Billerud Aktiebolag

Billerud's Sustainability and Public Affairs department monitors polit­ical and legislative developments and identifies issues of particular significance to Billerud and its value chain partners. The dialogue with decision makers often takes place in coordination with industry asso­ciations such as the Swedish Forest Industries Federation or the two Brussels-based industry associations, CEPI and ACE. Billerud also participates in network collaborations such as GRACE, EXTR:ACT and 4Evergreen, with the aim of accelerating the development of tech­nologies and new processes to enhance sustainability and the circu­larity of fibre-based packaging. [...] Billerud's North Amer­ican team monitors political and legislative developments and engages in dialogue directly and through trade groups with decision makers."
"The Board of Directors regularly oversees the company's sustainability work, for example by addressing strategic issues, following up on risk management, and regularly receiving information on work relating to the operations. Billerud applies the Swedish Code of Corporate Governance, whereby the Board is responsible for identifying how sustainability issues impact risks to and business opportunities for the company. It also provides that the Board of Directors is responsible for defining appropriate guidelines to govern the company's conduct in society, with the aim of ensuring its long-term value creation capability, and for ensuring that there is an appropriate system for follow-up and control of the company's operation and the risks to the company that are associated with its operations. [...] The Board of Directors has adopted a Responsible Business Policy. The policy states that the Company shall have adequate compliance procedures for responsible business compliance consisting of, among other things, continuous risk assessments and procedures for due diligence. These procedures enable the identifying of wrongdoings or material breaches of the Code of Conduct. [...] The CEO is responsible for the ongoing overall operational management of Billerud's business operations in accordance with instructions and regulations established by the board. This includes the ultimate operational responsibility for climate-related issues. The CEO has signed and is ultimately responsible for the commitment to climate targets in line with Science Based Targets initiative and is responsible for the quarterly follow-up of the company's two main climate related KPIs, emission intensity and energy efficiency. Executive Vice President (EVP) Commercial reports to the CEO and has overall responsibility for the Sustainability and Public Affairs function, which is responsible for the ongoing work with climate-related issues such as analyses, follow-up and reporting. The Sustainability and Public Affairs function also has the responsibility for monitoring global developments, trends and regulations linked to climate issues. [...] An important part of the company's climate management is also the integration of climate-related targets in the company's incentive programmes for Europe. 10% of the possible outcome in the annual bonus programme was linked to climate and energy-related goals during 2022.

## 10. Accountability, monitoring, and compliance
This Policy has been approved by the Board of Directors of Billerud. The Policy owner EVP Legal & Strategic Projects is responsible for implementing this Policy, including by:

(i) developing more detailed rules (Directives) for the subject matter, consistent with the
purpose and intent of this Policy,
(ii) ensuring that the Policy and underlying Directives are communicated and known to
Representatives,
(iii) monitoring and following up compliance with the Policy and underlying Directives; and
(iv) taking other actions, including corrective and reporting measures necessary to achieve
the purpose and intent of this Policy.

Billerud's Representatives are expected to report violations (including suspected violations) of this
Group Policy to their immediate supervisor or to the Policy owner. Anonymous reporting of
wrongdoings can be made through Billerud's whistleblowing system (Speak-Up Line). Questions or
feedback about this Policy can be directed to the Policy owner.

Governance Climate-related risks and opportunities in Billerud are governed on a strategic level by the Board of Directors and on an operational level by the CEO, Group Management Team and EVP Sustainability & Public Affairs. The Board of Directors continuously manages climate-related risks, opportunities and impacts as part of the work with strategic issues concerning operations, investments and acquisitions. Climate-related issues are also a recurring agenda item at the company's board meet­ings. For example, the Board of Directors annually reviews the Group Sustainability Policy (including climate issues) and monitors progress linked to the company's targets for energy efficiency and fossil-free production. The CEO is responsible for the ongoing overall operational management of Billerud's business operations in accordance with instructions and regulations established by the Board. This includes the ultimate oper­ational responsibility for climate-related issues. The Sustainability and Public Affairs function is responsible for all climate-related issues such as analyses, follow-up and reporting as well as monitoring global devel­opments, trends and regulations linked to climate issues.

