5493009YRUJJDCFF0R80-2025-12-31-1-en


		3

Review by the Board

of Directors

The year 2025 began with signs of economic recovery and a gradual pickup in customer

activity. However, the improvement proved short‑lived as trade disruptions drove

heightened uncertainty, while demand across key stainless steel end uses in Europe and

North America remained weak. The European market also faced sustained pressure from

low‑priced imports from Asia. The U.S. market saw some tailwinds, with volumes picking up

as customers redirected orders to domestic producers, including Outokumpu, in response

to tariff increases. The ferrochrome market remained balanced, as Southern African

producers operated at limited production levels due to electricity shortages and high costs.

Demand for Outokumpu’s ferrochrome remained solid, supported by its low emissions and

European origin, which continued to be a key differentiator amid geopolitical uncertainty.

Group adjusted EBITDA of EUR 167 million ended slightly below the previous year’s level of

EUR 177 million driven by developments in business area Europe. In addition to challenging

market conditions, fourth‑quarter profitability in business area Europe was further affected

by temporary challenges related to the supply chain planning solution in the Enterprise

Resource Planning (ERP) rollout, which amplified the decline in customer deliveries and

weighed on results. At the same time, business area Americas achieved a significant

improvement in adjusted EBITDA, driven by higher volumes and lower costs, partially

supported by short‑term cost‑saving measures. Selling prices in the U.S. recovered in the

second half of the year. Adjusted EBITDA in business area Ferrochrome improved in 2025,

The stainless steel bridge in Södertälje,

spanning Sweden’s E4 motorway,

showcases innovative engineering and

environmental responsibility. Quickly

constructed to replace an old wooden

bridge, it symbolizes the city’s dedication to

sustainability and is designed to last over

120 years with minimal upkeep.

marking the third consecutive year of growth, supported by lower variable costs and

short‑term cost‑saving measures.

In response to the weak stainless steel demand and sustained low‑priced Asian imports,

the company initiated a EUR 100 million restructuring program, to be completed by the end

of 2027, focusing on business area Europe and Group functions.

While net debt increased moderately in 2025 to EUR 265 million from EUR 189 million in

the previous year, it remained at a healthy level. The increase was driven by negative free

cash flow, reflecting weaker result. Nevertheless, the company’s solid balance sheet,

together with its total liquidity reserves of 1.2 billion, provides a solid starting point for

2026.


		4

Outokumpu’s business model rests on a strong foundation built around strategic priorities

such as circularity, smart decarbonization and secure access to sustainable and

cost‑effective raw materials. These priorities have already positioned the company as a

sustainability leader in the industry, which is an increasingly important advantage as CBAM

and the EU ETS are expected to reshape the competitive landscape and reward early

movers in the years ahead. To ensure CBAM’s full effectiveness and a level playing field,

the company continues to urge the EU Commission to expand CBAM to steel-intensive

downstream sectors and indirect emissions, and to introduce robust measures that prevent

circumvention.

Building on this foundation, a key milestone in the company’s strategic journey during

2025 was the launch of the EVOLVE growth strategy for 2026–2030, designed to

strengthen resilience to market cycles by improving cost competitiveness, building a

stronger product portfolio, and differentiating into areas that support higher growth and

profitability. In support of the implementation of the new strategy, Outokumpu’s Leadership

Team was further strengthened by three new appointments, bringing valuable experience.

Matthieu Jehl was appointed President, business line Stainless Europe; Johann Steiner was

appointed President, business area Americas; and Anouk de Graaf was appointed Executive

Vice President, People, Sustainability & Corporate Relations.

Capital allocation is also a key factor in the new EVOLVE growth strategy, with the company

committed to maintaining a healthy balance sheet while balancing resilience, growth and

dividends, supporting competitive total shareholder returns over the longer term.

During the year, Outokumpu was recognized for its sustainability leadership by Corporate

Knights, being named among Europe’s 50 most sustainable companies, and received a

Platinum rating from EcoVadis as well as an A‑rating for climate from CDP. Outokumpu also

took part in the global climate dialogue at COP30, advocating the critical role of stainless

steel in the green transition and the importance of effective carbon pricing. In partnership

with its customers and suppliers, Outokumpu has achieved approximately 75% lower carbon

footprint compared to the industry average.

Despite Outokumpu's strong commitment to safety and industry leading performance, a

fatal accident occurred in the third quarter at the San Luis Potosi site in Mexico. Following

the accident, Outokumpu has conducted a thorough investigation, reinforced

communication to ensure full awareness and understanding across the organization, and

taken immediate corrective actions.

Looking ahead, the company is well positioned, supported by a robust strategy that unlocks

new and distinctive business opportunities across the value chain, while Outokumpu

continues progressing towards its decarbonization targets by 2030 and beyond.

The Board wishes to thank Outokumpu’s committed organization, which once again

demonstrated strong dedication and resilience throughout a demanding year.

CRU Market development overview

According to CRU’s latest estimates, global apparent consumption of stainless steel flat

products is expected to have increased by 3.8% in 2025 compared to 2024. EMEA and

APAC are to increase by 2.6% and 3.7%, respectively, while the Americas is expected to

show the biggest growth at 6.9%.

(Source: CRU Stainless Steel Flat Products Market Outlook November 2025)

Adjusted EBITDA, € million

Stainless steel deliveries, 1,000 tonnes


		5

Net debt, € million

*Including discontinued operations

Results

Adjusted EBITDA in January–December 2025 was EUR 167 million (EUR 177 million).

Stainless steel deliveries were 2% lower compared to the previous year. Deliveries

increased in business area Americas, and decreased in business area Europe. Average

selling prices for stainless steel decreased in both business areas, with the decline

particularly pronounced in business area Europe. This resulted in sales of EUR 5,468

million (EUR 5,942 million).

Profitability was supported by significantly lower raw material costs in business area

Europe, short-term cost-saving measures of EUR 63 million and result in business area

Ferrochrome. Profitability declined in business area Europe and improved in business area

Americas. Raw material-related inventory and metal derivative gains were EUR 18 million in

January–December 2025 (gains of EUR 3 million).

The Group's EBITDA was EUR 88 million (EUR 162 million). Items affecting comparability in

EBITDA amounted to EUR -79 million (EUR -15 million), mainly related to restructuring

provision in relation to the implementation of the EVOLVE growth strategy, recognized in the

second quarter, and restructuring costs in the fourth quarter related to personnel reduction.

EBIT was EUR -134 million (EUR -51 million). Depreciation, amortization and impairment

amounted to EUR 222 million (EUR 213).

Net financial expenses were EUR 43 million (EUR 41 million), including interest expenses of

EUR 54 million (EUR 64 million).

Income taxes were EUR 36 million (EUR 49 million) including the impact of Germany's

corporate tax rate decrease, which reduced the net result by EUR -10 million.

Net result was EUR -137 million (EUR -40 million) and earnings per share was EUR -0.31

(EUR -0.09).

ROCE for the rolling 12 months was -3.2% (-1.2%), driven by weaker profitability.

Results


€ million	2025	2024
Sales	5,468	5,942

Adjusted EBITDA	167	177
Items affecting comparability in EBITDA
Restructuring costs	-71	-7
Litigation provisions	-6	-2
Environmental	-2	-5
Loss on disposal of shares in Group companies and businesses	—	-3
Inventory revaluations	—	2
EBITDA	88	162

Operating profit (EBIT)	-134	-51
Net result for the financial year	-137	-40
Earnings per share, €	-0.31	-0.09
Diluted earnings per share, €	-0.31	-0.09

Adjusted EBITDA margin, %	3.1	3.0
Return on capital employed, rolling 12 months (ROCE), %	-3.2	-1.2


		6

Cost structure, %

Adjusted EBITDA by segment


€ million	2025	2024
Europe	-46	58
Americas	102	59
Ferrochrome	138	106
Other operations and intra-group items	-27	-46
Total adjusted EBITDA	167	177

Items affecting comparability in EBITDA


€ million	2025	2024
Europe	-65	-3
Americas	-7	-8
Ferrochrome	-1	—
Other operations	-7	-4
Total items affecting comparability in EBITDA	-79	-15
Total EBITDA	88	162

Strategy execution

Outokumpu’s strategy

In June 2025, Outokumpu announced its new EVOLVE strategy for 2026–2030. EVOLVE is

a growth-focused strategy that seeks to build a stronger, more resilient portfolio by

leveraging Outokumpu’s competitive advantages and allocating capital based on two

strategic roles: foundational and transformative businesses. Through EVOLVE, Outokumpu

aims to increase its value by driving cost competitiveness and cash generation in

sustainable stainless steel, growing profitably in advanced materials and alloys, increasing

value from the chrome mine and ferrochrome business by moving up the chromium value

ladder, and revolutionizing value creation through innovative materials and proprietary

technologies. A solid financial position, geographically diversified assets, strong market

positions in Europe and the Americas, and secure access to critical raw materials provide a

robust platform for executing this strategy.

Strategy progress in 2025

In 2025, Outokumpu completed its previous strategy period, aiming to strengthen its core

business while maintaining strict capital discipline. The company targeted total capital

expenditure of EUR 600 million for 2023–2025, and as plans evolved, capital expenditure

for 2025 was reduced to EUR 145 million, resulting in capital expenditure of EUR 531

million for the period.

Outokumpu’s financial targets included an EBITDA run-rate improvement of EUR 350 million

by the end of 2025 and maintaining a net debt to adjusted EBITDA ratio below 1.0x in

normal market conditions. The EBITDA run-rate improvement target, raised from EUR 200

million to EUR 350 million in May 2024 to underline the company’s focus on continuous

improvement, was achieved, with EUR 63 million delivered in 2025. At year end, net debt

to adjusted EBITDA was 1.6x reflecting the current cyclical market conditions.

Progress in 2025 was driven by a focused set of initiatives across all business areas. In

business area Europe, key contributors included the closure and transfer of the precision

strip operations in Germany from Dahlerbrück to Dillenburg, raw material efficiency and

cost management in the Avesta melt shop in Sweden, and further optimization of scrap

sorting and utilization between Krefeld in Germany and Tornio in Finland. These were

complemented by several energy-efficiency projects, and improved prematerial sourcing for

quarto plate.

In business area Americas, continued optimization of its route to market, together with

further yield improvements and energy-efficiency investments in Calvert, U.S., strengthened

regional performance. In business area Ferrochrome, continued implementation of sub-level

caving and consumable efficiency measures contributed to additional EBITDA run-rate

improvements.

Together, these achievements mean that Outokumpu exits 2025 with a stronger, more

efficient, and more customer-oriented core business. In a market environment where pricing

and demand pressures have outpaced the company’s ability to fully offset its cost base,

these improvements have materially mitigated the impact and left Outokumpu in a better

financial position than it would otherwise be.

The Kemi mine has been pursuing carbon neutrality by the end of 2025. The objective

remains firmly in place, and the goal is now close to being achieved. The target is that the


		7

mine will become the world’s first carbon‑neutral mine, although progress has been delayed

by the increase in the mining tax.

The planned EUR 40 million investment in a biocarbon production plant in Germany is

currently on hold due to changes in investment assumptions. Outokumpu is evaluating

more favorable alternatives for the business case.

Transition to EVOLVE

Under the new EVOLVE growth strategy, Outokumpu is translating its ambitions into

concrete actions through a focused set of foundational and transformative initiatives, each

with a distinct role in value creation and capital allocation. The strategy is underpinned by

financial targets for 2026–2030: a net debt to EBITDA ratio of 1.0x, with disciplined

financial flexibility allowing it to temporarily exceed 2.0x to support strategic investments

and manage cyclical market conditions, and an EBITDA improvement of EUR 250 million to

be achieved through foundational initiatives. In 2026, Outokumpu's total capital

expenditure is expected to be approximately EUR 200 million.

Foundational initiatives

Foundational businesses focus on generating strong cash flow and supporting shareholder

returns, while funding growth in transformative areas. Capital expenditure is therefore

focused on maintenance, mandatory investments, and targeted investments into

competitiveness and smart decarbonization. These investments are supported by a

continuous focus on cost competitiveness, leveraging sustainability leadership, and

securing the supply of critical raw materials, with a targeted minimum internal rate of return

of 15%.

In business area Europe, Outokumpu is optimizing its operational footprint and production

capabilities. Outokumpu has conducted a feasibility study to improve European

competitiveness by investing approximately EUR 200 million in a new annealing and

pickling line in Tornio, Finland, while intending to close two less competitive lines in

Krefeld, Germany. The investment remains under review.

Transformative initiatives

Transformative initiatives are designed to unlock new profit pools and drive value in higher-

growth, higher-margin, and less cyclical markets, with a targeted minimum internal rate of

return of 20%.

The global advanced materials and alloys market shows strong growth potential.

Outokumpu has started a feasibility study to assess a potential investment in its melt shop

in Avesta, Sweden, to enable further expansion into high-nickel alloys, while also exploring

selective inorganic opportunities within this area.

As a low‑emission ferrochrome producer and the owner of the only chrome mine in the EU,

Outokumpu is increasing the value of its chrome mine and ferrochrome business by moving

up the chromium value ladder and driving new value creation through innovative materials

and proprietary technologies to produce low‑CO₂ metals, while repositioning ferrochrome

business from an internal supplier to an unrestricted market player. The company aims to

establish a platform for premium products, initially focusing on chromium materials, where

its own chrome mine offers the ideal launchpad. To support the development, Outokumpu

is investing approximately USD 45 million in a pilot plant in New Hampshire, U.S., to pilot

and advance proprietary technology for producing critical low‑CO₂ materials, such as

chromium metal and enriched ferrochrome. The pilot plant is planned to be operational in

the first half of 2027.

Cost competitive foundation

In response to weak stainless steel demand and intense competition from low‑priced

imports into the European market, conditions that have resulted in unsustainably weak

profitability in business area Europe, Outokumpu has initiated a restructuring program

aimed at achieving EUR 100 million in annual cost savings by the end of 2027. The program

focuses primarily on business area Europe and global Group functions, with savings

generated through fixed‑cost reductions, including workforce reductions, efficiency

improvements across the organization, and optimization of the production footprint.

Strengthening the company’s foundations is essential to successfully executing

Outokumpu’s growth‑focused EVOLVE strategy.

Personnel negotiations in Finland, Sweden, and Germany were completed in the fourth

quarter of 2025, processes in other countries continue. In total, the restructuring is

expected to impact approximately 650 full‑time positions by the end of 2027.

EBIT and return on capital employed

Outokumpu has redefined its capital employed and ROCE definitions in 2022.

Comparative information for 2021 has been restated accordingly.

*Capital employed Includes discontinued operations.


		8

Net result and earnings per share

Equity-to-assets ratio and debt-to-equity ratio*

Capital expenditure and depreciation and amortization

*Including discontinued operations. In 2025, 2024 and 2023

no discontinued operations impact in the balance sheet.

Financial position and cash flow

Cash flow and net working capital


€ million	2025	2024
Free cash flow	-46	-71
Change in working capital	112	27
Capital expenditure	145	216
Inventories	1,608	1,764

Free cash flow in January–December 2025 was EUR -46 million (EUR -71 million). The

improvement was mainly driven by changes in working capital and lower capital

expenditure, more than offsetting the decline in results, which included a negative impact

on financial items due to foreign exchange rates. Working capital contributed EUR 112

million to cash flow (EUR 27 million), supported by reduction in inventory. Capital

expenditure was EUR 145 million in 2025 (EUR 216 million).

Inventories on the balance sheet decreased and stood at EUR 1,608 million at the end of

December (December 31, 2024: EUR 1,764 million). The inventory decrease of EUR 156

million was driven by lower inventory value per tonne, partly offset by higher inventory

volumes towards the end of 2025.

Financial position


€ million	2025	2024
Net debt
Non-current debt	519	246
Current debt	108	256
Cash and cash equivalents	362	313
Net debt	265	189
Net debt to adjusted EBITDA	1.6	1.1

Gross debt	627	502
Debt-to-equity ratio (gearing), %	7.8	5.0
Equity-to-assets, ratio, %	59.8	63.2

Liquidity reserves, € billion	1.2	1.1

Net debt was EUR 265 million at the end of December 2025 (December 31, 2024: EUR

189 million). The EUR 76 million increase compared to year-end 2024, was primarily driven

by negative free cash flow and the dividend payout. Gross debt was EUR 627 million

(December 31, 2024: EUR 502 million), and gearing was 7.8% (December 31, 2024:

5.0%).


		9

In the first half of 2025, Outokumpu completed conversions of convertible bonds totaling

EUR 125 million. In Q1 2025, Outokumpu signed a three-year EUR 200 million loan. The

maturity of the loan is in March 2028 including a one year extension option, which was

used in Q4 2025 and the new maturity is in March 2029. In Q3 2025, Outokumpu signed a

three-year EUR 100 million term loan with a maturity date in July 2028, including one year

extension option. In November, Outokumpu refinanced its main liquidity facility by entering

into a new EUR 800 million committed unsecured revolving credit facility, replacing its

previous committed liquidity facilities of similar size. The new facility, maturing in February

2030, includes two 12-month extension options that can be exercised in 2027 and 2028,

potentially extending maturity to 2032. The margin of the new facility is linked to emission

reductions in line with the approved emission reduction target by the Science Based

Targets initiative for 2030.

Cash and cash equivalents were EUR 362 million at the end of December 2025

(December 31, 2024: EUR 313 million) and overall liquidity reserves were EUR 1.2 billion

(December 31, 2024: EUR 1.1 billion). The liquidity reserves include cash and cash

equivalents and EUR 800 million of outstanding committed credit facilities, which were fully

unutilized. At the end of 2025, the outstanding amount of issued commercial papers was

EUR 50 million.

Business areas

Outokumpu has three business areas, which are also Group’s operating segments. More

information about the business areas can be found in note 2.1 in the consolidated

Financial Statements.

External sales by business area, 5,468 € million

Capital expenditure by business area, 145 € million

Europe


EUR million, or as indicated	2025	2024
Stainless steel deliveries, 1,000 tonnes	1,148	1,222
Sales	3,600	4,102
Adjusted EBITDA	-46	58
Items affecting comparability in EBITDA	-65	-3
EBITDA	-111	55
Operating capital	1,849	1,959
Return on operating capital, rolling 12 months, %	-8.5	-3.0

In 2025, business area Europe’s adjusted EBITDA was EUR -46 million (EUR 58 million).

Stainless steel deliveries decreased by 6% compared to the previous year, mainly impacted

by market weakness, while average stainless steel selling prices were significantly lower.

This resulted in sales of EUR 3,600 million (EUR 4,102 million).

Profitability was mainly supported by lower raw material costs and short-term cost-saving

measures. Raw material-related inventory and metal derivative gains were EUR 0 million

(gains of EUR 3 million). Business area Europe’s return on operating capital was -8.5%

(-3.0%), mainly driven by weaker profitability.

In 2025, apparent consumption in EMEA showed an increase of 2.6% compared to 2024

(Source: CRU Stainless Steel Flat Products Market Outlook November 2025). EU cold-rolled

imports increased to a level of 25% from the previous year's level of 22% (Source:

EUROFER, January 2026).


		10

Americas


EUR million, or as indicated	2025	2024
Stainless steel deliveries, 1,000 tonnes	622	596
Sales	1,676	1,707
Adjusted EBITDA	102	59
Items affecting comparability in EBITDA	-7	-8
EBITDA	95	51
Operating capital	431	574
Return on operating capital, rolling 12 months, %	13.0	4.2

In 2025, business area Americas’ adjusted EBITDA increased to EUR 102 million (EUR 59

million). Stainless steel deliveries increased by 4% compared to the previous year, as

customers shifted to domestic producers. Average selling prices for stainless steel in USD

decreased both in the U.S. and Mexico, though this was offset by an improved product mix.

This resulted in sales of EUR 1,676 million (EUR 1,707 million).

Profitability was supported by lower raw material and variable costs, as well as a reduction

in fixed costs driven by short-term cost-saving measures. Raw material-related inventory

and metal derivative gains were EUR 19 million (losses of EUR 3 million). Business area

Americas’ return on operating capital was 13.0% (4.2%), mainly driven by stronger

profitability.

In 2025, the apparent consumption decreased by 1% compared to 2024. The share of

cold-rolled imports into the US decreased to 21% compared to a level of 25% in 2024. The

share of cold-rolled imports into North America decreased to 30% from a level of 34% in

2024. (Source: American Iron and Steel Institute, AISI, based on Jan-Nov data).

Ferrochrome


EUR million, or as indicated	2025	2024
Ferrochrome deliveries, 1,000 tonnes	395	374
Sales	462	469
Adjusted EBITDA	138	106
Items affecting comparability in EBITDA	-1	—
EBITDA	137	106
Operating capital	835	863
Return on operating capital, rolling 12 months, %	10.0	5.5

In 2025, business area Ferrochrome’s adjusted EBITDA increased to EUR 138 million (EUR

106 million). Ferrochrome deliveries increased by 6% compared to the previous year, driven

by higher external demand, partly offset by weaker internal deliveries. Ferrochrome sales

price was lower, mainly driven by unfavorable EUR/USD foreign exchange rate. This resulted

in sales of EUR 462 million (EUR 469 million).

Profitability was supported by lower variable costs, partly driven by short-term cost-saving

measures. Business area Ferrochrome’s return on operating capital was 10.0% (5.5%),

mainly driven by stronger profitability.

Research and development

Outokumpu’s Research and Development (R&D) function builds technical expertise that

supports the development of materials for new application areas, advances process

technologies, and enables improvements to the existing product offering. Also, intellectual

property, including patents, has a major role in creating value through innovations.

Under Outokumpu’s growth-focused strategy, EVOLVE, R&D activities increasingly focused

on progressive and exploratory activities to drive growth in new and modified grades,

including applications such as the production and use of green hydrogen.

R&D also provided expertise to reduce carbon emissions in Outokumpu’s production

processes. Following the development of biocoke, additional non-fossil reduction

opportunities were identified, such as hydrogen and biomethane. As part of these efforts, it

was successfully demonstrated how waste streams, including slag and carbon dioxide, can

be converted into valuable products such as carbon-negative concrete blocks. In addition,

R&D supported the ongoing proprietary technology development project to produce low-CO₂

materials, such as enriched ferrochrome and chromium metal.

Alongside ongoing product development, R&D also hosted the Outokumpu Corrosion

Academy – a series of online lectures – which continued throughout the year to foster

customer dialogue and offer customers, engineers, and students opportunities to deepen

their understanding of stainless steel and corrosion.

Outokumpu operates three R&D centers – in Avesta, Sweden; Krefeld, Germany; and Tornio,

Finland – where a team of 62 experts drives innovation in materials and technologies,

supporting Outokumpu’s value creation. In 2025, Outokumpu’s R&D expenses were EUR 11

million, representing 0.2% of the annual sales (2024: EUR 15 million and 0.2%). In addition

to the direct R&D expenses, Outokumpu has also various strategic initiatives and

development projects ongoing.

Risks and uncertainties

Outokumpu is exposed to a range of risks and uncertainties that may adversely affect its

business and operations. To mitigate these risks, the company applies continuous and

comprehensive risk management across its operations.

Global economic activity, shifts in trade and economic policies, and geopolitical tensions

expose Outokumpu to risks and uncertainties in its operating environment. These factors

could have an adverse impact on the company's operations, financial performance, and

overall financial position.


		11

The main short-term risks relate to the development in trade policies and increased

geopolitical tensions, which could disrupt global trade, increase inflation, and slow

economic growth, ultimately leading to possible weakening of demand and pressure on

stainless steel prices, even with their broad range of end uses.

The U.S. administration’s shifts in trade policies has created uncertainties in global trade

flows and imposed duties of 50% on steel imports in 2025. As a result, high volumes of

low-priced Asian imports risk being diverted into Europe, continuing to burden the European

stainless steel market. To address this, the European Commission has proposed more

effective safeguards to strengthen the industry’s competitive position, with measures

expected by mid-2026. Since Outokumpu operates in both the US and Europe, imposed

tariffs may support US operations while potentially negatively impacting European

operations if effective safeguards are not implemented.

Starting January 2026, the Carbon Border Adjustment Mechanism (CBAM) aims to ensure

that imported carbon-intensive goods face the same carbon costs as those produced within

the EU. However, uncertainties remain regarding the effectiveness of these measures in

preventing circumvention, ensuring a level playing field in climate action and preventing

carbon leakage.

The company remains exposed to risks related to volatile metal prices, especially nickel.

Financial derivatives are used to manage the impacts of nickel price changes.

Cyber security threats and dependencies on critical suppliers and machinery expose

Outokumpu to the risk of operational disruption and additional costs.

Significant legal proceedings

In May 2025, Outokumpu commented on unconfirmed news about a possible legal process

initiated in Moscow by Rosatom against Outokumpu, among other parties. By the end of

the reporting period, Outokumpu has not received any official notification regarding the

reported claim or the process. From the beginning, Outokumpu has denied and continues to

deny all grounds for liability related to the terminated Fennovoima nuclear power plant

project, including the existence of any contractual relationship or obligation between

Outokumpu and any Rosatom company. Rosatom has already previously and groundlessly

attempted to involve Outokumpu in the arbitration proceedings concerning the termination

of the Engineering, Procurement and Construction (EPC) contract regarding the Fennovoima

nuclear power plant project. As we communicated on February 14, 2025, the arbitral

tribunal confirmed that it does not have jurisdiction to adjudicate claims brought by RAOS

Project Oy and JSC Rosatom Energy International (JSC REIN) against Outokumpu. This

decision terminated the arbitral proceedings with respect to Outokumpu. There may be

attempts in the future to join Outokumpu in legal disputes arising out of the terminated

project.

On July 16, 2018, a class of plaintiffs, consisting of former and current Outokumpu Calvert

mill employees, brought a suit against Outokumpu Stainless USA, LLC in the U.S. federal

district court, alleging that the company failed to pay full wages for regular work and

overtime work they performed. The district court entered a default judgment against

Outokumpu in 2021 with respect to liability without Outokumpu having the opportunity to

argue the merits of the allegations and subsequently found Outokumpu liable to the

plaintiffs for approximately USD 13 million in the aggregate, plus attorney’s fees.

Outokumpu unsuccessfully appealed the district court’s decision and the matter was

remanded to the district court for a final judgment. On July 2, 2025, the district court

issued a partial judgment requiring Outokumpu to pay the plaintiffs approximately USD 13

million plus post-judgment interest and notify certain individuals, who were not previously

notified at the initial stages of the case, that they have a right to opt-in to the class and

receive damages payments for the relevant period. Outokumpu is now awaiting the district

court’s further ruling on the damages for these additional opt-in plaintiffs, Outokumpu’s

previously argued defenses, and the amount Outokumpu must pay the plaintiffs’ attorneys

for their fees. Outokumpu now has an approximately USD 11 million provision in respect of

this matter as approximately half of the provision was settled in July 2025.

On January 19, 2018, Outokumpu Nirosta GmbH was served with a claim in the district

court of Krefeld for a declaratory judgment by the owner of a warehouse in Krefeld that

Outokumpu had leased until the end of 2016. The claim related to the responsibility for

maintenance and repair of the warehouse and amounted to EUR 19 million. The parties

reached a settlement which the court confirmed on June 4, 2025, and according to which

Outokumpu has agreed to pay the claimant in total approximately EUR 6 million in three

equal installments in 2025, 2026 and 2027. The first installment was paid in June 2025.

Outokumpu has an appropriate provision in place for the remainder.

Shares and share capital

On December 31, 2025, Outokumpu’s share capital was EUR 311 million and the total

number of shares was 473,016,832. At the end of December, Outokumpu held 1,808,411

treasury shares. The average number of shares outstanding was 450,344,651 in 2025

(424,237,776). The closing share price at the end of the period, on December 31, was

EUR 4.48.

2020, Outokumpu issued senior unsecured convertible bonds of EUR 125 million maturing

on July 9, 2025. The bonds were convertible into new and/or existing ordinary shares in

Outokumpu at a set conversion price. In the first half of the year 2025, Outokumpu

received conversion notices and converted EUR 124.7 million and a total of 47.0 million

shares. The company resolved to issue 47.0 million new shares as conversion shares and

cancel 30.8 million of its own shares. 11.7 million new shares were issued in the second

quarter and 35.3 million shares in July 2025. In 2023 bonds amounting to EUR 0.2 million

were converted.


		12

The conversion period ended on June 25, 2025. The remaining unconverted amount of EUR

0.1 million was paid on the maturity date.

Principal shareholders on December 31, 2025


	Shares	%
Solidium Oy	70,793,208	14.97
Varma Mutual Pension Insurance Company	24,888,403	5.26
Ilmarinen Mutual Pension Insurance Company	15,360,000	3.25
The Social Insurance Institution of Finland	8,388,652	1.77
Elo Mutual Pension Insurance Company	7,306,000	1.54
State Pension Fund	6,500,000	1.37
Mandatum Life	6,396,566	1.35
OP Life Assurance Company Ltd.	5,982,957	1.26
Nordea Life Assurance Finland Ltd.	3,667,542	0.78
Oy Etra Invest Ab	3,000,000	0.63
Nordea Bank Abp	2,374,239	0.50
Etola Erkki Olavi	2,000,000	0.42
Laakkonen Mikko Kalervo	1,706,000	0.36
Op Finland Index	1,675,049	0.35
Sinituote Oy	1,538,560	0.33
Insurance Company Fennia Life	1,438,289	0.30
Op Finland Investment Fund	1,424,191	0.30
Seligson & Co Equity Fund	1,294,560	0.27
Nordea Pro Finland Fund	1,285,877	0.27
Ojala Alpo Armas	1,285,860	0.27
Total	168,305,953	35.58

Nominee accounts held by custodian banks	125,212,557	26.47
Treasury Shares	1,808,411	0.38
Other Shareholders	177,689,911	37.57

Total	473,016,832	100.00

Management shareholdings and

share-based incentive programs

On December 31, 2025, the members of the Board of Directors and Outokumpu Leadership

Team (OLT) altogether held 1,070,697 shares, corresponding to 0.23% of the total number

of shares.

Outokumpu has established share-based incentive programs for the Outokumpu Leadership

Team (OLT) members, selected managers and key employees, which include a Performance

Share Plan and a Restricted Share Pool for key employees.

In 2025, after deductions for applicable taxes, a total of 154,661 shares were delivered to

OLT members in the incentive programs based on the terms and conditions of the

programs. Outokumpu used its treasury shares for the reward payments.

The Performance Share Plan and the Restricted Share Pool Program are currently ongoing

for periods 2023–2025, 2024–2026, 2025–2027 and their continuation for the period

2026–2028 was approved by the Board of Directors in December 2025. For vesting

conditions see note 3.4 in the consolidated Financial Statements.

In 2022, Outokumpu introduced a new sustainability-focused performance criterion for the

Performance Share Plan, reflecting its commitment to continuous improvement in

sustainability. All plan periods now incorporate an earning criteria aligned with

Outokumpu’s Science Based Targets initiative (SBTi), specifically targeting CO₂ emission

reductions. For all plan periods, 80% of the remuneration is linked to return on capital

employed, with the remaining 20% tied to the CO₂ emission reduction goal.

More details on the share-based incentive programs can be found in note 3.4 in the

consolidated Financial Statements.

The members of the OLT and the Board of Directors are introduced in the Corporate

Governance Statement included in the Annual Report and at the Outokumpu website. Their

shareholdings are also presented in the Corporate Governance Statement and their

remuneration in note 3.2 in the consolidated Financial Statements. Corporate Governance

Statement and Remuneration Report are also included in the Annual Report.

Changes in management and Board of Directors

On November 4, 2025, Outokumpu appointed Anouk de Graaf as EVP, People,

Sustainability and Corporate Relations and a member of Outokumpu Leadership Team as of

February 1, 2026.

On October 6, 2025, Outokumpu appointed Johann Steiner as President, business area

Americas as of October 6, 2025. Previously Johann held the role of EVP, Strategy,

Sustainability & People. Tamara Weinert, the previous position holder, pursued new

challenges.

On April 3, 2025, Hilde Merete Aasheim and Olavi Huhtala were elected in Outokumpu's

Annual General Meeting as new members of the Board of Directors. At the same time Pierre

Vareille's position as a member of the Outokumpu Board of Directors ended.


		13

On February 12, 2025, Outokumpu appointed Matthieu Jehl as President, business line

Stainless Europe and member of the Outokumpu Leadership Team. He started in this

position at the end of August. Niklas Wass, the previous position holder, left his position on

March 31, 2025. Johann Steiner, EVP, Strategy, Sustainability and People acted as interim

President, business line Stainless Europe, before Matthieu Jehl started.

Information presented in the notes to the Financial

Statements

Related party transactions are disclosed in the Group Consolidated Financial Statements

note 6.4 and in the Parent company’s Financial Statements notes 8, 11, 14 and 17.

Corporate governance

Outokumpu’s Corporate Governance Statement can be found at the Outokumpu website

and in the Governance and remuneration section in the Annual Report.

Annual General Meeting

Outokumpu’s Annual General Meeting 2025 was held on April 3, 2025, in the Congress

Wing of Finlandia Hall, in Helsinki, Finland. The Annual General Meeting supported all of the

proposals by the Board of Directors and the Shareholders' Nomination Board. The

resolutions of the Annual General Meeting were published in a separate stock exchange

release.

The Annual General Meeting approved the financial statements and discharged the Board

of Directors and the CEO of the company from liability for the financial year 2024. The

Annual General Meeting decided that a dividend of EUR 0.26 be paid for the financial year

2024, in two installments. The Annual General Meeting also authorized the Board of

Directors to repurchase the company’s own shares and to decide on the issuance of shares

as well as special rights entitling to shares.

In addition, the Annual General Meeting approved the proposals by the Shareholders’

Nomination Board regarding the members of the Board of Directors and their remuneration.

According to the proposal by the Shareholders’ Nomination Board, the Annual General

Meeting decided that the Board of Directors shall consist of eight (8) members. The Annual

General Meeting re-elected Heinz Jörg Fuhrmann, Kari Jordan, Päivi Luostarinen, Jyrki Mäki-

Kala, Petter Söderström and Julia Woodhouse of the current members and elected Hilde

Merete Aasheim and Olavi Huhtala as new members, all for the term of office ending at the

end of the next Annual General Meeting. The Annual General Meeting also re-elected Kari

Jordan as the Chairman and elected Jyrki Mäki-Kala as the new Vice Chairman of the Board

of Directors.

Nomination Board

Outokumpu’s Shareholders’ Nomination Board consists of the representatives of the four

largest shareholders registered in the shareholder register of the company following Nasdaq

Helsinki’s first trading day in August.

The Nomination Board has been established to annually prepare proposals on the

composition of the Board of Directors and director remuneration for the Annual General

Meeting.

On August 1, 2025, the four largest shareholders of Outokumpu were Solidium Oy, Varma

Mutual Pension Insurance Company, Ilmarinen Mutual Pension Insurance Company and The

State Pension Fund of Finland. As the State Pension Fund of Finland informed Outokumpu

that it will not use its nomination right, the right transferred to the Social Insurance

Institution of Finland.

The Shareholders' Nomination Board comprised Matts Rosenberg, CEO at Solidium Oy;

Pekka Pajamo, Senior Vice-President, CFO, Finance and Internal Services at Varma Mutual

Pension Insurance Company; Esko Torsti, Head of Alternative Investments at Ilmarinen

Mutual Pension Insurance Company and Lasse Lehtonen, Director General at The Social

Insurance Institution of Finland, as well as Kari Jordan, Chairman of the Board of Directors

of Outokumpu. As of December 8th, 2025 Kari-Pekka Mäki-Lohiluoma, Deputy Director

General of the Social Insurance Institution of Finland has substituted Lasse Lehtonen.

The Nomination Board submitted its proposals to Outokumpu’s Board of Directors on

January 19, 2026, see Events after the balance sheet date.

Board of Directors’ proposal for profit distribution

According to the parent company's financial statements on December 31, 2025,

distributable funds totaled EUR 2,652 million, of which retained earnings including the net

result of the year were EUR 341 million.

The Board of Directors proposes to the Annual General Meeting to be held on March 26,

2026, that a dividend of EUR 0.13 per share to be paid for year 2025 in two installments.

This corresponds to a total dividend of EUR 61 million. The proposal reflects the company’s

financial performance and cyclical market conditions, while maintaining the financial

flexibility to invest in transformative growth.


		14

Outlook for Q1 2026

Outokumpu's adjusted EBITDA improvement in the first quarter of 2026 is expected to

benefit mainly from recovering stainless steel delivery volumes, which are forecast to rise

by 20–30% from the fourth quarter of 2025. The change in deliveries mainly reflects

normal seasonality and the exceptionally low level in business area Europe in the

comparative period, which was additionally affected by challenges related to the supply

chain planning solution in the ERP rollout in the fourth quarter.

With the current raw material prices, some raw material-related inventory and metal

derivative gains are forecasted to be realized in the first quarter.

Guidance for Q1 2026

Adjusted EBITDA in the first quarter of 2026 is expected to be higher compared to the

fourth quarter of 2025.

Events after the balance sheet date

On January 19, 2026, Outokumpu announced the proposals of the Shareholders'

Nomination Board to the Annual General Meeting 2026. The Shareholders’ Nomination

Board proposes that the Board of Directors would consist of 10 members or, if one or more

of the candidates proposed are unavailable, a correspondingly smaller number. The

Nomination Board proposes that the current members of the Board of Directors Hilde

Merete Aasheim, Heinz Jörg Fuhrmann, Olavi Huhtala, Kari Jordan, Päivi Luostarinen, Jyrki

Mäki-Kala, Petter Söderström and Julia Woodhouse would be re-elected, and that Timo

Ritakallio and Jenni Lukander would be elected as new members, all for the term of office

ending at the end of the next Annual General Meeting. The Nomination Board also

proposes that Kari Jordan would be re-elected as the Chairman and Timo Ritakallio elected

as the Vice Chairman of the Board of Directors.

On January 8, 2026, Outokumpu announced it has signed a Memorandum of Understanding

with Norsk e-Fuel, a Nordic pioneer in Power-to-Liquid project development, to work together

towards realizing a CO-to-SAF (Sustainable Aviation Fuel) production plant. Norsk e-Fuel

starts a feasibility study in 2026 and anticipates taking an investment decision around

2028, with production start planned for 2032. Outokumpu would provide carbon monoxide

(CO) side streams from its ferrochrome production as a feedstock for the production of

80,000-100,000 tons of eSAF annually. The plant would be located next to Outokumpu’s

stainless steel mill in Koivuluoto, Tornio, Finland and once operational, it would create

financial value for Outokumpu through increased side stream utilization. The project will

support Outokumpu’s decarbonization journey by allowing the company to reduce direct CO₂

emissions by 200,000 tons annually, representing 20% of Outokumpu's global direct

emissions.


		15

Sustainability statement

Outokumpu’s vision is to pioneer materials and technologies that power tomorrow. With the purpose of a world that lasts forever,

Outokumpu’s products are made from 97% recycled materials, which it then turns into fully recyclable stainless steel. We support

our customers in reducing their emissions with stainless steel that has an approximately 75% lower carbon footprint than the

industry average*. With a high climate ambition, the company is committed to reducing its emission intensity by 42% by 2030

aligned with the science-based target to keep global warming below 1.5 degrees. Outokumpu's targets also include achieving zero

safety incidents, enhancing equal pay, fostering supply chain sustainability and conducting business in an ethical and responsible way.

The Haro bridge in Rioja, Spain

connects the old town to wineries,

and Outokumpu’s stainless steel

with low carbon footprint was used in

the main structure of the bridge. The

bridge mirrors the use of materials in

wine production – wood and

stainless steel.

*Outokumpu’s average product carbon

footprint (2025): 1.6 kg CO₂e per kg of

stainless steel based on lifecycle assessment.

Global average carbon footprint of stainless

steel: 7.3 kg CO₂e per kg of stainless steel.

(Outokumpu’s calculation based on data

provided by CRU, worldstainless, and Kobolde

& Partners AB 2022).


General disclosures	17
Environmental information	46
Social information	82
Governance information	116


		16

Abstract photo with people sitting on stairs_2024_04_09_outokumpu_saksa_2488 (3).jpg

Content


General disclosures	17

Basis for preparation	18
Governance	19
Strategy	26
Impact, risk and opportunity management	30

Environmental information	46

EU Taxonomy	47

E1 – Climate change	53

E2 – Pollution	65

E3 – Water and marine resources	69

E4 – Biodiversity and ecosystems	73

E5 – Resource use and the circular economy	77

Social information	82

S1 – Own workforce	83

S2 – Workers in the value chain	101

S3 – Affected communities	110

Governance information	116

G1 – Business conduct	117


		17

General disclosures

Outokumpu's sustainability statement

includes updates from Outokumpu’s

new EVOLVE strategy and a review of

the double materiality assessment.

Preparation follows the European

Sustainability Reporting Standards.


