General disclosures

Basis for preparation of the Sustainability Statements

Introduction

The Netherlands is preparing to transpose the EU Corporate Sustainability Reporting Directive (CSRD) into national legislation. These Sustainability Statements have been prepared on a voluntary basis and largely align with the European Sustainability Reporting Standards (ESRS). The Sustainability Statements are not in compliance with ESRS. TSN is issuing its Sustainability Statements for the year ending 31 March 2026, and based on the outcome of our Double Materiality Assessment (DMA).

The section titles used in the Sustainability Statements mirror the layout of the ESRS. The Sustainability Statements comprise the Sustainability Statements chapters and additional information incorporated by reference. Terms and definitions used in the text are defined by TSN unless explicitly stated otherwise.

Reporting entity

The Sustainability Statements are prepared on a consolidated basis and encompass Tata Steel Nederland B.V. and its subsidiaries (“the Group”, “TSN Group”). Non-consolidated joint ventures, joint operations and associates are not included. The basis of consolidation specified by the ESRS varies per topic. For each environmental, social or governance related topic, the ESRS define the relevant reporting boundary. Depending on the topic, this may require reporting based on financial control (for water use, resource use, and circular economy), reporting based on relationships (covering own employees, workers in the value chain, and impacted communities), or reporting using a combined operational and financial control approach under the ‘ESRS boundary’ (for energy and GHG emissions). These boundaries differ from TSN's historical reporting. Reporting energy and GHG emissions takes place on the basis of consolidated accounting group. Although acquisition of LAG Velsen B.V. is recognised in the financial statements as of 1 January 2026, reporting includes related energy and GHG emissions for the full reporting period. Prior to the acquisition, LAG Velsen B.V. was understood to be under operational control of TSN. More details can be found in accounting policies disclosures related to specific metrics, which are presented alongside topical disclosures.

When assessing impact, risks and opportunities, as part of the Double Materiality Assessment, TSN considered the entire value chain. Selected policies, actions and targets extend to our value chain where relevant. Only a limited number of metrics extend to the value chain; these are related to the topics of ‘Climate change’ and ‘Workers in the value chain’.

Time horizons

This Sustainability Statements have been prepared in line with the time horizons set out in ESRS 1: the short-term horizon is defined as 0–1 year, the medium-term horizon as 1–5 years, and the long-term horizon as beyond 5 years. 

For our climate-related risks and scenario analysis, we apply different long-term horizons. For Physical Risk, long-term is 2050 (4°C scenario), and for Transition Risk, long-term is 2045 (1.5 and 2.5 °C scenario).

Comparative information

This reporting year, TSN made significant efforts to improve the definition and calculation of metrics. This was aimed at achieving greater alignment with ESRS and better sustainability reporting. This resulted in changes, replacement, and the introduction of new metrics as well as ceasing the disclosure of selected metrics. The accounting policies of the metrics involved provide information about the changes. Comparative information is revised unless it is impracticable to revise comparative amounts. In such cases, TSN discloses this fact. Any revision of comparative figures is explained in the notes to the relevant metric, including the difference from the previously disclosed amount. Comparative information is not presented for material impacts, risks and opportunities or related topics reported for the first time in the reporting period, in line with ESRS 1. TSN will continue to improve the definition and calculation of metrics, which may lead to adjustments of comparative information in sustainability reporting over future reporting periods.

This applies to the following topics:

• Own workforce, matter of working time, health and wellbeing, gender pay gap, incidents of discrimination and other human rights incidents;

• Business conduct, matter of political influence and lobbying;

• Polltion, substances of very high concern;

• Resource inflows, externally sold by-products.

Comparative information is also not presented when revision is impracticable. This applies to the following topic:

• Climate change, Scope 3 GHG emissions;

• Own workforce, coverage by collective bargaining agreements. 

Material judgement and information subject to significant uncertainties and (inherent) limitations

In preparing qualitative and quantitative disclosures, judgement is exercised and estimates and assumptions are applied.

The preparation and presentation of the Sustainability Statements require the application of professional judgement to determine which information is relevant, reliable and useful for disclosure. This includes identifying material impacts, risks and opportunities, the likelihood of their occurrence, and relating them to the relevant topic. It also includes identifying material information and interpreting reporting requirements.