Sustainability & Public Affairs is the owner of the Sustainability Policy and is, as such, accountable for the implementation of the policy. The process for monitoring the policy includes the annual oversight and Board approval of the policy as well as compliance adherence of the policy through, for example, targets and metrics. Anonymous compliance wrongdoings can be made through Billerud's whistleblowing channel, the Speak-Up Line. Read more in G1-1 on page 146. [...] The representative responsible for the oversight of these activities is the EVP Sustainability & Public Affairs, who also is a part of Billerud's Group Management Team. [...] Billerud's Public Affairs Directive sets out the high-level principles and minimum requirements that comprise Billerud's general commitment to a responsible public affairs engagement. The directive supplements the Sustainability Policy. [...] Billerud's Public Affairs Director is the most senior level in the organization accountable for implementation of the directive.

Governance Climate-related risks and opportunities in Billerud are governed on a strategic level by the Board of Directors and on an operational level by the CEO, Group Management Team and EVP Sustainability & Public Affairs. The Board of Directors continuously manages climate-related risks, opportunities and impacts as part of the work with strategic issues concerning operations, investments and acquisitions. Climate-related issues are also a recurring agenda item at the company's board meet­ings. For example, the Board of Directors annually reviews the Group Sustainability Policy (including climate issues) and monitors progress linked to the company's targets for energy efficiency and fossil-free production. The CEO is responsible for the ongoing overall operational management of Billerud's business operations in accordance with instructions and regulations established by the Board. This includes the ultimate oper­ational responsibility for climate-related issues. The Sustainability and Public Affairs function is responsible for all climate-related issues such as analyses, follow-up and reporting as well as monitoring global devel­opments, trends and regulations linked to climate issues.

The CEO and the Group Management Team are responsible for day-to-day operations and implementation of the sustainability goals and strategies set by the Board of Directors. The Sustainability function, which is represented on the Group Management Team, is responsible for developing Billerud's sustainability agenda and for coordinating it across different functions in the company. The Sustainability Group Policy sets out Billerud's overarching ambition regarding the three fundamental pillars of sustainability: environmental, social, and governance (ESG) aspects. The Legal & Compliance function, which is also represented on the Group Management Team, owns the Responsible Business Program, which is designed to ensure that Billerud, in its contribution to a more sustainable world, conducts business responsibly and in compliance with all applicable laws and regulations. Key legal areas in focus for the responsible business program include anti-corruption and human rights. The program includes due diligence processes aimed at detecting risks in these areas. [...] Management regularly updates the Board of Directors regarding the fulfillment of Billerud's sustainability objectives. This includes, for example, reporting on health and safety at work, climate and whistleblowing cases. The number of whistleblowing cases, types of concerns as well as potential corrective and disciplinary actions following an investigation are reported to the Board of Directors at least annually. The Audit Committee receives a more detailed report quarterly, or as needed to ensure adequate monitoring and oversight. Similar status reporting may be conducted to the Group Management Team. [...] The Board of Directors review and approve the Annual and Sustainability Report prior to publication.

Governance Climate-related risks and opportunities in Billerud are governed on a strategic level by the Board of Directors and on an operational level by the CEO, Group Management Team and EVP Sustainability & Public Affairs. The Board of Directors continuously manages climate-related risks, opportunities and impacts as part of the work with strategic issues concerning operations, investments and acquisitions. Climate-related issues are also a recurring agenda item at the company's board meet­ings. For example, the Board of Directors annually reviews the Group Sustainability Policy (including climate issues) and monitors progress linked to the company's targets for energy efficiency and fossil-free production. The CEO is responsible for the ongoing overall operational management of Billerud's business operations in accordance with instructions and regulations established by the Board. This includes the ultimate oper­ational responsibility for climate-related issues. The Sustainability and Public Affairs function is responsible for all climate-related issues such as analyses, follow-up and reporting as well as monitoring global devel­opments, trends and regulations linked to climate issues.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]The Director of Sustainability is also the Head of Public Affairs. Positions and strategies for policy influence are coordinated and decided within this function. Coordination is ensured through an industry organization network where policy topics discussed in our major trade organizations are aligned. The executive management team is briefed regularly regarding positions and strategies for policy influence for significant topics.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes