AFRY AB

AFRY's Board of Directors incorporates sustainability topics into the overall decision process. Sustainability initiatives are also integrated into existing staff functions, ensuring their execution. Each division head is responsible for developing and driving the sustainability approach in their operations and in all their assignments through consultants. They also have contacts for sustainability-related issues depending on local needs. A new steering committee called the Sustainability Committee was established at Group level during the year for the purpose of following up previously approved sustainability-related activities and to prepare for new activities decided on by Group Executive Management. AFRY's Head of Strategy and Sustainability is the chairman of the committee and other standing members are the President and CEO, Group General Counsel, Head of HR, CFO, Head of Communications and Director of Sustainability. Other stakeholders are invited to attend meetings as appropriate. The Sustainability Committee had six meetings in 2021.

Governance, Risk and Compliance In autumn 2019, ÅF Pöyry's Governance, Risk och Compliance (GRC) organisation was launched. Work was done throughout 2020 and involved a range of initiatives to strengthen the Group's governance, internal control and risk management to better manage the conditions that follow from a greater international presence. Examples of these initiatives include: the appointment of the new roles of Chief Compliance & Ethics Officer and Head of Risk and Security at Group-level, both of whom report to the Group General Counsel; the appointment of the new Head of Internal Audit role, which reports to the Audit Committee; monitoring and harmonising our systematic risk management processes; an update to the risk assessment process at the tender stage; new Group-wide delegation of authorities; updates to policies and internal governance documents; and an e-learning course on ÅF Pöyry's Code of Conduct for all employees in the Group. GRC efforts will remain in the spotlight in 2021. In May 2020, a steering committee was established at Group level to coordinate GRC efforts: GRECS (Governance, Risks, Ethics, Compliance and Sustainability). ÅF Pöyry's Group General Counsel is chair of the committee, while the Chief Compliance & Ethics Officer is the secretary. Other permanent members include the President and CEO, the CFO, the EVP and Head of Human Resources, the EVP and Head of Communications and Brand, the Head of Risk and Security and the Head of Sustainability, while other stakeholders and division heads are invited when appropriate. GRECS held two meetings in 2020 after it was formed. Leadership and culture The President and CEO and the Group Executive Management bear ultimate responsibility for GRC at ÅF Pöyry, while the work is managed by Group General Counsel Susan Gustafsson, who is a member of the Group Executive Management. All managers in the Group take particular responsibility to live up to the values and principles described in our Code of Conduct and to ensure employees have understood it and are complying with it in their areas of responsibilities. Serving as a good role model is part of ÅF Pöyry's "brave leadership" criteria. Risk management Continuous efforts are made to identify and manage operational risks. In 2020, ÅF Pöyry focused on enhancing risk management in assignments by way of a new process for assessing risks at the tender stage: the Code of Conduct Assessment process. The new process was launched on 1 July 2020 and replaces the previous Sustainability Risk Assessment process. A clearer and common process for mapping risks in connection with assignments will strengthen the organisation's ability to manage uncertainty and its potential consequences. The Code of Conduct Assessment process is based on criteria that reflect ÅF Pöyry's Code of Conduct and thus also the 10 principles of the Global Compact. All tenders that are to be approved by a Head of Business Area or higher in accordance with the delegation of authorities (high-risk assignments) must conduct a Code of Conduct Assessment before the tender. The risk assessment conducted at this stage highlights security risks as well as social and environmental risks linked to the specific client, country, sector, business partner and type of assignment. If it is not possible to guarantee that the risks can be managed, ÅF Pöyry does not take on the assignment. Continuous evaluations are conducted of how ÅF Pöyry is adhering to the Code of Conduct Assessment process within the framework of the Group-wide internal quality audit programme. Any deviations are reported to the risk manager, the person responsible for the bid and the division's quality control function for follow-up. The quality audits conducted in 2020 showed that in 56 percent of the assignments reviewed, it was possible to confirm that they were preceded by risk assessments using criteria that reflected the 10 principles of the Global Compact in line with the risk management process in place when the assignment was launched. System support has been established in the new Group-wide CRM system that will be rolled out in early 2021 in order to obtain a more precise data set for follow-up of risk assessments for high-risk assignments. Since the launch of the Code of Conduct Assessment process, the Chief Compliance & Ethics Officer has been consulted regarding compliance issues relating to tenders on 28 occasions.

##### Trade and business associations

As a company we are recognizing that membership in associations can influence policy on climate, which is why we have initatied a mapping on our trade and business associations on Group level for aligment with the 1.5 degree ambition. [...] ##### Public policy engagement

We aim to align external policy and engagement to the goal of halving emissions by 2030 and reaching (net) zero by 2050 and support engagements where we as an actor can have influence on policy development on national and international level as appropriate to each business and market. [...] ##### Roles and responsibilities

The influence we have on climate action in society is closely linked to everything we do; our offerings, our assignments and our partnerships. As described in our Sustainability Policy, we are commited to sharing our knowledge and expertise through investments in cooperation and partnerships. This includes AFRY experts being part of boards, networks and governmental collaboration programmes. We regularly discuss and evaluate received requests for new partnerships.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]The sustainability policy guides the company in participating in engagement activities that are consistent with the overall climate change strategy. The sustainability e-learning, which is mandatory for all employees, is the process in which we ensure that the organization's engagement activities are consistent with the overall climate change strategy. For example, in our Sustainability Policy we commit to continuously challenging the way we work and raise the standards for ourselves by identifying opportunities, risks, and improvement possibilities in our entire value chain. By engaging directly with policy makers through high-level forums such as COP26, we challenge the way we work today.

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

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 sustainability policy guides the company in participating in engagement activities that are consistent with our climate commitment. The sustainability e-learning, which is mandatory for all employees, is the process in which we ensure that the organization's engagement activities are consistent with the overall climate change strategy. For example, in our Sustainability Policy we commit to continuously challenging the way we work and raise the standards for ourselves by identifying opportunities, risks, and improvement possibilities in our entire value chain. By engaging directly with policy makers through high-level forums such as COP and produce policy recommendations based on our expertise within sectors both impacting and impacted by climate change such as energy, we challenge the way we work today.