Nabaltec-Policy-2024-e

20 2 4 SUS TA INABIL I T Y POL IC Y

CONTENTS 01 Guidelines for our understanding of sustainability 02 General information 02 Objectives of the sustainability policy 02 Area of application and target groups 02 Basis for Nabaltec’s understanding of sustainability, consideration of standards and specifications 05 Identification of key topics 06 Nabaltec’s central sustainability action areas 06 Our central fields of action in the area of the environment 07 Our central fields of action in the area of social affairs 07 Our central fields of action in the area of corporate management 08 Managing sustainability in the company 08 Integration of risks, opportunities and impacts into existing risk and opportunity management 09 Monitoring of sustainability goals and measures 09 Data and information basis 10 Ongoing reporting 10 Dealing with violations 11 Final provisions 11 Responsibility for the implementation of the policy 11 Accessibility and validity 11 Legal notice 12 Imprint

G U I D E L I N E S F O R O U R U N D E R S T A N D I N G O F S U S T A I N A B I L I T Y 01 GUIDELINES FOR OUR UNDER STANDING OF SUSTAINABILIT Y Our understanding of sustainability is based on the conviction that economic, ecological and social goals must be in balance with one another in order to ensure the company’s long-term success. This policy forms the framework for all employees and departments at Nabaltec to systematically anchor sustainability in the company - as the basis for long-term competitiveness, innovative strength and resilience. To this end, we base our actions on three clear guidelines: 1. We firmly anchor sustainable principles in our business processes. 2. We consistently align our entire value chain with responsible standards. 3. We continue to actively shape the future viability of our industry. S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4 N A B A L T E C A G

02 G E N E R A L I N F O R M A T I O N GENER AL INFORMATION Objectives of the sustainability policy This sustainability policy provides a binding framework for our actions. It describes how we understand sustainability, implement it in our day-to-day business and monitor it through clear responsibilities and suitable control mechanisms. Area of application and target groups This policy sets out the behavior we expect from our employees, business partners, suppliers and other relevant stakeholders. It serves as a binding guide for decisions, priorities and objectives in all areas of the value chain. In addition to the Code of Conduct, which sets out binding rules for all employees and managers on how to act with integrity and in accordance with the law in everyday working life, the sustainability policy defines strategic guidelines and key areas of action for structurally anchoring sustainability in the company. Basis for Nabaltec’s understanding of sustainability, consideration of standards and speciﬁcations Our understanding of sustainability is based on the guiding principle of future-oriented development: We act with foresight and are committed to reconciling ecological, social and economic goals. We organize our business activities in such a way that environmental awareness, social responsibility and entrepreneurial success are equally taken into account and combined. The United Nations Sustainable Development Goals (SDGs) serve as a guide for us to categorize our activities in social terms. Based on our materiality analysis, we have identified seven SDGs to which we contribute directly or indirectly: N A B A L T E C A G S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4

G E N E R A L I N F O R M A T I O N 03 ◆ SDG 3: Health and well-being Relevant sub-goals: ◆ 3.4. Promoting mental health and well-being in the workplace. ◆ 3.8. Access to high-quality health services and protective measures for all employees. ◆ SDG 7: Affordable and clean energy Relevant sub-goals: ◆ 7.2. Increasing the share of renewable energies in the global energy mix. ◆ 7.3. Doubling the global increase in energy efficiency. ◆ SDG 8: Decent work and economic growth Relevant sub-goals: ◆ 8.4. Increase resource efficiency and promote sustainable production methods. ◆ 8.5. Full and productive employment and decent work for all. ◆ 8.7. Measures against child and forced labor in the supply chain. ◆ 8.8. Protection of employee rights and safe working conditions. ◆ SDG 9: Industry, innovation and infrastructure Relevant sub-goals: ◆ 9.2. Promotion of sustainable industrialization. ◆ 9.4. Sustainable modernization of industries through resource efficiency. ◆ 9.5. Strengthening research and innovation for sustainable development. ◆ SDG 10: Fewer inequalities Relevant sub-goals: ◆ 10.2. Social, economic and political inclusion for all. ◆ 10.3. Ensuring equal opportunities and reducing discrimination. ◆ SDG 12: Sustainable consumption and production Relevant sub-goals: ◆ 12.2. Sustainable management and efficient use of natural resources. ◆ 12.4. Environmentally friendly handling of chemicals and waste. ◆ 12.6. Promotion of sustainability reporting in companies. ◆ 12.7. Promotion of sustainable public and private procurement processes. ◆ SDG 13: Climate protection measures Relevant sub-goals: ◆ 13.1 Strengthening resilience to climate-related risks. ◆ 13.2 Integration of climate protection measures into corporate strategies. S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4 N A B A L T E C A G

