, the company has OHS-related internal procedures for visitors and employees of the companies that provide services to Groglass.

Processing of employee data, incl. rights related to data privacy, are addressed in the Employee Data Privacy Policy.

Groglass commits to comply with the above mentioned principles in its Code of Conduct. The Code is developed in accordance with the principles of the UN Global Compact which are derived from other international documents, incl. Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work.

The compliance with these principles is monitored through the employee engagement processes and mechanisms described below in S1-2 “Processes for engaging with own workers and workers’ representatives about impacts.”

The company’s Code of Conduct is developed in accordance with the principles of the UN Global Compact which are derived from other international documents, incl. Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work.

Groglass Code of Conduct explicitly prohibits any form of discrimination, incl. based on racial and ethnic origin, religion, age, sex, sexual orientation, family status, political opinion, income level, incapacity for work or disability. The Code also promotes equal treatment of all employees. The equal treatment is further detailed in the Internal Rules of Procedure which set the rules for employment commencement and termination, remuneration, etc.

Groglass has no specific policy on inclusion or positive action for people from groups at particular risk of vulnerability in its own workforce.

Open communication and structured feedback processes enable employee engagement and participation in decision-making and opportunities for growth and development. There are several communication channels that provide an opportunity for every employee to receive information and express their opinion: a quarterly employee pulse survey, a quarterly employee general meeting, an employee intranet, an email for suggestions/complaints, and a mailbox for paper messages. The annual trainings on the Code of Conduct, as well as other trainings and instructions, also provide an opportunity for employee feedback. Groglass also conducts annual development reviews for mid-level managers and specialists.

Groglass’ employees were one of the key stakeholder groups engaged in the stakeholder survey of 2025. As to the material impact “Workplace with elevated OHS impacts”, the company sets targets related to the work environment, and employees are involved in the annual assessment of their working environment.

 Forms of engagement include direct communication with the OHS specialist or the option to leave a message in HR portal. Additionally, internal claims can be registered through the Production Shift Manager; these claims will be reviewed to determine the necessity of corrective actions.

Groglass engages directly with employees through the mechanisms described above.

The responsibility for employment engagement lies with the Adminitrative and HR Department. The key roles responsible are the HR Manager (for employee satisfaction, training and development, and other HR matters) and the OHS specialist (for matters related to the working environment, health and safety).

The effectiveness of engagement is evaluated by indirect metrics like eNPS (Employee Net Promoter Score) and percentage of employees responding to the employee surveys.

In the DMA of 2025, elevated OHS impacts were identified as material for own workforce. The ISO 45001-based OHS management system includes processes for identifying specific impacts on specific worker groups and how these impacts are best prevented and and ensuring that the unique needs, vulnerabilities, and exposures of different worker groups are fully reflected in the organisation’s risk assessment and operational controls. This includes integrating dedicated procedures for consultation, participation, training, monitoring and review. As a result, the organisation can more effectively prevent harm, reduce disparities in risk exposure, and implement timely remedial actions, thereby supporting a safer, healthier, and more inclusive working environment for all workers.

Employees are involved in the assessment of work environment risks through interviews and on-site observation of work processes. Risks are reviewed annually. If the protocol remains valid (i.e., no changes have occurred during the year), it is marked as ‘reviewed.’ If updates are required, a re-assessment is performed. Additionally, a re-assessment is conducted after every accident. Immediate assessment is also carried out if there are any changes, such as the introduction of new equipment.

Various measures are implemented both on a continuous basis and as one-time initiatives to prevent OHS incidents and to minimise the impacts that are constantly present in everyday working environment (for example, noise). If an incident has occurred, it is promptly investigated and corrective actions are implemented.

If an employee has developed work-related ill health it is also getting investigated, measures are taken in accordance with occupational doctor recommendations (for example, workload is reduced, workplace adjustments are provided).

The primary way for resolving issues and raising concerns is through one’s direct manager or, if this is not possible for some reason, through the Administrative and HR Department. Matters related to health and safety can also be taken up directly with the OHS specialist.

Apart from that, employees can raise their concerns through the various communication and engagement channels described in S1-2 “Processes for engaging with own workers and workers’ representatives about impacts.” Concerns can also be submitted on the internal HR portal, and there is a whistleblowing procedure in place for reporting potentially illegal, unsafe or unethical activities or situations that cannot be resolved otherwise.

OHS related-concerns can also be raised through the Mission Zero platform, which is a voluntary and public initiative established in 2022 by the companies aiming at zero workplace accidents, prevention of work-related fatalities and preventive measures to protect and preserve the health of employees. Reports through the website can be submitted both in an anonymous and non-anonymous way.