This report contains selected forward-looking statements relating to our sustainability ambitions, targets and anticipated performance in the short, medium and long term. We acknowledge inherent uncertainties of these statements and note that actual outcomes may differ materially from those expressed or implied due to a range of factors. Stated ambitions and targets are formulated on the basis of the assumption that the Tailor‑Made Agreement will be concluded. Setting targets in absence of the Tailor-Made Agreement is subject to significant uncertainty; no separate targets for the scenario when the Tailor-Made Agreement is not concluded are reported in the 2025/26 Statements. No information about any anticipated financial effects of sustainability-related risks and opportunities is reported this year.

The list below summarises the significant uncertainties affecting the qualitative information, quantitative information, metrics and monetary amounts presented in these Sustainability Statements. These uncertainties arise when information relies on estimates, assumptions, proxy data, external factors or forward-looking information. Information on measurement uncertainties and assumptions can be found in the respective topic-specific sections.

• Our GHG emissions calculations are largely based on the use of databases for emission factors.

• Within our own operations, the emission levels of pollutants are measured at different frequencies and multiple measuring points, in accordance with local regulations and permit requirements. The sample locations and frequency are designed to deliver the most representative data set possible, taking into account the inevitable variations across an operating plant located over a large surface area. As with all sampled data, however, it cannot be guaranteed that all emissions are detected 100% of the time. This is an inherent limitation.

• For reporting water consumption, we apply defined estimation methods, such as assuming full discharge of seawater used for once-through cooling and a small evaporation loss for brackish water. Another limitation relates to permit-based estimates for certain unmetered discharge flows.

• There is uncertainty about future events related to the Green Steel Project. Due to the long-time horizon and significance of the investments related to the project, TSN’s disclosures about this project are subject to uncertainties.

• For selected topics, calendar year data is used as a proxy for reporting financial year information. This is stated in relevant accounting policies alongside metrics disclosures.

The judgements and (inherent) uncertainties and limitations mentioned above, in conjunction with the recognition that TSN's management systems, controls, (quality and reliability of) data and performance relevant to preparing these Sustainability Statements are not yet at the level that TSN aims to achieve, make that that the information included in these Statements is subject to possible adjustments in future reporting periods.

Use of relief for metrics with partial scope

These Sustainability Statements contain information about selected material impacts, risks and opportunities identified in TSN's own operations with partial scope of the relevant reporting boundary. Such cases relate to metrics where TSN is unable to use reliable direct or estimated data for part of the scope. Due to the novelty of the reporting framework, TSN needs time to gradually improve the quality of data and increase coverage in future reporting periods. Partial scope in this reporting period includes information about Tata Steel IJmuiden (TSIJ) as a basis, and additionally information about relevant other subsidiaries of TSN, where data quality permits.

Significant events after the end of the reporting period

No significant events occurred after the end of the reporting period that would require adjustment or disclosure in these Sustainability Statements. Except for the matter temporary suspension of DSP operation in April 2026 due to chrome-6 emission levels exceeding permit thresholds, as reported in the Pollution chapter. ​

Changes in preparation or presentation

Selected comparative information is revised due to changes in definitions and calculation methodologies to reflect the maturing approach to measurements and reporting. Such revisions were made where practicable, meaning that sufficient reliable historical information was available to enable revision. This is stated in relevant accouting policies.

Relief for metrics in the value chain

We are using the transitional provision to not disclose metrics for the following topics: 'Workers in the value chain’, 'Responsible value chain’ and ‘Affected communities in the IJmond region’.

Relief for acquisitions and disposals

During the reporting period, TSN completed the acquisition of LAG Velsen B.V., thereby becoming the owner of three power plants previously owned by Vattenfall. Use of relief for acquisitions is partially applied to this acquisition of LAG Velsen B.V. The acquisition is recognised in the financial statements as of 1 January 2026. Metrics related to energy consumption and production and direct and indirect GHG emissions (Scopes 1 and 2) include information about the LAG Velsen B.V. Reporting consolidated amounts for energy and GHG emissions historically included LAG Velsen B.V. which was under operational control prior to acquisition. There is therefore no significant difference in the total amounts reported for these metrics. No other metrics include information about LAG Velsen B.V. in this reporting period, and were not historically reported. The sustainability impacts, risks and opportunities associated with the acquired business will be assessed and, where relevant, reflected in the materiality assessment and sustainability reporting for the subsequent reporting period.

Governance

The role of the administrative, management and supervisory bodies

Overseeing material sustainability impacts, risks and opportunities at TSN involves numerous administrative, management and supervisory bodies. The chart below aims to provide an understanding of the composition of the administrative, management and supervisory bodies relevant for overseeing and managing sustainability impact risks and opportunities. The chart is not exhaustive. Names of functions may not be identical to names of departments.

Composition of the TSN's administrative, management and supervisory bodies

The Board of Management (BoM) is responsible for the daily management of TSN as well as overseeing sustainability impacts, risks and opportunities. It does so by approving sustainability policies, strategy and targets and reviewing progress. The Supervisory Board (SB) oversees and advises the BoM. The BoM has oversight and control over sustainability matters. Our transformation and CSRD implementation are driven from across the functions. 

The Director of Sustainability reports to the CEO and is supported by senior managers and experts from various functions. He leads the Sustainability function and advises the BoM on sustainability strategy, reporting and accreditations. He is responsible for developing, enhancing and overseeing the implementation of sustainability policies across TSN Group. He plays a crucial role in driving CSRD implementation.

Detailed profiles, backgrounds and qualifications of the BoM and various Committee members, including skills and expertise, as well as diversity and independence ratio can be found in the section in the Management Report.

The BoM has collective expertise across sustainability, sustainability reporting, risk and compliance, health, safety and environment, and internal audit. It is supported by relevant internal functions with specialist knowledge in these areas. Where appropriate, external advisors are engaged on a project specific basis.

During 2025/26, the BoM was informed about the status of CSRD readiness and approved the hiring of external advisors for support. The CEO and CFO were regularly updated about the readiness status and implementation activities. These activities were related to conducting the Double Materiality Assessment, improving definitions and calculations, processes, roles and responsibilities, internal controls, risk and compliance, due diligence, and conducting impact assessments, among other areas.

Sustainability-related performance incentives

The remuneration of the members of the BoM for the financial year 2025/26 and remuneration policies for members of administrative, management and supervisory bodies can be found in the Remuneration Report section of the Management Report.

Statement on due diligence

The due diligence process is an ongoing series of actions designed to identify, prevent, mitigate and account for how TSN addresses the actual and potential negative impacts on the environment and people. In this reporting period, TSN worked on improving its due diligence process. Key initiatives started in the reporting period and which TSN plans to continue after the period end are:

• Formalising and documenting the stakeholder engagement framework.

• Developing TSN's Human Rights Policy and Responsible Supply Chain Policy. Defining governance, including roles and responsibilities, for their effective implementation.

• Improving the approach to grievance and complaints mechanisms covering both local communities and the value chain. Improving the approach to assess the effectiveness and accessibility of such mechanisms. Developing processes for information tracking to ensure timely and fair resolution of issues.

• Maturing the integration of due diligence into supplier risk assessment. Developing a framework for supplier due diligence and risk assessments.

The table below outlines how the key elements and phases of the due diligence process are incorporated into the TSN sustainability statement, indicating where each component is addressed. At this stage, maturity of core elements of our due diligence varies. 

Mapping of due diligence core elements to sustainability statement sections

Risk management and internal controls over sustainability reporting

During the 2025/26 financial year, TSN focused on the setup and initial implementation of sustainability reporting controls as part of its CSRD programme. We recognise the complexity of sustainability reporting, involving a diverse range of topics. We acknowledge that this process will take time and our control environment for sustainability reporting will undergo annual improvement cycles. This year, we focused on targeted risk assessments identifying key risks related to data completeness and integrity, consistency of definitions and methodologies, data availability across subsidiaries and the timeliness of information. Controls are designed and executed by the responsible operational functions and include management reviews and senior oversight. As noted above, these controls are not yet at the level that TSN aims to achieve.

We aim to progressively enhance sustainability reporting controls and further integrate these into TSN’s broader internal control environment as part of the multi‑year In Control Programme, with oversight exercised by executive management and progress reported through established governance channels.

TSN is in process of integrating sustainability related risks into TSN’s enterprise‑wide risk management and internal control framework, as described in the Risk & Compliance chapter of this Annual Report. Within this COSO‑aligned framework, TSN has continued to develop dedicated internal controls over sustainability reporting to support the preparation of reliable, complete and consistent sustainability information in accordance with applicable laws, regulations and internal requirements.