Basis for preparation	18
Governance	19
Strategy	26
Impact, risk and opportunity management	30


		18

Basis for preparation

Outokumpu’s sustainability statement (“Konsernikestävyysraportti” as per Finnish

Accounting Act (1336/1997)) was prepared on a consolidated basis. Where information

has been published in other parts of the report, Outokumpu has made use of incorporation

by reference and cross references have been inserted. (ESRS2-BP-1-5-(a))

Scope of consolidation

The scope of consolidation of Outokumpu’s sustainability statement is the same as for the

Financial Statements. The consolidation principles rely on operational control, unless

otherwise stated. See also Note 6.5 Subsidiaries in Financial Statements for more

information about the Group. Associated companies, joint ventures and subcontractors are

not included. Previously owned assets such as inactive closed mines are not included

unless otherwise stated. (ESRS2-BP-1-5-(b)-(i))

Outokumpu’s subsidiaries listed in Note 6.5 in the Financial Statements are exempted from

individual or consolidated sustainability reporting pursuant to Articles 19a(9) or 29a(8) of

Directive 2013/34/EU. (ESRS2-BP-1-5-(b)-(ii))

Coverage of value chain

In addition to Outokumpu’s own operations, the sustainability statement contains relevant

upstream and downstream value chain information on material sustainability matters. The

evaluation of materiality has been made according to the double materiality assessment

presented in its corresponding section. The assessment of impacts, risks and opportunities

analyzed cover both the upstream and the downstream value chain. More information on

impacts, risks and opportunities can be found later in sections of this sustainability

statement. (ESRS2-BP-1-5-(c))

Omission of information and use of exemption

Outokumpu has not used the option to omit a specific piece of information corresponding

to intellectual property, know-how or the results of innovation. (ESRS2-BP-1-5-(d))

Outokumpu has not used the option to exempt the disclosure of impending developments

or matters in the course of negotiation, as provided for in articles 19a(3) and 29a(3) of

Directive 2013/34/EU. (ESRS2-BP-1-5-(e))

Time horizons and specific circumstances

Outokumpu uses the ESRS standard definitions for short-, medium- and long-term. (ESRS2-

BP-2-9-(a-b))

All figures presented have been rounded, and consequently the sum of individual figures

may deviate from the presented aggregate figure. Key figures have been calculated using

exact figures.

Value chain estimation

Outokumpu uses both direct and indirect sources to calculate value chain greenhouse gas

emissions. Indirect emission factors are used in particular for raw materials, and other

input materials, as well as to calculate transportation emissions. (ESRS2-BP-2-10-(a))

Supplier-specific primary data is prioritized, but when this is not available, the estimation

described below has been used:

• For metallic alloys and other input materials, Outokumpu has used a weighted average

of supplier-specific emissions and emission factors of life-cycle assessments from

relevant industry associations.

• For transport, the company has used typical distances and types of transport with well-

to-wheel emissions according to the EEA report 2/2022 of the European Environmental

Agency for European transport and with the published emission factors of the US EPA for

US transport. For business travel, greenhouse gas emissions reports of service providers

have been used.

• Customers’ avoided carbon emissions are calculated using the difference between the

global average stainless steel carbon footprint of 7.3 tonnes of carbon dioxide

equivalents per tonne of stainless steel, and Outokumpu’s average product carbon

footprint of 1.6 tonnes of carbon dioxide equivalents per tonne of stainless steel. The

global average is calculated as a weighted average of the regional averages for Asia,

Europe, North America and India. Outokumpu’s product carbon footprint is based on life-

cycle assessment and includes both European and North American production. Avoided

emissions are based on steel amounts delivered. The calculation methodology for

avoided emissions has been verified by a third party in 2024.

In the absence of specific supplier data or industry association life-cycle-based emission

data, Outokumpu has used database values from, for example, EcoInvent, or data from

standards (ISO 14404). (ESRS2-BP-2-10-(b))

The resulting level of accuracy of the described value chain estimations is considered to be

reasonably high and sufficient to give a representative picture of Outokumpu’s

performance. (ESRS2-BP-2-10-(c))


		19

Outokumpu is constantly reviewing its value chain data and updating it with new

information. Outokumpu’s aim is to increase the share of direct emission data and to

increase accuracy enabled by developments in information technology. (ESRS2-BP-2-10-(d))

Sources of estimation and outcome uncertainty

Quantitative metrics and monetary amounts that have been identified as including a high

level of measurement uncertainty include:

• value-chain Scope 3 GHG emissions,

• volume of rain water within the water consumption metrics,

• volume of recycled and reused water, and

• financial effects of identified impacts, risks and opportunities. (ESRS2-BP-2-11-(a))

Uncertainty is due to limited availability of primary data, lack of instrumentation for fully

measuring recycled and reused water, the viability of future techniques, price development,

availability of bio-based solutions, and low-emission raw materials and fuels. (ESRS2-BP-2-11-

(b)-(i)) Assumptions are disclosed in more detail in their respective chapters. (ESRS2-BP-2-11-

(b)-(ii))

Due to long time horizons and changing market conditions, assessments of investments

toward Outokumpu’s climate transition plan contain uncertain information. (ESRS2-BP-2-12)

Changes in preparation, presentation or reporting errors

The calculation method for the restricted operating expenditure (OpEx) in EU Taxonomy

reporting has changed from previous year after a review of accounts. Previous accounts

that were previously fully attributable are now only partly attributable and therefore more

representative. The changes resulted in EU Taxonomy restricted OpEx reported in for 2024

to be adjusted. Scope 2 (location-based) greenhouse gas emissions calculations have been

updated to utilize more recent emission factors, resulting in changes to prior period’s

reported emissions. Reported value for 2024 Scope 2 (location-based) emissions changed

from 540,274 tCO2 to 448,567 tCO2. This also affects Total greenhouse gas emissions

values for prior period, changing from 3,878,026 tCO2 to 3,786,319 tCO2. (ESRS2-BP-2-13-

(a-c))

A misstatement in the prior period’s E1 Climate change chapter was discovered whereby

the total EU Taxonomy eligible capital expenditure (CapEx) was referred to as EUR 78

million, when it should have been reported to be EUR 157 million of eligible and aligned

CapEx. The prior period included a reported value of EUR 59 million for interests and

financing expenses in the sustainability statement when it should have been EUR 74

million. No other errors were identified in the prior period’s sustainability information.

(ESRS2-BP-2-14-(a-c))

Other legislation or sustainability reporting standards

Outokumpu’s sustainability statement has been prepared in accordance with Corporate

Sustainability Reporting Directive (Directive (EU) 2022/2464), the European Sustainability

Reporting Standards (ESRS) as defined in the Commission Delegated Regulation (EU)

2023/2772, the Finnish Accounting Act’s Chapter 7 on sustainability reporting and the EU

Taxonomy Regulation (2020/852). (ESRS2-BP-2-15)

For water analyses, Outokumpu follows the standards: EN ISO 11885:2009, EPA Methods,

and EN 872:2005. ISO 17025 testing and calibration laboratories certifications have been

accredited by Swedac. For self-declared environmental claims, Outokumpu has followed ISO

14021 and received certification by TÜV SÜD 2024. (ESRS2-BP-2-AR-2)

Incorporation by reference

Outokumpu refers to the Financial Statements for the following data:

• net revenue in Energy consumption and mix in the Climate change chapter (ESRS

E1-5-43) and Greenhouse gas emissions in Scopes 1, 2 and 3 (ESRS1-6-55 & AR-55),

• list of subsidiaries in the consolidated statements in this section on Basis of preparation

(ESRS2-BP-1-5), and

• carbon allowances in Internal carbon pricing in the Climate change chapter (ESRS E-8-

AR-65). (ESRS2-BP-2-16)

Transitional provisions

Outokumpu utilizes transitional provisions and omits information described in ESRS1 “10.2

Transitional provision related to chapter 5 Value chain”, “10.4 Transitional provision: List of

Disclosure Requirements that are phased-in” described in Appendix C, and the anticipated

financial effects of disclosure requirements E1-9 and E5-6.

Governance

Composition and experience of management bodies

At the end of 2025, the Board of Directors consisted of eight non-executive members, while

the Outokumpu Leadership Team consisted of eight executive members. (ESRS2-GOV-1-21-(a))

There are no employee representatives on the Board of Directors or Outokumpu Leadership

Team. (ESRS2-GOV-1-21-(b))

The Board of Directors as a whole has broad experience of international business,

management and good governance in various sectors, including the steel, metal, chemical

and forest industries, as well as the technology, banking and automobile sectors. The

Outokumpu Leadership Team also possesses broad international competence and

experience concerning, inter alia, the steel, metal, forest, machinery engineering and


		20

chemical industries. The Board of Directors also has access to internal and external

stakeholders and experts with regard to sustainability-related topics. (ESRS2-GOV-1-21-(c))

At the end of the reporting year, four out of sixteen members, or 25% (2024: 25%), of all

the members in the administrative, management and supervisory bodies were women. In

more detail, three out of eight members, or 38% (2024: 29%), of the Board of Directors

were women. In the Outokumpu Leadership Team, one out of eight members, or 13%

(2024: 22%), was a woman. (ESRS2-GOV-1-21-(d))

At the end of 2025, all (100%) members of the Board of Directors were independent of the

company and its significant shareholders, excluding one Board member, Petter Söderström,

who was independent of the company but not one of its major shareholders. (ESRS2-

GOV-1-21-(e))

Roles and responsibilities

The Board of Directors and the President and Chief Executive Officer, who is supported by

the Outokumpu Leadership Team, are the administrative, management and supervisory

bodies of Outokumpu responsible for the management and operations of the Outokumpu

Group with regard to sustainability matters.

The Board of Directors consisted of the following members:

• Kari Jordan (Chairman),

• Hilde Merete Aasheim (as of April 3, 2025)

• Heinz Jörg Fuhrmann,

• Olavi Huhtala (as of April 3, 2025),

• Päivi Luostarinen,

• Jyrki Mäki-Kala,

• Petter Söderström,

• Pierre Vareille (until April 3, 2025), and

• Julia Woodhouse.

The Board of Directors has set up two permanent committees, the Audit Committee and

the Remuneration Committee, which consist of Board members and report to the Board of

Directors.

The Audit Committee was chaired by Jyrki Mäki-Kala, and the other members of the

committee were Olavi Huhtala (as of April 3, 2025), Päivi Luostarinen, Petter Söderström

and Julia Woodhouse (until April 3, 2025). The Remuneration Committee was chaired by

Kari Jordan, and the other members of the committee were Hilde Merete Aasheim (as of

April 3, 2025), Heinz Jörg Fuhrmann, Pierre Vareille (until April 3, 2025) and Julia

Woodhouse (as of April 3, 2025).

The Outokumpu Leadership Team, chaired by the President and CEO, is a reporting and

decision-making forum for steering and managing Outokumpu’s corporate agenda, including

its sustainability matters. The Leadership Team operates by virtue of the CEO’s mandate.

The Outokumpu Leadership Team consisted of:

• Kati ter Horst (President and CEO),

• Stefan Erdmann,

• Matthieu Jehl (as of August 26, 2025),

• Juhani Ristaniemi,

• Martti Sassi,

• Marc-Simon Schaar,

• Rolf Schencking,

• Johann Steiner,

• Niklas Wass (until March 31, 2025), and

• Tamara Weinert (until October 6, 2025). (ESRS2-GOV-1-22-(a))

The Board of Directors has responsibility for overseeing material impacts, risks and

opportunities by deciding upon the strategy and long-term targets of the Group and by

monitoring their implementation, as stated in the Board and Board Committee Charters.

Further, the Board of Directors decides on annual business plans and monitors their

implementation.

As stated in the Board and Board Committee Charters, it is also the duty of the Board of

Directors to nominate and dismiss the members of the Outokumpu Leadership Team and to

define their areas of responsibility, based on a proposal by the Board’s Remuneration

Committee.

Within the Outokumpu Leadership Team, the material impacts, risks and opportunities have

been allocated to its members to ensure further integration into the existing processes. As

set out in the Corporate Governance Policy, the decision-making authority of the

Outokumpu Leadership Team follows from the authority of the CEO, and it is the duty of

this body to run and develop the Group’s operations in line with the strategy and targets

set by the Board of Directors. (ESRS2-GOV-1-22-(b))

Monitoring and managing impacts, risks and opportunities

The Board of Directors decides on Outokumpu’s strategy and the long-term targets of

Outokumpu Group, such as its sustainability targets and strategy. The Board of Directors

also monitors their implementation and charges the President and CEO with formulating

and carrying out the necessary practices and procedures.

In addition to this, Outokumpu’s top management regularly reviews progress regarding

material impacts, risks and opportunities in various forums, as further described below.

(ESRS2-GOV-1-22-(c))


		21

To further ensure its continued progress within sustainability matters and to evaluate its

sustainability strategy, Outokumpu has founded an internal Environment, Social, and

Governance (ESG) Steering Group. The ESG Steering Group also monitors, manages and

oversees impacts, risk and opportunities. The progress in set sustainability targets is

reported to the Outokumpu Leadership Team and the Board of Directors by the Vice

President – Sustainability.

In 2025, the ESG Steering Group consisted of:

• Johann Steiner, President – Business Area Americas (until October 6, 2025)

• Marc-Simon Schaar, Chief Financial Officer,

• Stefan Erdmann, Chief Technology Officer, and

• Juhani Ristaniemi, Executive Vice President – General Counsel, and

• Martti Sassi, President – Business Area Ferrochrome.

Johann Steiner acted as the Chairman of the ESG Steering Group, and Heidi Peltonen, Vice

President – Sustainability, facilitates and participates in the meetings. (ESRS2-GOV-1-22-(c)-(i))

The Outokumpu Leadership Team acts as a reporting and decision-making forum for

steering and managing Outokumpu’s corporate agenda, including its sustainability matters,

while taking into account impacts, risks and opportunities. The Outokumpu Leadership

Team also approves transition and action plans related to sustainability.

Further, each Outokumpu business area is steered by a Business Area Board, chaired by

the CEO. The Business Area Boards consist of the CEO, the CFO, the head of the respective

business area and selected other key members of senior management. Each individual

reports on their own responsibilities, as necessary.

The decision-making authorities of the Outokumpu Leadership Team and the Business Area

Boards follow from the authority of the CEO. It is the duty of these bodies to manage the

Group’s operations in line with the strategy and targets set by the Board of Directors.

(ESRS2-GOV-1-22-(c)-(ii))

Outokumpu has taken into account the existing risk management processes when

conducting the double materiality assessment of assessing material impacts, risks and

opportunities. Furthermore, Outokumpu is currently developing controls to assess progress

in the targets related to material impacts, risks and opportunities. Outokumpu has

identified risks and controls related to sustainability reporting, and more information on

sustainability risks and controls can be found in the section Risk management and internal

controls over sustainability reporting, below in this chapter. (ESRS2-GOV-1-22-(c)-(iii)

Setting targets and monitoring progress

Each business area and group function of Outokumpu is responsible for ensuring its own

operational compliance with the sustainability targets and action plans, which includes

implementing necessary measures and ensuring that monitoring, data collection and

reporting are carried out.

The President and CEO, being responsible for the company’s operational management,

regularly monitors the set targets related to the most material impacts, risk and

opportunities, together with the rest of the Outokumpu Leadership Team.

The Board of Directors approves the sustainability targets related to material impacts, risks

and opportunities and monitors how the Group is proceeding toward the targets, based on

status and action plans presented. (ESRS2-GOV-1-22-(d))

Expertise and skills in sustainability

Both the Board of Directors and the Outokumpu Leadership Team are regularly given

updates and presentations on sustainability-related topics from both internal and external

stakeholders and experts. In addition to this, the Board of Directors attends annual site

visits to part of Outokumpu’s operations, bringing them first-hand insights and expertise in

sustainability matters.

In 2025, the Board of Directors and the President and CEO, assessed their ways of working

and performance with support from an external service provider. One of the objectives of

the assessment was to identify strengths and potential development areas. The

assessment promotes and facilitates the Board of Directors’ and the CEO and President’s

general understanding and knowledge, and ensures that relevant matters are part of the

Board of Directors’ agenda. (ESRS2-GOV-1-23)

To gain an external stakeholder view of material impacts, risks and opportunities,

Outokumpu has had an external ESG Advisory Council to the CEO, consisting of different

stakeholders, to support Outokumpu in setting its ambition and roadmap in sustainability.

The ESG Advisory Council also shared insights on new sustainability topics during 2025.

The ESG Advisory Council consisted of three external advisors in addition to Outokumpu’s

senior executives participating in the council:

• Antoine Allanore, Professor of Metallurgy, Massachusetts Institute of Technology,

• Riikka Joukio, Independent Sustainability Senior Advisor, and

• Julia Woodhouse, Board member and member of the Remuneration Committee of

Outokumpu (ESRS2-GOV-1-23-(a))

As mentioned above, both the Board of Directors and the Outokumpu Leadership Team

receive regular updates and presentations on relevant sustainability matters, which also

relate to the material impacts, risks and opportunities. In addition to this, the Outokumpu

Leadership Team has regular strategy workshops, where sustainability topics are covered.

These updates, presentations and workshops all contribute to ensuring that the Board of


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Directors’ and Outokumpu Leadership Team’s skills and expertise are adequate with

respect to relevant impacts, risks and opportunities. (ESRS2-GOV-1-23-(b))

Roles and expertise in business conduct

The Board of Directors and the President and Chief Executive Officer, who is supported by

the Outokumpu Leadership Team, are the administrative, management and supervisory

bodies of Outokumpu responsible for the management and operations of Outokumpu Group

related to business conduct matters.

Outokumpu has a group-wide Ethics and Compliance (E&C) Program in place. Outokumpu’s

Legal and Compliance function is responsible for managing the implementation and

continuous development of Outokumpu’s E&C Program. The Legal and Compliance function

reports to the CEO, as well as directly to the Board Audit Committee, on E&C-related

matters. E&C updates are made regularly to the Outokumpu Leadership Team, to the Board

Audit Committee and to the Board of Directors.

E&C-related matters are also regularly handled by an internal Ethics and Compliance

Steering Group which consists of the Head of Controls and Internal Audit, Head of Ethics

and Compliance, and selected members of the Outokumpu Leadership Team. The E&C

Steering Group monitors the implementation and further development of the E&C Program

and gets regular updates on various ethics and compliance matters, such as Code of

Conduct, anti-corruption, competition law compliance, data privacy, know your business

partner, and misconduct reporting. The E&C Steering Group also receives a regular update

on internal investigations. In addition, the Legal and Compliance function maintains a

global network of ethics and compliance contact persons and several data protection

governance bodies, which meet on a regular basis and support the implementation of the

E&C Program in the business areas, business lines and group functions.

Responsibility for managing supplier relationships lies primarily with the Procurement

function, which reports to the Chief Financial Officer. The Procurement Leadership Team

oversees supplier performance, including sustainability and ethical business conduct in

day-to-day operations. Oversight of upstream value chain sustainability performance is

exercised through the ESG Steering Group. Collaboration between Procurement, Supplier

Sustainability, Group Sustainability, Health and Safety, and Legal and Compliance teams

ensures that supplier due diligence, audits, and improvement measures are aligned with

company standards and regulatory expectations. (G1-ESRS2-GOV-1-5-(a))

The members of the Outokumpu Board of Directors complete the Outokumpu Code of

Conduct e-learning. In addition, the Outokumpu Code of Conduct e-learning is an annual

mandatory e-learning course for the members of the Outokumpu Leadership Team. There

are also other mandatory, regular E&C e-learning courses in the fields of anti-corruption,

data protection, competition law compliance, and knowing our business partners, which are

taken by the Outokumpu Leadership Team. In addition, Outokumpu Leadership Team

members receive updates and are trained on the various ethics and compliance topics by

the Legal and Compliance function.

Furthermore, in addition to ethics and compliance training, there is other mandatory

training, such as health and safety training, to be taken by the members of the Outokumpu

Leadership Team. (G1-ESRS2-GOV-1-5-(b))

Sustainability matters addressed by the bodies

The ESG Steering Group follows up on the progress of material impacts, risks and

opportunities at least six times a year. Implementation of due diligence and effectiveness

of policies, actions, metrics and targets are also reviewed by the ESG Steering Group at

least six times a year.

Both the Board of Directors and the Outokumpu Leadership Team are informed about the

effectiveness of policies, actions, metrics and targets, including implementation of due

diligence, at least twice a year, starting from 2025. (ESRS2-GOV-2-26-(a))

The Board of Directors considers impacts, risks, and opportunities as part of the company’s

strategy process. Additionally, these impacts, risks and opportunities are assessed and

discussed when reviewing and making decisions on major transactions, case by case.

Potential trade-offs associated with those impacts, risks and opportunities are considered

in the assessment, with the recognition that sustainability is a core value for Outokumpu.

The Outokumpu Leadership Team considers the impacts of the company’s actions within

the value chain, along with the risks and opportunities for its own operations, as part of its

role. It also cascades these considerations throughout the team members’ respective

business areas, functions, and operations. (ESRS2-GOV-2-26-(b))

The Board of Directors has addressed the set targets related to the material impacts, risks

and opportunities of climate, energy, circularity, safety, fairness and belonging annually.

The Outokumpu Leadership Team monitors the progress for the mentioned targets

regularly. In 2025, progress in the following sustainability topics was presented to

stakeholders:

• decarbonization and progress on Outokumpu’s climate transition plan,

• health and safety,

• due diligence development,

• ethics and compliance, and

• sustainability reporting and recent regulatory requirements. (ESRS2-GOV-2-26-(c))

Sustainability performance in incentive schemes

Outokumpu operates two incentive schemes applicable to the members of its leadership

team. The short-term incentive plan (STI) supports the achievement of annual financial and


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strategic targets. The performance share plan (PSP) is designed to promote the

achievement of long-term strategic targets and align the management’s interests with the

those of shareholders. (ESRS2-GOV-3-29-(a))

In the short-term incentive plan, there are two sustainability-related targets. Safety, in

terms of total recordable injury frequency rate (TRIFR), with a target below 1.5 in 2025,

accounts for 10% of the short-term incentives for both the President and CEO and other

Leadership Team members. Diversity, in terms of the number of diverse leaders added to

the company, accounts for 10% of the short-term incentives of the Leadership Team

members, but not the President and CEO. The diverse leaders target included in the short-

term incentive plan is to add 100 diverse managers by the end of 2025. In the

performance share plan, the sustainability-related target focuses on CO2 emission

reduction in line with Outokumpu’s SBTi commitment, for a 20% weight. (ESRS2-GOV-3-29-(b))

Outokumpu’s remuneration policy considers sustainability-related metrics as potential

performance criteria but does not make them mandatory. (ESRS2-GOV-3-29-(c)) The

sustainability-related variables comprises 20% of the total variable remuneration for

management, except for the CEO, for whom it is 15%. (ESRS2-GOV-3-29-(d))

Incentive schemes for the President and CEO are approved by the Board of Directors, while

incentive schemes for other members of the Leadership Team are approved by the

Remuneration Committee of the Board of Directors. (ESRS2-GOV-3-29-(e))

Climate-related considerations in remuneration

Outokumpu’s long-term incentive plan, the Performance Share Plan, includes sustainability-

related criteria for the ongoing plan periods 2023–2025, 2024–2026 and 2025–2027.

The performance share plan sets the compensation criteria for each period and is a part of

the regular compensation for management, comprising close to 200 leaders including the

Outokumpu Leadership Team.

As of 2022, 20% of the Performance Share Plans awarded to management have been tied

to a greenhouse gas emissions reduction target, according to Outokumpu’s Science Based

Targets initiative (SBTi) commitment to keep global warming below 1.5°C. Specifically,

Outokumpu’s greenhouse gas emissions per tonne of crude steel produced must reach a

reduced level each year, as outlined under disclosure requirement E1-4.

In 2025, the performance of Outokumpu’s management has been comprehensively

assessed against the greenhouse gas emission reduction targets:

• Achieved a 33% reduction in greenhouse gas emissions compared to the 2016 baseline,

over its target of a 27% reduction for this period.

• Against the SBTi target 2025 (1.52), the outcome of the greenhouse gas reduction was

1.39 in Performance Share Plan 2023–2025.

(E1-ESRS2-GOV-3-13)

Statement on due diligence

During 2025, Outokumpu continued to develop a group-wide sustainability due diligence

process covering the company’s own operations and value chain. This work was based on

the previous actions that Outokumpu has taken to identify and manage its impacts on

human rights and the environment. Outokumpu committed to the United Nations Guiding

Principles (UNGPs) on Business and Human Rights in 2021. Since then, the company has

further developed its approach to human rights due diligence.

Sustainability due diligence process

Based on the risk-based approach, the initial focus of Outokumpu’s sustainability due

diligence was on the high-risk upstream raw material value chains. Consequently, further

implementation of the UNGP framework was continued in 2025 by setting a corporate

target for all high-impact supplier spend to be covered by the Supplier Code of Conduct by

2030. Additionally, renewed Supplier Requirements with aligned expectations were

released in December 2025. On-site assessments remained central to managing human

rights and environmental impacts also in 2025. The company expanded its value chain

analysis beyond direct suppliers to identify salient impacts related to social and

environmental topics.

Regarding Outokumpu’s own operations, the sustainability due diligence process

development in 2025 was based on the human rights impact assessment findings and

related actions defined in 2024. A governance structure for sustainability due diligence

implementation was defined in 2025: Outokumpu’s sustainability due diligence status is

discussed annually at Outokumpu’s Board of Directors. When relevant, it will also be a

discussion item for Outokumpu’s ESG Steering Committee consisting of Group Leadership

Team representatives. Moreover, Outokumpu’s cross-functional Sustainability Due Diligence

Working Group was launched in 2025 to coordinate the implementation process regarding

Outokumpu’s own operations, upstream value chain and the closed mines previously

operated by Outokumpu. The Working Group consists of representatives of key group

functions for due diligence: Group Sustainability, Supplier Sustainability, General

Procurement, Human Resources, Health & Safety, Legal and Ethics & Compliance. Head of

Human Rights and Head of Supplier Sustainability function as co-leads for the Working

Group.


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Outokumpu’s Human Rights Policy was comprehensively updated in December 2025 to

correspond the updated salient human rights impacts and address the key aspects of

Outokumpu’s sustainability due diligence process development. A general internal guideline

on sustainability due diligence at Outokumpu was also published in December 2025. In

addition, Outokumpu’s group-level approaches regarding grievance mechanisms, remedy,

and stakeholder engagement, including affected communities, were further developed by

releasing internal guidelines on these topics in December 2025. These documents will

serve as basis to develop sustainability due diligence further in 2026.

In 2025, human rights due diligence implementation was initiated for key group functions

and local HR and Health & Safety teams. One of the key focus areas was to further develop

the data gathering process regarding cases of discrimination, work-related complaints and

severe human rights-related cases in the company’s own operations as defined in the data

point ESRS S1-17 (see S1 Own workforce chapter). Furthermore, an environmental due

diligence approach was introduced to local environmental teams at operations. Group

Sustainability, Legal, and Supplier Sustainability established a process to systematically

review regulatory due diligence frameworks relevant to Outokumpu.

Moreover, the sustainability due diligence was further integrated into corporate

instructions. Outokumpu contributed to chosen research projects on sustainability due

diligence implementation and participated in external events and peer discussions on this

topic. ResponsibleSteel surveillance audit findings at Outokumpu’s European operations in

2025 supported the work on sustainability due diligence.

Outokumpu will continue to develop its sustainability due diligence process for both its own

operations and value chain upstream based on existing commitments and emerging legal

requirements during 2026. Besides the ongoing work on supplier sustainability due

diligence, the main planned actions include continued implementation of human rights and

environmental due diligence locally at Outokumpu’s own operations and further

development of group-level approaches related to grievance mechanisms, remedy and

affected communities. (ESRS2-GOV-4-30), (ESRS2-GOV-4-32)


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Main elements of Outokumpu sustainability due diligence in 2025


Elements of sustainability due diligence	Main measures in 2025 at Outokumpu	Report section
Policy and governance	Human Rights Policy update	S1 and S3 Policies
	Supplier Code of Conduct and Supplier Requirements update	S2 Policies
	Internal guidelines on sustainability due diligence, grievance mechanisms, remedy and stakeholder engagement	General Disclosures, Governance
	Establishing Sustainability Due Diligence Working Group	General Disclosures, Governance
	Launching regulatory tracking for sustainability due diligence	General Disclosures, Governance
	Introduction of sustainability due diligence concept to local operations	General Disclosures, Governance
	Defining a governance structure for sustainability due diligence implementation	General Disclosures, Governance
Identify, assess and prioritize	Updated double materiality assessment of environmental and social impact	General Disclosures, Impact, risk and opportunity management
	Biodiversity impact assessment on own operations and value chain	E4 Biodiversity and ecosystems
	Water stewardship plan and water management plan for mining operations	E3 Water and marine resources
	Process development for cases, complaints and severe human rights	S1 Incidents
	Continued implementation of supplier sustainability due diligence	S2 Policies
	Closed mines program on impact identification	E2 Pollution, E4 Biodiversity and ecosystems
Cease, prevent and mitigate	Continued implementation of supplier sustainability due diligence	S2 Engagement, Remediation and Actions
	Closed mines program on impact management	E2 Pollution, E4 Biodiversity and ecosystems
	Certifications and audits: ISO, ResponsibleSteel, Towards Sustainable Mining Finland, Fair Pay Certificate, internal audits on environmental and social performance	E1 Policies, S1, S2, S3
Monitor progress	Continued implementation of supplier sustainability due diligence	S2 Actions and Targets
Monitor progress	Closed mines program on impact monitoring	E2 Pollution, E4 Biodiversity and ecosystems
Report and communicate	Outokumpu Sustainability Statement	Sections concerning sustainability due diligence in this table
Report and communicate	Closed mines program on communicating on progress	E2 Pollution, E4 Biodiversity and ecosystems
Provide and enable remedy	SpeakUp channel maintenance and investigations	G1 Business Conduct and Corporate Culture
	Internal guideline on grievance mechanisms and remedy	General disclosures, Governance
	Closed mines program on providing channels to raise concerns and provide remedial actions	E2 Pollution, E4 Biodiversity and ecosystems
Listen to and engage with stakeholders	Ongoing and targeted stakeholder engagement	General disclosures, Strategy and S3
	Internal guideline on stakeholder engagement, including affected communities	General disclosures, Strategy and S3
	Closed mines program on engaging with related stakeholders	General disclosures, Strategy and S3


		26

Risk management and internal controls over

sustainability reporting

Risk assessment is a dynamic and iterative process that identifies and evaluates risks to

achieve predefined objectives. The process includes five stages: identification, evaluation,

mitigation, control, and reporting. The internal control system, based on the COSO

Framework, includes a control environment, risk assessment, control activities, information

and communication, and monitoring. The Board of Directors oversees internal controls,

while the CEO and executive management implement them. The ESG Steering Group

reviews sustainability disclosures and manages related risks. Control activities target the

prevention, detection, and correction of reporting errors and ensure proper authorization

structures. Sustainability-related risks and controls are integrated into existing procedures.

(ESRS2-GOV-5-36-(a))

Risks related to sustainability reporting are managed according to Outokumpu’s risk

management policy, which is approved by the Board of Directors. Sustainability reporting

risks are identified and evaluated in workshops, focusing on the most relevant parts of the

sustainability reporting process. (ESRS2-GOV-5-36-(b))

The main risks in sustainability reporting include a lack of accuracy and timeliness. These

are assessed annually, considering financial and non-financial impacts and likelihood.

Mitigation involves designing the reporting process and practices to enable controlled

reporting and regular internal controls. Key control activities ensure data completeness and

correctness, with IT system controls and access reviews being crucial. In 2025, Outokumpu

further developed IT systems and the data collection process for sustainability reporting.

(ESRS2-GOV-5-36-(c))

Sustainability reporting items are integrated into Outokumpu’s common processes, with

clear roles and responsibilities defined. Group-wide policies guide employees, and

communication occurs through meetings, intranet, emails, and digital platforms. The ESG

Steering Group regularly addresses sustainability topics and oversees issues related to

reporting. (ESRS2-GOV-5-36-(d))

The Audit Committee oversees the management of sustainability reporting risks. The ESG

Steering Group validates sustainability related risk assessments and assesses risk

mitigation, including the effectiveness of internal controls. It also recommends corrective

actions if needed. Internal control deficiencies are communicated to responsible parties,

including executive management and the Board of Directors. The internal audit function

ensures a robust control environment, with findings reported to the Audit Committee

regularly. (ESRS2-GOV-5-36-(e))

Strategy

In the second phase of Outokumpu's strategy, the aim was to strengthen the company's

core by the end of 2025. The focus was on three key priorities: sustainability, growth from

productivity, and customer-focused steering. Outokumpu remained committed to capital

discipline, limiting its capital expenditure to EUR 550 million for the years 2023–2025,

while also increasing its focus on shareholder returns. Outokumpu's planned capital

expenditure for the year 2025 was EUR 160 million.

In June 2025, Outokumpu announced its growth-focused EVOLVE strategy, aiming to build a

stronger portfolio and improve resilience to cyclicality. With EVOLVE, Outokumpu aims to

increase its value by driving cost competitiveness and cash generation in sustainable

stainless steel, growing profitably in advanced materials and alloys, and revolutionizing

value creation with innovative materials and technologies. Outokumpu’s strategic direction

is guided by the EVOLVE strategy for 2026–2030, which builds on its established

leadership in sustainable stainless steel.

As Outokumpu transitions to the EVOLVE strategy, its priorities shift toward expanding its

portfolio into high-margin, high-value grades, and differentiating through close customer

collaboration. Outokumpu is also exploring new frontiers in innovative materials and metals,

with a particular focus on producing low-CO₂ metals. Through targeted investments in smart

decarbonization and low-emission solutions, Outokumpu aims to create a lasting

competitive advantage and deliver value for all stakeholders. (ESRS2-SBM-1-40-(g))

The implementation of the Carbon Border Adjustment Mechanism (CBAM) from January

2026 represents a key step toward fair carbon pricing and the development of lead

markets for green steel. With its low‑carbon stainless steel and ferrochrome, Outokumpu is

well positioned to benefit from CBAM. To ensure the mechanism’s full effectiveness and a

level playing field, the company continues to urge the EU Commission to expand CBAM to

steel‑intensive downstream sectors and indirect emissions, and to introduce robust

measures that prevent circumvention.

Outokumpu’s current offering consists of low-emission stainless steel produced mainly from

recycled materials and ferrochrome. Stainless steel products can further be divided into

classic products that provide the most commonly used stainless steel products, and the

advanced materials serving specific stainless steel applications or demanding end use.

Most of the products are offered to customers as flat products, that is, as hot and cold

rolled coils, strip or sheet, but Outokumpu also offers a variety of options ranging from

heavy plates and hot rolled coil to specialized components and metal powders.

Outokumpu’s commitment to innovation drives identifying new business opportunities,

investments in technologies, and the invention of new products. (ESRS2-SBM-1-40-(a)-(i))


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Outokumpu’s main markets are Europe (65% of the Group’s sales in 2025) and the

Americas (31% ). The main customer segments are distributors (48% of sales), metal

processing and tubes (16%), automotive (10%), heavy industries (1%), and appliances (8%).

(ESRS2-SBM-1-40-(a)-(ii))

No Outokumpu products are banned in any markets, and the company does not operate in

the fossil fuel sector. (ESRS2-SBM-1-40-(a)-(iv), (ESRS2-SBM-1-40-(d)-(i))

Outokumpu’s headcount of 8,605 (number of employees) (8,736 in 2024) by geographical

area is disclosed in chapter S1 Own workforce. (ESRS2-SBM-1-40-(a)-(iii))

Outokumpu is not disaggregating information based on ESRS sector classification. (ESRS2-

SBM-1-40-(c)) (ESRS2-SBM-1-41)

Outokumpu has set its sustainability targets based on material impacts, risks, and

opportunities, considering the magnitude of its entire business, and it does not have

separately defined goals for specific products or customer groups. The company’s mid-term

climate target is to reduce emission intensity by 42% by 2030, from the 2016 baseline, in

line with its science-based climate target. This target applies to operations of both the

company and its supply chain. Outokumpu’s long-term target is to be carbon neutral by

2050. In line with its purpose, working towards a world that lasts forever, the company’s

ambition is to support its customers in reducing their emissions in all customer groups in

all geographies. (ESRS2-SBM-1-40-(e))

In line with the company vision of pioneering materials and technologies to power

tomorrow's world, Outokumpu today produces stainless steel with an approximately 75%

lower product carbon footprint than the global industry average*. During 2025, the

company supported customer industries in reducing their carbon footprint approximately by

12 million tonnes, and had a recycled material content of 97%***. To push the industry

even further, the company innovated the Outokumpu Circle Green^© product line, with an up

to 93% lower product carbon footprint compared to the global average**. The detailed

environmental impact of Outokumpu’s product categories always depend on the raw

materials and production processes used. (ESRS2-SBM-1-40-(f))

Alongside our new strategy, EVOLVE, Outokumpu introduced the Outokumpu Way – a set of

guiding principles, ABCs. While the company strategy, EVOLVE, sets the direction and vision

for the company, the Outokumpu Way brings it to life. Outokumpu’s ABCs – Ambition

beyond the obvious, Better together and Customer success – invites the organization to

deliver on the strategy in every day decisions and actions.

* Outokumpu’s average product carbon footprint (2025): 1.6 kg CO₂e per kg of stainless steel based on

lifecycle assessment. Global average carbon footprint of stainless steel: 7.3 kg CO₂e per kg of stainless

steel. (Outokumpu’s calculation based on data provided by CRU, worldstainless and Kobolde & Partners AB,

2022).

** The recycled material content measures the amount of recycled and recovered metals in relation to

crude steel output. It is aligned with ISO 14021, and it excludes recovered metals generated in the same

steel making process. The method is also aligned with the EU taxonomy criteria for use of recycled steel in

steel manufacturing.

*** Global average carbon footprint of stainless steel:7.3 kg CO₂e per kg of stainless steel (Outokumpu’s

calculation based on data provided by CRU, worldstainless and Kobolde & Partners AB, 2022). Outokumpu

Circle Green CO₂ emissions: down to 0.5 kilos of CO₂e per kg of stainless steel.

Business model and value chain

Outokumpu’s business model is based on circularity, and the majority of the company’s raw

materials comes from recycled steel. Outokumpu’s value chain includes research and

development, raw material sourcing and extraction, inbound logistics, production, sales and

marketing, outbound logistics, processing and use, as well as scrapping and recycling back

to the value chain. Structurally, the business is divided into three business areas – Europe,

the Americas, and Ferrochrome – where each has responsibility for sales, supply chain

management and operations. They are also Outokumpu’s operating segments under

International Financial Reporting Standards (IFRS). The Ferrochrome business area

operates in the upstream of Outokumpu’s value chain, producing ferrochrome raw material

for the other business areas, which focus on stainless steel and advanced materials

manufacturing and sales. The business areas are supported by the Group functions. (ESRS2-

SBM-1-42)

Outokumpu is part of a global supply chain, including raw material, service, and other

material suppliers worldwide. Sustainable sourcing, with the process of selecting and

managing suppliers, is critical across all purchases, especially in raw material sourcing. The

key inputs Outokumpu sources from its partners are scrap metal, metals required for

stainless steel production, such as nickel and molybdenum, and low-emission energy to run

its energy-intensive manufacturing operations. Responsible sourcing is a pivotal part of

Outokumpu’s sustainability roadmap, and the company is actively partnering with

companies in its upstream to secure access to low-emission raw materials. Examples of

this are the partnerships with CRONIMET to retain a supply of high-quality scrap metal, with

a Canadian company, FPX Nickel, to secure a long-term supply of low-emission nickel metal

and with Greenland Resources, to secure access to low-emission molybdenum from

Greenland. (ESRS2-SBM-1-42-(a))

Outokumpu's main outputs are stainless steel products that have an approximately 75%

lower carbon footprint compared to the industry average. In 2025, Outokumpu delivered

roughly 1.8 million tonnes of stainless steel (1.8 million tonnes in 2024), which supported

their customers in reducing their supply chain emissions by approximately 12 million

tonnes*. The annual production of ferrochrome is roughly 382,000 tonnes in 2025 (2024:

398,000 tonnes) .

Outokumpu creates value for its stakeholders by being the global leader in sustainable

stainless steel. For customers, Outokumpu's products provide a solution to reduce their

Scope 3 emissions. For investors, Outokumpu aims to pay a stable and growing dividend


		28

over time, while maintaining the flexibility to invest in transformative initiatives that yield a

minimum internal rate of return (IRR) of 20%, accounting for market cyclicality.