04 G E N E R A L I N F O R M A T I O N In specific areas, our sustainability work is also based on the following international agreements, standards and legal requirements: ◆ Paris Climate Agreement The agreement has formed the international framework for climate protection since 2015. Nabaltec supports the goal of achieving net-zero greenhouse gas emissions by 2045 at the latest and aligns its climate strategy with science-based pathways. ◆ United Nations Universal Declaration of Human Rights This declaration defines fundamental human rights, including respect for the dignity, freedom and equality of all people. We recognize the universal rights enshrined in the Declaration of Human Rights as a binding framework and consistently take them into account in our company and in all supply- chain-related decisions. ◆ Fundamental principles of the International Labour Organization (ILO) These principles, such as the prohibition of child and forced labor, freedom of association and the right to collective bargaining, represent internationally recognized standards for fair and humane working conditions. Nabaltec is committed to complying with them and regards them as binding guidelines for dealing with labor and social standards. ◆ OECD Guidelines for Multinational Enterprises The Guidelines provide companies with key principles on human rights, the environment, labor, anti-corruption and disclosure. The guiding principles help us at Nabaltec to recognize risks along the value chain at an early stage, to communicate credibly with stakeholders and to develop sustainable business relationships. ◆ UN Global Compact With its ten principles, the UN Global Compact sets out fundamental expectations for corporate behavior at an international level. It serves Nabaltec as a central orientation framework for responsible corporate governance in a global context. ◆ Responsible Care Global Charter This voluntary commitment by the chemical industry stands for continuous improvement in the areas of environment, health and safety. By signing the charter, Nabaltec supports the principles of the charter and is committed to the safe and responsible handling of products throughout their entire life cycle. Other internal company guidelines specify individual topics, such as the environment, human rights, occupational safety, compliance and supply chain responsibility. N A B A L T E C A G S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4

I D E N T I F I C A T I O N O F K E Y T O P I C S 05 IDENTIFICATION OF KEY TOPICS Effective sustainability management is based on clearly defined fields of action. We determine these with the help of a double materiality analysis. In doing so, we evaluate systematically: ◆ the impact of our business activities on the environment and society (“Impacts”), ◆ sustainability-related risks and opportunities for our company (“Risks and Opportunities”). We update the results at least every three years or in the event of significant changes. They form the basis for our strategic goals and measures. The analysis and evaluation process comprises several iterative steps: First, we analyze the business and regulatory environment. We then build up targeted knowledge on sustainability issues and involve internal and external stakeholders. Finally, we systematically assess material sustainability topics based on the strength of their associated impacts, risks and opportunities (IROs). From this, we derive specific targets and measures, determine responsibilities and define relevant monitoring and reporting structures. S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4 N A B A L T E C A G

06 N A B A L T E C ’ S C E N T R A L S U S T A I N A B I L I T Y A C T I O N A R E A S NABALTEC’S CENTR AL SUSTAINABILIT Y AC TION AREAS Our central ﬁelds of action in the area of the environment ◆ Climate protection and decarbonization: We will become climate-neutral in the long term. To achieve this, we are gradually reducing emissions along our entire value chain - primarily through greater efficiency, renewable energies and low-emission raw materials. ◆ Energy efficiency: We are increasing in all areas of the company energy efficiency - through targeted investments in modern, energy-saving technologies, the needs-based replacement of outdated systems and the orientation towards and implementation of proven best-practice solutions. ◆ Conserving resources and the circular economy: We use natural resources carefully, especially water and raw materials. We use closed-loop systems, reuse materials and reduce waste in production. ◆ Environmental management and monitoring: We integrate environmental aspects into our corporate processes through certified management systems in accordance with ISO 14001 and ISO 50001. These systems enable us to continuously monitor, optimize and manage our environmental and energy targets. ◆ Industry-specific standards and guidelines: In addition to regulatory requirements (e.g. REACH), we take into account industry-specific environmental standards and guidelines (e.g. RoHS, SVHC) with the aim of minimizing environmental impact and ensuring maximum product safety. We rely on suitable control mechanisms and internal standards to identify and avoid potential risks along the value chain as early as possible. ◆ Production of environmentally friendly products: By manufacturing environmentally friendly, non-toxic products that do not release harmful chemicals, we make a positive contribution to environmental protection. At the same time, we are making a significant contribution to sustainable future technologies with our product portfolio - for example in the field of electromobility. N A B A L T E C A G S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4