Strategy

Strategy, business model and value chain

TSN Group operates an integrated steelmaking business model focused on the production of high-quality flat steel products, including hot-rolled steel, cold-rolled steel and a range of specialty grades essential to industrial and consumer applications.

Steel is indispensable for the energy transition, such as for solar farms, batteries for electric vehicles and the production of lighter, sustainable products. Steel is made from iron ore, which can be found in the earth's crust at many locations. In some places in Australia, South America, India and Scandinavia, ore is close to the surface, making it easy to extract. Details about our supply chain can be found in the section Responsible value chain. A list of key materials in our resource inflows and related metrics can be found in the section Circular economy and resource use.

Tata Steel Nederland (TSN) is one of the major steel producers in mainland Europe, with approximately 12,000 employees. We supply high-quality steel and steel products to customers, most of whom are located in Europe, with some in the US. The TSN Group headcount by geographical area is disclosed in the section Own workforce.

A brief explanation of the process of making steel and steel products can be found on our website under the links Process of steelmaking | Tata Steel and Plants | Tata Steel.

Business model

In IJmuiden, we produce iron from ore and coal. TSN has long held a leading position in energy-efficient iron- and steelmaking. However, our continued reliance on fossil resources means that residual greenhouse gas emissions remain challenging to abate. Achieving significant reductions will require a transition to new technologies, strong collaboration across our complex global supply chain, and supportive policies and actions from public authorities. As part of the Green Steel Project, we are planning to switch to a production method that is better for the environment: ore and hydrogen and/or natural gas or biomethane. This requires that we replace the plants on our site and infrastructure. Until we have done that, we will continue to use our blast furnaces. More information about the transition plan can be found in the section Climate change.

The steel industry is an energy-intensive sector with inherent emissions and environmental impacts, which necessitate effective pollution control. Given the complexity of TSN’s industrial operations, incidents causing environmental pollution are an inherent risk. TSN has implemented standard procedures to prevent such incidents and to manage any that may occur. 

The process of steel manufacturing produces blast furnace slag as the melted leftovers from making iron, and steel slag as the residue that forms when impurities are removed during the steelmaking process. The Dutch government has imposed partial and temporary bans on the use of steel slag in specific applications. Restrictions are application specific with some permitted uses. These requirements limit how TSN can apply or market steel slag as a by‑product domestically.

Improper use of steel slag, for example in road construction without adequate treatment or containment, can lead to a negative environmental impact. When properly treated the reuse and recycling of blast furnace slag (BFS) and steel slag contribute to decarbonisation and circularity in other sectors by replacing CO₂-intensive raw materials. TSN takes measures to promote compliance with environmental legislation among users of steel slag, in order to mitigate associated risks. TSN is deploying a slag roadmap and implementing duty of care for by-products. This is aimed at preventing health risks from inhalation and skin, mouth and eye contact. In addition, TSN has established policies and actions aimed at integrating circular economy principles across its operations. More about our policies and actions related to this matter can be found in the chapter Circular economy and resource use.

Steelmaking in IJmuiden involves emissions and operational activities that may affect the local environment and contribute to nuisance experienced by nearby residents, such as noise, dust and odour. We recognise the importance of addressing community concerns in the IJmond region and of managing potential environmental and health‑related risks in accordance with applicable regulations. As reported previously, we developed a comprehensive Roadmap plus programme to tackle noise, dust, odour and emissions and aim to continue doing so. More information about the Roadmap plus programme, its results, future planned actions as part of the Green Steel Project and how we engage with residents is reported in the sections Pollution and Affected communities in the IJmond region.

While steel is produced in IJmuiden, it is further processed at our various sites in Europe for high-quality applications. We produce coated steel for the agricultural sector, manufacture precision tubes and structural hollow sections, and process steel for use in batteries and cars or for innovative products in roof and wall cladding. With services including decoiling, blanking and slitting, we serve various customer groups.

Business Units of TSN Group:

TSN operates a diversified portfolio of downstream steel businesses that serve construction, industrial and manufacturing markets. The Building Systems business unit manufactures coated steel products for the agricultural sector, housing and construction, supplying applications such as roofing, façades and drainage systems. The Colors business unit produces pre‑painted steel coils with corrosion protection and UV resistance, which are used in construction products including roof and wall cladding, as well as in a range of industrial applications such as garage doors, cold storage, lighting, domestic appliances and door frames.
The Distribution business unit processes steel sourced from Tata Steel IJmuiden and third‑party suppliers through activities including decoiling, blanking and slitting, enabling tailored supply to customers. The Plating business unit supplies specialised steel products to sectors including battery manufacturing and automotive applications, with processing activities in cold rolling mills and annealing plants in Germany and the United States for uses such as batteries, brake lines and fuel lines.

The Tubes business unit produces structural, precision and galvanised steel tubes in a range of steel grades, including high‑strength qualities, serving applications across construction, engineering, automotive, heating systems, industrial packaging and household appliances.

TSN Group serves numerous industrial markets, including:

• Construction & infrastructure

• Automotive

• Agriculture

• Consumer goods manufacturing

• Energy & power

Key consumer groups of the Group include:

• Industrial manufacturers in automotive, construction and engineering requiring durable, customisable flat steel products.

• Manufacturers of domestic appliances, furniture and home heating products.

• Public and infrastructure contractors, historically using TSN’s by-products in civil engineering applications.

Strategy

Sustainability is embedded in TSN’s overall strategy through the company‑wide SCALE transformation programme,which combines financial performance improvement, the Green Steel Project and Licence to Operate. Further details are provided in the Strategy section of the Annual Report.

As an operator in a hard‑to‑abate sector, we recognise that steelmaking is associated with significant environmental and social impacts, risks and opportunities. Our double materiality assessment provides us with a holistic overview of the material matters. This in turn informs our sustainability strategy and sustainability statements. Selected material topics are also of significant importance to our stakeholders, including local communities, NGOs, local authorities and regulators. Decarbonisation, pollution and impacts on nearby communities are outlined in the Joint Letter of Intent (JLoI) between TSN and the Dutch government. Our key efforts across these topics are summarised in sections Green Steel Project and Licence to Operate.

The Sustainability Statements build on these two sections by providing a comprehensive overview of TSN’s material sustainability impacts, risks and opportunities. The Statements also include topics such as water management, biodiversity, own workforce, responsible value chain and governance, and serve as the primary source of detailed sustainability information.

Value chain

TSN’s value chain encompasses the process from raw material procurement to the distribution and recycling of finished steel products. Upstream, raw materials such as iron ore and coal are procured from international suppliers and transported to IJmuiden via the seaport. They are then processed by TSN to produce steel, which is transported to external customers and TSN's own downstream operations. We distribute finished products to customers directly from TSIJ, or via TSDE business units and our network of distribution hubs, via rail, road and water. TSN’s products are used in various market segments and eventually undergo end-of-life treatment, often involving the collection and recycling of scrap steel.

An overview of our value chain is presented in the Who we are section of the Annual Report.

Interests and views of stakeholders

TSN continues to further develop its approach to stakeholder engagement across the value chain, including with employees, neighbouring communities and other affected parties. These engagements help us better understand stakeholder concerns and expectations, assess the impacts of our activities and identify areas requiring follow‑up actions. Stakeholder insights are used as input for our risk assessments and to support continuous improvement.

Feedback from key stakeholders is actively sought and taken into account when reviewing our strategy and business model, including our sustainability priorities. In particular, stakeholders in the IJmond region continue to express concerns about our emissions and their potential health impacts. We take these concerns seriously and consider them an important driver for improving our operations and reducing impacts where possible.

Recent regulatory findings and fines for breaches of environmental and compliance requirements underline the urgency of these efforts and clearly show that we have not met stakeholder expectations. We regret this and acknowledge the seriousness of these outcomes, as further described in the Stakeholder engagement section of this Annual Report.

The Board of Management and the Supervisory Board are kept informed of stakeholder engagement outcomes and related perspectives through regular management reporting. As part of the ongoing development of our stakeholder engagement practices, we are strengthening how stakeholder views are assessed, escalated and acted upon. This is intended to ensure that relevant perspectives reach the appropriate decision‑makers within TSN and that follow‑up actions are clearly defined. Further information on our stakeholder engagement approach is provided in the relevant topical chapters.

Material impacts, risks and opportunities

TSN conducted a double materiality assessment (DMA) to identify the material impacts, risks and opportunities (IRO). This has resulted in the material IROs as outlined below. The overview illustrates where these IROs are located in the operations and value chain, connecting them to the overarching strategy and business model. Details of how we manage material IROs can be found in the topical chapters.