In addition, for 2025 interests and financing expenses were EUR 65 million, (2024: EUR 74

million) and employee benefits EUR 782 million to employees in 2025 (2024: EUR 714

million). Outokumpu Group is contributing to society with operational taxes, value-added

taxes, and employment taxes etc. Corporate taxes in 2025 had a cash flow impact of EUR

-9 million (2024: EUR 2 million refund). Outokumpu contributes to the United Nations'

Sustainable Development Goals through both the way it operates and its products. (ESRS2-

SBM-1-42-(b))

Outokumpu’s role and presence varies between each part of its value chain. Outokumpu’s

core activities range from research and development to outbound logistics, while further

processing, use and recycling are not part of Outokumpu’s core activities. Research and

development focuses on the innovation of products and materials, including, high alloy

steels, other steels and side-stream products. In raw material sourcing and extraction

Outokumpu plays a double role: Outokumpu has its own mining operations in Kemi, Finland,

for the extraction of chromite ore, the required primary raw material for stainless steel, but

is also active in raw material sourcing, focusing on securing low-emission scrap, nickel and

other relevant raw materials from external sources. The production step covers refining,

smelting, and production of stainless steel, including casting, shaping, heat treatment, and

finishing. The sales and marketing step includes sales, customer relationships

management, and distribution and channels. In inbound and outbound logistics,

Outokumpu manages inventories of both raw materials and finished products, and utilizes

partners for the transportation of both. (ESRS2-SBM-1-42-(c))

* Outokumpu’s average product carbon footprint (2025): 1.6 kg CO₂e per kg of stainless steel based on

lifecycle assessment. Global average carbon footprint of stainless stee): 7.3 kg CO₂e per kg of stainless

steel. (Outokumpu’s calculation based on data provided by CRU, worldstainless and Kobolde & Partners AB,

2022).

Interests and views of stakeholders

Having global operations, Outokumpu engages with a variety of stakeholders around the

world. Outokumpu engages with these stakeholders and communities to understand

expectations, address concerns, and support long‑term positive impacts in the areas where

it operates. Company’s own workforce, customers, investors, value chain workers and the

communities the company affects directly or indirectly are among the key stakeholders for

Outokumpu. (ESRS2-SBM-2-45-(a)-(i))

Engagement with stakeholders takes place both locally in the operations and centrally at

the group level. Currently, Outokumpu has certain structured frameworks in use locally to

engage with stakeholders, for example at Kemi mine, Finland, through the Towards

Sustainable Mining Finland standard. During 2025, Outokumpu continued to develop a

systematic engagement approach for European operations based on the ResponsibleSteel

certification. Outokumpu also launched a closed mines program in Finland 2025, and part

of the work is increased transparency and systematical engagement with local stakeholders

and other interested parties.

In 2025, Outokumpu started to develop its approach to stakeholder engagement. The work

will continue in 2026 with the aim to gradually establish a group-level process to identify

and better understand various stakeholder interests and views and how they are connected

to Outokumpu’s strategy and business model. The process development is supported by an

internal guideline on stakeholder engagement that was published in December 2025.

The interests, views and rights of Outokumpu’s own workforce, including respect for their

human rights, are integrated into strategy and decision-making through a range of

established engagement and feedback mechanisms. Outokumpu’s own workforce is a key

group of affected stakeholders, and their perspectives inform the company’s people

strategy, safety priorities, pay-equity commitments and operational leadership approach.

Workforce engagement takes place at corporate and local level through employee-

representative cooperation, continuous dialogue between employees and managers,

personnel and Fairness & Belonging surveys, leadership and capability-building trainings,

town halls and other operational meetings, as well as dedicated reporting and grievance

channels such as the Speak Up channel. These mechanisms collect insights on topics such

as safety and work environment, fairness and equal treatment, leadership behaviors,

communication practices, career opportunities, and confidence in raising concerns.

In addition, Outokumpu’s human-rights impact assessments, ResponsibleSteel audits, pay-

equity analysis, occupational safety reviews, and structured processes under collective

agreements provide important views and risk insights from different workforce groups,

including production employees, shift workers, temporary or agency workers, migrant

workers and low-paid workers.

The results of these assessments and engagement channels feed directly into

Outokumpu’s sustainability strategy, shaping decisions related to pay transparency and

equity, workforce wellbeing, leadership development, working-time practices, and

occupational safety. These ongoing insights also support enhancements to Outokumpu’s

operational culture and inform the development of longer-term people-related priorities.

This approach ensures that the workforce’s views and rights are systematically integrated

into Outokumpu’s business model. ESRS2-SBM-2-45-(a)-(ii))

The views, interests and rights of value chain workers and affected communities are taken

into account at the group level and locally at operations through various practices.

Outokumpu’s double-materiality assessment identifies upstream value-chain workers

related to mining, refining, alloy production and scrap processing activities. Among these

workers, young and migrant workers in higher-risk sourcing countries are identified as


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stakeholder groups with potential negative impacts concerning working conditions, forced

and child labour risks and community impacts. These worker-related risks may translate

into financial and operational exposures such as supply disruption, regulatory risk and

reputational loss, and consequently inform Outokumpu's sourcing and procurement

strategy. Besides the value-chain workers, related local affected communities are also

considered as part of Outokumpu’s supplier sustainability due diligence.

Outokumpu addresses the risks related to value chain workers and related affected

communities through its Supplier Code of Conduct and supplier sustainability due diligence

including EcoVadis screening, onsite sustainability audits and human-rights impact

assessments with related corrective-action plans. The local communities are approached

case-by-case, based on the company’s risk-based approach to mapping and screening its

suppliers and related community stakeholders. The results of these assessments feed into

supplier selection, long-term partnerships and procurement decisions that reinforce

Outokumpu's low-emission, circular business model.(ESRS2-SBM-2-45-(a)-(ii))

In addition to the communities in Outokumpu’s upstream value chain, the local

communities around Outokumpu’s own operations are also impacted by the company. The

local engagement activities range from addressing environmental concerns and supporting

local education to participating in public consultations, partnering with business

stakeholders and contributing to community well‑being. The feedback informs local site-

level actions and decision-making. The following examples illustrate key interactions at

Outokumpu’s local operations during the reporting year:

• Environmental responsiveness: Addressed community concerns on noise, dust,

and water quality through targeted corrective actions, equipment upgrades, and

research partnerships to improve resource efficiency and environmental

performance.

• Community dialogue and public participation: Participated in public consultations

for future investments, provided transparent communication through media

engagement, and held open‑day events to build trust and strengthen community

relationships.

• Education and talent development: Collaborated with universities, colleges,

schools, and vocational institutions through career fairs, site visits, workshops,

apprenticeships, and thesis opportunities, supporting local skills development and

attracting future talent. Special initiatives promoted greater participation of young

women in steel industry career paths.

• Business partnerships: Engaged with business stakeholders through

presentations, facility tours, and advisory roles to discuss supply chains, workforce

needs, regional development, and sustainability priorities.

• Community support and volunteerism: Supported local organizations, youth

activities, cultural events, and non‑profits through sponsorships and employee

volunteer programs benefiting children, families and seniors, among others.

• Innovation collaboration: Presented ongoing research and advanced sustainable

material innovations through stakeholder forums and partnerships, promoting

circular solutions and low‑carbon technologies.

In 2025, Outokumpu established an internal guidance on stakeholder engagement,

including local affected communities. Based on this guidance published in December

2025, Outokumpu continues to integrate the views of affected communities into its

strategy and decision-making by developing further structured stakeholder engagement and

sustainability due diligence processes as of 2026. These development actions ensure that

Outokumpu’s business model supports both long-term value creation and positive societal

impact. More information on the affected communities can be found in the chapter S3 of

this Sustainability statement.

In 2025, a group-wide approach on Outokumpu’s stakeholder engagement and tools for

planning and tracking the engagement activities and outcomes were tested locally at pilot

sites in Finland, Sweden and Germany. Aspects related to informing the company’s

administrative, management, and supervisory bodies about stakeholder views and interests

and how they are linked to the strategy and business model were also discussed. The

approach will be further developed and rolled out to all locations in 2026. (ESRS2-SBM-2-45-

(d))

The attached table includes a summary of Outokumpu’s key stakeholders, as well as the

topics and forms of engagement. In 2026, Outokumpu will continue the stakeholder

engagement process development in unison with the sustainability due diligence process

regarding its own workforce, value chain workers, and the affected communities as these

two topics are closely interlinked. (ESRS2-SBM-2-43) (ESRS2-SBM-2-45-(a)-(iii-v)), (ESRS2-

SBM-2-45-(b-c))


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Interests and views of various stakeholders


Stakeholder type	Examples of engagement topics	Examples of engagement types
Shareholders, investors, other capital market stakeholders	• Profitability • Long-term value creation • Societal value creation • Strategy and governance • Environmental and social impact	• Continuous dialogue • Annual General Meeting • Quarterly and annual publications • Events and site visits
Own workforce	• Strategy and organization • Well-being, health and safety • Competence development • Fairness and belonging • Working conditions and labour rights	• Continuous dialogue • Employee representative cooperation • Personnel surveys and trainings • Townhalls and other meetings • SpeakUp and other reporting channels
Customers and end-users	• Quality and service • Product information and safety • Environmental and social impact	• Continuous dialogue • Customer surveys and audits • Contractual requirements • Sustainability due diligence
Suppliers, partners and workers in the value chain	• Production input quality and availability • Environmental and social impact	• Continuous dialogue • Supplier visits and audits • Joint projects and trainings • Contractual requirements • Sustainability due diligence
Affected communities (own operations and value chain)	• Well-being, health and safety • Environmental and social impact • Community impact • Rights of indigenous peoples	• Continuous dialogue • Site visits • Supporting local community projects • Sustainability due diligence
Policymakers	• Industrial and trade policy • Climate policy • Sustainability regulation • Political and regulatory landscape	• Continuous dialogue • Public hearings and other consultation processes • Events and site visits
Authorities	• Legal compliance • Environmental and social impact	• Continuous dialogue • Compliance reporting • Inspections and other site visits
Business organizations	• Competitiveness and sustainability • Industry standards and initiatives • Corporate approach on political and regulatory developments	• Continuous dialogue • Representation and events
Civil society representatives	• Environmental and social impact	• Continuous dialogue • Joint projects
Research and educational institutions	• Research and innovation • Product and process development • Future employment needs • Environmental and social impact	• Joint projects • Recruitment events and student fairs • Lectures, study visits, thesis assignments and traineeships

Impact, risk and opportunity

management

Outokumpu identified a total of nine material topics consisting of 21 material sub-topics for

the company in its double materiality assessment. Stainless steel production and its supply

chain require significant amounts of energy and raw materials, contributing to greenhouse

gas emissions and impacting negatively on climate change. Energy and raw material price

volatility and high renewable fuel costs pose financial risks for the company’s operations.

However, additional energy efficiency initiatives create opportunities for reducing energy

consumption and costs. Outokumpu has mitigated its impacts by using recycled raw

materials, low-emission energy, and improving energy efficiency.

Producing stainless steel with over 90% recycled raw materials has a positive impact by

reducing reliance on primary raw materials, reducing carbon emissions and mitigating

biodiversity loss caused by mining. Rising carbon prices, availability of low-emission raw

materials and uncertain decarbonization technologies are seen as a financial risk. On the

other hand, the significantly lower carbon footprint of Outokumpu’s stainless steel

compared to the industry in general, along with vertically integrated ferrochrome

production, can create a competitive advantage and financial opportunities for the

company, especially considering the EU’s Carbon Border Adjustment Mechanism.

Stainless steel production processes and mining operations in Outokumpu’s supply chain

can cause negative impacts on the environment. These potential impacts are caused by

water usage, release of emissions to air and water, and generation of waste, if not

mitigated appropriately. Tighter regulation and rising costs of landfill waste can potentially

increase costs and compliance risks for the company. However, the life-cycle benefits of

long-lasting stainless steel can have a positive impact by supporting sustainability, safety

and hygiene in applications within the downstream. Additional financial opportunities exist

in recycling raw materials and developing by-products from the company’s waste streams.

Due to the nature of steel production processes, employees can face dangerous working

conditions. Outokumpu has invested in high safety standards and employee well-being

which represent financial opportunities in enhanced performance and talent attraction. By

promoting a fair and inclusive workplace, the company fosters innovation and attracts

talent. To prevent incidents of harassment, discrimination and unconscious biases that can

lead to financial risks, the company puts significant efforts into educating its employees on

appropriate work behavior.


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Materials topics based on impact and financial materiality

In total nine out of the ten topics were assessed to be material for Outokumpu. Five topics were assessed

to have both impact and financial materiality and four topics were found to have purely impact materiality.

Description of material impacts, risks and

opportunities resulting from materiality assessment

Outokumpu’s material impacts, risks, and opportunities have been identified through a

comprehensive materiality assessment. These factors are closely linked to our strategy and

business model, influencing resource allocation and driving continuous adaptation across

the company’s operations and value chain.

E1 Climate change

Climate change is a material issue due to the emission and energy-intensive nature of

Outokumpu’s operations and upstream activities, such as raw material extraction,

processing, and transportation. Regulatory developments and growing demand for low-

emission stainless steel present competitive advantages. While energy cost and availability

pose business risks, opportunities exist in enhancing energy efficiency and adopting new

energy technologies.

E2 Pollution

Potential negative impacts may arise from air and water pollution if not properly managed,

both within direct operations and throughout the value chain.

E3 Water and marine resources

Water consumption and discharges in direct operations and the value chain can have

negative impacts. Conversely, stainless steel products contribute positively to water supply

infrastructure.

E4 Biodiversity and ecosystems

Outokumpu’s production activities and legacy sites, especially in vulnerable areas, can

affect species and ecosystem health. Supply chain impacts include habitat disturbance and

biodiversity loss, particularly from mining high-risk commodities near sensitive regions.

E5 Resource use and the circular economy

The use of primary resources and waste generation in our operations are key negative

impacts. However, stainless steel products are durable and recyclable, and they support

circularity. Increased demand for low-emission stainless steel and by-product utilization

offers business opportunities, although scrap availability and pricing remain risks.

S1 Own workforce

Positive impacts stem from prioritizing physical and mental well-being, which enhances

talent attraction, retention, and productivity. Risks include negative health outcomes,

reduced productivity, and legal costs if working conditions fall below company standards.


		32

Fair pay, collective bargaining, employee engagement, equal opportunities, training, and

inclusive workplace initiatives drive innovation and employer attractiveness, while

minimizing risks such as inequality, harassment, and discrimination.

S2 Workers in the value chain

Risks for supply chain workers include health and safety issues, excessive working hours,

limited freedom of association, and inadequate wages. Severe human rights concerns in

the value chain, such as forced, bonded, or child labor, may arise. Strong due diligence

processes can mitigate these risks and enhance value chain resilience.

S3 Affected communities

Outokumpu contributes to community development through taxes, support initiatives, and

sponsorships. However, environmental degradation can impact local communities near the

production sites and within our supply chain. Indigenous rights, including land, forest, and

water rights, may be at risk in the supply chain without a sufficient due diligence in place.

G1 Business conduct

Robust business conduct policies and a culture of transparency, ethics, and responsibility

drive positive impacts and promote responsible practices also among suppliers. Non-

compliance or lapses in corporate culture can result in financial and reputational risks.

Emphasizing sustainability in sourcing enhances resilience and operational efficiency.

(ESRS2-SBM-3-48-(a))

Material impacts, risks and opportunities per topic and value chain phase


Topic	Impact materiality		Financial materiality		Value chain phase
	Positive	Negative	Opportunity	Risk	Upstream	Own operations	Down- stream
E1 Climate change		x	x	x	x	x	x
E2 Pollution		x			x	x
E3 Water and marine resources	x	x			x	x	x
E4 Biodiversity and ecosystems		x			x	x
E5 Resource use and circular economy	x	x	x	x	x	x	x
S1 Own workforce	x	x	x	x		x
S2 Workers in the value chain		x	x	x	x
S3 Affected communities	x	x			x	x
G1 Business conduct	x	x		x	x	x	x

Material impacts, risks and opportunities in this report

Processes to identify and assess material impacts, risks and opportunities (IRO-1) are

disclosed in General disclosure (ESRS2), in the Impact, risk and opportunity management

section, for environmental topics, E1-E5. Disclosure requirements in ESRS covered by the

undertaking’s sustainability statement (IRO-2) are presented after IRO-1.

Material impacts, risks and opportunities and their interaction with the strategy and

business model (ESRS2-SBM-3) are described in each topic’s section covering Material

impacts, risks and opportunities.

Effects of material impacts, risks and opportunities on the business

model, value chain, strategy and decision-making

Outokumpu has integrated sustainability into its strategy, vision and purpose. The

company's vision is to pioneer materials and technologies that power tomorrow.

Outokumpu’s vision directly aligns with its strategy to mitigate sustainability-related risks

and capture opportunities associated with the transition to a low-carbon economy.

Outokumpu’s EVOLVE strategy emphasizes sustainability leadership as one of Outokumpu’s

strategic pillars.

The identified impacts, risks and opportunities, particularly those linked to climate change,

the circular economy, and biodiversity, influence Outokumpu’s business model by shaping

product innovation, operational processes, and the adoption of low-emission technologies.

For instance, commitments to reducing greenhouse gas emissions and improving energy

efficiency drive investments in low-emission production methods and renewable energy,

ensuring alignment with global warming targets aimed at keeping global warming below

1.5°C.

In the value chain, sustainability considerations are central to fostering resilience and

enhancing supply chain practices. Efforts to promote circular economy principles, such as

increasing recycled content in stainless steel production, mitigate risks of resource scarcity

and strengthen relationships with environmentally conscious suppliers. Biodiversity

preservation further supports long-term operational continuity and resource security.

Pollution prevention and waste reduction efforts are done not only to meet regulatory

standards but also to reduce operational costs and enhance Outokumpu’s competitive

advantage. Similarly, fostering supply chain sustainability reduces risks associated with

unethical practices or non-compliance among suppliers. The company’s targets also guide

Outokumpu’s efforts to achieve zero safety incidents, enhance fairness and belonging, and

foster supply chain sustainability. Outokumpu is strongly committed to the highest ethical

standards and complies with the applicable laws and regulations of the countries in which it

operates as well as with the agreements and commitments it has made. (ESRS2-SBM-3-48-(b))


		33

Material impacts

People and the environment

The production of stainless steel demands significant amounts of energy and resources,

leading to greenhouse gas emissions and underscoring the importance of climate change

mitigation for Outokumpu. Effective waste management is crucial to prevent possible

environmental and health problems. By providing employment to thousands of employees

across its operations, Outokumpu has positive impacts on the livelihoods of its workers and

their families. Outokumpu also provides training and skills development, with a further

positive impact on people and ensuring potential negative health and safety impacts are

minimized. Outokumpu has also recognized that individuals involved in their supply chain,

especially within alloy manufacturing, may face adverse impacts due to working conditions

or effects on surrounding communities. (ESRS2-SBM-3-48-(c)-(i))

The business model

The main impacts originate from Outokumpu’s business model, as manufacturing stainless

steel is energy-intensive due to melting processes and requires significant amounts of

resources, such as scrap metal and metal alloys. Outokumpu’s business model reduces the

need for virgin raw material, but due to large volumes impacts are still significant. Large

amounts of greenhouse gases are still released into the atmosphere. The mining of primary

metals for alloys is also energy intensive and contributes to resource depletion. Outokumpu

includes impact mitigating actions in its strategy and ways of working. The company has

also established a climate transition plan which is integrated into the strategy. In addition,

Outokumpu continues to use large amounts of recycled metals in its production, in 2025

96.7% (2024: 95.3%). (ESRS2-SBM-3-48-(c)-(ii))

Time horizons

The expected time horizons of the described impacts are short-term when considering the

company’s own workforce and value-chain workers, short-to mid-term when considering

pollution, water, the circular economy, and affected communities, and long-term for climate

change and biodiversity. (ESRS2-SBM-3-48-(c)-(iii))

Business relationships

Material impacts occur in Outokumpu’s own business activities as well as in the upstream

and downstream value-chain, as described above. Business relationships extend impacts to

value chain workers, in particular Outokumpu’s raw material suppliers, since the mining of

metals for alloying elements has the potential to negatively affect local environments and

communities where they are mined.

(ESRS2-SBM-3-48-(c)-(iv))

Current and anticipated financial effects

Major current financial effects of sustainability related to impacts, risks and opportunities

stem from investments related to Outokumpu’s decarbonization. For the reporting year

2025, the capital expenditures related to decarbonization and the climate transition are

presented in the notes to the financial statements, in the section Climate matters, as well

as in the E1 Climate change chapter, in the section Climate transition plan. (ESRS2-

SBM-3-48-(d))

Outokumpu is not reporting on the information prescribed by ESRS2-SBM-3 paragraph 48(e)

based on the extended phase-in period provided by the quick-fix delegated act of 11 July

2025. (ESRS2-SBM-3-48-(e))

Resilience

Outokumpu assesses the resilience of its strategy and business model on an ongoing basis.

A review of resilience was done in 2025 during development of the new EVOLVE strategy.

Outokumpu’s strategy and business model are resilient to the identified material impacts,

risks and opportunities. Outokumpu’s low-carbon footprint and high use of recycled raw

materials build resilience against climate-related transition risks and helps take advantage

of new business opportunities involving the green transition. Outokumpu is committed to

the science-based target of keeping global warming below 1.5°C. Outokumpu reduces its

transition risks by implementing low-carbon technologies, and increasing the use of clean

energy in its product portfolio. Outokumpu also has preventive measures in place to

minimize pollution at its production facilities. Outokumpu’s production facilities are

situated close to water sources and a major share of Outokumpu’s water use is recycled.

Outokumpu’s only operational mine is based on underground mining, with limited direct

biodiversity impacts. With a strong focus on safety, Outokumpu is able to reduce negative

safety incidents. Through its supplier engagement and sustainability requirements

Outokumpu is able to mitigate risks related to its upstream value chain, including

minimizing negative impacts on workers in its value chain. Good business conduct and a

robust governance structure are built into Outokumpu’s strategy and business model, which

support addressing material impacts and risks and taking advantage of opportunities.

(ESRS2-SBM-3-48-(f)

Changes compared to the previous reporting period

The reviewed double materiality assessment performed in 2025 resulted in slight changes

to material impacts, risks and opportunities overall. Some changes were due to

methodological advancements in evaluations of impacts, risks and opportunities.

In summary, key changes to the previous double materiality assessment are as follows:

• Identification of the material positive impacts Outokumpu has in managing its

relationships with suppliers resulting in materiality of G1-2 Management of relationships

with suppliers. These were deemed material due to Outokumpu’s increased activity on

managing sustainability matters in supplier management and growing business

importance.

• Non-materiality of potential negative impacts Outokumpu may have in terms of

substances of concerns and very high concern leading to non-materiality of E2-5. These


		34

were deemed non-material due to low or no amounts handled by Outokumpu activities or

low or no negative health effects in the state the substances are handled.

• Non-materiality of sub-topic E4 Impacts and dependencies on ecosystem services. These

were deemed non-material due to unidentified material impacts, risks and opportunities.

• Non-materiality of S3 Communities’ civil and political rights. These were deemed non-

material due to unidentified material impacts, risks and opportunities.

• Evaluation scaling of risks and opportunities better aligned with Outokumpu’s enterprise

risk management.

• Update of tools used for evaluating impacts, risks and opportunities. (ESRS2-SBM-3-48-(g))

Additional disclosures

Outokumpu provides entity-specific information in addition to disclosures required by ESRS

in cases where it is believed to be material for gaining a better understanding of

Outokumpu’s impacts, risks and opportunities. (ESRS2-SBM-3-48-(h))

Double materiality assessment process

The double materiality assessment adhered to the general principles described in ESRS1

chapter 3. Outokumpu reviewed its double materiality assessment during the spring of

2025. The materiality assessment process consisted of four parts:

1. Exploring impacts, risks and opportunities

2. Engaging stakeholders

3. Assessing impact and financial materiality

4. Validating and finalizing outcomes

Key activities involved a preliminary assessment (including a review of the previous double

materiality assessment), focused analysis on subject-matter topics, interviews, cross-

functional workshops, analysis of identified impacts, risks and opportunities and materiality

definition for these impacts, risks and opportunities as well as ESRS topics, sub-topics and

sub-sub-topics based on a set threshold. The process inherently assumes that sufficient

understanding of impacts, risk and opportunities related to complex and interdependent

phenomena was achieved. (ESRS2-IRO-1-53-(a))

The process to identify, assess, prioritize and monitor Outokumpu’s potential and actual

impacts on people and the environment includes both continuous monitoring and focused

efforts by both Outokumpu employees and external parties such as partners, service

providers and other stakeholders. Outokumpu’s Sustainability function coordinates several

of the efforts, such as the double materiality assessment process, which is reviewed every

year, and updated if major changes occur in Outokumpu’s business. The double materiality

assessment is performed as a network activity and involves representatives of various

functions, such as Sustainability, Finance, Enterprise Risk Management, Strategy,

Operations, Legal, Compliance and HR. (ESRS2-IRO-1-53-(b))

For analyzing specific issues that give rise to a heightened risk of adverse impacts,

Outokumpu’s value chain (upstream and downstream) and its own operational activities are

mapped out to enable a full scope analysis. All sites and locations are included in the

analysis, with Outokumpu’s production sites residing in Finland, Sweden, Germany, the

United States and Mexico. As raw materials consumption, energy use and industrial

manufacturing operations are significant factors in Outokumpu’s potential impacts on

people and the environment, these are given specific focus. The general double materiality

assessment process included the assessment of material impacts, risks and opportunities

related to business conduct matters. (ESRS2-IRO-1-53-(b)-(i)), (G1-ESRS2-IRO-1-6)


		35

Value chain and key activities

SustainabilityStatementInfographs_v1 (1).jpg

Outokumpu considers potential impacts it may be involved with through its own operations

or as a result of its business relationships with continuous monitoring activities, preventive

measures and addressing issues. (ESRS2-IRO-1-53-(b)-(ii))

To help understand potential impacts Outokumpu may have on its stakeholders, interviews

with stakeholders, such as customers, investors, suppliers and NGOs, were held during the

double materiality assessment review in 2025. In addition, continuous dialogue and

engagement with various stakeholders and external experts is done throughout the year to

ensure a broad understanding of stakeholder concerns. (ESRS2-IRO-1-53-(b)-(iii))

Outokumpu’s double materiality assessment process involved identifying potential and

actual impacts on people and the environment, both negative and positive impacts. These

impacts were categorized to be related to one of the ESRS topics. Impacts were assessed

for severity (considering scale, scope, and irremediability for negative impacts) and

likelihood, following ESRS guidelines. Severity was rated from 1 (low) to 4 (extreme), scale

from 1 (very low) to 5 (very high), scope from 1 (limited) to 5 (global), and irremediability

from 1 (easily remediated) to 5 (non-remediable). Likelihood ranged from 1 (rare, 0-6%) to

5 (actual, 100%). Materiality was determined using combined severity and likelihood

scores, as shown in the image. (ESRS2-IRO-1-53-(b)-(iv))

The process used to identify, assess, prioritize and monitor risks and opportunities that

have or may have financial effects on Outokumpu was performed together with the those

for impacts. The process used similar methodologies. (ESRS2-IRO-1-53-(c))

Outokumpu considered the connections of impacts and dependencies with risks and

opportunities by using a common categorization provided by the ESRS topics, sub-topics

and sub-sub-topics and mapping both the impacts and the risks and opportunities for

Outokumpu on this common framework. Further evaluation of the size and likelihood of the

risks and opportunities further allowed for the analysis of these connections. The main

identified connections were related to climate change mitigation, resource inflows and

working conditions of own workforce. (ESRS2-IRO-1-53-(c)-(i))


		36

SustainabilityStatementInfographs_v2 (1).jpg

The financial effects on earnings, cash flow and equity of risks and opportunities of

sustainability related matters were evaluated on size of financial effect and likelihood of

financial effect. Size of effect was scored on a range of 1 (low, below EUR 50 million), 2

(medium, more than EUR 50 million), 3 (high, more than EUR 100 million) and 4 (extreme,

more than EUR 150 million). The size of financial effects estimates used in the double

materiality assessment contained significant uncertainties as the evaluations were based

on expert judgment, and not on advanced financial modelling. Likelihood of financial effect

was scored using a similar range to that of potential and actual impacts. The materiality

was determined with a combined scoring of financial effect and likelihood. The materiality

threshold for risks and opportunities was depicted in the image above. (ESRS2-IRO-1-53-(c)-(ii))

Outokumpu’s Enterprise Risk Management assesses and ranks sustainability-related risks

in the same way as other risk categories. Material sustainability risks are incorporated into

Outokumpu’s digital risk evaluation systems, enabling the implementation of suitable

controls and mitigation strategies. (ESRS2-IRO-1-53-(c)-(iii))

The double materiality assessment and its results were discussed and validated throughout

the process by Outokumpu’s ESG Steering Group, which includes representation by the

Outokumpu Leadership Team. Monthly meetings in Spring 2025 were used for decision-

making on the double materiality assessment. The outcomes of the assessment were

confirmed with Outokumpu’s Audit Committee. Internal control procedures included a multi-

step approval process, data validation by subject matter experts and the CSRD reporting

process as part of Outokumpu’s group internal control supervision. (ESRS2-IRO-1-53-(d))

The process to identify, assess and manage impacts and risks is integrated into

Outokumpu’s overall risk management process by involving the Enterprise Risk

Management team in the double materiality assessment preparation process and utilizing

the outcomes of the double materiality assessment as in input to Outokumpu’s overall risk

management process. This integrative approach supports the evaluation of Outokumpu’s

overall risk profile. (ESRS2-IRO-1-53-(e))

The opportunities identified in the double materiality assessment process are reported to

Outokumpu management through which they become integrated into management

processes. The identified opportunities serve for consideration in the development of

sustainability-related planning and action, strategy and operational improvement. (ESRS2-

IRO-1-53-(f))

Input parameters used in Outokumpu’s double materiality assessment included previous

double materiality assessment, Outokumpu’s existing research materials and

documentation, publicly available reporting and statistics, industry-specific publications,

and expertise provided by both internal and external stakeholders. The scope of input

parameters used in the process to identify, assess and manage material impacts, risks and

opportunities included Outokumpu’s activities in which Outokumpu has operations, as well

as Outokumpu’s upstream and downstream value chain activities. (ESRS2-IRO-1-53-(g))

The double materiality assessment was reviewed for the financial year 2025. The review

included a more granular level assessment compared to the assessment done for financial

year 2024 in terms of impacts, risks and opportunities evaluations. The assessment also

benefited from being able to utilize the previous assessment as an input. Further

integration between Outokumpu’s Enterprise Risk Management process was also achieved.

Outokumpu reviews its double materiality assessment annually, and revisions are triggered

by major changes in Outokumpu’s business activities or environment. (ESRS2-IRO-1-53-(h))

Identifying material climate-related impacts, risks and opportunities

In Outokumpu’s 2025 double materiality assessment review, climate-related impacts, risks

and opportunities from its earlier assessments in 2023 and 2024 were taken as the basis

and re-evaluated according to the updated methodology described above. Findings and

conclusions are based on a combination of pre-2025 analysis as well as analysis performed

during the double materiality assessment review of 2025. The process included internal

and external expert evaluation.


		37

Impacts on climate change

Outokumpu's operations impact climate change through greenhouse gas emissions. By

incorporating inputs such as evaluations of different mitigation techniques and calculated

transition scenarios that project future emissions, as well as value chain emissions

identified and assessed based on life-cycle studies and expert judgment, different

greenhouse gas emission sources were identified. The majority come from indirect

emissions connected to the sourcing of raw materials such as nickel, as well as energy

consumption. (E1-ESRS2-IRO-1-20-(a)), (E1-ESRS2-SBM-3-AR-9)

Physical risks in own operations and the value chain

Outokumpu has identified climate-related hazards as part of physical climate risk analysis

for production sites, as required by the EU taxonomy’s do-no-significant-harm criteria for

climate change adaptation. The assessments have been based on the methodology

presented in Appendix A in Annex I of the Climate Delegated Act, focusing on short-, to

long-term effects by considering climate projections up to at least 10-30 years in the

future. The assessments have focused only on Outokumpu’s own operations and the

physical risks they face. (E1-ESRS2-IRO-1-20-(b))

Transition risks and opportunities in own operations and the value chain

Outokumpu has identified climate-related transition events as part of its transition plan. In

Outokumpu’s scenarios, it is acknowledged that the stainless steel industry is energy-

intensive, and production processes have high greenhouse gas emissions. Raw materials

and transport also contribute to these emissions. The main risk is that decarbonization

technologies and investments would not be viable and effective enough to meet transition

requirements. New regulations and new technologies needed for transition could increase

production costs. Limited availability of low-emission raw materials, like steel scrap or

alloys with reduced climate impact, is also a risk. (E1-ESRS2-IRO-1-20-(c))

Scenario analysis regarding physical and transition risks and opportunities

To identify and assess the physical and transition risks and opportunities, Outokumpu has

performed a variety of analyses. Regarding physical risks, Outokumpu has performed a risk

analysis for its own operations, according to the EU taxonomy’s do-no-significant-harm

criteria, and has evaluated the financial risks by site. The supply chain was evaluated in

terms of the risk of interruption in supply to its operations. According to the analysis,

physical climate risks do not pose a material financial risk for Outokumpu. Regarding

transition risks and opportunities, Outokumpu has performed a stated policy scenario and

sustainable development scenario analysis in line with the International Energy Agency Iron

and Steel Technology Roadmap (2020). (E1-ESRS2-IRO-1-21), (E1-ESRS2-SBM-3-AR-13)

Identified climate-related hazards

Outokumpu has identified transition-related climate change risks based on its double

materiality assessment. In addition, climate-related hazards have been identified as part of

a physical climate risk analysis for production sites, according to the EU taxonomy’s do-no-

significant-harm criteria for climate change adaptation. These assessments follow the

methodology of Appendix A, Annex I of the Climate Delegated Act, focusing on short to long-

term effects, considering climate projections up to at least 10–30 years in the future.

These assessments focus only on Outokumpu’s own operations and the physical risks they

face. In these assessments, Outokumpu identified climate-related risks from short- to long-

term time horizons. However, the hazards were not linked to the expected lifetime of the

assets, strategic planning horizons or capital allocation plans.

The site-specific assessment took into consideration the likelihood, magnitude, and

duration of the hazards at each location, whenever deemed necessary or plausible. Each

factor was assessed based on scientific research of potential changes under different

scenarios. The assessments took into consideration the different likelihood of extreme

weather conditions, such as cyclones, floods, and so on, in different geographical locations.

Duration was a key factor when looking at the effects of heat stress in Alabama, where the

number of hot-temperature days is expected to increase from 7 in 2022 to 47 in 2050,

under a high-temperature scenario. The magnitude of the hazards at Group level were

assessed as part of the double materiality assessment and overall business risk processes,

which determined the physical risks to be non-material.

Assessments were largely based on shared socioeconomic pathways (SSPs) and climate

change scenarios by the UN’s Intergovernmental Panel on Climate Change (IPCC), including

SSP5 – 8.5, where physical risks are most prevalent. The scenarios were considered

through local or regional projections of climate-related hazards under the IPCC’s climate

change scenarios, such as those made by the Swedish Meteorological and Hydrological

Institute. These projections provided insights into local risks at each site in different

scenarios. Due to the limited data on scenarios from different local or regional providers,

the level of detail varied across the assessments. Some assessments were able to identify

risks based on geospatial coordinates, whereas others looked at changes on a national

level. Additionally, some projections relied on the IPCC’s Sixth Assessment Report data,

while others relied on the older Fifth Assessment Report data. (E1-ESRS2-IRO-1-AR-11-(a-d))

Identified transition events

Outokumpu has identified transition events that may pose risks to Outokumpu and have an

adverse impact on Outokumpu’s operating environment and financial position in the long,

medium, and short term.

Identified transition events in Outokumpu’s climate-related scenarios include:

• evolving climate change policies, increasing regulation and reporting requirements;

• increased price of CO2 emissions and the related rising electricity price;

• increased cost of raw materials and uncertainty about availability of energy and low-

emission raw materials at affordable prices;

• viability and effectiveness of decarbonization technologies in the coming years;


		38

• risk of losing customers and market share; on the other hand, customers switching to

low-emission steel could have a positive impact.

The financial impacts of the climate transition risks are significant and have been

estimated for the target period until 2030. To be able to attain the 1.5°C climate target,

the company has created and committed to a transition plan, in which many greenhouse

gas emission reduction projects have been initiated already.

Outokumpu has also assessed assets and business activities that are incompatible with or

that need significant efforts to be compatible with the transition to a climate-neutral

economy. The production of ferrochrome requires coke as a reductant in the process, and

while coke is used in the ferrochrome production process, emissions could be seen as

partly locked in. Ferrochrome production is not included as eligible under the EU taxonomy.

In stainless steel production, the use of electrodes is considered as locked-in emissions,

but does not pose a material risk to the greenhouse gas emission reduction targets.

Outokumpu has also assessed locked-in emissions from the upstream value chain with

lime-related emissions being the main source. However, the company has identified ways to

reduce greenhouse gas emissions from locked-in emissions, as well. (E1-ESRS2-IRO-1-AR-12-(a-

d))

The climate scenarios used by Outokumpu are seen to be compatible with assumptions

made in its financial statements. Outokumpu includes current and rising EU ETS emission

allowance costs in its financial calculations. Further information on purchases and related

costs for emission allowances is available in the Financial Statements, Note 4.1 Intangible

assets and property, plant and equipment (in the Intangible assets table). Expenses related

to the use of emission allowances are included in Other operating expenses in the

consolidated statement of income. Increasing costs of emission allowances have been

taken into account in the DMA process. (E1-ESRS2-IRO-1-AR-15)

Identifying material pollution-related impacts, risks and opportunities

All Outokumpu production sites have valid environmental permits. Production-related

emissions from the company’s own operations have been assessed by continuous

monitoring and in environmental impact assessments. Impacts and risks have also been

identified in discussions with local authorities. This is an ongoing process since the sites

are in constant dialogue with local authorities due to renewal of permits or if there are

investigations. Value chain emissions have been screened mainly by means of life cycle

assessments, according to ISO 14040 methodology indicating where in the value chain

highest risks are. LCAs have identified that mining and production of alloying elements

could potentially cause pollution in the upstream value chain. (E2-ESRS2-IRO-1-11(a))

Local communities have the possibility to raise topics either in permit processes or in

regular stakeholder meetings at which Outokumpu production site representatives explain

their activities to local residents. This is part of normal business, and no additional

measures were introduced in the context of the double materiality assessment process. (E2-

ESRS2-IRO-1-11(b))

Stainless steel and ferrochrome manufacturing have a negative impact on the environment

in the form of air and water emissions. The production processes generate pollutants such

as metals and nitrates that may enter water bodies and have negative impacts on water

quality and aquatic ecosystems, if not properly managed. Thus, all operating sites are

subject to environmental permits and have pollution abatement techniques such as waste

water treatment plants installed at sites. This applies to the company’s operations in Kemi

and Tornio in Finland; Avesta, Nyby and Degerfors in Sweden; Krefeld and Dillenburg in

Germany; Calvert, Alabama in the US; and San Luis Potosí in Mexico. (E2-ESRS2-IRO-1-AR-9)

Identifying material water-related impacts, risks and opportunities

Actual and potential impacts, risks, and opportunities regarding water resources at

Outokumpu’s own production sites and in the value chain have been assessed in the double

materiality assessment process. All Outokumpu’s production sites were screened to

understand impacts resulting from their water use. Screening was performed through site

representative interviews and data analysis. Marine resources were analyzed as part of the

process; however, the results indicated that they are immaterial in terms of impacts, risks, and

opportunities for Outokumpu. A water risk mapping tool (Aqueduct WRI) was also utilized to

assess water-related risks. (E3-ESRS2-IRO-1-8-(a))

Water-related topics are a part of the human rights impact assessments that Outokumpu

conducts in the upstream value chain. Assessments include gathering input from affected

communities. This information has been utilized as background information in the double

materiality assessment. Direct suppliers were consulted for double materiality assessments,

as well as customers, representing the downstream value chain. (E3-ESRS2-IRO-1-8-(b))

Identifying material biodiversity-related impacts, risks and

opportunities

Actual and potential impacts on biodiversity and ecosystems at our own site locations and

in the value chain have been assessed during the double materiality assessment process

and a comprehensive biodiversity assessment done in 2025. The assessment covered the

scope, which was widened to cover also the supply chain, policies, methodology, pressures,

dependencies, and analysis approach. After reassessment, based on the location-specific

environmental factors, major pressures, supply chain risks, dependencies and the actual

biodiversity drivers, the final risk level and the priority sites and recommendations were

determined. (E4-ESRS2-IRO-1-17-(a))

Dependencies on biodiversity and ecosystems and their services have been assessed in the

double materiality assessment. Outokumpu also conducted a biodiversity screening in

2023, and a comprehensive biodiversity assessment in 2025, including dependencies on

biodiversity and ecosystems. (E4-ESRS2-IRO-1-17-(b))


		39

Transition and physical risks and opportunities related to biodiversity and ecosystems have

been assessed in the double materiality assessment. Outokumpu also conducted a

biodiversity screening in 2023, and a comprehensive biodiversity assessment in 2025,

including dependencies on biodiversity and ecosystems, including transition and physical

risks. These confirmed the conclusions of the double materiality assessment. (E4-ESRS2-

IRO-1-17-(c))

Outokumpu has considered systemic risks by understanding that there are

interdependencies between ecosystems and climate change and resource use. A more

detailed systemic risks analysis was not performed during the double materiality

assessment. (E4-ESRS2-IRO-1-17-(d))

Outokumpu has consulted local communities as part of the environmental permit process.