All employees who are in direct employment relationship with Groglass can use any of the channels described in S1-2 “Processes for engaging with own workers and workers’ representatives about impacts.” If the whistleblowing channel is used, the report can be submitted in any of the following ways: 1) in person to the Administrative and HR Department; 2) by sending it to a designated e-mail address; 3) by sending it by post; 3) by putting it in the box for incoming mail.

Temporary employees hired from the employment agencies during production peaks can report emergency situations directly to the Production Shift Manager or through their own employer. Unfortunately, agency workers do not have the option to submit claims anonymously.

The mechanisms are the same for all matters.

Regular employee surveys are sent to all employees; information about other channels are provided in relevant trainings and instructions.

There is a display in the work areas, where current information and popularisation of reporting channels are displayed.

The mechanism for addressing received complaints or whistleblowing reports is described in ESRS G1-1.

There are no dedicated mechanisms for assessing effectiveness. However, messages have been received via the email for suggestions and in the physical mailboxes, which may indirectly indicate the effectiveness of these channels.

Surveys regarding awareness of these channels are not conducted. See also S1-3 “Disclosure of how issues raised and addressed are tracked and monitored and how effectiveness of channels is ensured”.

See G1-1 “Business conduct policies and corporate culture.”

See S1-3 “Processes to remediate negative impacts and channels for own workers to raise concerns.”

See key actions in ESRS S1-4.

There are no specific measurments of the effectiveness of the S1 key actions. The eNPS (Employee Net Promoter Score) can provide an indirect indication of the overall effectiveness of the key actions under S1.

See S1-3 “Processes to remediate negative impacts and channels for own workers to raise concerns.”

Prevention, mitigation and eventual remedy of negative impacts on own workforce is ensured through the ISO 45001-based and externally certified OHS management system. For more details, see S1-3 “Processes to remediate negative impacts and channels for own workers to raise concerns.”

The budget for OHS related activities is set up based on the actions planned for the given year. It is then reviewed and approved as an integral part of the annual budget. The responsibility for the implementation lies with the OHS specialist at the Administrative and HR Department.

If additional resources are required for projects that emerge during the year, Investment Committee meetings are organised to decide on the feasibility of implementation.

The Company’s primary annual objectives are defined in collaboration with Supervisory Board and the Management Board. To determine the strategy for achieving these objectives, engagement discussions are held with department heads, after which the goals are cascaded within each department. To meet departmental targets, each team defines specific KPIs for their operations and outlines the necessary activities. The annual goal-setting process is inclusive, involving all department heads, as well as mid-level managers and specialists.

See in “Targets related to managing material IROs” ESRS S1-5.

Consumer-related IROs were identified as an integral part of the DMA process and assessed according to its IRO assessment methodology and materiality thresholds (see ESRS 2 IRO-1 and ESRS 2 SMB-1). Two impacts (both positive) and one opportunity were assessed as material in the DMA process. Since no material negative impacts on consumers and end-users were identified, the S4 disclosures related to negative impacts are omitted.

Yes.

The very end-users of Groglass products are the users of art and culture in museums, exhibition halls (i.e. visitors), showcase users in stores, and users of technical screens at the airports, medical institutions, etc. In most cases, they do not have direct contact with the product and do not perceive it as a separate part of their experience. Thus, for the purpose of the S4 standard, Groglass defines its consumers as customers and their employees that come in direct contact with the company’s product and that have certain demands for the product’s quality and performance, and an interest in its environmental footprint.

See also the value chain illustration in SBM-1 “Strategy, business model, and value chain” and stakeholder mapping in SBM-2 “Interests and views of stakeholders.”

The key groups of the Groglass’ product users that benefit from the product and service transparency and safe product handling practices are glass distributors, glass processors. This includes the employees of these companies who come into direct contact with the Groglass products through cutting, preparing and washing the product.

The users of the Groglass products do not include the following groups:

• consumers of products that are inherently harmful to people and/or increase risks for chronic disease;

• consumers of services that potentially negatively impact their rights to privacy, to have their personal data protected, to freedom of expression and to non-discrimination;

• consumers who are dependent on accurate and accessible product- or service-related information, such as manuals and product labels, to avoid potentially damaging use of a product or service;

• consumers who are particularly vulnerable to health or privacy impacts or impacts from marketing and sales strategies, such as children or financially vulnerable individuals.

See the impact descriptions above, under the disclosure “Identified material impacts, risks and opportunities”.

The sustainability-related opportunity of expanding the EPD portfolio of the company’s products arises mainly from the interest of the technical glass segment in the environmental performance of their acquired products.