Material impacts, risks and opportunities for TSN in the reporting period

As part of the 2025/26 reporting cycle, TSN updated its initial double materiality assessment to reflect developments in its activities, operating environment and stakeholder expectations. The main changes compared with the prior assessment are summarised below.

• New material negative impact related to working time, health and wellbeing of own workforce.

• New material positive impact related to reskilling of own workforce for green transition.

• New material opportunity related to low-CO₂ steel products.

• New positive impact related to enablement of green hydrogen economy.

• New material negative impact of warm-water discharge related to biodiversity.

• New positive impact related to the use of blast furnace slag.

• New material positive impact and opportunity related to resource inflows, particularly circularity.

• New material risk related to improper use of steel slag.

• New material positive impact related to transition of TSIJ steel manufacturing site and related political influence and lobbying.

Interaction of material impacts risks and opportunities with strategy and business model, and financial effects

TSN’s strategy and business model interact closely with its material sustainability matters, particularly climate change mitigation, pollution prevention, resource efficiency, circularity, and community wellbeing in the IJmond region. TSN’s long-term decarbonisation pathway is built around replacing traditional blast furnaces with Direct Reduced Iron (DRI) plants and Electric Arc Furnaces (EAF), targeting significant reduction of greenhouse gases emissions and carbon-neutral production by 2045. Planned strategy emphasise the execution of the Green Steel Project, increased use of scrap to enhance circularity, and significant investments to transition towards hydrogen-based steelmaking infrastructure. Funding of our planned decarbonisation measures is part of the negotiations and subject to reaching a Tailor-Made Agreement. In parallel, TSN’s focus on high-quality, durable and recyclable steel products supports downstream customers in meeting their own sustainability objectives. Further information on the Green Steel Project is provided in the Climate change chapter.

Tata Steel Nederland’s sustainability strategy is focused on the progressive transformation of its IJmuiden operations towards cleaner, greener and more circular steel production. The strategy prioritises the reduction of particulate matter, nitrogen oxides and heavy-metal emissions, supported by targeted environmental improvement programmes, including the Roadmap Plus programme and the planned installation of a large-scale DeNOx facility.

TSN’s long-term decarbonisation pathway is built around replacing traditional blast furnaces with Direct Reduced Iron (DRI) plants and Electric Arc Furnaces (EAF), targeting significant reduction of greenhouse gases emissions and carbon-neutral production by 2045. Planned strategy emphasises the execution of the Green Steel Project, increased use of scrap to enhance circularity, continued collaboration with the Dutch government under the Tailor-Made Agreement, and significant investments to transition towards hydrogen-based steelmaking infrastructure. Funding of our planned decarbonisation measures is part of the negotiations and subject to reaching a Tailor-Made Agreement. Further information on the Green Steel Project is provided in the Climate change chapter.

The topical chapters of the Sustainability Statements provide details on actions resulting from the current and planned strategy.

TSN has assessed the current financial effects associated with its material sustainability-related risks and opportunities. This assessment evaluated whether any of the identified risks and opportunities had a material effect on TSN’s financial position, financial performance or cash flows during the reporting period. Where material financial effects were identified, these are described and, where applicable, quantified in the relevant topical chapters.

The effects on TSN’s financial position and financial performance for the financial year 2025/2026 are disclosed with reference to the consolidated financial statements, where relevant. No material effects on cash flows were identified in the reporting period and are therefore not presented. Information on anticipated financial effects has been omitted in accordance with the phased‑in disclosure provisions of ESRS 1 (Appendix D).

In addition, the disclosures about climate change scenario analysis and resilience can be found in the chapter Climate change.

Process to identify and assess material impacts, risks and opportunities

TSN conducts an annual Double Materiality Assessment (DMA) to identify and assess actual and potential sustainability related impacts, risks and opportunities across its value chain in accordance with ESRS 1 and ESRS 2. In line with the principle of double materiality, sustainability-related topics were considered material if they were material from the perspective of impact materiality or from the perspective of financial materiality, or both.

In 2025/26, TSN performed its second full DMA cycle, updating and refining the assessment conducted in the previous year. The updated process incorporates new sector insights, stakeholder feedback and amendments introduced in the ESRS 1 – Exposure Draft (July 2025) simplification options.