Regarding suppliers, affected communities are being consulted as part of the human rights

impact assessment. A holistic approach to consulting affected communities will be

developed moving forward, and more information about this is in the S3 chapter.

Currently, Outokumpu does not have a corporate-wide approach or a documented process

on how to engage affected communities directly in setting targets to manage material

negative impacts, advance positive impacts, and manage material risks and opportunities.

In 2025, Outokumpu continued to develop its sustainability due diligence process, covering

its own operations and the value chain. Defining an approach for engaging with various

affected communities was part of this work. The process development will continue in 2026

to enable direct engagement with affected communities regarding target setting. (E4-ESRS2-

IRO-1-17-(e) )

While Outokumpu's sites are not located in sensitive areas, Outokumpu has identified

areas of high biodiversity value that are owned by the company or located near its sites.

Activities at these sites include stainless steel manufacturing and chrome mining. All

operational sites are located within 10 kilometers of at least one protected area. Activities

have potential negative impacts on biodiversity. (E4-ESRS2-IRO-1-19-(a))

Due to identified impacts on nature in the value chain and its own operations, Outokumpu

plans to implement biodiversity mitigation measures. Biodiversity management

requirements are also determined by the ResponsibleSteel standard and the Towards

Sustainable Mining standards. In addition, Outokumpu has defined biodiversity

management plans for Stainless Europe and Advanced Materials. (E4-ESRS2-IRO-1-19-(b))

Identifying material resource use and circular economy-related

impacts, risks and opportunities

Impacts, risks, and opportunities related to resource use and the circular economy,

particularly concerning resource inflows, resource outflows, and waste, at Outokumpu’s own

site locations and in the value chain, have been assessed in the double materiality

assessment process. The process included screening of the company’s own assets and

activities. (E5-ESRS2-IRO-1-11-(a))

Outokumpu’s human rights impact assessments are used to gather input from local

communities in the upstream value chain. This information feeds into the double

materiality assessment. Direct suppliers were consulted for the double materiality

assessment, as well as customers, representing the downstream value chain. (E5-ESRS2-

IRO-1-11-(b))


		40

Disclosure Requirements in ESRS covered by the sustainability statement


Section	Disclosure requirement	Disclosure requirement name	Location (page #)
General disclosures	BP-1	General basis for preparation of the sustainability statements	18
General disclosures	BP-2	Disclosures in relation to specific circumstances	18
General disclosures	GOV-1	The role of the administrative, management and supervisory bodies	19
General disclosures	GOV-2	Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies	22
General disclosures	GOV-3	Integration of sustainability-related performance in incentive schemes	22
General disclosures	GOV-4	Statement on due diligence	23
General disclosures	GOV-5	Risk management and internal controls over sustainability reporting	26
General disclosures	SBM-1	Strategy, business model and value chain	26
General disclosures	SBM-2	Interests and views of stakeholders	28
General disclosures	SBM-3	Material impacts, risks and opportunities and their interaction with strategy and business model	30
General disclosures	IRO-1	Description of the processes to identify and assess material impacts, risks and opportunities	34
General disclosures	IRO-2	Disclosure requirements in ESRS covered by the undertaking’s sustainability statements	40
Environmental, Social, Governance	MDR-P	Policies adopted to manage material sustainability matters	Within each sustainability matter
Environmental, Social, Governance	MDR-A	Actions and resources in relation to material sustainability matters	Within each sustainability matter
Environmental, Social, Governance	MDR-M	Metrics in relation to material sustainability matters	Within each sustainability matter
Environmental, Social, Governance	MDR-T	Tracking effectiveness of policies and actions through targets	Within each sustainability matter
Environmental	Taxonomy Regulation	Disclosures pursuant to Article 8 of Regulation (EU) 2020/852	47
Environmental	E1-1	Transition plan for climate change mitigation	54
Environmental	E1-2	Policies related to climate change mitigation and adaptation	55
Environmental	E1-3	Actions and resources in relation to climate change policies	57
Environmental	E1-4	Targets related to climate change mitigation and adaptation	58
Environmental	E1-5	Energy consumption and mix	60


		41


Section	Disclosure requirement	Disclosure requirement name	Location (page #)
Environmental	E1-6	Gross Scopes 1, 2, 3 and Total GHG emissions	61
Environmental	E1-8	Internal carbon pricing	64
Environmental	E2-1	Policies related to pollution	65
Environmental	E2-2	Actions and resources related to pollution	66
Environmental	E2-3	Targets related to pollution	67
Environmental	E2-4	Pollution of air, water and soil	67
Environmental	E3-1	Policies related to water and marine resources	69
Environmental	E3-2	Actions and resources related to water and marine resources	70
Environmental	E3-3	Targets related to water and marine resources	71
Environmental	E3-4	Water consumption	71
Environmental	E4-1	Transition plan and consideration of biodiversity and ecosystems in strategy and business model	74
Environmental	E4-2	Policies related to biodiversity and ecosystems	74
Environmental	E4-3	Actions and resources related to biodiversity and ecosystems	75
Environmental	E4-4	Targets related to biodiversity and ecosystems	76
Environmental	E4-5	Impact metrics related to biodiversity and ecosystems change	76
Environmental	E5-1	Policies related to resource use and circular economy	77
Environmental	E5-2	Actions and resources related to resource use and circular economy	78
Environmental	E5-3	Targets related to resource use and circular economy	78
Environmental	E5-4	Resource inflows	79
Environmental	E5-5	Resource outflows	80
Social	S1-1	Policies related to own workforce	85
Social	S1-2	Processes for engaging with own workers and workers' representatives about impacts	87
Social	S1-3	Processes to remediate negative impacts and channels for own workers to raise concerns	88
Social	S1-4	Taking action on material impacts on own workforce and approaches to mitigating material risks and pursuing material opportunities related to own workforce and effectiveness of those actions	89


		42


Section	Disclosure requirement	Disclosure requirement name	Location (page #)
Social	S1-5	Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities	91
Social	S1-6	Characteristics of the undertakings employees	91
Social	S1-8	Collective bargaining coverage and social dialogue	95
Social	S1-9	Diversity metrics	95
Social	S1-10	Adequate wages	96
Social	S1-11	Social protection	96
Social	S1-13	Training and skills development metrics	97
Social	S1-14	Health and safety metrics	97
Social	S1-15	Work-life balance metrics	98
Social	S1-16	Compensation metrics (pay gap and total compensation)	99
Social	S1-17	Incidents, complaints and severe human rights impacts	99
Social	S2-1	Policies related to value chain workers	102
Social	S2-2	Processes for engaging with value chain workers about impacts	106
Social	S2-3	Processes to remediate negative impacts and channels for value chain workers to raise concerns	107
Social	S2-4	Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions	107
Social	S2-5	Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities	109
Social	S3-1	Policies related to affected communities	112
Social	S3-2	Processes for engaging with affected communities about impacts	114
Social	S3-3	Processes to remediate negative impacts and channels for affected communities to raise concerns	114
Social	S3-4	Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions	114
Social	S3-5	Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities	115
Governance	G1-1	Business conduct policies and corporate culture	117
Governance	G1-2	Management of relationships with suppliers	123


		43

List of data points that derive from other EU legislation


Section	Disclosure requirement	Data point name	Location (page #)
General disclosures	ESRS2 GOV-1	Board's gender diversity paragraph 21 (d)	20
General disclosures	ESRS2 GOV-1	Percentage of board members who are independent paragraph 21 (e)	20
General disclosures	ESRS2 GOV-4	Statement on due diligence paragraph 30	##
General disclosures	ESRS2 SBM-1	Involvement in activities related to fossil fuel activities paragraph 40 (d) i	27
General disclosures	ESRS2 SBM-1	Involvement in activities related to chemical production paragraph 40 (d) ii	Not material
General disclosures	ESRS2 SBM-1	Involvement in activities related to controversial weapons paragraph 40 (d) iii	Not material
General disclosures	ESRS2 SBM-1	Involvement in activities related to cultivation and production of tobacco paragraph 40 (d) iv	Not material
Environmental	ESRS E1-1	Transition plan to reach climate neutrality by 2050 paragraph 14	54
Environmental	ESRS E1-1	Undertakings excluded from Paris-aligned benchmarks paragraph 16 (g)	55
Environmental	ESRS E1-4	GHG emission reduction targets paragraph 34	##
Environmental	ESRS E1-5	Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) paragraph 38	60
Environmental	ESRS E1-5	Energy consumption and mix paragraph 37	60
Environmental	ESRS E1-5	Energy intensity associated with activities in high climate impact sectors paragraphs 40 to 43	61
Environmental	ESRS E1-6	Gross Scope 1, 2, 3 and Total GHG emissions paragraph 44	61
Environmental	ESRS E1-6	Gross GHG emissions intensity paragraphs 53 to 55	64
Environmental	ESRS E1-7	GHG removals and carbon credits paragraph 56	Not material
Environmental	ESRS E1-9	Exposure of the benchmark portfolio to climate-related physical risks paragraph 66	Phased‑in transition
Environmental	ESRS E1-9	Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a)	Phased‑in transition
Environmental	ESRS E1-9	Location of significant assets at material physical risk paragraph 66 (c)	Phased‑in transition
Environmental	ESRS E1-9	Breakdown of the carrying value of its real estate assets by energy-efficiency classes paragraph 67 (c)	Phased‑in transition
Environmental	ESRS E1-9	Degree of exposure of the portfolio to climate- related opportunities paragraph 69	Phased‑in transition
Environmental	ESRS E2-4	Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil paragraph 28	68
Environmental	ESRS E3-1	Water and marine resources paragraph 9	69


		44


Section	Disclosure requirement	Data point name	Location (page #)
Environmental	ESRS E3-1	Dedicated policy paragraph 13	70
Environmental	ESRS E3-1	Sustainable oceans and seas paragraph 14	Not material
Environmental	ESRS E3-4	Total water recycled and reused paragraph 28 (c)	72
Environmental	ESRS E3-4	Total water consumption in m3 per net revenue in own operations paragraph 29	72
Environmental	ESRS2 IRO 1 - E4	paragraph 16 (a) i	73
Environmental	ESRS2 IRO 1 - E4	paragraph 16 (b)	74
Environmental	ESRS2 IRO 1 - E4	paragraph 16 (c)	74
Environmental	ESRS E4-2	Sustainable land / agriculture practices or policies paragraph 24 (b)	Not material
Environmental	ESRS E4-2	Sustainable oceans / seas practices or policies paragraph 24 (c)	Not material
Environmental	ESRS E4-2	Policies to address deforestation paragraph 24 (d)	Not material
Environmental	ESRS E5-5	Non-recycled waste paragraph 37 (d)	80
Environmental	ESRS E5-5	Hazardous waste and radioactive waste paragraph 39	80
Social	ESRS2 SBM3 - S1	Risk of incidents of forced labor paragraph 14 (f)	85
Social	ESRS2 SBM3 - S1	Risk of incidents of child labor paragraph 14 (g)	85
Social	ESRS S1-1	Human rights policy commitments paragraph 20	86
Social	ESRS S1-1	Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 21	86
Social	ESRS S1-1	Processes and measures for preventing trafficking in human beings paragraph 22	86
Social	ESRS S1-1	Workplace accident prevention policy or management system paragraph 23	86
Social	ESRS S1-3	Grievance/complaints handling mechanisms paragraph 32 (c)	88
Social	ESRS S1-14	Number of fatalities and number and rate of work-related accidents paragraph 88 (b) and (c)	98
Social	ESRS S1-14	Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e)	98
Social	ESRS S1-16	Unadjusted gender pay gap paragraph 97 (a)	99
Social	ESRS S1-16	Excessive CEO pay ratio paragraph 97 (b)	99
Social	ESRS S1-17	Incidents of discrimination paragraph 103 (a)	100


		45


Section	Disclosure requirement	Data point name	Location (page #)
Social	ESRS S1-17	Non-respect of UNGPs on Business and Human Rights and OECD paragraph 104 (a)	100
Social	ESRS2 SBM3 – S2	Significant risk of child labor or forced labor in the value chain paragraph 11 (b)	102
Social	ESRS S2-1	Human rights policy commitments paragraph 17	104
Social	ESRS S2-1	Policies related to value chain workers paragraph 18	106
Social	ESRS S2-1	Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines paragraph 19	106
Social	ESRS S2-1	Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 19	106
Social	ESRS S2-4	Human rights issues and incidents connected to its upstream and downstream value chain paragraph 36	109
Social	ESRS S3-1	Human rights policy commitments paragraph 16	113
Social	ESRS S3-1	Non-respect of UNGPs on Business and Human Rights, ILO principles or and OECD guidelines paragraph 17	114
Social	ESRS S3-4	Human rights issues and incidents paragraph 36	115
Social	ESRS S4-1	Policies related to consumers and end-users paragraph 16	Not material
Social	ESRS S4-1	Non-respect of UNGPs on Business and Human Rights and OECD guidelines paragraph 17	Not material
Social	ESRS S4-4	Human rights issues and incidents paragraph 35	Not material
Governance	ESRS G1-1	United Nations Convention against Corruption paragraph 10 (b)	Not material
Governance	ESRS G1-1	Protection of whistleblowers paragraph 10 (d)	Not material
Governance	ESRS G1-4	Fines for violation of anti-corruption and anti-bribery laws paragraph 24 (a)	Not material
Governance	ESRS G1-4	Standards of anti-corruption and anti-bribery paragraph 24 (b)	Not material

(ESRS2-IRO-2-56)

Determination of materiality

Outokumpu concluded that the ESRS topic S4 of consumers and end-users was not

material in its double materiality assessment, based on Outokumpu’s limited impacts, risks

and opportunities related to consumers and end-users explained by the nature of

Outokumpu’s business-to-business activities and value-chain position. (ESRS2-IRO-2-58)

Outokumpu’s double materiality assessment identified material impacts, risks and

opportunities based on the evaluation and thresholds described above. Management

judgment was also used when determining material ESRS sub-topics. Determination of

material disclosure requirements and individual data points was based on the results of the

double materiality assessment on material sub-topics. The following perspectives were

considered: significance of the information in relation to the matter it purports to depict or

explain, and the capacity of such information to meet the users’ decision-making needs. In

addition, the Omnibus Package’s quick fix amendments were considered in determining

information required for disclosures. (ESRS2-IRO-2-59)


		46

Environmental information

Outokumpu is setting the industry standard

with its low carbon footprint stainless steel

and high level of circularity. Stainless steel

has a pivotal role in mitigating climate

change and accelerating the green

transition.


EU Taxonomy	47
E1 – Climate change	53
E2 – Pollution	65
E3 – Water resources	69
E4 – Biodiversity and ecosystems	73
E5 – Resource use and the circular economy	77


		47

EU Taxonomy

Non-financial companies are required to disclose the share of their sales, and both the

capital and restricted operational expenditure associated with environmentally sustainable

economic activities, as defined in the EU Taxonomy Regulation (2020/852). Eligible

activities are those that are within the scope of the regulation. An aligned activity is defined

as an eligible economic activity that is making a substantial contribution to at least one of

the climate and environmental objectives, while also doing no significant harm to the

remaining objectives and meeting minimum safeguards.

Outokumpu has evaluated its activities in relation to the EU taxonomy, resulting in the

identification of aligned, eligible and non-eligible activities. Outokumpu has identified it's

steel making activities as eligible, in line with economic activity 3.9 “Manufacture of iron

and steel” as outlined in Commission Delegated Regulation (EU) 2021/2139. Key

performance indicators were calculated using consolidated financial information and

additional accounting principles are disclosed after the table below. Full tables are

available at the end of the EU Taxonomy section.

EU Taxonomy key performance indicators


2025	Total € million	Eligible and aligned, %	Eligible and non-aligned, %	Non-eligible, %
Sales (Turnover)	5,468	91%	0%	9%
Capital expenditure	143	77%	0%	23%
Restricted operating expenditure	604	79%	0%	21%

2024
Sales (Turnover)	5,942	93%	0%	7%
Capital expenditure	201	78%	0%	22%
Restricted operating expenditure¹⁾	595	79%	0%	21%

Outokumpu’s turnover is 91%

eligible and aligned to the EU

taxonomy. Finland-based Lappset

has chosen Outokumpu Circle

Green® for its slides as part of its

mission to create more

environmentally friendly

playgrounds.

1) Percent related data has been revised. The calculation method for the restricted operating expenditure

has changed from previous year after a review of accounts. Accounts that were previously fully attributable

are now only partly attributable and therefore more representative. 2024 figure has been adjusted.

The preparation of the key performance indicators requires management to make

judgments, estimates and assumptions on eligible and aligned economic activities, capital

expenditure allocated to those activities and related restricted operating expenditure.

Taxonomy sales (turnover) are presented in accordance with IFRS, in line with the reported

sales in the Group’s consolidated Financial Statements. Outokumpu’s principles for

defining sales (turnover) can be found in note 2.2 in the Group’s consolidated Financial

Statements. The manufacturing of iron and steel is listed as an eligible economic activity.


		48

Taxonomy eligibility and alignment is reported only for Outokumpu operations; sales from

service centers are excluded from eligibility. The impact of service centers is, however,

insignificant as Group internal sales from mills to service centers are still eligible. Since the

service centers are excluded from eligibility, restricted operating expenditure and capital

expenditure associated with service centers is also excluded from eligibility. The main

items of sales that are considered non-eligible include sales of ferrochrome, raw materials,

other services, and energy. Only eligible activities have been assessed for alignment.

Outokumpu has invested in and holds stakes in energy companies in order to secure low

emission electricity. However, Outokumpu does not hold direct nuclear ownership; its

ownership is considered immaterial and is not included in the group taxonomy key

performance indicators.

All steelmaking sites have been assessed, and they meet the technical screening criteria

for substantial contributions to climate change mitigation, which requires that the steel

scrap input relative to product output is not lower than 70% in the production of high alloy

steel. Activities have been assessed to comply with the Do No Significant Harm (DNSH)

criteria.

• Criteria for DNSH to climate change adaptation: physical risks material to Outokumpu’s

production units have been screened and assessed and are part of the company’s

overall risk management strategy.

• Criteria for DNSH sustainable use and protection of water and marine resources and

criteria for DNSH for protection and restoration of biodiversity and ecosystems:

assessment, permits and plans are in place for all production sites, and all sites meet

current legislation.

Outokumpu’s production sites do not use any prohibited substances. In a few activities

where substances of concern are being used, Outokumpu has considered them either

essential since the use is defined as best available technology in the Bref documents, or

non-material as the activity is insignificant compared to total eligible sale, thus meeting the

DNSH criteria for pollution prevention and control.

In 2025, Outokumpu conducted a self-assessment related to the EU taxonomy minimum

safeguards. The self-assessment was based on the previous external evaluations (2022

and 2024) on Outokumpu’s alignment on minimum safeguards. The self-assessment

covered human rights due diligence, liability, corruption, taxation and fair competition.

Based on the progress made with no reported breaches against the criteria, it was

concluded that Outokumpu continues to align with the minimum safeguards, The results

were documented and validated by senior management.

Taxonomy capital expenditure is presented and measured as cash-based. Taxonomy capital

expenditure consists of purchases of property, plant and equipment and purchases of

intangible assets excluding purchases of emission allowances (Note 4.1 in Group Financial

Statements). Taxonomy capital expenditure is presented in accordance with IFRS and in

line with Outokumpu’s consolidated statement of cash flows. Capital expenditure

associated with taxonomy-eligible economic activities has been considered eligible, while

capital expenditure related to the Ferrochrome business area, service centers, and directly

to corporate functions has been considered non-eligible.

As all steelmaking activities were considered aligned, related capital expenditure was also

considered aligned, since it is necessary to uphold the substantial contribution of the

activities. As there are no eligible but non-aligned activities, there are no CapEx plans to

expand taxonomy-aligned economic activities, or plans to allow the activities to become

taxonomy-aligned. Outokumpu discloses its climate transition plan including information on

capital expenditure in the section E1 Climate Transition Plan. The climate transition plan

covers both eligible and non-eligible activities.

Taxonomy-restricted operating expenditure consists of expenses related directly to

maintenance and servicing of assets, as well as research and development expenses. Of

the total taxonomy-restricted operating expenditure, the portion supporting taxonomy-

eligible economic activities has been considered eligible. Expenses related to the

Ferrochrome business area, service centers, and corporate functions have been considered

non-eligible. Research and development expenses have been included in full and

considered eligible except for the part related to the manufacture of ferrochrome, service

centers and corporate.

Only one taxonomy-eligible economic activity has been identified as relevant and taken into

account in the calculations, together with one environmental objective. While recycling of

metallic scrap is at the core of Outokumpu’s business, the collection and sorting of scrap

as outlined in the circular economy criteria document is not considered an economic

activity in itself for Outokumpu. Outokumpu continues to develop its calculations and

definitions as new information becomes available.


		49

EU Taxonomy turnover, capital expenditure and operational expenditure

Proportion of turnover from products or services associated with Taxonomy-aligned economic activities – disclosure covering year 2025

Financial year 2025

2025

Substantial Contribution criteria

DNSH criteria

(“Does Not Significantly Harm”)

Economic activities

Code

Turnover

Proportion

Turnover,

2025

Climate Change

Mitigation

Climate Change

Adaptation

Water

Pollution

Circular Economy

Biodiversity

Climate Change

Mitigation

Climate Change

Adaptation

Water

Pollution

Circular Economy

Biodiversity

Minimum

safeguards

Proportion

of Taxonomy-

aligned (A.1)

- eligible (A.2)

turnover,

2024

Category

enabling

activity

Category

transitional

activity

EUR

(millions)

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y/N

A . TAXONOMY-ELIGIBLE ACTIVITIES

A.1. Environmentally sustainable activities (Taxonomy-aligned)

Manufacturing of iron and steel

3.9

4,971

91%

N/EL

93%

Turnover of environmentally sustainable

activities (Taxonomy-aligned) (A.1.)

4,971

91%

93%

Of which enabling

Of which transitional

4,971

91%

93%

A.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)

EL;

N/EL

EL;

N/EL

EL;

N/EL

EL;

N/EL

EL;

N/EL

EL;

N/EL

Manufacturing of iron and steel

3.9

N/EL

Turnover of Taxonomy-eligible but not

environmentally sustainable activities (not

Taxonomy-aligned activities) (A.2)

A. Turnover of Taxonomy-eligible

activities (A.1+A.2)

4,971

91%

93%

B. TAXONOMY-NON-ELIGIBLE

ACTIVITIES

Turnover of Taxonomy-non-eligible

activities

497

TOTAL

5,468

100%

Taxonomy turnover total is presented in accordance with IFRS, in line with the sales in the Group’s consolidated statement of income in the Financial Statements. Outokumpu’s principles for defining turnover (sales) can be

found in note 2.2 in the Group’s Financial Statements. The manufacturing of iron and steel is listed as an eligible economic activity.


		50

Proportion of CapEx from products or services associated with Taxonomy-aligned economic activities – disclosure covering year 2025

Financial year 2025

2025

Substantial Contribution criteria

DNSH criteria

(“Does Not Significantly Harm”)

Economic activities

Code

CapEx

Proportion

of CapEx,

2025

Climate Change

Mitigation

Climate Change

Adaptation

Water

Pollution

Circular Economy

Biodiversity

Climate Change

Mitigation

Climate Change

Adaptation

Water

Pollution

Circular Economy

Biodiversity

Minimum

safeguards

Proportion

of Taxonomy-

aligned (A.1)

- eligible (A.2)

CapEx, 2024

Category

enabling

activity

Category

transitional

activity

EUR

(millions)

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y/N

A . TAXONOMY-ELIGIBLE ACTIVITIES

A.1. Environmentally sustainable activities (Taxonomy-aligned)

Manufacturing of iron and steel

3.9

110

77%

N/EL

78%

CapEx of environmentally sustainable activities

(Taxonomy-aligned) (A.1.)

110

77%

78%

Of which enabling

Of which transitional

110

77%

78%

A.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)

EL;

N/EL

EL;

N/EL

EL;

N/EL

EL;

N/EL

EL;

N/EL

EL;

N/EL

Manufacturing of iron and steel

3.9

N/EL

CapEx of Taxonomy-eligible but not

environmentally sustainable activities (not

Taxonomy-aligned activities) (A.2)

A. CapEx of Taxonomy-eligible

activities (A.1+A.2)

110

77%

78%

B. TAXONOMY-NON-ELIGIBLE

ACTIVITIES

CapEx of Taxonomy-non-eligible

activities

23%

TOTAL

143

100%

Taxonomy capital expenditure is presented and measured as cash-based and reported in the Group’s Financial Statements, Consolidated statement of cash flows, in line items in Cash flow from investing activities.

Taxonomy capital expenditure consists of purchases of property, plant and equipment and purchases of intangible assets excluding purchases of emission allowances (Note 4.1 in Group Financial Statements). Taxonomy

capital expenditure is presented in accordance with IFRS and in line with Outokumpu’s statement of cash flows. Capital expenditure associated with taxonomy-eligible economic activities has been considered eligible while

capital expenditure related to the Ferrochrome business area, service centers and directly to corporate functions has been considered non-eligible.


		51

Proportion of OpEx from products or services associated with Taxonomy-aligned economic activities – disclosure covering year 2025 ¹⁾

Financial year 2025

2025

Substantial Contribution criteria

DNSH criteria

(“Does Not Significantly Harm”)

Economic activities

Code

OpEx

Proportion

of CapEx,

2025

Climate Change

Mitigation

Climate Change

Adaptation

Water

Pollution

Circular Economy

Biodiversity

Climate Change

Mitigation

Climate Change

Adaptation

Water

Pollution

Circular Economy

Biodiversity

Minimum

safeguards

Proportion

of Taxonomy-

aligned (A.1)

- eligible (A.2)

OpEx, 2024

Category

enabling

activity

Category

transitional

activity

EUR

(millions)

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y;N;

N/EL

Y/N

A . TAXONOMY-ELIGIBLE ACTIVITIES

A.1. Environmentally sustainable activities (Taxonomy-aligned)

Manufacturing of iron and steel

3.9

477

79%

N/EL

79%

OpEx of environmentally sustainable activities

(Taxonomy-aligned) (A.1.)

477

79%

Of which enabling

Of which transitional

477

79%

A.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)

EL;

N/EL

EL;

N/EL

EL;

N/EL

EL;

N/EL

EL;

N/EL

EL;

N/EL

Manufacturing of iron and steel

3.9

N/EL

OpEx of Taxonomy-eligible but not

environmentally sustainable activities (not

Taxonomy-aligned activities) (A.2)

A. OpEx of Taxonomy-eligible

activities (A.1+A.2)

477

79%

B. TAXONOMY-NON-ELIGIBLE

ACTIVITIES

OpEx of Taxonomy-non-eligible activities

126

21%

TOTAL

604

100%

Taxonomy-restricted operating expenditure consists of expenses related directly to maintenance and servicing of assets, as well as research and development expenses. Of the total taxonomy-restricted operating

expenditure, the portion supporting taxonomy-eligible economic activities has been considered eligible. Expenses related to the Ferrochrome business area, service centers, and corporate functions have been considered

non-eligible. Research and development expenses have been included in full and considered eligible, except for the part related to the manufacturing of ferrochrome, service centers and corporate.

¹⁾ Comparative data has been revised. The calculation method for the restricted operating expenditure has changed from previous year after a review of accounts. Accounts that were previously fully attributable are now only

partly attributable and therefore more representative. 2024 figure has been adjusted.


		52

Nuclear and fossil gas related activities


Row	Nuclear energy related activities
1	The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle.	No
2	The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies.	No
3	The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades.	No
	Fossil gas related activities
4	The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.	No
5	The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.	No
6	The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels	No

Due to insignificant ownership in nuclear and fossil related activities, Outokumpu does not do further

analysis on related activities.


		53

Addressing climate change is one of the greatest

opportunities of our time to drive innovation and

build sustainable economies. Outokumpu has

committed to the science-based climate target of

limiting global warming below 1.5°C. The company

accelerates the green transition through its

products’ low carbon footprint and by supporting

customers in reducing their emissions.

E1 – Climate change

TARGETS

Reduce direct, indirect and

supply chain emission

intensity by

42%

by 2030 from a 2016

baseline

PROGRESS

Reduced emission intensity

across direct, indirect and

supply chain altogether

33%

by end of 2025 from a

2016 baseline

Material impacts, risks and opportunities


Climate change mitigation

Negative impact	Actual	High greenhouse gas emissions from energy-intensive production of stainless steel, even with energy efficiency measures and lower- emission energy sources
Negative impact	Actual	High emissions associated with raw materials and transportation logistics
Opportunity		Well positioned towards sustainability regulation (e.g. Carbon Border Adjustment Mechanism (CBAM) and EU Taxonomy alignment)
Opportunity		Demand for low-emission stainless steel is expected to grow in future
Risk		Increased production costs due to additional regulation and required technologies
Risk		Limited availability and high price of low-emission raw materials such as steel scrap or alloys


Energy

Negative impact	Actual	Significant energy consumption of stainless steel production and reliance on fossil fuels
Negative impact	Actual	High energy demand of raw material extraction, processing, and transportation
Opportunity		Enhancing cost competitiveness, innovation, and business resilience from new energy technologies, energy efficiency and optimizing energy utilization
Risk		High cost and limited availability of renewable energy

(E1-ESRS2-SBM-3-48-(a))

Outokumpu has assessed climate impacts in its double materiality assessment, in

connection with the company’s strategy and business model. Most of the impact arises

from the nature of Outokumpu’s key activity, stainless steel production, which is energy-

intensive. Outokumpu has, however, reduced that impact significantly over the years, which

now presents a competitive advantage by being able to provide low-carbon footprint

stainless steel.

Outokumpu identified the following climate transition risks, related to Outokumpu’s

business model and strategy:


		54

• new regulations and technologies needed for the transition, which could increase

production costs,

• availability and price of low-emission raw materials and energy,

• energy cost constituting a substantial part of the total steel manufacturing costs, and

the vulnerability of energy-intensive operations to fluctuations in energy prices.

Outokumpu considers the climate-related risks it has identified to be climate-related

transition risks. Climate-related physical risks were not considered material for Outokumpu.

(E1-ESRS2-SBM-3-18)

Climate resilience is at the core of Outokumpu’s strategy and operations. In spring 2025,

Outokumpu analyzed on a high-level the resilience of its strategy and business model

during the double materiality assessment and the revision of the company strategy. The

assessment done by the Group Sustainability and Group Strategy, covering the whole value

chain with a focus on Outokumpu’s own operations and upstream supply and the

customers’ perspective. The outcome of the analysis is not reported in isolation, but it is

part of the overall resilience of Outokumpu which is disclosed in the Impact, Risk and

Opportunity Management chapter’s Resilience section. (E1-ESRS2-SBM-3-19-(a))

Outokumpu has analyzed its transition risks based on the Task Force on Climate-related

Financial Disclosures (TCFD) when committing to science-based targets in 2021.

Technology deployment and energy consumption have been taken into account in the

decarbonization plan, which is aligned with the 1.5 degree science-based climate target

and outlines mitigation actions and related costs and opportunities (E1-ESRS2-SBM-3-19-(b)),

(E1-ESRS2-SBM-3-AR-7-(a))

In the short-term, Outokumpu aims to continue to strengthen its core by delivering low-

emission stainless steel as a solution for customers to reduce their climate impact. This

foundational business ensures competitiveness and raw material security while generating

the financial strength needed to fund transformation initiatives. In the medium-term the

company further aims to build resilience in its strategy through its science-based climate

targets and expansion into lower-emission advanced materials and alloys. In the long term,

the EVOLVE strategy targets the transformation of Outokumpu into a pioneering force in

materials and technology solutions that power tomorrow by innovating low-CO₂ metals and

enriched ferrochrome. (E1-ESRS2-SBM-3-AR-8-(b))

Due to its low-carbon footprint and high use of recycled raw materials, the company has

built resilience against climate-related transition risks. Outokumpu is further committed to

the science-based target by 2030 and to reducing its transition risk by implementing low-

carbon technologies, and increasing the use of clean energy in its product portfolio. (E1-

ESRS2-SBM-3-19-(c)), (E1-ESRS2-SBM-3-AR-7-(b)), (E1-ESRS2-SBM-3-AR-8-(a))

Climate transition plan

Outokumpu is committed to climate targets in line with the Paris Agreement, aiming to

keep global warming below 1.5°C and achieve carbon neutrality by 2050. The company

prepared its decarbonization roadmap in 2021 and has since continuously assessed and

updated it. In 2025, an updated roadmap and transition plan were developed to mitigate

climate change as an integral part of the company’s strategy and business planning.

(E1-1-14) Detailed below are the various elements within Outokumpu’s transition plan.

Greenhouse gas emission reduction targets

Outokumpu targets a reduction in carbon emission intensity across scope 1, scope 2, and

scope 3 by 42% by 2030 from the 2016 baseline. This target follows the cross-sectoral

pathway. Outokumpu’s stainless steel already has an approximately 75% lower carbon

footprint than the industry average. Innovations such as Circle Green, featuring an up to

93% lower carbon footprint compared to the industry average*, support customers in

reducing their emissions.

Outokumpu’s exposure to coal and gas is mainly through the use of coke in ferrochrome

production and natural gas in stainless steel processing. The company’s transition plan

includes a gradual switch to bio-based coke and biofuels, thereby reducing fossil fuel

dependency. Exposure to oil-related activities is not material and continues to decline, as

demonstrated by the ongoing fuel switch from light fuel oil to natural gas. (E1-1-16-(a))

Decarbonization levers

Outokumpu’s key decarbonization levers in the transition plan are:

• increasing the use of scrap,

• improved energy efficiency and yield,

• increasing the use of low-carbon energy,

• increasing the use of alternative fuels and electrification,

• increasing the use of biocoke,

• increasing low-emission primary raw materials, and

• investigating carbon capture and storage/utilization

Ongoing and planned actions that align with these listed decarbonization levers can be

found under E1-3 in the action and resources section below. (E1-1-16-(b))

* Global average carbon footprint of stainless steel: (2025): 7.3 kg CO₂e per kg of stainless steel

(Outokumpu’s calculation based on data provided by CRU, worldstainless and Kobolde & Partners AB,

2022). Outokumpu Circle Green product carbon footprint: down to 0.5 kg of CO₂e per kg of stainless steel.


		55

Investments and funding

To meet its 1.5°C-aligned climate targets, Outokumpu has committed to doing smart

decarbonization investments. In 2022-2025, Outokumpu has invested EUR 56.8 million in

areas such as energy efficiency, low-carbon energy, and biocoke. An additional

approximately EUR 122.6 million in investments is planned for the coming years to support

decarbonization initiatives. The company continues to evaluate the transition investments

required by 2030 as well as evaluating the operational expenditure related to the transition

plan. Read more about key actions in 2025 in the Actions section in this chapter.

Investments are also disclosed in the Financial statements’ 1.2 Basis of preparation, in the

section Climate matters.

In 2025, approximately EUR 7 million (2024: EUR 5 million) of EU taxonomy eligible and

aligned capital expenditure were towards projects related to the climate transition plan.

The investments related to biocoke support reducing a significant amount of Outokumpu’s

direct emissions, but this capital expenditure is not included in the EU eligible and aligned

taxonomy KPI since ferrochrome manufacturing is not taxonomy eligible. (E1-1-16-(c))

Locked-in emissions and regulatory alignment

Outokumpu has conducted a qualitative assessment of potential locked-in fossil

greenhouse gas emissions from its key assets, products, and value chain at the end of

2023 and January 2024. The analysis indicated that some emissions related to coke and

lime are considered locked-in. However, these are not expected to pose a material risk or

jeopardize Outokumpu’s science-based target. (E1-1-16-(d))

Regarding alignment with the EU Commission’s Delegated Regulation 2021/2139,

Outokumpu has no additional objectives or plans at this stage, as all current economic

activities that are eligible are expected to remain aligned. (E1-1-16-(e)) Outokumpu derives

its revenue mainly from steel manufacturing and is thus not excluded from the EU Paris-

aligned benchmarks. (E1-1-16-(g))

Capital expenditure in coal, oil and gas-related economic activities

Outokumpu did not have any capital expenditure in oil-, gas-, and coal-related activities in

2025. Total capital expenditures including decarbonization and EU Taxonomy-related

investments are presented in previous sections. (E1-1-16-(f))

Alignment with strategy and financial planning

Decarbonization has been an integral part of Outokumpu’s strategy. In the phase 1 of its

previous strategy, Outokumpu committed to the 1.5°C target and created its

decarbonization roadmap, and in phase 2, continuing through 2025, the focus was on

strengthening the core business through sustainability, productivity-driven growth, and

customer-focused steering. In the new growth-focused strategy decarbonization is a key

lever when Outokumpu aims to evolve from a trusted stainless steel producer into a

pioneering force in low-emission metals and technologies. The climate transition plan is

embedded in financial planning by considering financial investments needed to execute its

emissions reduction activities. Internal carbon pricing is used to evaluate the most feasible

decarbonization levers for Outokumpu. (E1-1-16-(h))

Governance and oversight of the transition plan

Outokumpu’s science-based climate target was proposed by the CEO and approved by the

Board of Directors in 2021. The transition plan is approved by the ESG Steering Group and

the CEO. The plan is regularly reviewed as part of the company’s strategic process. The

CEO and the Board approve specific action plans linked to the transition plan during annual

strategy and planning cycles, and the transition plan is integrated into the Sustainability

Statement.

In addition to internal governance, Outokumpu has benefitted in 2025 from the support of

an external ESG Advisory Council, which advised on all sustainability matters, including the

company’s pathway to decarbonization. More detailed information on governance roles is

available in the General Information chapter. (E1-1-16-(i))

Progress in implementing the transition plan

By the end of 2025, Outokumpu achieved a 33% (2024: 32%) greenhouse gas emission

intensity reduction from the 2016 baseline, demonstrating that the company is ahead of its

SBTi target, which is aligned with the implementation of Outokumpu’s transition plan. This

was achieved through high use of recycled steel as raw material, low-carbon energy, and

incremental improvements in operations, reaching a lower emission intensity than set in

the transition plan. Read more about the progress in the Metrics and targets section in this

chapter. Outokumpu also set an ambitious target to reach carbon neutrality at the Kemi

mine by the end of 2025. Achieving carbon neutrality at the Kemi mine has been an

investment worth millions of euros for Outokumpu. Outokumpu was on schedule in terms of

reaching the goal. However, due to uncertainty with the national mining tax increase, the

company could not implement the final measures planned to achieve the goal in 2025, and

as a result, achieving carbon neutrality will be delayed. (E1-1-16-(j))

Policies

Outokumpu’s Sustainability Policy outlines the company’s sustainability principles and

goals, in relation to the sustainability of the economic, environmental, and social aspects.

The main principles of the policy outline that sustainability has a central role in

Outokumpu’s vision, strategy and planning. The principles include acting safely for the

employees and the company’s stakeholders, respecting human rights, and committing to

increasing fairness and belonging. The Sustainability Policy includes topics on climate

change mitigation, energy efficiency, and renewable energy deployment, and outlines steps

to reach carbon neutrality.


		56

While the company is committed to keeping global warming below 1.5°C, Outokumpu

manages climate change by embedding the circular economy into the core of its business

by utilizing over 90% recycled steel to reduce dependence on primary raw materials. This

also reduces greenhouse gas emissions and mitigates biodiversity loss, which Outokumpu

also considers in its decision-making. The company employs risk-based environmental

management to actively minimize waste, pollution, and water use, with reuse practices and

targeted conservation in high-risk regions. Outokumpu optimizes material and energy use to

continuously improve efficiency and prioritize renewable energy and raw material sources

over non-renewable options whenever viable to help reduce GHG emissions. The company is

committed to conducting business with high integrity, by making responsible, sustainable,

and ethical decisions. The company operates based on its key ethical principles, the

Outokumpu Code of Conduct, and other company policies and instructions, as well as the

Outokumpu Way (replacing the previous Ways of Working), which form the basis of

Outokumpu’s actions, operations, and corporate culture. (E1-2-25)

Outokumpu’s Sustainability Policy states that Outokumpu helps its customer to tackle

climate change through lower-emission solutions, creating value for the company, society,

and the environment. Through the policy, Outokumpu commits to take climate change

seriously, acknowledges the need for a just transition, and operates according to long-term

climate targets based on science. Outokumpu’s transition plan states targets and steps to

reach the long-term target of carbon neutrality by 2050. (E1-MDR-P-65-(a))

Scope, accountability, stakeholders, and availability

The Sustainability Policy must be followed globally by all Outokumpu businesses,

companies, directors, officers and employees. In addition, Outokumpu also expects its

business partners across the value chain to follow similar standards to those outlined in

the Sustainability Policy. (E1-MDR-P-65-(b)) The CEO and the Executive Vice President,

Strategy, Sustainability and People (until October 6, 2025) is accountable for the

implementation of the policy. (E1-MDR-P-65-(c)) Outokumpu includes the views of

stakeholders such as shareholders, employees, customers, suppliers, investors and

authorities, as well as general public and non-governmental organizations, as part of its

policy management. The public policies are also available for external stakeholders on

Outokumpu’s website. (E1-MDR-P-65-(e)) The policy requires Outokumpu to strive for a

continuous, systematic, and open dialogue through engaging with stakeholders. (E1-MDR-

P-65-(f))

Third-party standards

Outokumpu is committed to the UN Sustainable Development Goals and is also a signatory

member of the UN Global Compact. The company is committed to the business ambition of

the 1.5°C objective by 2050 and is a member of the Science Based Targets initiative.