While the company’s Code of Conduct is primarily oriented towards Groglass employees, the principles and norms laid out in the document are equally valid in the communication and interactions with the customers and their representatives. For more specific commitments related to human rights, see S1-1 “Policies related to own workforce.”

See S4-2 “Processes for engaging with consumers and end users about impacts” below.

See S1-1 “Policies related to own workforce.”

No such cases were identified by Groglass in the reporting year.

Regular direct engagement forms include communication via the sales team, as well as discussions and feedback in business meetings, exhibitions and networking events. The feedback is also received through the annual customer satisfaction questionnaire and analyse the findings to implement necessary adjustments based on customer feedback. Declarations of conformity are regularly issued; complaints about the product and/or delivery, and inquiries about sustainability topics are reviewed and addressed when such arise. Customer feedback, incl. sustainability-related inquiries, serve as an input for the further development of product portfolio and company-level decisions. A recent example for this is the increasing interest in the product EPDs from the customers in the technical glass segment, which is expected to result in the development of such declarations for technical glass products.

Groglass customers were also one of the key stakeholder groups surveyed in the DMA process of 2025. For more details on this process, see ESRS 2 IRO-1 “Description of the processes to identify and assess material impacts, risks, and opportunities.”

The functions involved in the regular engagement activities are primarily the Sales Department, the Order Management Department, and to a certain degree the Marketing Department. The DMA-related engagement activities are coordinated by the Quality System Manager in the Administrative and HR Department.

In the DMA of 2025, no negative impacts on consumers as defined under S4.SBM-3 were identified.

Any concerns can be raised directly with Groglass through the mechanisms listed in S4-2 “Processes for engaging with consumers and end-users about impacts.” The procedure for submitting quality-related claims is laid out in the General Terms of Business Sale and Delivery that are publicly available on the company’s website .

There are no third-party grievance mechanisms for customers/consumers.

The potential development of Environmental Product Declarations (EPDs) is reviewed by the Management Board at least annually. A conceptual decision is made to either proceed with or postpone the initiative, in alignment with the company’s business development strategy.

See the impact descriptions  in “Identified material impacts, risks and opportunities” (under S4.SBM-3 “Material impacts, risks and opportunities and their interaction with strategy and business mode.”)

No such incidents have been identified by Groglass in the reporting period.

The budget for customer-related activities is set up based on the actions and events planned for the given year. It is then reviewed and approved as an integral part of the annual budget.

No other specific targets are set . Activities related to managing material IRO are defined in S4-4 “Key actions”.

Consumers and end-users are not directly engaged in setting the targets or tracking the undertaking’s performance against them.

The highest level of responsibility to approve and implement all policies, incl. those addressing business conduct matters, lies with the company’s Management Board. The key documents addressing business conduct are Groglass’ Code of Conduct, the Internal Rules of Procedure, the Purchasing Procedure, and the Supplier Code of Conduct.

The content of these documents is reviewed and updated by the responsible department managers. The company’s Management Board then reviews the changes and approves the documents. The documents are reviewed when necessary (if changes have occurred) or at least once every 2 years, in accordance with the internally established procedure.

See ESRS 2 GOV-1.

The key document that addresses Groglass’ corporate culture is its Code of Conduct that lays out the company values and main principles for ethical conduct. These form the very basis of the employee attitude towards work and are to be applied both internally and in the communication and interactions with external parties. All employees, incl. managers and members of the Management Board, are annually trained on the Code and its requirements. The HR Department Manager is responsible for the training.

Adherence to the Code of Conduct is overseen by the Ethics Commission. When a complaint or whistleblowing report is received, an ad-hoc review committee is formed by the Management Board to investigate the matter.

Ethical corporate behaviour is also being promoted through Groglass’ Supplier Code of Conduct, where zero tolerance for corruption, extortion, and bribery and prohibition of unlawful advantages to influence business decisions are clearly stated.

In Latvia, all companies with more than 50 employees are required to establish a whistleblowing procedure according to the Whistleblowing Law which transposes the EU Directive (EU) 2019/1937. Such procedure has been in place in Groglass since 2022, and it is primarily meant for employees. The information and training about the procedure is provided to all employees as part of the training on the Code of Conduct. New employees are introduced to the procedure upon the beginning of employment.

If an employee knows of or suspects a potential violation in the workplace (for example, violations of workplace safety, corruption, discrimination, mobbing, or risks for the company reputation), he/she is obliged to use the whistleblowing mechanism and submit the whistleblowing form in any of the following ways: 1) in person to the Administrative and HR Department; 2) by sending it to a designated e-mail address; 3) by sending it by post; 3) by putting it in the box for incoming mail.

To protect the whistleblower’s identity, the report is registered and reviewed as restricted access information, and the submitter’s data is pseudonymised. The whistleblower’s report can also be submitted anonymously.