N A B A L T E C ’ S C E N T R A L S U S T A I N A B I L I T Y A C T I O N A R E A S 07 Our central ﬁelds of action in the area of social aﬀairs ◆ Retain employees in the long term: We offer a stable and future-oriented working environment as a basis for the recruitment and long-term retention of qualified specialists. We position ourselves as an attractive employer through a corporate culture that is geared towards the different life phases of our employees and supports their individual development. ◆ Enable work-life balance: We consistently promote the compatibility of family and career. Flexible working models, part-time options and reliable support services are an expression of social responsibility for us and increase the satisfaction of our employees. ◆ Ensure safe, fair and healthy working conditions: We attach great importance to ensuring a non-discriminatory, safe and healthy working environment based on respect, fairness and long-term employment prospects. We pay attention to fair remuneration, conditions in line with collective agreements and the protection of physical and mental health. We have a comprehensive certified occupational health and safety management system for implementation and continuous improvement. ◆ Targeted promotion of training and further education: We invest specifically in the training of young people and focus on the continuous further qualification of our employees in order to secure skilled workers in the long term and systematically promote individual development potential. This will strengthen our competitiveness and innovative power in the long term. ◆ Assuming social responsibility: Nabaltec is closely linked to its home base in Schwandorf and the region. We make an active contribution to local social development by supporting social projects, educational initiatives and charitable institutions in the region. Our central ﬁelds of action in the area of corporate management ◆ Anchoring sustainability in corporate management: We systematically integrate ethical, social and ecological standards into our management processes by incorporating sustainability aspects into existing risk and opportunity management - as described in the following section on managing sustainability in the company - and carrying out structured monitoring of sustainability targets and measures. ◆ Responsibility along the supply chain: We rely on structured and risk-based supplier management. We give preference to suppliers who are certified according to recognized international environmental and social standards. We attach particular importance to climate protection, biodiversity and resource conservation and respect for human rights. To this end, we have implemented an audit and management process to ensure legal compliance, minimize supply chain risks and ensure sustainable raw material procurement. S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4 N A B A L T E C A G

08 M A N A G I N G S U S T A I N A B I L I T Y I N T H E C O M P A N Y ◆ Taking sustainable product responsibility: We integrate sustainability aspects into research, development and product design at an early stage. Resource efficiency, environmental compatibility, durability and recyclability are at the heart of our innovation processes. ◆ Maintaining and expanding innovative strength: We create space for continuous improvement, promote internal idea processes and cooperate with external partners to develop sustainable solutions in line with technical, regulatory and social requirements. ◆ Promote integrity and transparency: We foster a corporate culture of openness, compliance and integrity. Through transparent reporting channels and training, we raise awareness of legally and ethically correct behavior at all levels. MANAGING SUSTAINABILIT Y IN THE COMPANY Integration of risks, opportunities and impacts into existing risk and opportunity management The Management Board bears overall responsibility for risk and opportunity management at Nabaltec, including the assessment and management of potential effects on the company and its environment. Controlling is responsible for the operational management, implementation and further development of the system. The Supervisory Board regularly monitors the effectiveness of the risk and opportunity management system as part of its control function. At Nabaltec, sustainability is anchored as a strategic cross-cutting issue throughout the company and is integrated into risk and opportunity management. Risks arising from regulatory, competition law or environmental requirements are proactively identified, evaluated and integrated into decision-making processes by internal experts from the areas of quality assurance and sustainability, regulatory affairs, environmental and occupational safety and patent law. N A B A L T E C A G S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4

M A N A G I N G S U S T A I N A B I L I T Y I N T H E C O M P A N Y 09 Ultimate responsibility for sustainability management at Nabaltec lies with the Chairman of the Management Board, who is responsible for strategic corporate planning as well as the relevant sustainability areas such as corporate governance, technical services, quality, environmental and energy management, occupational safety, environmental protection and plant and process development. This means that sustainability has been established at the highest organizational level and is managed in close coordination with the operating units. Sustainability management has a cross-divisional impact and is designed to combine long-term responsibility with economic performance. The Head of Quality Assurance and Sustainability is responsible for the operational coordination and further development of sustainability management at Nabaltec. This function serves as an interface between the specialist departments in order to systematically integrate sustainability issues into all relevant areas of the company. Monitoring of sustainability goals and measures Continuous monitoring of the targets set, measures adopted and key performance indicators defined is an integral part of Nabaltec’s sustainability strategy. A clearly structured monitoring process creates transparency, enables accountability and promotes the continuous improvement of our sustainability efforts. The Head of Quality Assurance and Sustainability is responsible for the overarching implementation and achievement of sustainability targets. In this function, he reports regularly, but at least once a year, on progress and further development to the Executive Board as the highest level of responsibility for sustainability in the company. Data and information basis Effective management of sustainability goals requires a reliable and consistent data and information basis. Nabaltec therefore defines clear requirements for the collection, processing and quality assurance of sustainability data and information. This includes both internal data sources (e.g. from production, personnel, purchasing, finance) and external information along the value chain. To ensure the availability, quality and consistency of our data: ◆ responsible specialist departments, ◆ regular survey intervals, ◆ and documentation standards are defined. The data is provided in accordance with the requirements of international reporting standards and is designed for subsequent verifiability by third parties. In addition, processes for quality assurance, plausibility checks and progress tracking are established. S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4 N A B A L T E C A G

10 M A N A G I N G S U S T A I N A B I L I T Y I N T H E C O M P A N Y Ongoing reporting Until 2024, Nabaltec published sustainability-related information in accordance with the recommenda- tions of German Accounting Standard 20 (DRS 20) exclusively as part of the non-financial statement in the annual report. To document our commitment to sustainability and in view of increasing regulatory requirements and the expectations of our stakeholders, a separate, comprehensive sustainability report will be published additionally for the first time for the 2024 financial year. This report is and future reports will be based on European and international reporting standards. The publication of the sustainability report for the 2024 financial year marks the start of a systematic recording and presentation of our sustainability performance. The aim is to create a long-term data basis on the basis of which we can continuously develop our sustainability strategy and communicate it to our stakeholders in a comprehensible manner. Dealing with violations Promoting Nabaltec’s sustainability principles is the responsibility of all employees and stakeholders. Only together can we establish a sustainable corporate culture and achieve the goals we have set ourselves. This also includes not tolerating abuses and actively following up on reports of violations. Nabaltec strongly encourages all its employees and stakeholders to clearly address any behavior that may violate applicable law or the company’s ethical principles. Information on possible irregularities can be reported confidentially and anonymously via various reporting channels, such as the whistleblower system implemented together with the external service provider Ratisbona Compliance. Reports can be made digitally via a reporting platform, by telephone or in person. All information received will be reviewed promptly, confidentially and with the necessary neutrality. Whistleblowers will be protected from any form of discrimination - retaliation against employees who report a possible violation in good faith is expressly prohibited. If violations are proven, Nabaltec reserves the right to take appropriate measures depending on the severity. The focus is not to be on issuing warnings, but on improving our structures to prevent future violations. N A B A L T E C A G S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4

F I N A L P R O V I S I O N S 11 FINAL PROVISIONS Responsibility for the implementation of the policy Responsibility for the implementation of this policy lies with the Management Board of Nabaltec AG. Accessibility and validity The sustainability policy will be communicated proactively and transparently. Internally, it will be presented to all our employees. It will also be published on our website and can therefore be accessed and viewed by our external stakeholders and the public at any time. The policy is available for all interested readers to download at any time. Our sustainability policy will take immediate effect until amended or replaced. It will regularly be reviewed and adjusted as necessary to ensure that it is always in line with the corporate strategy and in line with current market practices and best practices. Changes require the approval of the Management Board of Nabaltec AG. Legal notice This policy reflects Nabaltec AG’s understanding of sustainability. It serves as a guide, but does not establish any contractual obligations or enforceable claims against the company. Schwandorf, 1 December 2025 Johannes Heckmann, CEO S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4 N A B A L T E C A G

12 I M P R I N T IMPRINT Publisher Nabaltec AG Version and key date Version 1.0, valid since signed by the Management Board on 1 December 2025 Reviewed by Johannes Heckmann, CEO Approved by Johannes Heckmann, CEO Website www.nabaltec.de/en Contact Text Nabaltec AG Alustraße 50 – 52 92421 Schwandorf, Germany Phone: +49 9431 53- 298 E-mail: info@nabaltec.de Internet: www.nabaltec.de/en/press/contact Nabaltec, Schwandorf, Germany cometis, Wiesbaden, Germany Concept & Design Silvester Group, www.silvestergroup.com N A B A L T E C A G S U S T A I N A B I L I T Y P O L I C Y 2 0 2 4

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Nabaltec AG Alustraße 50 – 52, 92421 Schwandorf, Germany Phone: +49 9431 53-298, Email: info@nabaltec.de, www.nabaltec.de/en