Outokumpu is also a member of the ResponsibleSteel initiative and committed to

supporting its vision and mission. Outokumpu also has ResponsibleSteel certification for all

its manufacturing sites in Europe, and all Outokumpu production sites are ISO 14001-

certified. As a chromium mining operator, Outokumpu is a member of the Finnish Network

for Sustainable Mining with related certification. (E1-MDR-P-65-(d))

Addressing material areas

Climate change mitigation

The Sustainability Policy includes climate change mitigation and outlines steps to reach

carbon neutrality. The policy includes actions to reduce greenhouse gas emissions both in

our own operations and in the supply chain, as well as improving energy efficiency and the

use of renewable energy. The policy also guides minimizing the use of primary raw materials

by replacing them with circular materials as one of the key actions to mitigating climate

impact.

In addition, Outokumpu’s Supplier Code of Conduct also addresses climate change by

expecting suppliers to reduce the negative impacts of their operations on the environment,

and especially on climate. More information about Outokumpu’s Supplier Code of Conduct

can be found in S2 Workers in the value chain chapter. (E1-2-25-(a))

Energy efficiency

As stated in Outokumpu's Sustainability Policy, Outokumpu aims to minimize the use of

resources and the negative impact of its operations on the surrounding environment by

proactively developing its production processes and its energy and material efficiency. This

means that Outokumpu continuously optimizes energy use and proactively develops and

improves energy efficiency to help reduce its impact on the environment. (E1-2-25-(c))

Renewable energy deployment

As part of its Sustainability Policy, Outokumpu minimizes the negative impacts of its

operation on the environment by increasing the share of low-carbon electricity, which is one

of the key elements in Outokumpu’s transition plan. The low carbon electricity includes

both renewable and nuclear energy. Outokumpu is also taking steps to replace its fossil

fuels with alternative solutions such as biofuels and electrification. (E1-2-25-(d))

Other

The Sustainability Policy also addresses biodiversity and its dependence on climate

change. By reducing greenhouse gas emissions and virgin resource material dependency,

Outokumpu contributes to maintaining biodiversity globally. In addition, the policy outlines

Outokumpu’s aim of reducing pollution, waste, and emissions to air, and reducing

environmental impacts through risk-based environmental management. (E1-2-25-(e))


		57

Actions

Outokumpu has identified and implemented key actions to mitigate climate change, and

both operational and financial resources have been reserved for them. During 2025,

Outokumpu continued to execute its decarbonization roadmap.

Outokumpu's key decarbonization levers, actions and expected outcomes to mitigate

climate change during 2025 have been:

• continuing the high use of scrap to reduce emissions from raw materials and reduce

virgin raw material dependency,

• establishing energy efficiency initiatives to reduce emissions from energy use and costs,

• securing availability of low-emission electricity through PPA’s and certificates to reduce

emissions from energy use,

• switching from fossil fuels to alternative fuels to reduce emissions from energy,

• bringing the Tornio biocoke agglomeration line into operation and securing a reliable

supply of high-quality biochar,

• signing a Memorandum of Understanding (MoU) with Boston Metal to enhance the

production of critical carbon-free metal, thus reducing the emissions from stainless steel

production.

Decarbonization levers, key actions and expected outcomes in the following reporting years:

• securing low-emission raw materials and energy through partnerships to further reduce

emissions from virgin raw materials and fossil energy,

• investing in biocoke to reduce emissions from coke,

• carbon capture and utilization of CO₂ and CO gas and supporting other industries to

reduce emissions through utilization of waste streams,

• capitalizing on proprietary technology to produce low-CO₂ metals.

Execution of these actions is also outlined in Outokumpu’s transition plan and is crucial to

meet Outokumpu’s science-based emission reduction target as outlined in its Sustainability

Policy objectives and targets. The company also participated in a three-year program toward

carbon neutral metals TOCANEM2, which supports the metal industry’s transition toward

carbon neutrality. (E1-MDR-A-68-(a)), (E1-3-29-(a))

Scope and time horizon

Actions to reduce greenhouse gas emissions cover Outokumpu’s value chain, focusing

especially on direct operations and the supply chain, where majority of the company’s

emissions are generated and in all geographical areas in which the company either

operates in or which are part of its upstream supply chain. If an action applies specifically

to a particular location, this is explicitly stated. For example, the biocoke agglomeration

plant in Tornio is specific to that site. Additionally, actions such as building partnerships

with suppliers extend to the upstream value chain of Outokumpu, demonstrating coverage

beyond the company’s direct operations. (E1-MDR-A-68-(b))

As decarbonization technologies develop, the company assesses the expected time

horizons for each key action continuously. The high use of scrap, low-emission raw

materials and low-emission energy are a continuous effort especially in the short-term,

whereas the current biocoke investments reported are for mid-term. Carbon capture and

storage/utilization is in the research phase and to be evaluated further. As a general rule,

Outokumpu applies the same definition of short-, medium- and long-term as in the

Corporate Sustainability Reporting Directive (“CSRD”): short-term is one year, mid-term is

up to five years, and long-term is more than five years. (E1-MDR-A-68-(c)) None of the actions

were related to any provision of remedy since there was no harm to society from actual

material impacts. (E1-MDR-A-68-(d)) Prior to the reporting year 2025, at the end of 2024,

Outokumpu had improved its emissions intensity by 32% from the 2016 baseline. (E1-MDR-

A-68-(e))

Financial resources

In 2025 Outokumpu has invested capital expenditures of EUR 8.3 million in smart

decarbonization and has decided to invest a further EUR 122.6 million in the following

years. The company continues to evaluate investments required by 2030, as well as

possible subsidies and other financing instruments to execute its decarbonization targets.

(E1-MDR-A-69-(a)) Outokumpu’s mid-term targets are based on existing, cost-efficient

decarbonization technologies, and the company has taken resource allocation into account

as part of its strategy process. In the long-term, Outokumpu sees decarbonization as

generating value in its business and enabling the achievement of the transition plan. (E1-3-

AR-29)

Outokumpu’s current operating expenses to implement actions taken are included in the

expenses disclosed in the consolidated statement of income and in Note 2.3. Any related

current capital expenditures is part of the line item Additions in Note 4.1 Intangible assets

and property, plant and equipment. (E1-MDR-A-69-(b)) The company has not yet made any

future allocation of financial resources. (E1-MDR-A-69-(c))

Achieved and expected GHG emission reductions

By the end of the reporting year, Outokumpu achieved a 33% reduction in CO₂ emissions

intensity against the 2016 baseline (2024: 32%). The expected CO₂ emission intensity

reduction according to the target was 27% in 2025 (2024: 24%). The expected emission

intensity reduction until 2030 is 42%, which corresponds additionally to approximately 1 Mt

CO₂ in absolute emissions. (E1-3-29-(b))

Resource dependence in action implementation

According to its strategy disclosed earlier, Outokumpu has gained a strong financial

position with a strong balance sheet to prepare the company for future investments.


		58

Decarbonization is an integral part of the company’s value creation, and so the investments

to mitigate climate change are also seen as an opportunity for the company. Already today,

Outokumpu supports its customers with low-emission stainless steel. Additionally, with the

biocoke investment, Outokumpu also sees the opportunity for new business models by

utilizing biogenic side-streams. In addition to its own capital expenditure investments, the

company also considers national and EU funds to decarbonize the industry. (E1-3-AR-21)

Capital expenditure and operational expenditure relationships

To achieve the SBTi target, Outokumpu has defined actions that are part of its smart

decarbonization. As reported above, in 2025, Outokumpu invested EUR 8.3 million (2024:

EUR 21.5 million) of capital expenditure in the implementation of those actions, in

particular improving energy efficiency and using biocoke. In addition, the company made

additional operational investments, following changes in operating methods. These are not

disclosed as separate line items in the Financial Statements. The investments made and

planned for the climate transition plan are included in the Financial Statements (Note 4.1,

Intangible assets and property, plant and equipment) (E1-3-29-(c)-(i))

In terms of capital and operational expenditure required to implement the actions taken or

planned, the majority of Outokumpu's operative and capital spending is eligible (in the

sense of EU 2021/2178), and it mainly excludes spending in the Ferrochrome business

area, as the relevant scope is manufacturing of iron and steel. (E1-3-29-(c)-(ii))

Targets

As outlined in Outokumpu’s Sustainability Policy, Outokumpu acknowledges the need for

the transition and operates according to long-term targets based on science. The transition

plan shows initiatives and steps toward both mid-term target by 2030 and carbon neutrality

by 2050. (E1-MDR-T-80-(a))

Outokumpu has set measurable targets for greenhouse gas emissions reduction and energy

efficiency improvement. The greenhouse gas emission reduction target is a relative target

of a 42% reduction per tonne of crude steel (measured in CO₂/tonne crude steel) by 2030,

based on the 2016 baseline. Outokumpu’s climate target of reducing greenhouse gas

emissions is relative, measuring the intensity per tonne of crude steel.

Outokumpu has set an energy efficiency target of 8% for 2025 as part of its

decarbonization program. The energy efficiency target is an absolute reduction from the

baseline. (E1-MDR-T-80-(b))

Scope and baseline year

The target of reducing emission intensity includes emissions in all three scopes: direct

emissions (Scope 1) and indirect and value chain emissions (Scopes 2 and 3). The energy

efficiency target covers Outokumpu’s own operations. (E1-MDR-T-80-(c))

To be as representative as possible, the current baseline for the emission intensity

reduction target is set as an average of three consecutive years, which are 2014, 2015

and 2016. Based on this, the baseline emission intensity value is 2.1 tCO2/tonne of crude

steel. The base year for the energy efficiency target is January–September 2022, and the

baseline value is 5,404 GWh. (E1-4-MDR-T-80-(d))

Milestones

Outokumpu’s climate targets span until 2050. Outokumpu’s mid-term greenhouse gas

emissions intensity target is set by 2030, which is then broken down into short-term,

annual targets that are executed by the business areas and functions. The company also

has a short-term target for energy-efficiency which is set for 2025. The Kemi mine’s carbon

neutrality target is also set for 2025. (E1-MDR-T-80-(e))

Methodologies and assumptions

To set the greenhouse gas emission reduction target, Outokumpu has performed a climate

scenario analysis according to the stated policies scenario, and a sustainable development

scenario analysis in line with the 1.5°C ambition of the Science Based Targets initiative.

The scope of Outokumpu’s SBTi target is stainless steel manufacturing and externally sold

ferrochrome is not included in this target. The energy efficiency target is measured in

cumulative run rate improvement from the baseline, measured in GWh. (E1-MDR-T-80-(f))

The greenhouse gas emissions intensity reduction mid-term target is science-based, and

the energy efficiency target is relative to past performance. (E1-MDR-T-80-g)) The GHG

emissions target has been reviewed and approved externally by the Science Based Targets

initiative, while the energy efficiency target has not been assessed by external

stakeholders. (E1-MDR-T-80-(h))

Changes in targets and metrics

For the science-based emission intensity target set in 2021, Outokumpu has not made any

changes in methodologies during the reporting year. However, the emission factors that are

used to calculate the greenhouse gas emissions are reviewed and updated annually. For

the energy efficiency no changes in methodology have been introduced in 2025. (E1-MDR-

T-80-(i))

Performance against disclosed targets

By the end of 2025, Outokumpu reduced its emission intensity by 33% (2024: 32%) from

the 2016 baseline. This was enabled through high recycled material content, low-carbon

energy and operational improvements. With regards to the energy efficiency target a run-


		59

rate improvement of 495 GWh (2024: 391 GWh) was achieved by the end of the year, out

of a total target of 600 GWh (E1-MDR-T-80-(j))

Managing material impacts, risks and opportunities through targets

Outokumpu’s climate targets are science-based, aligned with the aim of limiting the

increase in the global average temperature to 1.5°C above pre-industrial levels in line with

the Paris Agreement. To reach this target, Outokumpu aims to decrease direct emissions

(Scope 1) and indirect emissions (Scope 2) as well as emissions from the supply chain

(Scope 3) by 42% per tonne of stainless steel by 2030 compared to the 2016 baseline.

(E1-4-33)

Greenhouse gas emissions target and inventory boundaries

Outokumpu’s climate target is a combined emission intensity target, including Scope 1,

Scope 2 and Scope 3. The company has not disclosed specific targets for each scope. The

target differs from total reported GHG emission as it is set based on CO2 emissions only,

since other emissions were considered insignificant in the steel production process. The

target is based on market-based Scope 2. The target boundary also differs from gross

greenhouse gas emissions as it addresses the steelmaking process (excluding sold

ferrochrome) and does not include downstream processing. The baseline emission intensity

in 2016 for Scope 1 emissions was 0.45 tCO2/tonne of crude steel, Scope 2 was 0.45

tCO2/tonne of crude steel and Scope 3 was 1.18 tCO2/tonne of crude steel.

In 2025 the emission intensity was 0.45 tCO2/tonne of crude steel in Scope 1 (2024:0.44

tCO2/tonne), 0.13 tCO2/tonne of crude steel in Scope 2 (2024: 0.13 tCO2/tonne) and

0.81 tCO2/tonne of crude steel in Scope 3 (2024: 0.86 tCO2/tonne). Outokumpu’s target

is set for the emission intensity and the company currently does not have absolute science-

based emission targets.

Compared to the gross greenhouse gas emissions, the science-based target covers 96.7 %

of the emissions in Scope 1 (2024: 99.9%), 80.2 % in Scope 2 (2024: 78.7%) and 80.8 %

in Scope 3 (2024: 84.5%). (E1-4-34-(b))

As reported above, the current baseline for the emission intensity reduction target is set as

an average of three consecutive years, which are 2014, 2015 and 2016. Based on this,

the baseline emission intensity value is 2.1 tCO2/tonne of crude steel. (E1-4-AR-25-(a-b))

The climate target is science-based and is compatible with limiting global warming to

1.5°C, and it has been approved and published by the Science Based Targets initiative in

2021. The target is a non-sectoral intensity target. The assumptions around the target are

explained in the decarbonization plan, which is described in the chapter “Climate transition

plan” in this statement. (E1-4-34-(e)), (E1-4-16-(a))

Outokumpu’s CO2 emission intensity progress, tonnes of CO2 per tonne of steel

The restructuring resulted in a recalculation of the baseline and in 2% higher emission intensity figures.

* Including discontinued operations

Decarbonization levers and their contributions to the emissions

reduction target

Expected emission reductions from 2016 to 2030 (tCO2/tCS)

(E1-4-34-(a))


		60

Currently expected emissions reductions by source of emissions until the target year 2030

from the baseline in 2016 are outlined in the graph above in the report. Reduction

measures address all three scopes. In 2016, the company’s emission intensity was 2.1

tCO2/tCS and by 2030, the company aims to reduce its emission intensity to 1.2 tCO2/tCS.

In this timeframe, Outokumpu aims to reduce emission intensity by 0.11 tCO2/tCS from

coke-related emissions by switching to biocoke, and by 0.14 tCO2/tCS by increasing low-

carbon energy use globally as well as by replacing fossil fuels with renewable alternatives.

By integrating with the supply chain, Outokumpu aims to reduce its raw material emission

intensity by 0.04 tCO2/tCS. The company also sees that in the long-term, beyond the 2030

target carbon capture will be key in reducing emissions that are hard to abate. (E1-4-34-(f),

(E1-4-16-(b))

Use of scenario analysis in metrics and targets

Outokumpu has performed a policy scenario and sustainable development scenario

analysis in line with the International Energy Agency Iron and Steel Technology Roadmap

(2020). The company’s scenario analysis is according to a scenario well below 2°C and the

1.5°C ambition of the Science-Based Targets initiative. Available scenarios take into

account countries’ energy and climate-related policy commitments, and they provide a

baseline scenario against which Outokumpu assesses the additional policy actions and

measures needed to achieve the sustainable development scenario (SDS). The trajectory

for emissions in the sustainable development scenario of the IEA is consistent with

reaching global “net-zero” greenhouse gas emissions for the energy system as a whole by

around 2070. (Source: International Energy Agency or IEA Iron and Steel Technology

Roadmap, 2020.) Existing scenarios do not take into account the special features of

stainless steel production. Stainless steel is produced mainly from scrap but requires the

input of ferroalloys to achieve the right composition. To translate steel industry scenarios to

stainless steel production, it is assumed that the emission intensity of the steel sector is

the same as the intensity of stainless steel production, including Scope 3 emissions. The

target year for the scenarios is set to 2050 in line with the company’s carbon neutrality

target. (E1-4-AR-30-(c))

Energy consumption and mix

In 2025, Outokumpu monitored energy consumption both related to total energy used and

as a key performance indicator (KPI) tailored to the stainless steel process. The latter is an

intensity KPI that covers all Outokumpu’s production processes from ferrochrome

production to melting, hot-rolling and cold-rolling processes. The KPI is expressed as MWh/

produced steel and it is followed up on a monthly basis. (E1-5-MDR-M-75))

Total energy consumption


MWh or %	2025	2024
(1) Fuel consumption from coal and coal products (MWh)	0	0
(2) Fuel consumption from crude oil and petroleum products (MWh)	179,671	92,143
(3) Fuel consumption from natural gas (MWh)	1,835,545	1,689,701
(4) Fuel consumption from other fossil sources (MWh)	1,018,853	975,166
(5) Consumption of purchased or acquired electricity, heat, steam, and cooling from fossil sources (MWh)	716,967	714,565
(6) Total fossil energy consumption (MWh) (calculated as the sum of lines 1 to 5)	3,751,036	3,471,574
Share of fossil sources in total energy consumption (%)	53.0%	50.7%
(7) Consumption from nuclear sources (MWh)	2,687,489	2,714,398
Share of consumption from nuclear sources in total energy consumption (%)	37.9%	39.6%
(8) Fuel consumption for renewable sources, including biomass (also comprising industrial and municipal waste of biologic origin, biogas, renewable hydrogen, etc.) (MWh)	56,325	30,044
(9) Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (MWh)	589,039	632,120
(10) The consumption of self-generated non-fuel renewable energy (MWh)	0	0
(11) Total renewable energy consumption (MWh) (calculated as the sum of lines 8 to 10)	645,364	662,164
Share of renewable sources in total energy consumption (%)	9.1%	9.7%
Total energy consumption (MWh) (calculated as the sum of lines 6, 7 and 11)	7,083,889	6,848,136

(E1-5-37), (E1-5-38), (E1-5-39), (E1-5-AR-34)

In addition to energy intensity Outokumpu monitors specific metrics like the share of low-

carbon electricity use and the energy intensity expressed as total energy use per produced

ton of steel.During the reporting year, Outokumpu bought guarantees of origin from energy

producers covering 72% of its electricity need. In total the share of low-carbon electricity

was 89% (2024: 90%) Total energy intensity was 11,5 GJ/produced tonne of stainless

steel (10,9 GJ/ ton steel in 2024). Taking only the steel related operations into account,

the intensity was 8,6 t GJ/ton steel


		61

Energy intensity


MWh/EUR	2025	2024
Total energy consumption from activities in high climate impact sectors per net revenue from activities in high climate impact sectors (MWh/EUR)	0.0013	0.0012

(E1-5-40)

As Outokumpu produces stainless steel and ferrochrome, which are energy-intensive

processes, the company’s entire operations are defined as a high climate impact sector

according to the EU regulation. The company’s operations are covered by NACE code 24.1,

which matches economic activity 3.9 of Annex I to the Climate Delegated Act: manufacture

of iron and steel. (E1-5-42)

Outokumpu’s net revenue is EUR 5,468 million in note 2.2 in the Financial Statements

(2024: EUR 5,942 million). (E1-5-43)

Net revenue


€ million	2025	2024
Net revenue from activities in high climate impact sectors used to calculate energy intensity	5,468	5,942
Net revenue (other)	—	—
Total net revenue (Financial Statements)	5,468	5,942

(E1-5-AR-38-(b))

Energy methodologies, assumptions and verification

Outokumpu monitors energy as total energy consumption, expressed in MWh. In total

consumption all production sites as well as offices and service centers are included.

Consumption information and heat values are based on documentation from suppliers,

Lower heat values are used. The entity-specific metric on energy intensity is calculated as

Total Energy consumption in GJ divided by crude steel production. Used heat values and the

consumption of energy are based on documentation from suppliers. (E1-5-MDR-M-77-(a))

Energy use is part of the verification process by which the sites subject to the EU

emissions trading scheme report their emissions and energy use to local authorities.

Outokumpu’s production units included in the emissions trading scheme are Tornio, Finland;

Avesta, Nyby and Degerfors, Sweden; and Krefeld and Dillenburg; Germany. (E1-5-MDR-M-77-(b))

Scopes 1, 2 and 3 greenhouse gas emissions

Outokumpu’s key performance indicator in following its emissions is intensity-based

greenhouse gas emissions (GHG) per tonne of crude steel. This metric includes all three

scopes, and it is Outokumpu’s target in the Science Based Targets initiative.

(E1-6-MDR-M-75-(a))

Total greenhouse gas emissions

Scope 1 emissions are 1,027,622 tCO2eq (28%), Scope 2 emissions are 373,505 tCO2eq

(10%) and Scope 3 emissions are 2,237,699 tCO2eq (61%) of Outokumpu’s total emissions

in 2025. In total, Outokumpu’s market based greenhouse gas emissions were 3,638,827

tCO2eq. (E1-6-44-(a-d))

Outokumpu’s European production sites are subject to the EU ETS scheme. The percentage

of Outokumpu’s Scope 1 GHG emissions that are subject to this emission reduction

scheme is 84.0% , this number includes also the ships transporting material between

Tornio and Terneuzen. Outokumpu is not subject to any other regulated emission reduction

schemes. Further informations on purchases and related costs for emission allowances are

available in the Financial Statements, Note 4.1 Intangible assets and property, plant and

equipment (in the Intangible assets table). Expenses related to the use of emission

allowances are included in Other operating expenses in the consolidated statement of

income.

Outokumpu has no associate or joint ventures that Outokumpu has control over and needs

to report. However, if an associate is part of the value chain, the related value chain

emissions are accounted for. Therefore, the gross emissions reported are the emissions for

the consolidated group. (E1-6-50)

Outokumpu also uses biomaterials in production processes. The biogenic emissions from

biofuels amounted to 15,745 tCO2 in 2025 (2024: 8,256 tCO2). In addition to biofuels

there were biogenic emissions from raw materials like biocoke which have not been

quantified in 2025. (E1-6-AR-43-(c))


		62


Greenhouse gas emissions and targets
	Retrospective
	Base year²⁾	Comparative	N	%N/N-1
	2016	2024	2025	Change, %	2030³⁾	Annual % Target / base year
Scope 1 GHG Emissions
Gross Scope 1 GHG emissions (tCO2eq)¹⁾	1,213,634	990,643	1,027,622	4%	689,400	3%
Percentage of Scope 1 GHG emissions from regulated emissions trading schemes (%)		84%	84%
Scope 2 GHG Emissions
Gross location-based Scope 2 GHG emissions (tCO2eq))⁴⁾	n/a	448,567	435,773	-3%	n/a	n/a
Gross market-based Scope 2 GHG emissions (tCO2eq)	1,210,872	364,704	373,505	2%	28,200	7%
Significant scope 3 GHG emissions
Total gross indirect (Scope 3) GHG emissions (tCO2eq)	3,163,556	2,347,109	2,237,699	-5%	2,211,400	2%
1 Purchased goods and services	n/a	1,843,340	1,666,717	-10%	n/a	n/a
2 Capital goods	n/a		47,005		n/a	n/a
3 Fuel and energy-related activities (not included in Scope1 or Scope 2)	n/a	111,493	123,500	11%	n/a	n/a
4 Upstream transportation and distribution	n/a		26,585		n/a	n/a
5 Waste generated in operations	n/a	21,957	15,309	-30%	n/a	n/a
6 Business traveling	n/a	4,469	4,103	-8%	n/a	n/a
9 Downstream transportation	n/a	218,934	221,641	1%	n/a	n/a
11 Use of sold products	n/a	146,917	132,839	-10%	n/a	n/a
Total GHG emissions
Total GHG emissions (location-based) (tCO2eq)	n/a	3,786,319	3,701,094	-2%	n/a	n/a
Total GHG emissions (market-based) (tCO2eq)	5,588,062	3,702,456	3,638,827	-2%	2,929,000	3%

(E1-6-44), (E1-6-48), (E1-6-49), (E1-6-51), (E1-6-52), (E1-6-AR-46-(d)), (E1-6-AR-48)

¹⁾ Tonnes of CO2 equivalent.

²⁾ Base year emissions are only reported as CO2.

³⁾ The company has set its science-based target only on emission intensity, however reported in the table as illustrative absolute emission target for 2030.

⁴⁾ Scope 2 (location-based) greenhouse gas emissions calculations have been updated to utilize more recent emission factors, resulting in changes to prior period’s reported emissions. Reported value for 2024 Scope 2

(location-based) emissions changed from 540,274 tCO2 to 448,567 tCO2. This also affects Total greenhouse gas emissions values for prior period, changing from 3,878,026 tCO2 to 3,786,319 tCO2.

Methodologies, assumptions and validation for GHG emissions

The greenhouse gas measuring and reporting follows the GHG Protocol Corporate Standard

and steel industry standards such as ISO 14404. CO2 emissions of electricity are given both

as market-based and location-based. CO2 emissions outside the company (Scope 3) are

included. The main impact comes from purchased goods, mainly alloys. Emissions from

business travel and waste generated are also reported, at least partly, as well as

downstream transportation of products. Biogenic emissions in Scope 2 and 3 have not been

disclosed as the emission factors used do not include biogenic emissions (E1-6-MDR-M-77-(a))

Outokumpu’s sites that are subject to EU Emissions Trading have to verify their CO2

emissions annually; energy use is part of this verification process. The sites are Tornio,

Avesta, Nyby, Degerfors, Krefeld, and Dillenburg. Emissions are verified by accredited

verification bodies for the EU ETS scheme. The verifier depends on the country in which the

site is operating. (E1-6-MDR-M-77-(b))

Outokumpu is for the first time reporting emissions from upstream transportation and

capital goods, which impacts comparison to previous year values. Outokumpu has also

assessed the liner ships that transport steel coils and other materials between Tornio to

Terneuzen and concluded that while they are not owned by Outokumpu they will be reported


		63

in Scope 1 due to the nature of their use. In previous years product transports from Tornio

site have all been reported in Scope 3 as downstream transport. (E1-6-47)

Outokumpu has not identified any effects of significant events and changes in

circumstances (relevant to its GHG emissions) that occurred between the reporting dates of

the entities in its value chain and the date of the undertaking’s general purpose Financial

Statements. (E1-6-AR-42-(c))

Scope 1

Scope 1 emissions were calculated based on fuel and material consumption, including the

following greenhouse gases: CO2, N2O, and CH4. The rest of the GHGs were not relevant for

the fuels used. National emission factors from authorities were used for fuels, as these are

also used for ETS reporting. For materials, emissions were calculated based on carbon

content, in line with ETS methodology.

Scope 2

Greenhouse gas emissions of Scope 2 electricity are calculated and monitored by the

emissions factor of Outokumpu’s market-based electricity given by the electricity supplier for

the used electricity. This includes 100% of electricity use in the EU market, which comes

with guarantees of origin and from ownership in power production. In addition, location-

based electricity emissions are disclosed. They are calculated using public country-specific

emissions factors for electricity. the methodology and source of this data can vary, for the

main locations the electricity emission factor is based on latest available public data.

Electricity consumption in operations is calculated based on measured consumption, and

electricity consumption of offices is based on full-time employees multiplied by a factor for

electricity use. Purchased heat Scope 2 emissions are calculated based on supplier-specific

information or the US EPA data for heat.

Outokumpu reports both location-based and market-based GHG emissions. The science-

based target is calculated and reported using market-based Scope 2 emissions. During the

reporting year, Outokumpu bought guarantees of origin from energy producers covering 72%

of its electricity need. Outokumpu has access to certificates through ownership, power

purchase agreements (PPA) and electricity suppliers. The market-based emissions do not

include GHGs other than CO2. (E1-6-AR-45-(d))

Outokumpu uses electricity emission factors from suppliers or country-specific emissions

factors that do not separate the percentage of biomass or biogenic CO2 . Referring to

transitional provision related to the value chain, Outokumpu is not reporting on Scope 2

biogenic emissions in this report. Outokumpu is assessing how to retrieve this information in

future disclosures, for example by directly engaging with suppliers. (E1-6-AR-45-(e))

Scope 3

The percentage of GHG Scope 3 emissions calculated using primary data is 54% (2024:

66%). (E1-6-AR-46-(g))

Scope 3 emissions are reported from the following categories: purchased goods and

services (3.1), capital goods (3.2), fuel and energy-related activities (not included in Scope 1

or Scope 2)(3.3), waste generated in operations (3.5), business travel (3.6.), upstream and

downstream transportation and distribution (3.4, 3.9) and use of sold products (3.11).

Categories that are not reported include leased assets (3.8, 3.13) and franchises (3.14) as

not applicable. The processing and use of sold steel (3.10 and 3.11) are not included for

the material steel due to the wide and dispersed use of the material. However, the use of

sold waste gas is included under 3.11 End-of-life treatment(3.12) is not disclosed in the

table, but it is included in the purchased goods as the upstream emissions from collecting,

sorting and treating secondary steel are included. For investments (3.2 and 3.15), and for

employee commuting (3.7) Outokumpu is not reporting on these emissions since they have

been assessed as not material for Outokumpu. (E1-6-AR-46-(i))

Outokumpu uses both specific data and data base emission factors to calculate value

chain emissions; no biogenic emissions have been reported for the value chain. (E1-6-AR-46-

(j))

The reporting scope is the same as for Scope 1&2 which means that Outokumpu reports

on Scope 3 for processes over which it has operational control. The main Scope 3 impact

comes from purchased goods, mainly alloys. Emissions from business travel and waste

generated are also reported, and sold products to the extent feasible, as well as

downstream transportation of products.

Outokumpu follows a tiered approach for Scope 3 emission factors for both carbon

footprint calculations and greenhouse gas reporting. Outokumpu uses specific emission

factors when available, secondly industry-average collected data, and thirdly data from

databases or standards, such as ISO 14404 or the Ecoinvent database.

• Category 1 (purchased goods and services): This category includes raw materials and

consumables used by Outokumpu and the external hot rolling of slabs in the US.

Outokumpu calculates annual weighted average emission factors for its raw materials.

For each material raw material supplier Outokumpu requests first-hand specific data.

Where specific emission factors are missing, Outokumpu uses emission factors of the life-

cycle assessments of relevant industry associations such as the Nickel Institute and the

International Molybdenum Association when available. If neither specific supplier data nor

industry average data are available, data from ISO 14404 or EcoInvent is used.

Emissions related to other purchased goods are also calculated based on supplier-

specific emission factors when available, which is the case for lime and dolomite. For

consumables like electrodes emission factors from ISO 14404 are used.

• Category 2 (capital goods) emissions are based mainly on capital expenditure for

construction (buildings), machinery and equipment. Emission factors from the EPA

database 2022 have been applied to the amounts to calculate the emissions.

• Category 3 (fuel and energy-related activities not included in Scopes 1 and 2): Upstream

emissions of fuels are calculated using relevant emission factors from literature such as

the Well-to-Tank report from JRC. In some cases, emission factors from the steel industry

association are also used.

• Category 4 (upstream transport): Emissions are calculated based on distance and mode

of transport. Emission factors used are according to according to EEA report 2/2022 of

the European Environmental Agency for European transport, and with the published e-

factors of the US EPA for US transport.

• Category 5 (waste generated in operations): Outokumpu uses specific data from waste

treatment facilities

• Category 6 (business travel): For cars, trains and flights, Outokumpu uses the emission

reports from the service provider. The reports contain information on travelled distances

and related CO2 emissions, calculated using emission factors from relevant databases.


		64

• Category 9 (downstream transportation): Outokumpu calculates the emissions for intra-

company transport and deliveries based on mode of transport and typical distances. The

same emission factors as for category 4 (upstream transport) are used.

• Category 11 (use of sold products): Since there is a large range of uses it is not feasible

to calculate emissions for use for steel. Outokumpu also sells waste gas from

ferrochrome production, and that use is included in the calculations. The emissions are

calculated based on the carbon content of the waste gas. (E1-6-AR-46-(h)

(E1-6-AR-39)

Greenhouse gas emission intensity


GHG intensity per net revenue	2025	2024
Total GHG emissions (location-based) per net revenue (tCO2eq/€)	0.0007	0.0007
Total GHG emissions (market-based) per net revenue (tCO2eq/€)	0.0007	0.0006

(E1-6-53)

Quantitative reconciliation and GHG intensity per net revenue

Outokumpu’s total amount of net revenue in the reporting year, as used to calculate the

greenhouse gas emission intensity, was EUR 5,468 million (2024: EUR 5,942 million).

More information can be found in Note 2.2 in the Financial Statements. (E1-6-55)

Net revenue


Net revenue, € million	2025	2024
Net revenue used to calculate GHG intensity	5,468	5,942
Net revenue (other)	—	—
Total net revenue (in Financial Statements)	5,468	5,942

(E1-6-AR-55)

Internal carbon pricing

Internal carbon pricing has been used for several years for business case calculations

related to decisions on capital expenditure, as well as research and development projects.

The carbon price is part of Outokumpu’s guidelines on capital expenditure. In particular, it

is applied to the Group-wide decarbonization program when allocating the annual budget to

the projects submitted by each facility. Carbon pricing is applied to greenhouse gas

emissions of all scopes. The carbon price is reviewed annually, and it is based on the EU

emissions trading scheme’s price development assumptions of Bloomberg NEF and

management judgment. Outokumpu uses a fixed carbon price over time to reduce

fluctuations caused by uncertain price variations. (E1-8-62), (E1-8-63), (E1-8-MDR-M-75)

For 2025, the internal carbon price used was 100 EUR/tCO2. The same price was also used

for 2024. There is no external verification for the internal carbon price. (E1-8-MDR-M-77)

Outokumpu’s internal carbon pricing is not used for actual emission calculations or fixed

asset assessment. The Financial Statements include the allowances of the EU emissions

trading scheme which are assessed according to the company’s financial accounting

principles and differ from the internal shadow price. Information on emission allowance

purchases and costs is disclosed in the Financial Statements (Note 4.1, Intangible assets

and property, plant and equipment. In the financials statements, internal carbon pricing

has only been used in estimating avoided emission allowances costs in the Financial

Statements section on Climate matters and has utilized a consistent internal carbon price

of 100 EUR/tCO2. (E1-8-AR-65)


		65

E2 – Pollution

Our environment is facing growing pressure from

pollution and industrial emissions. Outokumpu

prevents, controls and mitigates pollution to

protect people and the environment.

KEY ACTIONS IN 2025

Pilot trials for hexavalent

chromium (Cr(VI)) reduction

are being conducted at the

Degerfors and Avesta sites.

A new scrubber is being

installed at the Degerfors

site to comply with the 2026

BAT limits

Projects to meet new limits

and improve efficiency at the

Tornio site.

PLAN FOR 2026–2029

Continuous monitoring of

performance in water

discharges and air

emissions.

Implementing best available

techniques in all operations

to reduce the emission of

pollutants.

Apply precautionary risk-

based environmental

management to prevent

incidents.

Material impacts, risks and opportunities


Pollution of air, water and soil

Negative impact	Potential	Emissions to air and water from own operations
Negative impact	Potential	Upstream value chain emissions to air, water and soil

(E2-ESRS2-SBM-3-48-(a))

Policies

Management of pollution is a part of Outokumpu’s Sustainability Policy. Outokumpu’s

Sustainability Policy commits to minimizing the negative impacts of its operations on the

environment and surrounding communities by continuously improving production processes

and energy and material efficiency. Performance in water consumption and discharges,

input materials and recycling, waste, and environmental incidents is continuously

monitored, with immediate action taken when required. To mitigate environmental impacts,

Outokumpu applies precautionary, risk-based environmental management to prevent

incidents and reduce emissions to air and discharges to water. The company aims to

reduce adverse effects from both current and past operations, including any associated

health impacts, and to remediate significant impacts to the best of its ability. Continuous

monitoring covers energy use, greenhouse-gas emissions, and water-related emissions,

including both regulated pollutants and those identified as relevant in impact assessments.

Details are provided in the table “Emissions to Air and Water.” (E2-MDR-P-65-(a)), (E2-1-15-(a)),

(E2-1-AR-11)

Outokumpu prevents incidents through precautionary, risk-based environmental

management. In cases of unforeseen water or soil contamination, Outokumpu aims to

remediate the negative impacts and restore the environment as closely as possible to the

state prior to the event. (E2-1-15-(c))

More information about Outokumpu’s Sustainability Policy and its scope, the approval

process for the policy, and disclosure of third-party standards, consideration given to key

stakeholders, and the availability of the policy, can be found in the Climate change (E1)

chapter. (E2-MDR-P-65-(b-f))

Outokumpu addresses pollution within its supply chain in the Supplier Code of Conduct,

which outlines environmental expectations for suppliers, for example, to reduce emissions


		66

into air, water, and soil. More information on pollution in the supply chain can be found in

the Workers in the Value Chain (S2) chapter, in the Policies section.

Actions

Key actions in 2025 included:

• At the Degerfors and Avesta sites, pilot trials are ongoing for a hexavalent chromium

(Cr(VI)) reduction method with strong lab results.

• At the Degerfors site, a new scrubber is being installed to meet 2026 BAT limits.

• In the reporting year, the Tornio site continued, as in the previous year, with projects to

meet new environmental limits, enhance air purification, cut oil use, reduce metals in

wastewater, and improve material efficiency.

As disclosed in the previous year regarding Outokumpu’s compliance with Best Available

Techniques (BAT) criteria and local permit levels, the actions are part of the company’s

ongoing efforts to reduce pollution and improve environmental performance. (E2-MDR-A-68-

(e))

Ongoing and future initiatives include:

• Outokumpu continuously monitors performance in water discharges and air emissions.

• To avoid and reduce pollution, Outokumpu follows local permit levels as the key driver

for reducing impact, as many of Outokumpu’s sites are subject to the Industrial Emission

Directive and Best Available Techniques (BAT) criteria. (E2-2-19)

• Precautionary, risk-based environmental management is applied to prevent incidents and

minimize emissions to air and water.

• Environmental incidents are followed up with immediate action when needed to prevent

negative impacts.

• Engaging stakeholders: where relevant, each site interacts with local stakeholders,

including businesses, government authorities, and surrounding communities.

The pollution action plan supports the policy objectives and contributes to the company’s

sustainability goals. In addition, the action plans contribute to achieving policy objectives

related to stakeholders, such as fostering continuous engagement, ensuring transparent

communication on sustainability performance, and meeting the expectations and

requirements of shareholders, employees, customers, suppliers, investors, and authorities,

as well as the public and non-governmental organizations. (E2-MDR-A-68-(a))

Outokumpu continuously measures relevant pollutants and takes action when needed, for

example, if emissions exceed target values. In such a case, the company takes immediate

action to prevent damage to the environment. All Outokumpu’s production sites have limit

values for emissions that are set together with relevant authorities, based on the legislation

and environmental impact assessment. (E2-2-18)

Outokumpu’s technical experts work together with selected customers to design end-

products that minimize pollution. (E2-2-AR-13) The operational expenditures and capital

expenditures for the implementation of the previously described action plan are part of

Outokumpu’s business-as-usual expenditures. (E2-MDR-A-69)

When it comes to actions in the value chain, Outokumpu conducts on-site assessments to

evaluate suppliers’ environmental practices, including how they manage pollution. More

information can be found in the Workers in the Value Chain (S2) chapter, in the

Engagement section.

Closed mines

Outokumpu dedicates significant effort each year to evaluating and managing previously

operated closed mines. Some of them still carry environmental permits and other

environmental and safety obligations. The water pollution topic is relevant to the closed

mines and a key focus area, and it is also closely linked to the negative impact on

biodiversity outlined in the table at the beginning of the Biodiversity and ecosystems (E4)

chapter.

During 2025 Outokumpu published the closed mines program focusing on reducing the

environmental impacts of the closed mines based on research. The company also

implemented measures at Enonkoski and Kotalahti to improve water flows and treatment to

reduce environmental impacts. The work continues in the upcoming years as part of the

closed mines program.