Various concerns can also be submitted on the internal HR portal and Employee Intranet.

Possible violations may be reported by external parties (external stakeholders) by sending a formal submission or complaint to the Groglass postal address or electronically to the email address indicated on the Groglass website.

When a complaint or whistleblowing report is received, an ad-hoc review committee is formed by the Management Board to investigate the matter.

Groglass has no separate policy on anti-corruption and bribery. However, the principles and measures for preventing bribery and corruption described in the Code of Conduct, the Internal Rules of Procedure, the Competition Law Compliance Guidelines, and the Supplier Code of Conduct are in line with the United Nations Convention against Corruption.

The Code of Conduct prohibits to retaliate or cause any negative consequences to a whistleblower if the issue was raised in accordance with the requirements set out in the Whistleblowing Law or this Code. To protect the whistleblower’s identity, the report is registered and reviewed as restricted access information, and the submitter’s data is pseudonymised.

Yes, the procedure for investigation of business conduct incidents is laid out in the internal Guidelines for Compliance with Competition Law for compliance with competition law and regulations.

All employees, incl. managers and members of the Management Board, are annually trained on the Code and its requirements.

Employee Code of Conduct training is conducted once a year, either in-person or remotely. The training is delivered using a presentation, which is subsequently distributed to all employees via email. During the training, specific scenarios are discussed, and upon completion of the training, all employees fill out an electronic test to verify their knowledge.

No formal assessment of the most-at-risk functions has been carried out. However, functions that deal with and make decisions on financial matters and business development do receive more extensive training / training that is more focused on issues like conflict of interest, gifts, cooperation with companies represented by relatives or family members.

The highest risks could be related to Procurement (purchase of raw materials) and the Technical Department (implementation of investment projects).

The following documents and procedures are relevant to prevention, detection and addressing incidents of corruption or bribery:

·       established accounting procedures and financial disclosures in accordance with the Law on Annual Statements and Consolidated Annual Statements (incl. independent auditor’s report;

·       Groglass’ Code of Conduct and the associated Internal Rules of Procedure, incl. regular trainings;

·       a detailed Purchasing Procedure that lays out the purchasing process, roles and responsibilities;

·       the whistleblowing procedure;

·       Procedure for investigation of business conduct incidents is laid out the internal guidelines for compliance with competition law and regulations;

·       Guidelines for Compliance with Competition Law;

·    Supplier Code of Conduct which is to be signed by suppliers upon entering into the contractual relationship with the company. By engaging in business with SIA Groglass, suppliers acknowledge that they understand and agree to comply with this Supplier Code of Conduct.

See also G1-1 Business conduct policies and corporate culture.

A meeting is convened with the Management Board members to discuss the composition of the commission, ensuring the situation can be assessed as independently as possible. The report is initially received only by the HR representative.

Reports and incidents are reported to the Board and reviewed as described above.

The policies are primarily communicated via trainings. New employees get acquainted with the policies relevant to their position at the beginning of the employment. Groglass’ Code of Conduct is available to all employees in the document management system and on the internal server.

Anti-corruption and anti-bribery matters are part of the training on the Code of Conduct. The training is conducted annually, and all employees are required to complete it.

In addition, the Guidelines were sent to high-risk functions for review and familiarisation. There is no separate training program for Guidelines for Compliance with Competition Law.

Just like all other employees, members of the Management Board are required to complete the annual trainings on the Code of Conduct.

IROs related to circular economy were identified as an integral part of the DMA process and assessed according to its IRO assessment methodology and materiality thresholds.

See also ESRS 2 IRO-1 and ESRS 2 SMB-1.

Currently, the employee data security system is supported by management and technical controls:

1. Key employee data is stored in the corporate HR portal. The portal is located in the cloud and is supported by an external IT company. Administrative access to the portal is limited to the HR team. Employee access is SSO with 2FA, integrated with the corporate user directory MS Entra ID.

2. Employee personal materials are stored on the corporate file server. Access to the network drive is limited to the HR team. All requests for access to the file server are registered in the company’s ticketing portal.

3. The internal procedure for handling employee data is laid out in the Employee Data Privacy Policy.

According to the company’s IT strategy, Groglass constantly implements the best practices of the ISO27001 standard. There is also a plan to upgrade the HR portal David to the new version of the HR system.

Customer data security sales CRM system prioritises client data protection through various security measures and compliance with data privacy regulations like GDPR. These measures include data encryption, secure connections, separate databases for each client, regular security audits, and adherence to industry standards like SOC 2 and SOC 3. Pipedrive also offers features like user permissions, single sign-on (SSO), and two-factor authentication (2FA) to enhance security.