Step 1: Review stakeholder- and value chain mapping

TSN began the current assessment by revisiting and updating the stakeholder mapping and value chain analysis initiated in 2025.

Stakeholders

The prior mapping formed the starting point and covered internal functions, employees, suppliers, customers, communities, regulators, NGOs and other parties potentially affected by TSN’s activities. TSN reviewed and expanded this mapping to ensure it reflects current realities and remains aligned with the range of individuals or groups that could experience material impacts through TSN’s operations or business relationships.

Value chain

TSN reassessed its value chain overview, covering upstream sourcing of materials, services and downstream product delivery. Attention was given to the locations and activities where TSN may cause, contribute to, or be directly linked to impacts, and where financial risks and opportunities may arise. As part of the update, TSN distinguished more explicitly between its business units (TSIJ and TSDE) and key activities within each. Overview of our value chain is presented in the Management Report, chapter Who we are.

Step 2: Identification of relevant sustainability matters

The identification phase was based on the prior year’s list of sustainability matters and associated IROs. These were refined using:

• Documentation prepared as part of the negotiations process and signing the JLoI. It included most recent and relevant insights into stakeholder engagement, also technical documentation, including impact assessments, project and technology descriptions.

• Peer and sector benchmarking, including metals and mining sector guidance, and

• Engagement with internal and external stakeholders.

Where relevant, sustainability matters were added, merged or redefined to reflect interconnections, sector developments or emerging issues. Descriptions of IROs were sharpened to move beyond the broader terminology used in the first assessment cycle.

TSN focused especially on activities, business relationships and geographies presenting heightened exposure to impacts or financial effects. Sustainability matters with short-, medium- or long-term relevance across the value chain were retained for further assessment.

Step 3: Assessment of impacts, risks and opportunities

For the 2025/26 reporting period, TSN applied the DMA simplification mechanism permitted under the Amended ESRS 1 – Exposure Draft (July 2025), specifically paragraph 3.4 and AR 17 to paragraph 48(a), which allows a top-down, topic focused approach.

Top-down materiality approach

• TSN determined “obviously” material or non-material (sub)topics at a topic level before assessing individual IROs.

• Full IRO-level assessment was performed only for topics classified as material or close calls.

Impact materiality assessment

• Negative impacts were assessed using criteria such as scale, scope, irremediability, and likelihood.

• Positive impacts were assessed using criteria such as scale, scope, and likelihood.

• The assessments considered both actual and potential impacts, as well as TSN’s involvement type (cause, contribute, directly linked).

Financial materiality assessment

• Financial effects were evaluated based on impact and likelihood, in alignment with TSN’s Enterprise Risk Management (ERM) manual and scoring framework.

Qualitative and quantitative methodology

TSN’s assessment used a combination of structured scoring, threshold mechanisms and qualitative judgment. TSN concluded that meaningful involvement from relevant departments and internal experts was essential to ensure robustness and contextual accuracy, especially in cases requiring professional judgment rather than purely quantitative scoring.

Step 4: Validation of assessment outcomes

Upon completion of the assessment, results underwent multilayer validation:

Internal validation

Senior management and subject matter experts reviewed the outcomes to confirm technical accuracy, alignment with business context and compliance with ESRS requirements.

External stakeholder validation

To further strengthen legitimacy, TSN involved a selected group of external stakeholders — including customers, NGOs, public agencies and representation groups — through structured interviews. Stakeholders validated the identified material topics and shared their expectations of what relevant information is expected by them. This input led to a better understanding of relevancy of information about material matters. Material information presented in these Sustainability Statements is informed by this consultation.

Final approval

The Board of Management (BoM) reviewed and approved the final set of material sustainability matters and associated IRO definitions. Following this approval, the results were presented to and discussed with the Audit Committee and the Supervisory Board.

Material information

Following the completion of the double materiality assessment, TSN has mapped material IROs to the disclosure requirements and data points within the ESRS.

To assess the materiality of information to be disclosed, a qualitative assessment was performed, rather than applying quantitative thresholds. This assessment focused on evaluating whether the information is relevant based on its significance to the matter it represents or its ability to meet the decision-making needs of users and wider stakeholders.

If a specific requirement was not found to align with a material IRO, the related data point or disclosure requirement has not been disclosed.