Scope and time horizon

Outokumpu takes actions to address pollution by targeting its own operations across all

areas of the business. (E2-MDR-A-68-(b)) The time horizon for the actions is from short to

medium term, with short-term actions including monitoring of emissions, and taking actions

on incidents. Medium-term actions are implementing risk-based environmental

management to prevent incidents and reduce emissions, and planning for the new

environmental permit in Tornio. (E2-MDR-A-68-(c))

Remedies and provisions

Outokumpu has not had any environmental incidents that would have caused material

harm. In the reporting year, there were 9 (2024: 8) environmental permit breaches at

operational sites, of which 1 (2024: 2) were related to water emissions. In total, there were

16 (2024: 15) environmental incidents at operational sites. Whenever necessary,

Outokumpu reported the incident to the environmental authorities, carried out corrective

actions immediately, or resolved the incidents together with the authorities. No

environmental damage was detected, nor was there any need for provision or remedy. In

addition there were two permit breaches related to water emissions from closed mines.

These breaches are addressed as part of the closed mines program. (E2-MDR-A-68-(d))


		67

Targets

Outokumpu has not set specific pollution targets. Instead, Outokumpu focuses on ensuring

progress on pollution through actions and policies. (E2-MDR-T-81-(a)) Outokumpu’s production

sites monitor and track emissions of relevant pollutants. The sites have also implemented

techniques to treat both water and air emissions before release into the environment. (E2-

MDR-T-81-(b))

The scope of monitoring varies by site size and activity, but all sites track particulate

matter and nitrogen oxides in air, and water emissions are monitored for nitrates,

suspended solids, and metals such as nickel and chromium. The results are analyzed and

followed up over time to ensure that emissions do not exceed environmental permit or

target limits, as well as to identify trends. (E2-MDR-T-81-(b)-(i)) The company has committed to

reducing environmental impacts and keeping to the limits defined in the environmental

permits, and to not increasing the impact on the surrounding environment. (E2-MDR-T-81-(b)-

(ii))

Metrics

Outokumpu monitors emissions to air and water in line with site activities, size, and permit

requirements. The most significant air emissions are particulate matter, nitrogen oxides,

and sulfur oxides. Although steel production typically generates high levels of dust,

Outokumpu’s filtration systems remove 99% of particulate matter, keeping emissions from

melt shops within permit limits and aligned with best available techniques. The main

discharges to water include metals and nitrates, which are continuously monitored. Any

exceedance of target values is followed up, even if it does not constitute a permit breach.

All wastewater is treated in Outokumpu’s own or municipal facilities before discharge.

Emissions to soil are not monitored regularly, as risks mainly stem from incidents such as

oil spills - no material incidents in the company’s operations were reported in 2025. (E2-4-

MDR-M-75)

Changes over time

Emissions into air have varied from year to year, partly based on production volumes, and

in 2025 emissions of particulate matter were 198,586 kg (2024: 125,860 kg), nitrogen

oxides emissions 1,369,906 kg (2024: 1,626,233 kg), and sulfur oxides emissions

224,280 kg (2024: 214,632 kg). This means that nitrogen oxide emissions have

decreased in 2025 while emissions of sulfur oxide and particulate matter have increased.

Emissions into water of nickel from Outokumpu’s closed mines has been included in

reporting. More information is available in the table on emissions on the next page.

(E2-4-30-(a))

Methodologies, assumptions and verification

Outokumpu performs measurements and analyses of pollutants in accordance with the

monitoring program specified in each environmental permit. Usually the measurements are

carried out by a third party except where Outokumpu has its own laboratory that is

accredited for the specific analysis. Outokumpu’s measurements are mainly direct

measurements. Measurements are in many cases continuous, which is the case with dust

and nitrogen oxides, or periodic, as with metals into air. The measurements are made in

accordance with recognized standards, such as EN 14792 for NOx and EN 13284 for

particles into air, and ISO 11885 or ISO 15587 for metals and minerals into water. For

Nitrate-N into water ISO 13395 is used. (E2-4-30-(b)) While emissions are mainly measured

directly, in some cases calculations also are applied; for example, NOx is calculated based

on NO2 measurements. (E2-4-MDR-M-77-(a))

Outokumpu’s production processes are all subject to environmental permits, which

dictate how the emissions should be measured and what the frequency is for reporting. The

emissions are either monitored in-house, which is the case for some water emissions, as

well as particles and nitrogen oxides into air. Emissions can also be monitored by external

companies, who provide reports to Outokumpu, which is the case for example for metals into

air. Each production facility is responsible for monitoring and reporting their emissions. The

emission data is reported both to relevant authorities and to Outokumpu Group. Data on

pollutants listed in Annex II of Regulation (EC) No 166/2006 (European Pollutant Release

and Transfer Register “E-PRTR Regulation”) are monitored and reported for each production

facility in accordance with the directive, taking into account relevant thresholds. This data is

then consolidated and reported in the emissions table. Nickel emissions to water from

closed mines are accounted for in addition to active operations. (E2-4-30-(c)) There is no

other external validation for the measurements. (E2-4-MDR-M-77-(b))

The choice of methodology is taken in discussion with local environmental authorities.

(E2-4-31)

The scope of reporting in 2024 was Outokumpu’s operational sites. In 2025 also closed

mines were included in scope and after a screening the emissions from old mines that

exceeded the thresholds were reported and included in 2025 emission data.


		68

Emissions into air and water


Pollutant type, 2025	Emission into air (kg)	Emission into water (kg)	Emission into soil (kg)
Ammonia (NH3)	58,739	—	—
Anthracene	—	—	—
Arsenic and compounds (as As)	60	18	—
Asbestos	—	—	—
Benzene	—	—	—
Cadmium and compounds (as Cd)	—	—	—
Chlorides (as total Cl)	—	—	—
Chromium and compounds (as Cr)	2,529	1,218	—
Copper and compounds (as Cu)	155	91	—
Cyanides (as total CN)	—	78	—
Fluorides (as total F)	—	23,213	—
Fluorine and inorganic compounds (as HF)	—	—	—
Hexachlorobenzene (HCB)	—	—	—
Hydrogen cyanide (HCN)	371	—	—
Lead and compounds (as Pb)	328	21	—
Mercury and compounds (as Hg)	43	1	—
Naphthalene	—	—	—
Nickel and compounds (as Ni) ¹⁾	765	937	—
Nitrogen oxides (NOx/NO2)	1,369,906	—	—
Non-methane volatile organic compounds (NMVOC)	—	—	—
Particulate matter (PM10)	198,586	—	—
PCDD + PCDF (dioxins + furans) (as Teq)	—	—	—
Pentachlorobenzene	—	—	—
Polycyclic aromatic hydrocarbons (PAHs)	—	—	—
Sulfur oxides (SOx/SO2)	224,280	—	—
Total nitrogen	—	968,887	—
Total organic carbon (TOC) (as total C or COD/3)	—	—	—
Total phosphorus	—	—	—
Trichlorobenzenes (TCBs) (all isomers)	—	—	—
Zinc and compounds (as Zn)	1,533	1,288	—

(E2-4-28-(a))

¹⁾ 85.67 kg of nickel as emissions into water from closed mines included in total in 2025. In 2024 closed

mines were not reporting emissions


Pollutant type, 2024	Emission into air (kg)	Emission into water (kg)	Emission into soil (kg)
Ammonia (NH3)	61,168	5,369	—
Anthracene	—	—	—
Arsenic and compounds (as As)	35	9	—
Asbestos	—	—	—
Benzene	—	—	—
Cadmium and compounds (as Cd)	—	116	—
Chlorides (as total Cl)	—	—	—
Chromium and compounds (as Cr)	2,665	1,369	—
Copper and compounds (as Cu)	162	67	—
Cyanides (as total CN)	—	149	—
Fluorides (as total F)	—	23,555	—
Fluorine and inorganic compounds (as HF)	—	—	—
Hexachlorobenzene (HCB)	—	—	—
Hydrogen cyanide (HCN)	426	—	—
Lead and compounds (as Pb)	206	71	—
Mercury and compounds (as Hg)	54	33	—
Naphthalene	—	—	—
Nickel and compounds (as Ni) ¹⁾	763	1,096	—
Nitrogen oxides (NOx/NO2)	1,626,233	—	—
Non-methane volatile organic compounds (NMVOC)	—	—	—
Particulate matter (PM10)	125,860	—	—
PCDD + PCDF (dioxins + furans) (as Teq)	—	—	—
Pentachlorobenzene	—	—	—
Polycyclic aromatic hydrocarbons (PAHs)	—	—	—
Sulfur oxides (SOx/SO2)	214,632	—	—
Total nitrogen	—	1,303,394	—
Total organic carbon (TOC) (as total C or COD/3)	36,480	—	—
Total phosphorus	—	—	—
Trichlorobenzenes (TCBs) (all isomers)	—	—	—
Zinc and compounds (as Zn)	1,983	—	—

Outokumpu does not have anything to report on soil for the reporting year within its value

chain.


		69

E3 – Water and marine resources

Water is essential for people, nature and the

economy. Outokumpu uses mainly surface water

from rivers and the sea, including rainwater. The

company measures the withdrawal of water,

recycles it as much as possible, and treats all

water before any discharges.

KEY ACTIONS IN 2025

Continuous groundwater

measurement devices and

additional surface movement

monitoring points installed in

the Kemi mine.

Prioritizing water efficiency

through recycling, treatment,

and stakeholder collaboration

for improved water

management.

PLAN FOR 2026–2027

Assessment of the impact of

water use on the environment

and more systematic analysis

of water resources.

Development of an

improvement plan for water

management at other sites.

Actions to optimize water use

at the San Luis Potosí site,

which is located in a high-risk

water area

Material impacts, risks and opportunities


Water consumption, withdrawals and discharges

Positive impact	Actual	Durability and corrosion resistance of stainless steel in water infrastructure
Negative impact	Actual	Water consumption of stainless steel production
Negative impact	Potential	Water use and discharges in the supply chain
Negative impact	Potential	Water discharges in own operations

(E3-ESRS2-SBM-3-48-(a))

Policies

Outokumpu’s Sustainability Policy addresses the sustainable sourcing and use of water

resources in its operations, optimization of water use, treatment and reuse of water, and

the prevention and abatement of water pollution. Whenever commercially viable, the

company considers sustainable sourcing practices, while ensuring compliance with

applicable regulations and striving to reduce environmental impacts. The preservation of

marine resources is not covered by Outokumpu’s Sustainability Policy since the topic of

marine resources is not material for Outokumpu. (E3-1-12-(a)-(i))

Outokumpu aims to reduce negative impacts through reusing water and wastewater

treatment. By optimizing material, energy, and water use, and proactively improving

products and processes, Outokumpu reduces its overall environmental footprint and helps

address the potential negative impacts of water consumption. In line with these

commitments, Outokumpu also creates positive impact beyond its own operations by

supplying durable, sustainable stainless steel for water infrastructure, such as desalination

plants, supporting long-lasting, resource-efficient solutions for delivering clean water. In

addition, Outokumpu is committed to reducing and monitoring material water consumption

in production plants located in geographical areas experiencing high water risk. The

company operates a cold rolling mill in San Luis Potosí, Mexico, which has been identified

by the Aqueduct assessment as a dry, extremely high water stress area. Outokumpu’s

policy focuses on mitigating these risks within its own operations. (E3-1-12-(a)-(ii)), (E3-1-12-(b))

Complementing these measures, Outokumpu prevents and reduces its impacts through

precautionary, risk-based environmental management, which includes preventing incidents,

reducing waste, avoiding emissions and discharges into water, and ensuring that waste and

production residues are handled without release into water bodies. In the event of


		70

unforeseen water contamination, the company seeks to remediate negative impacts and

restore the environment as closely as possible to its prior state. To support this,

Outokumpu continuously monitors water consumption and discharges through site-level

data collection and performance tracking, with immediate corrective actions taken when

necessary, ensuring ongoing improvement and effective water resource management.

(E3-1-12-a-(iii)), (E3-1-12-(c)), (E3-1-13), (E3-MDR-P-65-(a))

More information about Outokumpu’s Sustainability Policy and its scope, the approval

process for the policy, disclosure of third-party standards, consideration given to key

stakeholders, and the availability of the policy, can be found in the Climate change (E1)

chapter. (E3-MDR-P-65-(b-f))

Outokumpu expects suppliers to minimize adverse impacts on water, as outlined in the

Supplier Code of Conduct. More information can be found in the Workers in the Value Chain

(S2) chapter, in the Policies section.

Actions

Key actions taken in the reporting year:

• Installing three new continuous groundwater measurement devices in Kemi with

additional surface movement monitoring points next to groundwater measurement

locations.

• Continuing established practices of recycling and reusing water, treating wastewater

before discharge, and monitoring water resources to ensure sustainable management.

• The company also maintained its regular internal environmental audits on water topics

and ongoing collaboration with communities, authorities, and other stakeholders to share

data and strengthen collective water stewardship in line with its Sustainability Policy.

Key actions planned for the future are based on Outokumpu’s Water Stewardship plan,

developed in alignment with the Alliance for Water Stewardship standard, and Kemi mine’s

water management plan, developed to meet the requirements of the Towards Sustainable

Mining standard. The water stewardship plan focuses on minimizing water impacts,

improving efficiency, conducting regular assessments, engaging stakeholders, and driving

continuous improvement, while the Kemi mine’s plan addresses water entering the mining

area, its treatment, and potential risks such as water contamination.

Key actions planned for the future are the same as those reported in 2024:

• Analyze water usage from each source on each site.

• Assess the impacts of water use on the environment at each site, to gain insight into the

impact caused by sites.

• Develop continuous improvement plans for water management at each site.

• At the Kemi mine, efforts focus on preventing surface layer drying and reducing the risk

of groundwater depletion, with plans to implement a system for continuous monitoring of

groundwater levels and ground surface movements.

Overall, these actions aim to strengthen understanding of water use and its impacts,

enable proactive measures to reduce environmental risks, and drive continuous

improvement in water management and resource efficiency in line with Outokumpu’s

Sustainability Policy. For the Kemi mine, the expected outcome is a robust system for

tracking groundwater and surface conditions, directly supporting the policy’s focus on

effective monitoring. (E3-MDR-A-68-(a))

Actions in areas of water risk

For the reporting year, as in previous years, the San Luis Potosí site prioritized water

recycling. To enhance water use efficiency, the site not only uses its own treated water in

daily operations, but also purchases additional treated water externally.

In the reporting year, Outokumpu evaluated possible future actions at the San Luis Potosí

site:

• Standardization and maintenance of sprinkler headers at pickling lines to ensure optimal

performance

• Reduction of water flow in the final rinse

• Maximizing the use of longer pickling campaigns whenever possible

The expected outcome is more efficient water usage, in line with Outokumpu’s

Sustainability Policy, particularly the commitment to reduce and monitor material water

consumption in production plants located in geographical areas experiencing high water

risk. (E3-2-19)

The operational expenditures and capital expenditures for the implementation of the

previously described action plan are part of Outokumpu’s business-as-usual expenditure.

(E3-MDR-A-69)

When it comes to actions in the value chain, Outokumpu conducts on-site assessments to

evaluate suppliers’ environmental practices, including how they manage water

consumption, recycling, and water flow as part of their overall water management. More

information can be found in the Workers in the Value Chain (S2) chapter, in the

Engagement section.

Scope and time horizon

The water stewardship plan and its key actions cover only Outokumpu’s own operations.

Future actions from the plan apply to Business Area Europe (Tornio, Avesta, Nyby,

Degerfors, Krefeld, Dillenburg sites). The Americas business area, including sites in the US


		71

and Mexico, currently does not have a water action plan, although the San Luis Potosí site

has specific water reduction actions, as mentioned above. The Americas business area’s

water management plan will be developed within a medium-term time horizon. (E3-MDR-A-68-

(b))

Each key action for stainless steel sites, the Kemi mine, and the San Luis Potosí site, is

planned to be completed within a medium-term time horizon. The assessment of the

impact of water use on the environment and the development of the improvement plans on

water management key actions are planned to be fully completed by the end of 2027. (E3-

MDR-A-68-(c))

Remedies and provisions

In 2025, Outokumpu did not have any cases of harm by actual material impacts that would

require actions to provide remedy. (E3-MDR-A-68-(d))

Targets

Outokumpu has not set specific water targets including those for areas at water risk.

Instead, the company has been ensuring progress on water resources through actions,

policies, monitoring, and key performance indicators (KPIs). Outokumpu evaluated potential

group-level targets during the reporting year and, for the time being, has chosen not to set

a specific water-related target. (E3-MDR-T-81-(a)), (E3-3-23-(a,c))

The effectiveness of water-related policies and actions is tracked through multiple

processes, including monitoring metrics and KPIs, regular audits, and stakeholder

engagement. Outokumpu’s Sustainability Policy emphasizes continuous monitoring of water

performance. (E3-MDR-T-81-(b)), (E3-MDR-T-81-(b)-(i))

The ambition level and expectations for water-related matters are defined by Outokumpu’s

Sustainability Policy. At the San Luis Potosí site, the KPI is based on historical data, and

reviewed annually with participation from production, maintenance, and management. In

comparison to the previous year, during the reporting year, the San Luis Potosí site tracked

only one KPI, total water usage per packed tonne, to make water monitoring more

streamlined. The actual water volumes are measured directly: in 2025, the total water

usage per packed tonne was 1.59 m³ (2024: 1.75 m³), below a reference-level of 1.85 m³

set by the San Luis Potosí site. (E3-MDR-T-81-(b)-(ii))

Metrics

Outokumpu monitors key metrics – water withdrawal, discharge, consumption, recycled/

reused water, and total water stored – to track and manage the negative impact associated

with water consumption. (E3-4-MDR-M-75)

Total water consumption

Water consumption is a key metric for evaluating water resource management. On-site

consumption occurs mainly through evaporation in processes such as cooling systems, as

well as through wet waste materials, such as neutralization sludge, which release water into

the air as they dry rather than returning it to water bodies. Total water consumption for

sites and the Kemi mine is calculated as the difference between total water withdrawal and

total water discharged. For offices and service centers, total water consumption is based on

the full-time equivalent (FTE).

The provided data on water withdrawal and water discharge has been compiled following

recognized environmental management and sustainability standards. All Outokumpu sites

are ISO 14001 certified, which provides guidelines for monitoring and measuring

environmental performance, including water usage. Additionally, Outokumpu follows the GRI

303: Water and Effluents 2018 standard, which provides a framework for managing water

use.

Total water withdrawal includes all measured or calculated volumes of surface water,

seawater, municipal water, groundwater, and estimated rainwater. Rainwater is estimated

by multiplying annual precipitation, the collection area and surface-specific runoff

coefficients. At the Kemi mine, evaporation data is also included for greater accuracy. Total

water discharge includes all measured or calculated volumes, or estimated volumes based

on historical assumptions. Discharges may be directed to municipal treatment facilities,

surface water, groundwater, or seawater. At the San Luis Potosí site, withdrawal volumes

are directly measured, while discharged volumes are partially measured and partially

estimated.

In 2025, 90.19% (2024: 93.7%) of total water withdrawal volumes were based on

measurements, 0.01% (2024: 0.06%) were based on sampling and extrapolation, and

9.80% (2024: 6.24%) were based on estimations. For total water discharged volumes,

81.35% (2024: 87.16%) were based on measurements, 0.01% (2024: 0.06%) were based

on sampling and extrapolation, and 18.64% (2024:12.78%) were based on estimations.

Thus, the total water consumption for the reporting period is broken down as follows:

86.21% (2024: 89.53%) of water volumes were based on measurements, 0.01% (2024:

0.06%) were based on sampling and extrapolation, and 13.79% (2024: 10.41%) were

based on estimations.


		72

Water consumption data for Outokumpu’s own operations


Volume (m³)	2025	2024
(a) Total water consumption	8,015,549	6,289,440
(b) Consumption in areas at water risk	84,101	88,894
(c) Total water recycled and reused	13,379,698	13,070,955
(d) Total water stored	7,900	7,900
(d) Changes in water storage	—	—

(E3-4-28-(a-d))

Water withdrawal and discharges


Volume (m³)	2025	2024
Surface water	25,577,311	24,294,029
Seawater	13,397,907	13,735,214
Municipal water	756,544	923,235
Groundwater	2,891,318	2,713,863
Rainwater	2,020,765	2,315,454
Water withdrawal by source	44,643,846	43,981,794

Water discharges	36,628,296	37,692,355
Wastewater to municipal treatment	608,638	1,086,228
Discharge to surface water	28,993,759	30,173,613
Discharge to sea water	6,995,770	6,412,481
Discharge to groundwater	30,129	20,033

Total water recycled and reused

Water recycling in operations takes place within cooling systems, and through the recycling

of treated water back to the processes. In cooling systems, make-up water volumes serve

as the foundation for calculating recycled water volumes. Treated water is also recycled at

the sites, reducing the need to withdraw water from natural sources. Water recycling occurs

not only at stainless steel sites but also at the mine. In Kemi mine, around 99% of

withdrawn water was recycled during 2025 (2024: 99%).

At Outokumpu, apart from recycled water, there is also reused water, and there are

different ways of reusing water, depending on the site and its specific processes. Reused

water volumes are reported together with recycled volumes in the table "Water

consumption data for Outokumpu’s own operations”.

Recycled and reused water volumes can be either directly measured if make-up or treated

water volumes returned to the process are metered, calculated if data on make-up water

flow and production time is available, or estimated if data is based on historical data and

specific assumptions.

Total water stored

For total water stored, Outokumpu applies the GRI definition of water held in water storage

facilities or reservoirs, excluding water ponds. The water storage volumes are measured.

The changes in water storage during the reporting period are 0, as water is continuously

retrieved and supplied to the storage.

Water quality and quantity at water basins

Authorities or local water associations measure their respective water basins’ water quality.

Water basins’ water quantity is usually measured in flow rate. (E3-4-28-(e)), (E3-4-MDR-M-77-(a))

The data related to water resources is not validated by any external body other than the

assurance provider. (E3-4-MDR-M-77-(b))

Water intensity

2025


Metrics	Volume (m³)	Net Revenue (Million EUR)	Water Intensity (m³/Million EUR)
Water consumption and intensity	8,015,549	5,468	1,465.83

2024


Metrics	Volume (m³)	Net Revenue (Million EUR)	Water Intensity (m³/Million EUR)
Water consumption and intensity	6,289,440	5,942	1,058.52

(E3-4-29)


		73

E4 – Biodiversity and ecosystems

Biodiversity loss is one of the most significant

environmental challenges globally, along with

climate change and pollution. Since businesses

rely on natural resources, they must also protect

them. Outokumpu contributes to mitigating

biodiversity loss by reducing emissions, using over

90% recycled raw materials in its production and

turning its side streams into by-products.

KEY ACTIONS IN 2025

Completed biodiversity

assessment to identify the

material biodiversity impacts

and actions on a company

level, including supply chain..

Continued local work with

biodiversity actions.

Launched mine program

focusing on closed mines.

Biodiversity studies at two

closed mines.

Completed UN Global

Compact Finland’s training

program for science-based

targets for nature.

PLAN FOR 2026

Continue to develop the

biodiversity approach

regarding most material raw

material suppliers.

Review and update local

biodiversity action plans

based on new information

from biodiversity study.

Material impacts, risks and opportunities


Biodiversity and ecosystems

Negative impact	Potential	Potential impacts from industrial production activities on local ecosystems and vulnerable areas
Negative impact	Potential	Residual impacts from closed mines
Negative impact	Potential	Habitat disturbance and biodiversity disruption from mining of high- risk commodities in the supply chain

(E4-ESRS2-SBM-3-48-(a))

Outokumpu has conducted a comprehensive biodiversity assessment across its operations

and value chain deepening its understanding of the most material biodiversity impacts and

physical risks by incorporating environmental pressures into an analysis focusing on

sensitivities.

Based on the assessment and local environmental factors, four production sites – Tornio,

Calvert, Kemi, and Avesta – were identified as material due to their proximity to

biodiversity-sensitive areas and the magnitude of pressures such as land use change,

pollution, and water withdrawal. These sites are prioritized for biodiversity action planning

and mitigation. In contrast, service centers and office locations were found to have very

limited impacts and dependencies on nature, as they are primarily situated in urban or

industrial zones with minimal ecological interaction. (E4-ESRS2-SBM-3-16-(a))

Areas of high biodiversity value and threatened areas and species

Although Outokumpu’s production sites are not located within officially designated

biodiversity-sensitive areas, the company has identified areas of high biodiversity value

either owned by Outokumpu or situated nearby. These areas are associated with both

stainless steel manufacturing and chrome mining activities. (E4-ESRS2-SBM-3-16-(a)-(i))

Four sites – Calvert in the US, Tornio and Kemi in Finland, and Avesta in Sweden – were

assessed to have high biodiversity value. Dahlerbrück and Dillenburg (Germany), previously

considered to be priority sites, were reclassified as non-priority sites. The biodiversity

pressures of these sites are low, and the Dahlerbrück site is also closed. (E4-ESRS2-

SBM-3-16-(a)-(ii))

At the Kemi mine, the Natura 2000 area, Kirvesaapa, is located adjacent to the property

boundary in the northwest and east. However, no negative impacts from mining activities

on biodiversity have been identified.


		74

The Tornio site, which includes integrated ferrochrome and stainless steel production, is

located near the Tornionjoki river and the northern coast of the Gulf of Bothnia. The river is

protected under EU Natura legislation. Long-term monitoring since 1975 indicates that the

site does not have significant impacts on the Gulf or the river, which is located upstream

from the facility.

The second of Outokumpu’s two integrated stainless steel plants in Europe is located in

Avesta, Sweden, with land property of 2,5 km² in the south part of Dalarna County. Dalälven

in central Sweden is the second longest river in the country. It flows from the north of

Dalarna and into the Sea of Bothnia at Skutskär in northern Uppland. The main source of

water to Avesta site is Dalälven.

At the Calvert site in Alabama, US, approximately 80 hectares of wetland are located within

the plant’s property. These wetlands host a variety of wildlife, including wild turkeys, black

bears, and gopher tortoises. The site management has not identified any negative impacts

on local biodiversity. (E4-ESRS2-SBM-3-16-(a)-(iii))

Outokumpu has not identified negative impacts regarding land degradation, desertification,

or soil sealing. (E4-ESRS2-SBM-3-16-(b)) Overall, Outokumpu has not identified threatened

species affected by its operations. (E4-ESRS2-SBM-3-16-(c))

Biodiversity transition plan

Outokumpu has considered the resilience of its current business models and strategy in

relation to biodiversity and ecosystems-related physical, transition and systemic risks

during its double materiality assessment process. In addition, resilience was also assessed

in biodiversity screening in 2023 and in the biodiversity assessment completed in 2025.

(E4-1-13-(a))

Outokumpu’s double materiality assessment covered its operations and downstream value

chain, while the biodiversity screening performed in 2023 focused on Outokumpu’s own

operations. (E4-1-13-(b)) In the biodiversity screening, the company used location-based

screening with a ten-kilometer threshold from its sites when assessing biodiversity

sensitivity. (E4-1-13-(c)) The analysis considered a long-term time horizon of ten years. The

study completed in 2025 also looked at biodiversity pressures and widened its scope to the

supply chain. (E4-1-13-(d))

At a company level the most significant pressures stem from emissions, water use and

pollution, and land use, particularly at high-production sites such as Tornio, Calvert, and

Avesta. In the supply chain, raw materials such as nickel and manganese were also found

to carry high nature-related pressures due to sourcing from biodiversity-rich regions. The

conclusion of the biodiversity screening in terms of direct operations was that there are no

systemic risks for Outokumpu. Local physical risks related to biodiversity are currently most

relevant to Outokumpu, but transitional risks will increase over the years.

Outokumpu’s current strategy demonstrates resilience to biodiversity-related risks through

strong climate and circularity targets and site-level action plans. Scenario-based risk

analysis will deepen the understanding of the resilience. (E4-1-13-(e)) Outokumpu assessed

its stakeholders’ views by interviewing customers, suppliers, investors, non-governmental

organizations, and external industry specialists when conducting the double materiality

assessment. (E4-1-13-(f))

Policies

According to Outokumpu’s Sustainability Policy, Supplier Code of Conduct, and Supplier

Requirements, biodiversity aspects, including land-use change, direct exploitation,

pollution, and the state of species, are systematically considered in decision-making and

change management. These aspects are also assessed as part of environmental impact

assessments and permitting processes for operations.

Outokumpu demonstrates its commitment to biodiversity by safeguarding ecosystems and

maintaining favorable conditions. The company actively manages negative impacts on

biodiversity and, when necessary, undertakes remediation efforts, all in accordance with

the principles of the mitigation hierarchy.

Outokumpu supports the protection of biodiversity at its production sites located near high-

risk biodiversity areas, as well as throughout its value chain. The company also engages

with local communities on nature-related matters, including social impacts, whenever these

are considered material.

Outokumpu has a program for closed mines. The strategic and long term target of the

program is to reduce the environmental impacts of the closed mines based on research.

The program also focuses on making the work transparent and having an active dialogue

with stakeholders. The expansion of the mining program is evaluated annually.

More information about Outokumpu’s Sustainability Policy, including its scope, approval

process, disclosure of third-party standards, consideration of key stakeholders, and policy

availability, can be found in the E1 Climate Change chapter. Further details about

Outokumpu’s Supplier Code of Conduct and Supplier Requirements, including their scope,

approval processes, disclosure of third-party standards, consideration of key stakeholders,

and policy availability, are available in the S2 Workers in the value chain chapter in the

Policy section. (E4-2-22) (E4-MDR-P-65)

Outokumpu’s Sustainability Policy covers operational sites owned, leased, or managed in or

near protected areas or biodiversity-sensitive areas outside protected areas. Outokumpu’s

Sustainability Policy, Supplier Code of Conduct, and Supplier Requirements address

contributions to the drivers of biodiversity loss and impacts on ecosystems. (E4-2-23-(a))

(E4-2-24-(a))


		75

While Outokumpu contributes to maintaining global biodiversity, particularly through the

reduction of greenhouse gas emissions and by using recycled materials, and through slag

utilization, the company also prevents and reduces its impacts on biodiversity and

ecosystems through the policies mentioned above. Outokumpu applies risk-based

environmental management to prevent incidents and reduce waste, pollution, and

emissions to air, as well as discharges into water and harmful impacts related to noise and

vibration. In the event of unforeseen water or soil contamination, Outokumpu seeks to

remediate negative impacts and restore the environment as closely as possible to its

original state, whenever viable. Outokumpu also expects its raw material suppliers to

ensure that materials and services are produced sustainably and in an energy-efficient

manner that minimizes environmental impacts. This includes reducing greenhouse gas

emissions, sourcing renewable raw materials sustainably, conserving resources, and

protecting biodiversity. (E4-2-23-(b))

Outokumpu’s Sustainability Policy addresses material dependencies as well as physical and

transition risks and opportunities related to biodiversity and ecosystems. As mentioned

above, one of Outokumpu’s most significant contributions to mitigating biodiversity loss is

minimizing the use of virgin resources. The company leverages identified opportunities in

resource inflows and outflows, waste management, by-products, and waste recovery.

Furthermore, Outokumpu is committed to minimizing material water consumption at

production plants located in geographical areas facing high water risk. The company also

considers sustainable water sourcing in its operations whenever viable and aims to reduce

environmental impact through water reuse and wastewater treatment. Outokumpu

frequently assesses its impact on water. (E4-2-23-(c))

Outokumpu’s Supplier Code of Conduct and Supplier Requirements include provisions on

supplier transparency regarding biodiversity. According to these policies, suppliers and

subcontractors must ensure that all environmental risks are identified, assessed, and

mitigated by setting environmental improvement targets. These risks must also be

monitored, evaluated, and reported.

Suppliers are expected to cooperate transparently with Outokumpu by documenting

compliance, providing requested information, and if deemed necessary by Outokumpu,

granting Outokumpu or a third party authorized by Outokumpu access to conduct audits at

their facilities. Suppliers must also evaluate and monitor their own supply chains and, upon

request, provide evidence of their practices.

Raw material suppliers are required to have a system in place for identifying their products

by type and lot or serial number, as well as for tracking their status throughout all stages of

production and testing. They must maintain a traceability method that enables tracking of

the supply chain back to the original manufacturer of all items included in the supplied

product. (E4-2-23-(d))

Outokumpu’s Sustainability Policy states that the company supports the protection of

biodiversity at its production sites near high-risk biodiversity areas, as well as throughout its

value chain. The policy also addresses the consumption of resources from ecosystems,

such as water. According to the Supplier Requirements, suppliers must be able to provide a

plan for managing environmental risks and impacts, including those related to biodiversity,

and a plan to remediate any potential negative impacts. (E4-2-23-(e))

Outokumpu engages with local communities on nature-related matters, including social

impacts, whenever these are considered material. The company also interacts with

representatives of affected communities both near its own operations and along the supply

chain, including on environmental topics. (E4-2-23-(f))

Actions

Key actions related to biodiversity and ecosystems at Outokumpu in 2025 were:

• Completed comprehensive biodiversity assessment to identify the material biodiversity

impacts and actions on a company level; including impacts in the supply chain.

• Continued local work on biodiversity.

• Launched a mine program for closed mines.

• Biodiversity studies at two closed mines to define the baseline and potential actions.

• Completed UN Global Compact Finland’s training program for science-based targets for

nature.

Moving forward, Outokumpu will continue to develop the biodiversity approach with the

material impacts in the supply chain, especially nickel suppliers, and will utilize the

information from the assessment to develop the local approaches further. We will also

continue the closed mines program. The strategic and long-term target of the mine program

is to reduce the environmental impacts of closed mines based on research. Within the

program, we want to make our work more visible and communicate more with our

stakeholders. During 2025 we implemented actions at Enonkoski in Finland to stop

negative impacts on a small lake, and directed the waters to passive water treatment. We

will also continue the biodiversity work at the closed mines. (E4-MDR-A-68-(a,d))

The assessment of the biodiversity impacts, action plan and strategy was done on a global

scope with a time horizon until 2030 (E4-MDR-A-68-(b)), and it was completed in 2025. The

scenario work still needs to be deepened during the upcoming years. (E4-MDR-A-68-(c))

Outokumpu contributes to maintaining biodiversity globally especially by reducing

greenhouse gas emissions, and virgin resource material dependency and by utilizing slag.

Progress on these topics is explained in the chapters on Climate change and Resource use

and the circular economy. Additionally, Outokumpu has started to implement local

biodiversity action plans, and continues the work moving forward. (E4-MDR-A-68-(e)) The

operational expenditures and capital expenditures for the implementation of the previously


		76

described action plan are part of Outokumpu’s business-as-usual expenditures. (E4-MDR-

A-69)

More information on actions in the value chain can be found in the Workers in the Value

Chain (S2) chapter in the Remediation and Action sections. In Outokumpu’s analysis of its

suppliers it identified biodiversity-related matters.

(E4-3-25)

Incorporation of local and indigenous knowledge

Outokumpu is developing a group-wide approach to engaging affected communities in its

action plans. As a result, direct interaction with affected communities on biodiversity was

not included in the double materiality assessment process. Currently, Outokumpu is

developing a sustainability due diligence process that will cover both its own operations

and its value chain. A gap analysis and a related action plan to further develop the due

diligence steps were completed in 2024, and work continued in 2025. Outokumpu will

continue planning how to engage directly with affected communities.

Locally, Outokumpu has been consulting the affected communities regarding nature-based

solutions for example during the environmental permit process and environmental impact

assessments. In Kemi, the company also has continuous dialogue with a local bird

association to ensure for example that Outokumpu is taking bird-life into account in its

operations. In addition Outokumpu has consulted affected communities at it’s closed

mines by organizing local stakeholder events. (E4-3-28-(c))

Targets

Outokumpu contributes to maintaining biodiversity globally especially by reducing

greenhouse gas emissions, and dependency on virgin resources, and by utilizing slag, and it

has set targets for these. The progress related to these targets is described in the chapters

on E1 Climate change and E5 Resource use and the circular economy. The company has

not set specific, group-wide biodiversity targets. (E4-MDR-T-81-(b)),

Outokumpu is tracking the development of its most material biodiversity drivers in its own

operations, such as emissions, water consumption, waste and pollution. The company is

also reviewing biodiversity plans and actions in its own sites. Biodiversity is also part of the

supplier assessment processes for risk categories, such as mining. (E4-MDR-T-81-(b)-(i))

Outokumpu's Sustainability Policy, Supplier Code of Conduct and Supplier Requirements

define the ambition level and expectations. In addition, biodiversity management plans for

the business lines Stainless Europe and Advanced Materials define the expectations for the

company’s own operations. The company is also guided by the requirements of the

ResponsibleSteel and Toward Sustainable Mining standards. (E4-MDR-T-81-(b)-(ii))

Metrics

As Outokumpu does not have a separate global metric for biodiversity. Outokumpu follows

its contribution through the reduction of greenhouse gas emissions, and virgin resource

material dependency and through slag utilization. More information on the impact of

reducing greenhouse gas emissions, using recycled raw materials and utilizing slag is given

in the chapters on E1 Climate change and E5 Resource use and the circular economy.

Emissions from closed mines are included in the “Emissions into air and water” table in the

chapter E2 Pollution. (E4-5-MDR-M-75), (E4-5-MDR-M-77-(a-b))

Sites located near biodiversity-sensitive areas


		2025		2024
Description	Number of sites	Area (hectares)	Number of sites	Area (hectares)
Owned	4	2,619	5	2,121
Leased	1	238	1	238
Managed	—	—	—	—

(E4-5-35)

Change of land, freshwater and sea use

Outokumpu is not currently measuring changes in land, freshwater and sea usage. (E4-5-38)


		77

E5 – Resource use and the circular

economy

A circular economy is vital for tackling climate

change and biodiversity loss. Outokumpu’s

business is based on circularity: its stainless

steel products are made of over 95% recycled

material content, which reduces the use of

virgin resources.

TARGET IN 2025

The ambition to keep recycled

material content over

90%

annually, reaching 96.7% in

2025

The ambition to reach slag

utilization of

90%

by 2030 from a 2024

baseline

PLAN FOR 2026–2027

Developing strategies to

minimize waste generation.

Creating site-specific plans

for waste efficiency

improvement.

Integrating emergency

preparedness for waste

contamination into site-

specific emergency plans.

Material impacts, risks and opportunities


Resource use and outflows

Negative impact	Actual	Extraction of primary resources
Positive impact	Actual	Stainless steel products provide long-term, durable and recyclable materials
Opportunity		Using recycled steel, new materials streams and innovation with partners to meet growing demand for low-emission stainless steel
Opportunity		By-products from waste streams
Risk		Supply chain disruptions, limited alternatives and growing demand for scrap increase prices


Waste

Negative impact	Potential	Waste generated in own operations
Positive impact	Potential	Utilization of waste streams from the value chain

(E5-ESRS2-SBM-3-48-(a))

Policies

Outokumpu’s commitment to resource efficiency, as outlined in its Sustainability Policy

directly addresses the material impacts, risks, and opportunities associated with resource

use, outflows, and waste. By prioritizing recycled and renewable inputs and reducing

dependence on virgin raw materials, the company helps mitigate negative actual impacts,

such as the extraction of primary resources. At the same time, its focus on durable,

recyclable stainless-steel products reinforces positive impacts related to long-term material

efficiency. The policy’s focus on maximizing recycled content and optimizing resource flows

also supports opportunities, including the use of recycled steel, alternative material

streams, and innovations that meet growing demand for low-emission stainless steel. At the

same time, the company’s ability to generate value from by-products aligns with

opportunities tied to the circular use of waste streams. Outokumpu’s Supplier Code of

Conduct reinforces these commitments, requiring suppliers to pursue responsible

production, reduce resource use, and utilize recycled materials whenever possible. These

measures support the potential positive impact of utilizing waste streams across the value

chain. (E5-MDR-P-65-(a)), (E5-1-15-(a)), (E5-1-15-(b))


		78

More information about Outokumpu’s Sustainability Policy and its scope, the approval

process for the policy, disclosure of third-party standards, consideration given to key

stakeholders, and the availability of the policy, is in the Climate change (E1) chapter.

More information about Outokumpu’s Supplier Code of Conduct and Supplier Requirements

and their scope, the approval process for the policies, disclosure of third-party standards,

consideration given to key stakeholders, and the availability of the policy, can be found in

the Workers in the value chain (S2) chapter. (E5-MDR-P-65-(b-f))

Actions

Outokumpu continues its established practices and follows largely the same key actions in

the reporting year as before.

The key actions in relation to resource inflow:

• Improving traceability of internal scrap flows to maintain a high scrap input.

• Screening incoming raw materials to identify and remove any radioactive sources,

ensuring that the steel remains free from contamination.

The key actions in relation to resource outflow:

• Extracting valuable metals from slag and dust reducing the need for virgin metals.

The key actions in relation to waste:

• Identifying and categorizing waste generated to minimize risk of inappropriate disposal.

• Improving waste sorting, including biological waste and textiles in Sweden.

• Disposing of all waste safely and responsibly with licensed waste management providers.

• Exploring opportunities to recycle neutralization sludge.

• Conducting regular audits and monitoring at all sites to ensure compliance.

• Reviewing applicable local and national regulations to ensure all requirements are met.

Key actions planned for the future in relation to waste are based on the waste

management plan developed by Outokumpu. These actions apply to sites within Business

Area Europe (refer to Scope and time horizon section for further information). The waste

management plan outlines Outokumpu's commitment to minimizing environmental impacts

through effective waste management. Key actions planned for the future are the same as

those reported in 2024:

• Implementation of a review of the types of waste whenever there is a significant change

to the company’s processes, or at least every 5 years.

• Development of strategies to minimize waste generation from operations.

• Development of a continuous improvement plan for each site.

• Integration of emergency preparedness at each site for spills and other types of waste

contamination into their specific emergency plans.

These actions are expected to lead to a better understanding of Outokumpu’s waste

streams, enabling improved management and reduction of overall waste generation. They

also aim to enhance resource efficiency, achieve cost savings, and establish stronger

monitoring systems and data reporting processes. In addition, improved preparedness will

strengthen the company’s ability to respond effectively to spills and contamination events,

minimizing environmental impact. Together, these efforts support the implementation of

Outokumpu’s Sustainability Policy by reducing environmental impacts, promoting proactive

management, and reinforcing a commitment to continuous improvement in waste and

resource efficiency. (E5-MDR-A-68-(a))

The operational expenditures and capital expenditures for the implementation of the

previously described action plan are part of Outokumpu’s business-as-usual expenditure.

(E5-MDR-A-69) More information on actions in the value chain can be found in the Workers in

the value chain (S2) chapter.

Scope and time horizon

The waste management plan and future key actions include the company’s own operations,

and also cover, to some extent, downstream waste recovery operations. Future actions from

the plan apply to the Europe business area (Tornio, Avesta, Nyby, Degerfors, Krefeld,

Dillenburg). The Americas business area , including sites in the US and Mexico, currently

does not have a waste action plan. The Americas business area’s waste management plan

will be developed within a medium-term time horizon. (E5-MDR-A-68-(b))

Each key action, namely the implementation of the review of waste types, the development

of strategies to minimize waste generation, the development of an improvement plan for

waste management, and the integration of emergency preparedness for waste

contamination in the emergency preparedness plan, is planned to be completed within a

medium-term time horizon. The development of strategies and an improvement plan, as

well as the integration of emergency preparedness plan key actions are planned to be fully

completed by the end of 2027. (E5-MDR-A-68-(c))

Remedies and provisions

In 2025, Outokumpu has not had any cases of harm by actual material impacts that would

require actions. (E5-MDR-A-68-(d))

Targets

During the reporting year, Outokumpu established an entity-specific slag utilization target of

90% by 2030, to enhance circularity aligned with its new EVOLVE strategy. The target

directly supports Outokumpu Sustainability Policy objectives of minimizing the use of virgin


		79

resources through recycling and reuse, proactively developing products and processes to

lower environmental impacts, and utilizing opportunities in resource inflows, outflows, and

by-products to advance circularity. The target is relative, expressed as a percentage of total

slag generated, and applies to all sites with melt shops where slag is produced in

Outokumpu’s own operations. The target excludes radioactive slag and the slag generated

and stored at Calvert, since Calvert slag is not owned by Outokumpu, and by agreement the

slag is the property of the service provider handling the slag. Progress is measured against

a revised 2024 baseline of 86.5%. The previously reported figure of 88.6% included Calvert

(excluding stored slag at Calvert site). The revised baseline excludes all Calvert slag,

meaning Calvert is now fully removed from the scope. The target period covers 2025-2030,

with the goal of reaching 90% slag utilization by 2030.

This target is fully aligned with the EU’s Circular Economy Action Plan and waste hierarchy

principles, as slag utilization contributes to higher circular material use, reduces reliance on

primary raw materials, and ensures responsible waste management through recovery and

recycling rather than disposal. Internal stakeholder involvement has been key in defining

this target, with input from melt shop teams, by-product specialists, upper management,

and the sustainability team. Performance is monitored annually, and in 2025 slag

utilization reached 86.6%, showing no material change compared with the revised 2024

baseline of 86.5%. (E5-MDR-T-80-(a-h)), (E5-MDR-T-80-(j)), (E5-3-24-(b)), (E5-3-24-(c)), (E5-3-24-(e))

Apart from the slag utilization target, Outokumpu tracks resource use through its recycled

material content KPI. In line with the Sustainability Policy and Supplier Code of Conduct,

the company is committed to minimizing the use of primary raw materials by maximizing

the use of recycled and recovered metals in steel production. The group-level KPI ensures a

high rate of circular material use, with an ambition to achieve over 90% recycled material

content annually; in 2025 the company reached 96.7% (2024: 95.3%).

The slag utilization target and the recycled material content KPI support the circular

economy by addressing resource use and waste reduction. (E5-3-24-(f)) They are not required

by law (E5-3-27). Related to the waste hierarchy, the slag utilization target addresses

prevention as it aims to support the production of by-product instead of waste, while the

recycled material content KPI addresses recycling. (E5-3-25)

Metrics

Resource inflow

The recycled material content KPI supports the material opportunity to use as much

recycled metals as viable in the steel making process. This decreases the need for virgin

resources and lowers the value chain GHG emissions. For the ferrochrome process,

Outokumpu has identified the use of biomass as the best option to mitigate risks identified

in the double materiality assessment. (E5-4-MDR-M-75)

Outokumpu’s most important raw material is recycled steel, from both stainless and carbon

steel. All of Outokumpu’s stainless steel mills can be considered as significant recycling

facilities, and the company recycles over two million tonnes of metal per year. In addition to

recycled steel, Outokumpu uses primary alloys to get the right alloying composition in the

steel. The most important alloys are nickel and chrome, which are added to production

mainly as ferrochrome and ferronickel. Outokumpu also uses small amounts of other metal

alloys, including critical raw materials such as alloys of manganese, niobium, and titanium.

Other critical raw materials in the steelmaking process are fluorspar and silica. Slag

formers, such as lime and ferrosilica, which are used in the process, result in slag by-

products. Other material inflows are pickling acids used in the cold rolling mills. In

ferrochrome production the main inputs are chromite from the company’s Kemi mine and

coke, which is defined as critical raw material according to EU Regulation.

A significant amount of water is used in Outokumpu’s production processes, for example for

cooling. The company uses mainly surface water for these purposes. Water is not included

in the resource use table in this chapter. More information about water management is

available in the E3 Water and marine resources chapter.

Metal alloys are the most material upstream resources. The inflows to produce these

upstream resources are mainly metal ore, energy and water. (E5-4-30)

Data collection, methodologies and assumptions

The recycled material content KPI addresses resource inflow and is calculated as the share

of recycled and recovered metals used to manufacture the steel products in relation to total

crude steel produced. The calculations are aligned with ISO 14021 and exclude recovered

metals generated in the same steel making process. The method is also aligned with the EU

taxonomy criteria for the use of recycled steel in steel manufacturing. Packaging and

consumables such as pickling acids, which are not part of the product are not included in

these KPI calculations.

The calculation of total material use for monitoring resource inflow include, in addition to

the recycled material use, also other raw materials, and utilities for production of all

products, including packaging, are considered. More information can be found in the table

“Materials used in the process” below.

For resource inflow, the calculation is based on measured consumption, if data is

available. Otherwise purchased amounts are used. (E5-4-MDR-M-77-(a)). The KPI for recycled

content of Outokumpu’s steel products is verified annually against ISO 14021 by TÜV SÜD.

(E5-4-MDR-M-77-(b))


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Materials use


Product and material category, Weight (tonnes) or %	2025	2024
Total weight of products and materials	4,467,517	4,564,152
of which weight of secondary or recycled materials	2,275,075	2,275,966
% of secondary or recycled materials of total weight	50.9	49.9

(E5-4-31-(a,c))

Outokumpu uses small amounts of biological materials, they constitute only 0.4% of the

Total weight of products and materials. The biological materials used are packaging

materials and biocoke, the biocoke is sustainably sourced and its´share of Total weight of

products and materials is 0.06%. The biocoke is certified under the European Biochar

Certificate (EBC) or the FSC. (E5-4-31-(b))

Outokumpu weighs all raw materials entering its processes when the materials arrive at the

company’s sites. The data reported for the year is based on direct measurement. (E5-4-32)

As there is no overlap between categories of recycled and reuse no double counting can

occur. However, some virgin material flows are double counted as the input data to both

ferrochrome and stainless production is accounted for and there is a flow of virgin materials

between both production units . (E5-4-AR-25)

Resource outflow

Outokumpu tracks its performance and effectiveness related to material impacts, risks, and

opportunities for resource outflows through several key metrics, including the total waste

generated, total waste diverted from disposal, total waste sent for disposal, non-recycled

waste, percentage of non-recycled waste, and total hazardous and radioactive waste

produced. Metrics are categorized by hazardous and non-hazardous waste where relevant.

All the metrics can be found in the tables in the "Waste” section. (E5-5-MDR-M-75) No

external body other than the assurance provider has provided validation. (E5-5-MDR-M-77-(b))

Products and materials

Outokumpu’s main products are semi-finished products of stainless steel and ferrochrome.

While the stainless steel semi-finished products (mainly coils and plates) are used by

Outokumpu’s customers to manufacture stainless steel products, ferrochrome is used as

an ingredient in Outokumpu steel and other producers’ steel. Outokumpu’s steel is 100%

recyclable and is manufactured using, on average, 97% recycled content. The stainless

steel features a stable, self-healing oxide layer that protects against rust and corrosion,

thereby enhancing durability and eliminating the need for painting or other surface

treatments, resulting in low maintenance. The packaging materials (mainly cardboard and

plastics) contain on average 66% recycled material and are 100% recyclable. The wooden

pallets are sometimes re-used through pallet exchange programs. (E5-5-35)

Expected durability and recyclable content

Stainless steel is often used for its corrosion resistance, which is attributed to the passive

surface film that protects the material from corrosion. The service life of the steel depends

on the application rather than on the steel itself. It can vary from approximately 6 months

in mobile phones to 60 years in buildings or 120 years in bridges. As a steel supplier, it is

not possible to relate the durability of Outokumpu material in relation to industry averages

since Outokumpu products are semi-finished steel products that are manufactured into new

products upon delivery. However, Outokumpu helps its customers increase the durability of

their products by supplying information and advice on which steel grades are suitable for

different applications, thus prolonging the service life of the customers’ products.

Ferrochrome is mainly used as a raw material in stainless steel, which is why it is

impossible to estimate its durability. The iron and chrome stay in in the stainless steel

product until it is discarded and recycled into new stainless steel. Slag products are

mineral by-products from steel that are mainly used to replace primary raw materials such

as sand and gravel. When used, for example, as a base layer in road construction, they are

expected to exhibit the same durability as the road construction itself.

Outokumpu’s main product, stainless steel, had during 2025 an average recycled content

of 96,7% (2024: 95%) (calculated according to ISO 14021). Outokumpu's ferrochrome and

slag products do not contain any recycled materials. This reduces the weight of secondary

materials in relation to the total input of materials, when taking all produced materials into

account. The share of recycled material of all input materials and products is 50.9 % as

outlined in the previous “Materials used” table.

Ferrochrome and slag are not recyclable as such, but rather are materials to be included in

other products. However, the metallic constituents of ferrochrome; iron and chromium, are

recycled as part of the steel when the end-product is discarded.

The main packaging used for stainless steel semi-finished products consist of different

plastics and wooden pallets that can be reused through pallet exchange programs. The

plastics contain, on average, 66% recycled content and are all recyclable. (E5-5-36-(a,c))

Composition of waste and waste streams

The main waste streams come from Outokumpu’s ferrochrome operations, mining waste

and waste from ferrochrome production, and from its stainless steel production sites. These

include tailings sand, steelmaking dust, slag, sludges, oily waste, and scales. Most waste

consists of metals and minerals, either as such or as compounds in sludges. The slag

contains critical raw materials such as silica and manganese, which are identified as

critical raw materials in Annex II of the EU Critical Raw Materials Act. By weight, tailings

sand and steelmaking slag dominate, with 1,168,747 tonnes of tailing sand generated in

2025 (2024: 1,250,608 tonnes). Steel slag is partly classified as waste and partly as by-

product, with the waste portion also being usable. In 2025, the slag utilization rate, an

entity-specific metric, was 86.6% (revised 2024 figure: 86.5%). This figure includes slag as


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waste and as a by-product and excludes generated and stored slag at the Calvert site.

(E5-5-38)

Total amount of waste generated


Particulars of waste generated, Quantity (tonnes)	Type	2025	2024
Total amount of waste generated		2,048,286	2,787,009
Total amount of waste diverted from disposal		646,558	1,292,626
Total amount of hazardous waste diverted from disposal		53,608	57,896
Hazardous waste diverted from disposal	Preparation for reuse	0	0
Hazardous waste diverted from disposal	Recycling	53,359	57,541
Hazardous waste diverted from disposal	Other recovery operations	250	355
Total amount of non-hazardous waste diverted from disposal		592,950	1,234,730
Non-hazardous waste diverted from disposal	Preparation for reuse	19,051	15,846
Non-hazardous waste diverted from disposal	Recycling/ Stored¹⁾	569,104	1,214,603
Non-hazardous waste diverted from disposal	Other recovery operations	4,795	4,281
Total amount of waste directed to disposal		1,401,728	1,494,384
Total amount of hazardous waste directed to disposal		63,094	59,371
Hazardous waste directed to disposal	Incineration	0	0
Hazardous waste directed to disposal	Landfill	63,088	59,299
Hazardous waste directed to disposal	Other disposal operations	7	72
Total amount of non-hazardous waste directed to disposal		1,338,634	1,435,013
Non-hazardous waste directed to disposal	Incineration	0	0
Non-hazardous waste directed to disposal	Landfill	1,338,634	1,435,013
Non-hazardous waste directed to disposal	Other disposal operations	0	0
Non-recycled waste		1,425,824	1,514,865
Percentage of non-recycled waste		69.61	54.35

(E5-5-37-(a-d))

¹⁾The amount of stored slag from the Calvert site is included in the Recycling/Stored* row. The amount of

slag generated and subsequently stored in 2025 was 102,408 tons (2024: 962,000 tonnes). The 2024

data was reported as cumulative storage, comparable data for 2024 would be 112 222 tonnes. When

applying the previous methodology for comparability, the 2025 figure would have been 720,000 tonnes.

Hazardous and radioactive waste


Waste type, tonnes	2025	2024
Hazardous waste	116,703	117,266
Radioactive waste	0	179

(E5-5-39)

Avesta has radioactive slag stored on site. Radioactive slag generated at the Avesta site

was assessed by the Swedish Radiation Safety Authority as unsuitable for landfill disposal

and has not yet been categorized as waste. The authority has granted Avesta permission to

store this material on site. In 2025, the stored volume of radioactive slag amounted to 165

tonnes. As it has not been classified as waste, the radioactive slag is excluded from the

waste volumes reported in the tables.

Methodologies and assumptions

All Outokumpu sites are ISO 14001 certified, which provides a consistent framework for

monitoring and measuring environmental performance, including sustainable waste

management practices. Outokumpu also follows GRI 306: Waste 2020, ensuring structured

waste categorization and reporting. Waste is classified according to the Waste Hierarchy,

using standardized definitions for “preparing for reuse,” “recycling,” “other recovery

operations,” and “disposal.” Waste prevention, the first and most critical step in the

hierarchy, is a key focus area, emphasized in Outokumpu’s Sustainability Policy. Under the

“non-recycled” waste category, values are calculated by subtracting recycled waste from the

total generated waste. Waste is weighed, and for wet waste such as sludges, reporting is

based on dry weight. In cases where weighing is not possible, estimates are made using

reasonable assumptions and historical data.

The handling and disposal of Outokumpu’s main waste streams are highly dependent on

local regulations and infrastructure. For example, slag classification and utilization vary

across regions, and the ability to recycle certain waste streams depends on the availability

of further processing. Metal recovery from stainless steel dust, for instance, is only feasible

at a limited number of sites in Europe.

Outokumpu’s products are semi-finished and undergo further processing by customers.

Therefore, information about expected use and durability is based on industry estimations,

supported by factual data on material properties.

For offices and service centers, the waste generated is based on the full-time-equivalent.

For the Calvert site, the reported amount of stored slag in 2025 is lower compared to

2024 due to a revision in reporting methodology. In 2024, the figure reflected the total

amount of slag physically stored on site at year-end, including material generated in

previous years. In 2025, the reported stored slag includes only slag generated and stored

during the reporting year, which aligns better with ESRS requirements focusing on waste

generated within the reporting period and improves the comparability and accuracy of

annual data. It should be noted that the slag stored at the Calvert site is not owned by

Outokumpu and, in accordance with contractual arrangements, is the property of the service

provider responsible for handling the slag. (E5-5-40), (E5-5-MDR-M-77-(a))


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Social information

Outokumpu’s work on social sustainability

focuses on its own workforce, workers in

the value chain, and affected communities.

Outokumpu contributes to economic and

social well-being by providing jobs directly

to over 8,000 people and additionally

indirectly through its value chain around

the world, and to local communities,

through financial contributions.


S1 – Own workforce	83
S2 – Workers in the value chain	101
S3 – Affected communities	110


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S1 – Own workforce

Outokumpu employs over 8,000 people in

nearly 30 countries. In 2025, focus areas

related to its own workforce were health

and safety, as well as strengthening

fairness and belonging.

TARGETS

<1.5

Total recordable incident

frequency rate (TRIFR) by the

end of 2025

+100

diverse leaders in leadership

teams by the end of 2025

from the 2022 baseline

PROGRESS

1.8

The total recordable incident

frequency rate (TRIFR) at the

end of 2025

+64

diverse leaders in leadership

teams at the end of 2025

Pay equity

Women’s euro

0.994

Material impacts, risks and opportunities


Health and safety

Positive Impact	Potential	Mental and physical well-being of employees from well-being benefits, stress-reducing work organization and flexible modes of working
Negative Impact	Potential	Potential health and safety hazards from the inherent nature of steel production
Opportunity		Reduction of sick days as well as employee attraction and retention from attractive working conditions
Risk		Health issues and accidents causing decrease in productivity, increased attrition and sick days, legal and remediation costs, and reputational damages


Working time

Negative Impact	Actual	Mental health and well-being issues from high workload and shift work


Adequate wages

Positive Impact	Actual	Equal opportunities and fair pay


Social dialogue and collective bargaining

Positive Impact	Potential	High employee input and frequent engagement of collective bargaining


Diversity, Gender equality, Equal pay

Positive impact	Potential	Fairness, belonging and solid recruitment and promotion processes
Negative impact	Potential	Gender inequality and unconscious bias
Opportunity		Increased innovation, resilience, productivity and employer attractiveness and engagement from diversity


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Training and skills development

Positive impact	Potential	Providing training and skills development to employees in an equal manner
Opportunity		Productivity and commitment from engaged, resilient and well-trained people


Measures against violence and harassment in the workplace

Negative Impact	Potential	Harassment and bullying, intimidation, and discrimination

(S1-ESRS2-SBM-3-48-(a))

During the reporting year, Outokumpu finalized the second phase of its strategy and

introduced a new EVOLVE strategy to be implemented starting from 2026. Outokumpu’s

EVOLVE strategy aims to build a resilient, future-ready workforce capable of meeting

operational priorities such as delivery speed, production efficiency, and sustainability

targets. These priorities may affect workload and ways of working, and the company

addresses such risks through proactive measures that safeguard employee well-being,

health, safety, and sustainable work practices.

At the core of EVOLVE is a commitment to continuous improvement and development. The

strategy strengthens skills, career growth, and internal mobility while promoting

engagement, fairness and belonging. Outokumpu fosters collaboration and employee

participation in improvement initiatives and decision-making. Open communication, regular

feedback, and supportive leadership help employees navigate change, enhance

capabilities, and maintain a positive work environment. Ultimately, EVOLVE focuses on

attracting, developing, and retaining the talent essential to Outokumpu’s long-term

success. (S1-ESRS2-SBM-3-13-(a)-(i))

In July 2025, the company announced a restructuring program affecting selected

operations mainly in Europe with the objective to improve long-term competitiveness. In

total, the restructuring program was expected to impact approximately 650 full-time

positions by the end of 2027, including approximately 450 positions subject to

negotiations. Negotiations in Finland, Sweden and Germany were concluded by the end of

2025, resulting in reductions of 139, 109, and 120 positions, respectively. Processes in

other countries are expected to impact approximately 80 positions.

Outokumpu recorded a restructuring provision of EUR 32 million as an item affecting

comparability in EBITDA in the fourth quarter of 2025.

Most of the impacts related to Outokumpu’s own workforce arise from the nature of

Outokumpu’s key activity, stainless steel production. Outokumpu runs industrial operations

in which a significant part of its workforce is exposed to hazards such as heat, noise,

chemicals, and heavy machinery. The workforce in this type of industry is traditionally male

dominated, which may constitute a challenge but also an opportunity for fairness and

belonging

In turn, the identified impacts contribute to shaping Outokumpu’s strategy and business

model. For example, safety is a number one strategic priority, a license for the company to

operate, and it is ensured with clear targets and actions. (S1-ESRS2-SBM-3-13-(a)-(ii))

Risks and opportunities related to Outokumpu’s own workforce are intrinsically linked to

impacts and connected to Outokumpu’s business model. Mitigating the potential and

actual impacts on the workforce of a heavy industry context supports Outokumpu in

avoiding financial risks arising, for example, from hazards or productivity loss, and pursuing

financial opportunities linked to a competitive advantage and an engaged and innovative

workforce. (S1-ESRS2-SBM-3-13-(b))

Types of employees and non-employees

The company’s own workforce considered includes both Outokumpu’s own employees and

non-employees directly working in Outokumpu’s operations. By definition, non-employees

are people who work for Outokumpu but are not on Outokumpu’s payroll, namely self-

employed individuals and agency workers supplied by external staffing agencies. Self-

employed individuals are independent workers running their own business whom

Outokumpu hires to perform specific tasks or projects. Agency workers are people employed

by external staffing agencies for temporary needs, carrying out work under Outokumpu’s

direction and control, but with the agency as their employer. (S1-ESRS2-SBM-3-14-(a))

Identifying material impacts, risks and opportunities

Outokumpu updated its double materiality assessment in 2025. The identified key impacts,

risks, and opportunities related to Outokumpu’s own workforce reflect the topics outlined in

the table opening this section: health and safety, working time, adequate wages, social

dialogue and collective bargaining, fairness, equal pay, training and skills development, and

measures against violence and harassment.

The assessment distinguishes between positive and negative impacts affecting employees.

Positive impacts derive from Outokumpu’s proactive approach to employee well-being,

belonging, and skills development. Initiatives that promote flexible working arrangements,

strong collective bargaining, equal opportunities, ensuring adequate wages and fair pay

across all roles, and continuous training contribute to a fair, engaging, and resilient

workplace.

Negative impacts primarily relate to the inherent risks of industrial operations, including

health and safety hazards, long or irregular working hours, high workload, or isolated cases

of discrimination, harassment, or workplace violence. These are limited in scope and

typically remediable through established occupational safety systems, grievance

procedures, and corrective actions.


		85

Key risks identified include health and safety incidents, reduced productivity, absenteeism,

reputational harm, and legal or remediation costs. Opportunities include higher productivity,

stronger employee engagement, innovation, and retention through well-being, safety,

belonging, and continuous learning initiatives.(S1-ESRS2-SBM-3-14-(b-d))

Due to the energy-intensive nature of its operations, Outokumpu also considers the effects

of its climate transition plan. Mitigating climate change creates opportunities to engage

employees in the decarbonization journey, and no material negative impacts on workers are

expected, provided that climate targets are achieved. (S1-ESRS2-SBM-3-14-(e))

Risks related to forced or compulsory labor were not identified as material. Outokumpu’s

own operations are not considered exposed to such incidents and are located in regions

with strong labor regulation. Risks related to child labor were also assessed as non-

material. The company operates primarily in Europe and the Americas, where such risks are

minimal. In Mexico, where exposure is higher, strict recruitment and supplier screening

procedures ensure compliance with labor standards. (S1-ESRS2-SBM-3-14-(f-g))

Outokumpu continuously monitors potential vulnerabilities through fairness and belonging

surveys, ResponsibleSteel surveillance audits, and human rights impact assessments. The

2024 updated impact assessment on the company’s own workforce confirmed that no

significant differences exist across workforce groups, other than higher safety exposure for

production employees. A strong safety culture and preventive systems continue to minimize

these risks, ensuring equitable working conditions across all employee groups. (S1-ESRS2-

SBM-3-15), (S1-ESRS2-SBM-3-16)

Policies

The key policies related to Outokumpu’s own workforce are the Sustainability Policy, Code

of Conduct, Human Rights Policy, Health and Safety Policy, Recruitment Policy, and the

Global Policy on Remuneration and Working Time. Together, these policies provide a

comprehensive framework covering all of Outokumpu’s workforce and set the standards for

ethical, safe, and fair treatment of employees across the organization. Local-level policies

and regulations continue to apply, addressing topics such as working time, leaves of

absence, work environment and safety, equal treatment, training and development, and

remuneration practices. These local policies are designed to complement and align with the

principles and requirements established in the Key Policies. (S1-1-19), (S1-MDR-P-65-(b))

The Outokumpu Sustainability Policy states the company’s commitment to promoting

fairness and belonging, a work environment that allows all team members to contribute and

to develop, human rights and dignity, a safe and healthy workplace, and employee

development.

The Outokumpu Code of Conduct provides the principles and rules that all employees at

Outokumpu need to follow in their daily work, and it ensures that all Outokumpu employees

live up to the Ethical Principles, as well as the Outokumpu Way (replacing the previous

Ways of Working), which form the basis of Outokumpu’s actions, operations, and corporate

culture, and have the highest standards of integrity by setting examples and giving practical

advice.

Through the Global Policy on Remuneration and Working Time, Outokumpu is committed to

fair, lawful, and transparent practices regarding compensation, payments, working hours,

shift patterns, and overtime. These practices comply with legal standards, collective

agreements, and industry norms, and are adapted to local regulations to ensure

consistency across regions. All processes are documented and accessible to employees,

supporting transparency, fairness, and alignment with both global policies and local

practices.

The Human Rights Policy sets out the core principles guiding Outokumpu Group’s

commitment to respect human rights and manage related impacts through a structured

human rights due diligence process.

The Health and Safety Policy describes the main principles and rules followed by

Outokumpu in relation to occupational health and safety management. Health and safety

are integral parts of Outokumpu operations and decision-making, with a central role in

Outokumpu’s vision, strategies, and planning.

The Recruitment Policy outlines key principles that apply to recruitment at Outokumpu,

such as transparency, equitable opportunities, and one-over-one approval. It mandates the

usage of interview panels aligned with the demographics of the organization, and states the

goal of 50% diverse candidates on all short-lists. (S1-MDR-P-65-(a))

Scope, accountability, stakeholders, availability,

and third-party standards

More information about the approval process, stakeholders and availability, and coverage

of the policies as well as third-party standards is available in the following sections:

regarding the Sustainability Policy in the Climate change chapter (E1), for Code of Conduct

in the Governance chapter (G1) and the Human Rights Policy in Affected communities (S3).

The Recruitment Policy applies to all of Outokumpu’s workforce. The Group leadership team

member responsible for people matters is accountable for the implementation of this

policy. While it does not directly reflect any specific third-party standard, it is set to

safeguard the interests of Outokumpu’s workforce, notably in terms of equality and

nondiscrimination. This policy is available to all Outokumpu's employees on the company’s

intranet. (S1-MDR-P-65-(b-f))

Human Rights Policy commitments

Outokumpu has a comprehensive Human Rights Policy that defines the company’s

commitment to respect all internationally recognized human rights and provides a


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framework for embedding these principles across its operations and value chain. The policy

applies globally to all Outokumpu businesses, companies, directors, officers, and

employees, and the company expects its business partners to uphold similar standards.

The policy was updated in December 2025 and is aligned with international frameworks,

including the UN Guiding Principles on Business and Human Rights, the OECD Guidelines

for Multinational Enterprises, and the Ten Principles of the UN Global Compact. Outokumpu

adheres also to relevant internationally recognized conventions, such as the UN Universal

Declaration of Human Rights, the International Covenant on Civil and Political Rights, the

International Covenant on Economic, Social and Cultural Rights and the ILO Declaration on

Fundamental Principles and Rights at Work. The company is also a certified member of the

ResponsibleSteel initiative and the Finnish Network for Sustainable Mining.

More information about the Human Rights Policy commitments relevant to the company’s

own workforce is available in the Affected communities (S3) chapter in the Policy section.

(S1-1-20)

The following Outokumpu’s guiding human rights principles are stated in the Human Rights

Policy:

• respecting human rights across Outokumpu’s operations and value chain and expecting

the same commitment from all its business partners,

• complying with all applicable laws and adhering to global human rights frameworks,

• conducting a risk-based due diligence as part of corporate decision-making processes by

identifying, preventing, mitigating, and remediating adverse human rights impacts,

• enabling grievance and remedy by providing accessible grievance channels and ensuring

fair and effective remediation,

• engaging stakeholders by maintaining meaningful dialogue with communities and

vulnerable groups to address the identified impacts,

• ensuring accountability by upholding strong governance, training, and continuous

improvement in Outokumpu’s human rights practice. (S1-1-20-(a))

Outokumpu also cooperates with, informs and consults its employees and their

representatives. The Outokumpu Personnel Forum is an important information channel

between its personnel and management in European operations, based on the European

Works Council Directive. More information is available in this chapter in “Engaging with own

workforce” (S1-2). (S1-1-20-(b))

Measures to provide or enable remedy for human rights impacts were further developed as

part of Outokumpu’s sustainability due diligence process in 2025. An internal guideline on

remedy was published in December 2025, covering both Outokumpu’s own operations and

value chain, including its own workforce, value chain workers, and affected communities

that might be in the need of remedial actions. The remedy process will be elaborated

further in 2026 based on this internal guideline. More information on the sustainability due

diligence at Outokumpu is available in General Disclosures chapter. (S1-1-20-(c))

Alignment with internationally recognized instruments

In accordance with the United Nations Guiding Principles on Business and Human Rights

(UNGPs), Outokumpu commits to respecting human rights and undertaking human rights

due diligence as part of its corporate decision-making process.

According to Outokumpu’s Human Rights Policy, the company complies with all applicable

laws and regulations related to human rights and human rights due diligence in every

jurisdiction it operates in. Additionally, the policy outlines Outokumpu’s commitment to

internationally recognized instruments, including the Universal Declaration of Human

Rights, the International Covenant on Civil and Political Rights, the International Covenant

on Economic, Social and Cultural Rights, the European Convention on Human Rights, the

ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles

on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the

Ten Principles of the UN Global Compact.

The Human Rights Policy also supports the achievement of the UN Sustainable

Development Goals and follows relevant UN frameworks protecting vulnerable groups such

as women, children and migrant workers. Regarding indigenous peoples, the Policy refers to

the Indigenous and Tribal Peoples Convention, 1989 (No. 169) and the UN’s Declaration on

the Rights of Indigenous Peoples. Besides the Human Rights Policy, aspects related to

human rights are covered in the Code of Conduct, Sustainability Policy and Supplier Code

of Conduct. (S1-1-21)

As stated in the Human Right Policy, Outokumpu condemns all forms of forced or bonded

labor, modern slavery, and human trafficking. The company does not permit or tolerate

practices such as restrictions on freedom of movement, recruitment fees, confiscation of

identity documents or passports, debt bondage, or withholding of wages. These

commitments apply globally and are monitored through Outokumpu’s human rights due

diligence process. (S1-1-22)

Workplace accident prevention policy

The Health and Safety Policy describes the main principles and rules followed by

Outokumpu Group in relation to occupational health and safety management. Outokumpu is

aiming for health and safety excellence with implemented, standardized and disciplined

health and safety management practices and ambitious objectives. Outokumpu’s goal is to

prevent all workplace injuries and occupational ill health by eliminating and minimizing

health and safety risks, raising awareness and developing a positive culture. (S1-1-23)


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Policies eliminating discrimination

Outokumpu’s Code of Conduct, Human Rights Policy and Recruitment Policy all play a part

in eliminating discrimination and advancing fairness and belonging. (S1-1-24-(a))

Outokumpu's Code of Conduct specifically mentions various grounds for discrimination,

including racial and ethnic origin, color, sex, sexual orientation, gender identity, disability,

age, religion, political opinion, and more, adhering to both European Union regulations and

national laws. (S1-1-24-(b)) Outokumpu does not tolerate discrimination or intimidation; nor

verbal, psychological, physical, or sexual harassment; nor abuse at work, such as

humiliating or physical punishment. (S1-1-24-(c))

Outokumpu’s policies against discrimination and for fairness and belonging are

implemented via a combination of well-functioning ways to gain insights into the

perspectives of its people, such as formal and informal engagement practices, people pulse

surveys and a SpeakUp channel, for which more information is available in the Processes

section below in this chapter (S1-2), as well as targeted fairness and belonging related

actions, including regular pay equity monitoring and team dialogue trainings in its

operations. More information is available in the Actions and resources section below in this

chapter (S1-4). (S1-1-24-(d))

Engagement

Outokumpu engages with its workforce both directly and through workers’ representatives,

to gain perspectives and inform its decisions and activities aimed at managing actual and

potential impacts. Outokumpu’s own workforce is involved in determining which targets to

sets and which actions to drive, as well as in evaluating progress against the targets and

the outcomes of actions. (S1-2-27)

As workers’ representation largely depends on the location, the table provides an overview

of the type of representation in place in Outokumpu’s main countries of operation.

Besides local representation, Outokumpu also operates a European Works Council which is

kept informed and consulted on group-wide and cross-border topics. (S1-2-27-(a))

Direct engagement includes regular, structured communication with employees at all levels.

For example, employees are encouraged to give their views in direct discussions with their

manager, but also by contacting HR or management when needed. Regular people pulse

surveys provide another opportunity for feedback as do townhall meetings at many levels of

the organization, from the quarterly result reviews with the CEO to all-hands meetings in

different sites.

More formal engagement with workers’ representatives takes place locally from every week

to every quarter, depending on the site and the employee group concerned, but also

whenever there is a need to inform, consult or co-determine on specific topics. The topics

that call for some type of engagement depend on local agreements and regulations, but

typical subjects relate to workplace organization, safety and working conditions,

remuneration, employment protection and social plans. In some countries, there are

separate representatives for health and safety matters.

Type of representation in main countries of operation


Country	Coverage	Workers’ representation and collective bargaining
Finland	U	All employees are covered by employee representatives and collective agreements: Teollisuusliitto (blue-collar employees), Pro (salaried employees), YTN (senior salaried employees).
Sweden	U	All employees are covered by employee representatives and collective agreements: “Tjänstemannaavtalet” (white-collar employees) and “Röda Avtalet” (blue-collars)
Germany	U	Tariff and non-tariff employees are represented by a works council and covered by collective agreements. Executives are represented by a speakers’ committee and covered by company specific agreements.
UK	R	Employees are represented by the Employee Forum.
Netherlands	U	All employees are represented by a works council and included in collective agreements: CAO Metalelektro and CAO Metalelektro hoger personeel.
Lithuania	R	Employees are represented by a works council with an advisory function.
Italy	U	All employees are covered by employee representatives and collective agreements: “Metal Industry” (CCNL Aziende Industria metalmeccanica e della installazione di impianti) and “Dirigenti Industry”.
Poland	R	Employees are represented by a works council, which must be consulted about certain topics and informed about the economic situation of the employer.
USA	N	No unions nor formal employee representation are in place but employees can join regional Team Member Networking Groups (TNG) and reach out directly to any of the executive management via a link on the intranet, to ask a question or make a suggestion. All employee relations matters are handled through direct communication and collaboration between management and employees.
Mexico	U / N	All blue-collar workers are unionized. Every department in the plant has a union representative to support employees’ needs. White collar employees are not part of a union or subject to a collective bargaining agreement. Employees can reach out to any of the executive management directly, as in the US. Women may also join the Female TNG group. All employee relations matters for white- collar employees are handled through direct communication and collaboration between management and employees.

U = Collective agreement(s) and union(s) in place.

R = Organized employee representation in place.

N = No union nor organized employee representation in place.

On the European level, the Group Working Committee (GWC) meets on a quarterly basis

and the Outokumpu Personnel Forum (OPF) once a year. (S1-2-27-(b))

The person responsible for human resources (HR) in the context where the engagement

takes place normally bears the operational responsibility for facilitating that engagement.


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For example, in Germany, the labor director accounts for the engagement, and in Sweden,

it is the Head of HR who has this responsibility. The Executive Vice President –

Sustainability, Strategy and People heads the European Works Council. On some sites, the

managing director takes the lead in ensuring that the engagement happens, usually

together with the HR Business Partner. (S1-2-27-(c))

Although labor rights are considered in the different collective bargaining agreements and

emphasized in Outokumpu’s Code of Conduct and policies, there is no global agreement

with workers’ representatives specifically related to the respect for human rights in the

workforce. (S1-2-27-(d))

The effectiveness of the engagement is regularly assessed as part of the discussions

between the company and employee representatives, according to procedures described in

the different local agreements in place. (S1-2-27-(e))

To gain insights into the perspectives of employees who may be particularly vulnerable or

marginalized, Outokumpu combines multiple mechanisms, including both qualitative and

quantitative tools. Group-wide pulse surveys are conducted regularly, and the results are

analyzed and discussed at multiple levels, from the group and department to team levels,

whenever confidentiality allows, with actions taken to address identified issues.

Dashboards on fairness, pay transparency, and job framework, along with manager-level

dashboards, enable leaders to identify potential risks or inequities and take timely, data-

driven actions.

Employees are encouraged to raise concerns through their manager, manager’s manager,

company management, HR, compliance, internal audit, physical mailboxes, or the SpeakUp

channel. HR also monitors absences and other indicators of potential well-being issues to

provide prompt support. In the Business Area Americas, Team Member Networking groups

provide a safe space and representation opportunities for certain minority groups. Together,

these mechanisms ensure that the perspectives of all employees, particularly those who

are vulnerable or marginalized, are systematically captured and addressed. (S1-2-28)

Remediation

In 2025, Outokumpu continued to develop a group-wide sustainability due diligence

process based on the gap-analysis and action plan defined in 2024. The scope covers both

Outokumpu’s own operations and value chain; company’s own workforce, value chain

workers and affected communities being the main affected stakeholders.

Developing a group-level approach to providing and enabling remedy was one of the focus

areas for 2025. Outokumpu established an internal guideline in December 2025 on

remedial actions to identify and evaluate the current status of existing remedial practices.

The guideline will serve as the basis for further process development for remedy in 2026,

coordinated by Outokumpu’s Sustainability Due Diligence Working Group. Besides mapping

the current remedial actions and identifying completing forms of remedy, a procedure to

assess their effectiveness will be developed in 2026. Currently, these situations are

managed on case-by-case based on the UN Guiding Principles and OECD Guidelines and

consulting external experts, when needed. (S1-3-32-(a))

Grievance mechanisms

In addition to remedial actions, elaborating Outokumpu’s approach on grievance

mechanisms was a focus area for sustainability due diligence development in 2025. The

main grievance mechanism provided by Outokumpu is the SpeakUp channel through which

concerns can be raised in a confidential manner. It is hosted by a third party and allows the

company’s own workforce, workers in the value chain, affected communities, and other

external stakeholders to report their concerns confidentially and also anonymously, if

allowed by the local laws and regulations. ( S1-3-32-(b))

Besides SpeakUp, Outokumpu has recognized the need to provide additional grievance

mechanisms to its own workforce, value chain workers and affected communities. Also the

ResponsibleSteel surveillance audit findings in 2025 concerning Outokumpu’s European

operations provided guidance on this topic. Consequently, this approach was elaborated as

part of company’s sustainability due diligence process development during 2025.

Outokumpu published an internal guideline in December 2025 on grievance mechanisms to

identify and evaluate the current status of existing channels to raise concerns. The

guideline will serve as the basis for further process development on grievance mechanisms

in 2026, coordinated by Outokumpu’s Sustainability Due Diligence Working Group.

(S1-3-32-(c))

Outokumpu actively promotes awareness of the SpeakUp channel among its own workforce

through regular internal communications, training sessions, and introduction programs for

new employees. The SpeakUp channel is available in several languages. Link to the channel

can be found on the company intranet and on Outokumpu's external website. More

information about reporting misconduct can be found in the Governance section. (S1-3-32-

(d))

The issues that are raised via the SpeakUp channel are handled according to Outokumpu’s

internal procedure to ensure proper and independent investigation. Monitoring possible

remedial actions is included in this procedure. The effectiveness of the SpeakUp channel

based on the criteria set for grievance mechanisms by UNGPs or OECD guidelines will be

evaluated in 2026 as part of the further development of grievance mechanisms at

Outokumpu to ensure that they are aligned with internationally recognized sustainability

due diligence frameworks. (S1-3-32-(e))

Outokumpu has a strict non-retaliation policy for reports made in good faith. This means

that the person who reports an issue shall not face negative consequences if they have

reported their concerns in good faith. Furthermore, if the misconduct report is within the

scope of the EU Whistleblower Protection Directive (EU) 2019/1937 and the consequent


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local laws and regulations, they also receive protection based on these laws and

regulations. Outokumpu’s policies and practices are regularly reviewed and updated to

ensure that they also account for more recent developments. Business conduct topics and

how employees perceive the various elements of the company’s actions, operations and

corporate culture are also regularly evaluated and measured through various means, such

as employee engagement surveys targeted at all employees.

There were two employee engagement surveys conducted in 2025. These surveys included

questions around the key themes of corporate culture – ethical behavior, well-being, health

and safety, fairness and belonging, and raising concerns. In addition, the ResponsibleSteel

surveillance audits for Outokumpu’s European operations in 2025 focused on the

availability and awareness of grievance mechanisms. The findings emphasized the

importance of continued awareness-raising on the existing channels to raise concerns. No

indication of concerns about possible negative consequences for using these channels

were reported based on the audits. (S1-3-33)

The need to have additional procedures to assess Outokumpu’s own workforce’s awareness

of and trust in structures and processes for raising their concerns or needs and having

them addressed, will be evaluated in 2026 when further developing Outokumpu’s approach

to grievance mechanisms and remedy. (S1-3-34)

Actions

The work with Outokumpu’s own workforce focuses on the following topics: safety, health

and well-being, learning and development, fairness and belonging. Key actions include the

actions taken in 2025, as well as other ongoing and future actions.

Outokumpu takes proactive actions regarding its safety management system, including

hazard recognition, safety behavior observations and preventive safety actions, to flag

potential risks and unsafe acts and behaviors before they lead to an accident. Outokumpu

also continuously trains its employees to behave safely, for example through customized

trainings.

In 2025, Outokumpu continued to test state-of-the-art technology for safety and utilized AI-

driven robots in Finland, Germany, and Sweden to automate some parts of the safety

inspection work and reduce the exposure of employees to hazardous areas. The work on

utilizing AI will continue in 2026 in Finland and Germany.

During 2025, Outokumpu worked on enhancing its strategy regarding mental health. An

expected outcome of prioritizing the well-being of its employees, is that Outokumpu should

gain a competitive advantage by creating a more resilient, healthier, and more productive

workforce. The work will continue in 2026. Outokumpu encourages its employees to take

care of their physical health by offering various exercise benefits and discounts to sports

and well-being services, and health support programs on-site.

During the reporting year, the focus was on leaders as leadership forms the firm foundation

for a high-performing organization. Firstly, 360° assessments for Outokumpu leaders

continued during 2025, to support their self-awareness and development. Secondly,

emphasis was also put on leadership pipeline training for all leaders to develop their

leadership skills. During 2025, 4,069 hours of leadership training was delivered across the

company (2024: 3,400 hours). In addition, HR-facilitated “Team Excellence” training was

offered for leaders and their teams who want to understand and apply the foundations of a

high performing team. During 2025, 27 Team Excellence sessions were delivered (2024:

52). The work on leader training and capacity building continues in 2026.

Outokumpu supports professional development and growth by building capabilities across

the company, which is expected to meet the business needs and requirements for the

future. A total of 68,043 training hours were delivered during 2025 (2024: 70,913), across

all of Outokumpu’s locations. The average employee spent 7.9 hours in training during the

year (2024: 8.1 hours). The top learning categories involving the majority of Outokumpu’s

employees included safety, compliance, leadership, and belonging. The work is ongoing.

Outokumpu continuously promotes fairness and belonging by standardized recruitment and

promotion practices to mitigate potential biases.

In 2025, Outokumpu further advanced pay transparency and pay equity practices as part of

its Total Rewards strategy. Employees now have clear visibility to their job grade and

comparative ratio, enabling a better understanding of how individual pay aligns with the

applicable pay scale for their position and location. These tools empower employees to

discuss compensation transparently with their leaders and support trust in the fairness of

pay governance. Pay transparency was also embedded into updated Talent Acquisition

Ways of Working. Outokumpu implemented equity-first hiring practices by no longer

requesting prior salary history from candidates, including salary ranges in job postings, and

using transparent offer frameworks instead of salary expectation questions. These updates

reduce the risk of perpetuating historical pay inequities and ensure decisions from the start

of the employee lifecycle reflect internal fairness and external competitiveness.

Accountability in compensation governance was further reinforced in 2025. Hiring

managers and HR professionals now have structured access to digital compensation tools

and standardized benchmarking that includes both market-aligned pay scales and

statistical insights on internal salary consistency. This combination provides enhanced

visibility to external competitiveness and internal pay equity, helping leaders identify and

address gaps proactively. These improvements strengthen data-driven decision making and

support timely corrective actions where needed. Outokumpu renewed its Fair Pay Workplace

certification in 2025, confirming ongoing commitment to rigorous pay equity standards and

continuous improvement through regular monitoring and action plan follow up with an

external partner. Collectively, these actions help Outokumpu mitigate potential negative

impacts associated with operating in a traditionally male-dominated industry, reduce the


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risk of unjustified pay variations, and foster the positive outcomes linked to a diverse, fair,

and inclusive work environment where all employees can thrive. S1-MDR-A-68-(a))

Scope and time horizon

Safety actions take place globally throughout Outokumpu, with extra emphasize in

production sites and service centers. They include both employees and non-employees in

the workforce. The actions are part of a comprehensive safety management system which

is not limited in time but is operated on a continuous basis and enhanced year after year.

While the actions described above take place throughout Outokumpu, some of them are

targeted at a specific part of the workforce, such as leaders when it comes to leadership

training or operators and technicians when it comes to team dialogue training. They

normally do not include non-employees in the workforce.

The actions are part of a comprehensive human resources management framework which is

not limited in time but is operated on a continuous basis and enhanced year after year. (S1-

MDR-A-68-(b-c))

Actions related to impacts, risks and opportunities

Outokumpu is taking action to prevent negative outcomes related to the safety hazards to

which its workforce is exposed. During 2025, the company for example analyzed every

incident’s root cause and when relevant, shared the results group-wide to ensure that

preventive actions across the company were taken. Analysis was also done at group level

and embedded in the company’s annual planning, for example, regarding hand safety.

Already before 2024, it was ensured that all sites have first aiders in place and the

company has escalated routines to ensure that employees and contractors have the

chance to get to hospital by ambulance as quickly as possible in the case of a safety

hazard. These preventative actions will continue to be taken in 2026 and onward. In 2025,

the company focused more on learning from near-misses and will continue with the

established processes. (S1-4-38-(a))

In 2025, there were 190 (2024: 181) work related incidents reported that led to injuries.

Out of the 190 incidents, there were 35 (2024: 31) recordables reported, including the

classifications fatality, lost-time injury, restricted work injury or medical treated injury. In

each case, Outokumpu has given support with the provision of a remedy in the form of first

aid, medical treatment, rehabilitation and time off work. (S1-4-38-(b)), (S1-MDR-A-68-(d))

Outokumpu makes thousands of safety behavior observations (SBOs) each year, carefully

reports all hazards, and thoroughly investigates every safety incident. These observations,

reports and investigations inform action-taking, from very local and specific levels (for

example, changing one specific procedure on one production line) to group level (for

example, theme discussions and communication campaigns on a specific type of hazard).

(S1-4-39)

In 2025, Outokumpu has not taken any measures to mitigate impacts on workers that arise

from the transition to a greener economy, since the impact from this transition is positive

for Outokumpu’s workforce. The company continuously trains and develops its workforce on

green technologies when moving forward in its climate strategy. (S1-4-AR-43)

Outokumpu is taking action to deliver positive impacts to its workforce in terms of health

and well-being, learning and development, and fairness and belonging, as described above

in the paragraph on key actions. (S1-4-38-(c))

The effectiveness of actions and initiatives is continuously tracked and assessed through a

variety of metrics, such as people pulse surveys and health and safety records. Outokumpu

also holds regular review meetings and solicits feedback from its workforce, including

discussions with workers’ representatives, to ensure that its actions are yielding the

desired outcomes.

A good example of this tracking is the feedback Outokumpu receives from its employees

through regular people pulse surveys. The surveys are conducted with an external partner,

Viva Glint, to ensure confidentiality. In 2025, the Outokumpu engagement index remained

at a solid level compared to the external benchmarks being at 74 on a scale of 1–100. The

response rates are at a good level and provide us with representative and reliable results.

The engagement index consists of two questions that are the main drivers for engagement:

“How happy are you at Outokumpu?” and “Would you recommend Outokumpu as a great

place to work?”.

In 2025, people pulse surveys have included topics such as safety behavior, mental health,

fair and respectful treatment, strategy awareness, empowerment, and manager

satisfaction. After each pulse survey is completed all managers are responsible for making

the results transparent to their employees and implementing appropriate improvement

initiatives. More information is available in the Targets section below in this chapter.

(S1-4-38-(d))

Outokumpu continued to take action to prevent negative outcomes related to unequal or

non transparent compensation practices. After obtaining Fair Pay recertification in 2025,

the company strengthened its efforts to maintain the required standards and to further

reduce the risk of unexplained pay gaps across its workforce. The recertification process

reaffirmed the effectiveness of Outokumpu’s governance procedures on compensation

fairness and highlighted areas where continued monitoring and improvement are essential.

During 2025, the company reviewed gender pay outcomes across all countries, analyzed

the factors that contributed to any identified differences, and incorporated corrective

measures into its annual salary review and decision making processes. These insights

supported fair, consistent, and well documented compensation decisions and ensured that

local HR teams and leaders were equipped to act on potential risks.

Outokumpu also continued applying and refining the procedures required by the

recertification framework, which include structured analytical reviews, process


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documentation, and transparent communication on compensation principles. These

activities help minimize the risk of unintentional pay disparities and strengthen the

company-wide culture of fairness and accountability. Outokumpu also maintained

systematic monitoring of the explained salary gap between men and women, taking follow

up actions when required. These efforts will remain ongoing as part of Outokumpu’s long

term commitment to fair and equitable compensation practices. (S1-4-39)

Actions to mitigate material risks related to Outokumpu’s own workforce are the same as

the actions aiming to prevent, mitigate or remediate material negative impacts, as

described above in this section. (S1-4-40-(a))

As to the actions to pursue material opportunities related to the company’s own workforce

are the same as the actions aiming to deliver positive impacts, as described above in this

section. (S1-4-40-(b))

Outokumpu ensures through its policies and targets that the company’s own practices do

not cause or contribute to material negative impacts on its own workforce. To begin with,

Outokumpu has a safety-first approach to all its activities. The company believes that

strong safety performance correlates with improved quality and operational efficiency. Good

health and well-being of the personnel are essential values on their own. In addition, a

healthy and thriving team of professionals is an asset to the company’s success, and all

employees should return home healthy, safe and sound every day. Outokumpu strives

consciously toward a company culture in which all decisions and activities result from the

following safety principles:

• Safety before volume: safety takes priority over all other activities, including production.

• Safety starts with me: everyone is responsible for their own safety and for caring for the

safety of their colleagues.

• No shortcuts: procedures are followed and risks evaluated before acting.

• No repeats: all incidents are investigated and actions taken to prevent re-occurrence,

anywhere.

(S1-4-41)

Resource allocation to manage material impacts

Outokumpu allocates significant resources, both financial and non-financial, to managing

material impacts on its workforce. Financial resources include investments in safety

equipment, health and safety initiatives, and training programs, as well as the technology

and people to manage these. Non-financial resources include for example allocating time

and expertise for developing policies and processes, employee engagement and leadership

development. (S1-4-43), (S1-MDR-A-69-(a))

In 2025, approximately 80 experts worked in Health and Safety teams, and 124 in Human

Resources (in 2024: 100 in Health and Safety and 130 in Human Resources). There were

also more than 20 people working on compliance, internal audit, and employee

representation activities. Additionally, Outokumpu invested EUR 14.6 million related to

health and safety operational and capital expenditure projects (2024: EUR 14 million).

Besides project-related investments, Outokumpu also spent EUR 0.5 million in licenses for

learning and development tools supporting both health and safety as well as fairness and

belonging (2024: EUR 0.5 million). (S1-MDR-A-69-(b))

Outokumpu regularly reviews its resource allocation and adjusts it when needed to meet

business needs and the expectations of its own workforce, so that the company is

effectively managing its material impacts at all times. In 2025, the financial resources

allocated to managing material impacts related to the company’s own workforce remained

at a similar level as in 2024. (S1-MDR-A-69-(c))

Prior progress

2025, the total recordable incident frequency rate (TRIFR) was 1.8 and declined slightly

compared to 2024 with a TRIFR of 1.5. In 2025, Outokumpu’s engagement index was 74,

being -1 points against the external benchmark provided by the survey provider (in 2024:

76). Over 300 leaders participated in Outokumpu’s leadership programs. The number of

diverse leaders increased to 64 (in 2024: 57), against a target of +100. A 60% agreement

score was reached in all areas of belonging (in 2024: 60 %). In adjusted terms, women

earned EUR 0.994 for every EUR 1 earned by men (in 2024: 0.986). (S1-MDR-A-68-(e))

Targets

Outokumpu uses outcome-oriented targets in two focus areas to drive and measure

progress in addressing material impacts, risks and opportunities related to its own

workforce: safety as well as fair and inclusive workplace. Each individual target described

below serves multiple purposes related to the workforce: reducing negative impacts,

advancing positive impacts and managing material risks and opportunities. (S1-5-44-(a-c))

The ultimate goal for Outokumpu is to have zero accidents, with an underlying management

philosophy to continuously improve our safety practices. To strive towards that, Outokumpu

sets total recordable incident frequency rate (TRIFR) targets yearly.

In 2022, Outokumpu’s Board of Directors defined a set of fairness and belonging, targets

for 2025. These targets support the implementation of the company’s Sustainability Policy,

Code of Conduct, Human Rights Policy, and Recruitment Policy when it comes to building a

work environment where everyone, regardless of their particularities and differences, is

treated fairly and has the opportunity to contribute and to develop. (S1-MDR-T-80-(a))

In 2025, the target was to keep a world-class TRIFR level of 1.5, while evening out the solid

performance throughout its operations. This target is included for 10% weight in the short-

term incentive plan applicable to management, including the CEO.


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Fairness and belonging targets are to increase diversity in leadership by adding 100 diverse

leaders compared to the baseline of July 2022 and to ensure that all international

management teams include a minimum of 30% of diverse leaders, by the end of 2025.

In addition we aim to reach a 60% agreement score in the people pulse survey, on all

questions related to belonging and across all diverse employee groups.

The target to reach equal pay was also set in 2022. The pay equity ratio reached in 2025

was women's euro of 0.994 (2024: 0.996). Even if there was no target set for the Fair Pay

Workplace Certificate, Outokumpu maintains it to externally verify progress against the

equal pay target. (S1-MDR-T-80-(b))

Scope, baseline year and milestones

While these targets are set at a group level, they are turned into to site level targets, which

are included in local incentive plans. (S1-MDR-T-80-(c))

Since 2016, Outokumpu has reduced the total recordable incident frequency rates (TRIFR)

in relation to one million working hours, meaning work-related incidents, by 79%, from 8.7

to 1.8 in 2025. In targets related to workforce belonging, the baseline for adding 100

diverse leaders is July 2022. In the target of a minimum of 30% diverse leaders in the

international management teams, there is no baseline set. The target to reach equal pay

was set in 2022, and in belonging, the target is to maintain the baseline set by the fairness

and belonging survey conducted in 2022. (S1-MDR-T-80-(d))

Safety targets are set yearly, but closely followed on a monthly basis. For the target of

adding 100 diverse leaders by 2025, interim targets are defined for the end of each

calendar year and included in the short-term incentive plan applicable to the management

for 10% weight. Other target levels are intended to be maintained each year. (S1-MDR-T-80-

(e))

Methodologies and assumptions

To define appropriate target levels, the health and safety department analyzes the trends in

safety data across sites in the light of industry benchmarks, and it makes a proposal to the

management. At group and business area levels, the targets are approved by the Board of

Directors.

At Outokumpu, a diverse leader is defined as a manager, meaning an employee with a

minimum of one direct report, who is female and/or belongs to an ethnic minority and/or

whose nationality differs from their working country. (S1-MDR-T-80-(f))

Process and changes in targets

Outokumpu’s employees are involved in this target setting process via their health and

safety representatives as well as via their workers’ representatives. While employee

representatives were not directly involved in setting employee related targets, the

perspectives of employees obtained in surveys was a key input. (S1-MDR-T-80-(h)), (S1-5-47-(a))

In 2025, there was no change in the target principle, metrics and underlying methodology

that would impact comparability. (S1-MDR-T-80-(i))

Performance against disclosed target

In 2025, Outokumpu achieved a TRIFR of 1.8 (2024: 1.5). Performance declined slightly

compared to 2024.

By the end of 2025, altogether 64 diverse leaders had been added to the group and all 12

management teams included 30% or more diverse leaders. The Fair Pay workplace

certification was achieved in March 2024, and Outokumpu started to publicly disclose both

its unadjusted pay gap and adjusted pay gap. At the end of 2025, women in Outokumpu

earned EUR 0.994 for every EUR 1 earned by men (a gap of 0.06%), up from EUR 0.996 in

2024. These numbers consider the compensation from similar job positions, qualifications,

and experience. Without taking these explanatory factors into account, women earned EUR

1.09 for EUR 1 earned by men on average. This reflects the structural differences in gender

by type of job: men dominate the workforce at the mills while the proportion of women is

higher in office jobs.

In the company-wide People Pulse 2025 survey, the overall belonging score, calculated as

the average of eight related questions, was 79 (2024: 78), with individual question results

varying around this average. The agreement score increased +1 since the previous year.

The most significant increases were experiences in manager-related questions, such as how

the manager cares about the team members as people and values their perspectives. This

is reflected in the question “I feel like I belong in our team”, where the agreement score

increased +1 since the previous pulse, reaching a result of 83 which is 3 points higher than

the average of all companies surveyed using the tool Viva Glint. (S1-MDR-T-80-(j))

Process for tracking performance and identifying improvements

For safety performance, a dashboard and a presentation with more underlying data are

made available to all employees on the intranet, and the CEO hosts a monthly call to

review the situation and learn from incidents that may have happened. The progress is also

closely followed and discussed with all employees at site level.

To track performance against the fair and inclusive workplace targets and to identify

improvement opportunities, Outokumpu has several tools and practices. Diverse leaders in

leadership is monitored via a dashboard in PowerBI, which is updated quarterly and

discussed in management team meetings. Pay equity is regularly checked by HR thanks to

Syndio, a specialized pay equity platform, and remediation is proposed when necessary as

part of the annual salary review process. Belonging is followed up through regular pulse

surveys in Viva Glint, and discussed along with possible actions to take at team,


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department and company levels. All these systems operate under strict permission

authorization and governance, to ensure data reliability and protection. (S1-5-47-(b))

Every incident or near-miss is analyzed and every hazard is reported. Outokumpu has two

safety reporting systems in place: MIA in Europe and Intellex in the US. These systems use

workflows to generate actions to mitigate the reported items. More complex cases are

analyzed using root cause analysis methods and mitigation actions are also tracked in the

reporting system. Learning points and further actions are regularly discussed with employee

representatives, for example in the Group Working Committee.

Overall progress against the targets, learning points and further action points are regularly

discussed with employee representatives, for example in the Group Working Committee.

(S1-5-47-(c))

Characteristics of employees

As of December 31, 2025, the company had 8,605 (2024: 8,736) employees. The four

biggest countries represent 81% of the entire Outokumpu Group. At year-end 2025, those

four countries with the most employees were, in descending order, Finland, Germany,

Sweden and the US.

The tables below present the breakdown of all of Outokumpu’s employees by gender, region

and type of employment contract.

Employee headcount by gender


	2025	2024
Gender	Number of employees (headcount)	Number of employees (headcount)
Female	1,638	1,648
Male	6,967	7,088
Other	0	0
Not reported	0	0
Total employees	8,605	8,736

Employee headcount in countries with at least 50 employees,

representing more than 10% of the total headcount


	2025	2024
Country	Number of employees (headcount)	Number of employees (headcount)
Finland	2,587	2,589
Sweden	1,549	1,566
Germany	1,824	1,926
USA	970	978

(S1-6-50-(a))

Employees by contract type, broken down by gender (headcount)


2025
FEMALE	MALE	OTHER	NOT DISCLOSED	TOTAL
Number of employees (headcount)
1,638	6,967			8,605
Number of permanent employees (headcount)
1,539	6,733			8,272
Number of temporary employees (headcount)
99	234			333
Number of non-guaranteed hours employees (headcount)

Number of full-time employees (headcount)
1,510	6,048			7,558
Number of part-time employees (headcount)
128	919			1,047

*Gender as specified by the employees themselves. (S1-6-50-(b))


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2024
FEMALE	MALE	OTHER	NOT DISCLOSED	TOTAL
Number of employees (headcount)
1,648	7,088			8,736
Number of permanent employees (headcount)
1,526	6,801			8,327
Number of temporary employees (headcount)
122	287			409
Number of non-guaranteed hours employees (headcount)

Number of full-time employees (headcount)
1,534	6,137			7,671
Number of part-time employees (headcount)
114	951			1,065

Employees by contract type, broken down by region (headcount)


2025
Europe	America	Asia	Australia	Africa	Total
Number of employees (headcount)
6,796	1,758	45	3	3	8,605
Number of permanent employees (headcount)
6,489	1,736	41	3	3	8,272
Number of temporary employees (headcount)
307	22	4			333
Number of non-guaranteed hours employees (headcount)

Number of full-time employees (headcount)
5,749	1,758	45	3	3	7,558
Number of part-time employees (headcount)
1,047					1,047

(S1-6-52)


2024
Europe	America	Asia	Australia	Africa	Total
Number of employees (headcount)
6,899	1,786	45	3	3	8,736
Number of permanent employees (headcount)
6,509	1,769	43	3	3	8,327
Number of temporary employees (headcount)
390	17	2			409
Number of non-guaranteed hours employees (headcount)

Number of full-time employees (headcount)
5,835	1,785	45	3	3	7,671
Number of part-time employees (headcount)
1,064	1				1,065

The information on gender is based on self-reporting. The current split in gender is between

male and female, where the female rate is 19% (2024: 19%). During the last three years,

there has been a 2% increase in the female-to-male ratio.

Outokumpu has 1,047 part-time employees (2024: 1,065)and 7,558 full-time employees

(2024: 7,671), bringing the share of part-time employees to 12.2% (2024: 12.2%). A key

explanation is the collectively reduced working time in Germany from contractually 35

hours per week to 32 hours per week, due to difficult market conditions.

Outokumpu had 8,272 permanent employees (2024: 8,327) and 333 temporary

employees (2024: 409), 96.1% (2024: 95.3%) and 3.9% (2024: 4.7%), respectively.

Temporary workers enable the company to react to volatile market conditions. They are

also a valuable talent pool from which to hire permanent employees when needed. (S1-6-50-

(e))

In 2025, a total of 588 employees left Outokumpu (2024: 537), which is a turnover rate of

7.1% (2024: 6.4%) based on 8,272 permanent employees (2024: 8,327). (S1-6-50-(c))

Outokumpu’s total headcount can be found in the Group key figures in the Financial

Statements. (S1-6-50-(f)) In this report, Outokumpu reports its employees by headcount and

as of December 31, 2025. (S1-6-50-(d)-(i-ii))

Outokumpu also follows upon its workforce via other metrics, such as absences and

sickness rates. (S1-6-MDR-M-75)

Headcount methodologies, assumptions and validation

The headcount figures are taken from Outokumpu’s global personnel information system. All

relevant information is stored for each person, and this can be reported in different ways, for


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instance by full-time equivalent, employee group, employment status, absence status, all

organizational department levels, legal entity, location, and cost center, to name just a few.

Outokumpu distinguishes between headcount and full-time equivalent with the following

definitions:

• Headcount is the number of individuals employed by the company. Every such individual,

even working part-time, counts as 1.

• A full-time equivalent (FTE) is a unit of measurement used to calculate the number of full-

time hours worked by all employees in a business. If your business considers 40 hours to

be a full-time work week, then an employee working 40 hours per week would have an

FTE of 1.0. In contrast, a part-time employee working only 20 hours per week would have

an FTE of 0.5, which shows that their hours worked are equivalent to half of a full-time

employee. Additionally, FTE will be 0 for employees who are on sick leave or parental

leave for more than six months or who are on a notice period without a requirement to

work. (S1-6-MDR-M-77-(a))

The key figures related to Outokumpu’s own workforce are not validated by any external

body other than the assurance provider. (S1-6-MDR-M-77-(b))

Collective bargaining and social dialogue

Outokumpu maintains a consistent policy of freedom of association. All Outokumpu’s

employees are free to join trade unions according to the local rules and regulations. In

2025 , 78.5% of the Group’s employees were covered by collective agreements (2024:

78.8%). (S1-8-60-(a))

Collective bargaining and social dialogue coverage


	Collective bargaining coverage		Social dialogue
Coverage rate	Employees – EEA (for countries with >50 empl. representing >10% total employees)	Employees – non-EEA (estimate for regions with >50 empl. representing >10% total empl.)	Workplace representation (EEA only) (for countries with >50 empl. representing >10% total empl.)
0–19%		USA
20–39%
40–59%
60–79%
80–100%	Finland, Sweden, Germany		Finland, Sweden, Germany

(S1-8-60-(b-c)), (S1-8-63-(a)), (S1-8-AR-70)

Employee representation in Outokumpu’s non‑EEA operations covers less than 10% of the

workforce. Where unions are present, they provide formal representation; in locations

without unions, Outokumpu respects employees’ freedom of association. Across all

locations, management maintains regular communication channels to share information,

gather feedback, and promote dialogue on working conditions, ensuring transparency,

cooperation, and alignment with Outokumpu’s global commitments.

The Outokumpu Personnel Forum is an important information channel between its

personnel and management in the company’s European operations. The forum is based on

the European Works Council Directive. The Personnel Forum appoints the Group Working

Committee, which is responsible for the operative cooperation between the management

and employees. During the year, the committee convened five times. (S1-8-63-(b))

Outokumpu does not use metrics other than those stated above, to evaluate performance

and effectiveness in relation to collective bargaining coverage. (S1-8-MDR-M-75)

Collective bargaining methodologies, assumptions and validation

Similar to all headcount figures, data from employees who are covered by collective

agreement or individual contract are taken from Outokumpu’s global personnel information

system. The numbers concerning social dialogue are nearly the same. When there are

differences, data is collected individually from the countries concerned. (S1-8-MDR-M-77-(a))

The key figures related to Outokumpu’s own workforce are mainly validated by the

assurance provider. In addition, some of the metrics concerning the company’s own

workforce were covered during the ResponsibleSteel surveillance audits that were conducted

by an external party in 2025. (S1-8-MDR-M-77-(b))

Fair and inclusive workplace

Outokumpu has established targets and a comprehensive roadmap to strengthen a fair and

inclusive workplace.

Gender diversity at top management level

2025


Gender	Male	Female	Other	Not disclosed	Total
Number of top management employees	53	29	0	0	82
Percentage of top management employees	64.6%	35.4%	—%	—%	100.0%

2024


Gender	Male	Female	Other	Not disclosed	Total
Number of top management employees	54	33	0	0	87
Percentage of top management employees	62.1%	37.9%	—%	—%	100.0%

(S1-9-66-(a))

Outokumpu defines top management in its diverse leadership target as all leaders

belonging to a key management team, at business area, business line or group function

level. Besides the Outokumpu Leadership Team including the CEO, the leadership teams

from the Americas and Ferrochrome business areas, and the Stainless Europe and


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Advanced Materials business lines, as well as from the Group functions Finance, HR,

Procurement, Legal, Technology and IT, are part of Outokumpu’s top management. The

majority of the leaders of these leadership teams report to the CEO. (S1-9-MDR-M-77-(a)),

(S1-9-AR-71)

Outokumpu also follows the development of diversity in leadership on a quarterly basis

through two other metrics: the share of diverse leaders in each key management team

(related to its 30% target) and the number of diverse leaders added to the organization

overall (related to its +100 target). More information is available in the Targets related to

own workforce section (S1-5) in this chapter. (S1-9-MDR-M-75)

Age distribution across Outokumpu’s own workforce

2025


Age groups	Under 30 years	30-50 years	Over 50 years	Total
Number of employees	1,258	4,319	3,028	8,605
Percentage of employees	14.6%	50.2%	35.2%	100.0%

2024


Age groups	Under 30 years	30-50 years	Over 50 years	Total
Number of employees	1,310	4,400	3,026	8,736
Percentage of employees	15.0%	50.4%	34.6%	100.0%

(S1-9-66-(b))

The key figures related to own workforce are not validated by any other external body than

the assurance provider. (S1-9-MDR-M-77-(b))

Adequate wages

Outokumpu is committed to providing its team members with a comprehensive total

rewards package, encompassing base salary, short-term incentives and benefits aligned

with market practices and local pay structures, and equity-based long-term incentives for

eligible individuals.

According to its thorough analysis, all employees at Outokumpu are paid wages that meet

or exceed the established adequacy benchmarks within their respective countries.

(S1-10-69), (S1-10-70)

Outokumpu does not use metrics other than those stated above to evaluate performance

and effectiveness in relation to adequate wages. (S1-10-MDR-M-75)

Wage methodologies, assumptions and validation

To check whether all its employees are paid adequate wages, Outokumpu compared the

lowest salary paid in 2025 in each country with the minimum wage standards in the

respective country. For countries where minimum wage information is not available, data on

adequate wages is obtained by researching sector-specific wage agreements and/or

collective agreements. (S1-10-MDR-M-77-(a))

The key figures related to adequate wages are not validated by any external body other

than the assurance provider. (S1-10-MDR-M-77-(b))

Social protection

All Outokumpu employees are covered by social protection against loss of income due to

major life events. In many of Outokumpu’s operating countries, this coverage is mandated

by law or collective agreements. In some cases, Outokumpu provides benefits beyond what

public and collective programs mandate. These additional benefits are highlighted in the

table.

Social protection by country


Country	Sickness	Unemployment	Injury & disability	Parental leave	Retirement
Finland	X	X	X	X	X
Sweden	X Outokumpu	X Outokumpu	X	X Outokumpu	X
Germany	X	X	X Outokumpu	X	X
UK	X Outokumpu	X	X	X Outokumpu	X Outokumpu
Netherlands	X Outokumpu	X	X Outokumpu	X	X Outokumpu
Lithuania	X	X	X	X	X
Italy	X	X	X	X	X
Poland	X	X	X	X	X
USA	X Outokumpu	X	X Outokumpu	X Outokumpu	X Outokumpu
Mexico	X	X	X	X	X Outokumpu

X = covered by public program or collective agreement.

X Outokumpu = Outokumpu-specific coverage instead or on top of public program.

Only countries where Outokumpu has at least 50 employees are listed in the table. In

countries where Outokumpu has fewer than 50 employees, all employees are also covered

by social protection against loss of income due to sickness, unemployment, occupational

injury or disability, parental leave and retirement. (S1-11-74-(a-e)), (S1-11-75)


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Skills development

Outokumpu invests in the growth and advancement of its workforce. To support its

employees’ professional development, leadership skills, and succession planning,

Outokumpu implements various employee programs.

Overall, the number of training courses increased again in 2025. The focus remained on

management development, with its Leadership Pipeline training program, and its License to

Lead training especially designed for shift supervisors. In operations, safety was, as usual,

a key training topic. Function-specific qualifications were also in focus, with programs such

as Sales Academy and Finance Academy.

The majority of the training is organized in e-learning courses, although the number of face-

to-face events has increased significantly since the Covid years. The e-learning courses

focused on training in the areas of security, ethics and compliance and cyber and data

security, while leadership topics were mainly covered in face-to-face events.

Employees are encouraged and supported to set and achieve goals, ensuring they get

personal and professional benefits from the company’s development opportunities.

Training hours by gender

2025


Gender	Male	Female	Other	Not Disclosed	Total
Training hours	52,773	15,270	0	0	68,043
Average training hours per employee	7.6	9.3	0	0	7.9

2024


Gender	Male	Female	Other	Not Disclosed	Total
Training hours	55,479	15,434	0	0	70,913
Average training hours per employee	7.8	9.4	0	0	8.1

(S1-13-83-(b))

Performance discussions by gender

2025


Gender	Male	Female	Other	Not Disclosed	Total
Percentage of agreed performance discussions	97.5%	95.2%	—%	—%	97.0%

2024


Gender	Male	Female	Other	Not Disclosed	Total
Percentage of agreed performance discussions	92.0%	88.8%	—%	—%	91.4%

(S1-13-83-(a))

Outokumpu’s performance management happens in an annual and continuous process,

which ensures that managers and employees understand their main tasks, as well as how

they contribute to Outokumpu’s strategy implementation and business targets. Managers

need to follow up and support their direct reports in achieving their targets, which is seen

as an excellent opportunity to give regular feedback and leverage high performance. All

employees in Outokumpu are included in the performance management process.

Outokumpu also uses other metrics to evaluate performance and effectiveness in relation

to learning and development, such as training feedback scores, or average performance

rating in different areas. (S1-13-MDR-M-75)

Training methodologies, assumptions and validation

Learning information such as training hours as well as performance management-related

data is available in Outokumpu’s global personnel information system. Information from

external trainings is also maintained in the system. (S1-13-MDR-M-77-(a))

The key figures related to Outokumpu’s own workforce are not validated by any external

body other than the assurance provider. (S1-13-MDR-M-77-(b))

Health and safety

Outokumpu monitors, measures, analyzes and evaluates health and safety performance

regularly. The company uses both leading, or preventive, and lagging, or reactive, indicators

for health and safety. The company has in place a yearly development plan for health and

safety, and internal audits and regular reviews are made with the long-term objectives and

vision in the background. (S1-14-MDR-M-75)


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Work-related injuries


2025	Own workforce	Employees	Non- employees	Value chain workers on employer's sites
% of workforce covered under health & safety management system	100%	100%	100%	N/A
Number of fatalities as a result of work-related injuries & ill health	1	1	0	—
Rate of recordable work-related accidents in own workforce (TRIFR), %	1.8	1.7	2.0	N/A
Number of recordable work-related accidents	35	25	10	N/A
Number of cases of recordable work related ill health	N/A	4	N/A	N/A
Number of days lost to work-related injuries, ill health and fatalities	683	597	86	N/A

Lost days associated with a fatality cover the entire interval between the incident and the

date of death, in line with standard occupational health and safety reporting practices.

(S1-14-88-(a-e))


2024	Own workforce	Employees	Non- employees	Value chain workers on employer's sites
% of workforce covered under health & safety management system	100%	100%	100%	N/A
Number of fatalities as a result of work-related injuries & ill health	1	—	1	—
Rate of recordable work-related accidents in own workforce (TRIFR), %	1.5	1.4	2.0	N/A
Number of recordable work-related accidents	31	21	10	N/A
Number of cases of recordable work related ill health	N/A	3	N/A	N/A
Number of days lost to work-related injuries, ill health and fatalities	636	598	38	N/A

Health and safety methodologies, assumptions and validation

Outokumpu has implemented a corporate instruction that specifies each indicator and

prescribes the methodology for calculating incident frequency. This calculation is performed

by dividing the number of incidents per indicator by the total accumulated working hours,

standardized to one million working hours. (S1-14-MDR-M-77-(a))

Outokumpu regularly audits the following sites for its stainless steel operations: sites in

Tornio, Finland; Dillenburg and Krefeld, Germany; as well as Avesta, Degerfors and Nyby in

Sweden, are certified according to the ResponsibleSteel certification. In addition, its

operations in Avesta and Nyby in Sweden; Calvert in Alabama, the US; Castelleone in Italy;

and Alfortville in France are certified according to ISO 45001. The desired certification and

verifier depend on the country in which site is operating. (S1-14-MDR-M-77-(b))

Work-life balance

Outokumpu is committed to promoting the work–life balance of its team members. The

company offers various benefits such as paid leaves, occupational health care and support

programs, depending on the location. The company tries for and accommodates flexible

arrangements wherever the nature of work allows. It also supports part-time work and

encourages all of its employees to take the family-related leave to which they are entitled.

Outokumpu’s hybrid work policy for office employees in Europe promotes flexibility, well-

being, and compliance in modern working practices. While the company’s offices remain

the primary workplace, employees may work up to 50% of their working days remotely

within their country. Remote work arrangements are to be agreed with the employee’s

direct manager, ensuring a balance between business needs and individual preferences. All

remote work must comply with local legislation, collective agreements, and health and

safety requirements, safeguarding a consistent and fair approach across locations.

Performance expectations remain the same for office and remote work, and arrangements

may be reviewed if work quality or results are affected.

100% of 8,605 employees are entitled to take family-related leave. (S1-15-93-(a)), (S1-15-94)

86 (5.3%) of 1,638 women and 87 (1.2%) of 6,967 men have taken family-related leave

during the year.

Work–life balance – family-related leave by gender


2025	Male	Female	Other	Not disclosed	Total
Personnel utilized family-related leave by gender	1.2%	5.3%	—%	—%	2.0%


2024	Male	Female	Other	Not disclosed	Total
Personnel utilized family-related leave by gender	1.3%	2.3%	—%	—%	1.5%

(S1-15-93-(b))

Outokumpu does not use metrics other than those stated above to evaluate performance

and effectiveness in relation to work–life balance, although employees’ insights on that

topic are regularly checked in people pulse surveys. (S1-15-MDR-M-75)

Work-life balance methodologies, assumptions and validation

Absence information from employees, such as maternity and paternity leave, are taken from

the global personnel information system. Both short-term and long-term absences (6 months

or more) are tracked in the system. (S1-15-MDR-M-77-(a))

The key figures related to Outokumpu’s own workforce are mainly validated by the

assurance provider. In addition, some of the metrics concerning the company’s own


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workforce were covered during the ResponsibleSteel surveillance audits that were conducted

by an external party in 2025. (S1-15-MDR-M-77-(b))

Compensation

To ensure fairness and non-discrimination, Outokumpu runs regular statistical analyses of

compensation, considering internal job factors, individual factors, and external market

conditions. This enables the company to identify and address any pay discrepancies, which

are systematically corrected as part of its annual salary review process. It also works

closely with collective bargaining agents and employee representatives to ensure alignment

with both ethical and legal standards.

The company’s unadjusted gender pay gap is currently 9.45% (2024: 8.76%), meaning

female employees earn EUR 5,252 (2024: 4,804) more annually on average than male

employees. This unadjusted gap is largely due to the distribution of roles, with women more

represented in senior administrative and executive positions, which offer higher pay, while

men are more concentrated in operational roles, which tend to pay less. These structural

differences significantly influence the overall pay gap. (S1-16-97-(a))

The remuneration ratio between the highest-paid individual and the median-paid employee

is 27.69 to 1 (2024: 32.59 to 1), meaning that the highest pay is 27.69 times more than

the median. This ratio is largely influenced by the number of operational roles, which

typically offer lower pay. Additionally, the company’s salaries align with local market

practices, with many roles located in regions with high inflation, lower living costs, and

fluctuating exchange rates. While these salaries are lower, they remain competitive within

their local markets. (S1-16-97-(b))

To evaluate performance and effectiveness in relation to remuneration, Outokumpu also

calculates its adjusted gender pay gap, and in the USA, pay gaps linked to ethnicity. (S1-16-

MDR-M-75)

Compensation methodologies, assumptions and validation

To calculate the gender pay gap, Outokumpu compares the average actual pay of women

with that of men, regardless of possible explanatory factors such as job level, qualifications,

and experience. Currently only base pay and short-term incentives are included in the

calculation, but the company intends to include other compensation elements in the

calculation in the future.

To calculate the remuneration ratio, in 2025, Outokumpu considers base salaries and

short-term incentives on a target level, and compares the remuneration of the highest-paid

individual to the median remuneration of all other employees within the organization. As of

2025, the data set will be enhanced to include other compensation elements, such as

benefits and long-term incentives. (S1-16-97-(c)), (S1-16-MDR-M-77-(a))

The remuneration ratio is not validated by any external body other than the assurance

provider. The gender pay gap, however, is also validated by Fair Pay Workplace, the

independent organization Outokumpu works with to ensure pay equity. (S1-16-MDR-M-77-(b))

Incidents

In 2025, Outokumpu continued developing a group-wide process to track and report data

on the number of discrimination incidents, work-related complaints, and severe human

rights incidents within its own workforce. The approach is being built gradually to ensure

reliable and comparable data. In 2025, the focus was on the discrimination incidents and

work-related complaints received through the group-wide SpeakUp channel (see table

“Number of reported cases”). The reported numbers cover cases that were received

through the group SpeakUp channel in 2025. Starting 2026, a structured data collection

process is planned to be implemented across Outokumpu’s operations by engaging local

Human Resources and Health & Safety teams to ensure comprehensive and consistent

reporting.

Regarding severe human rights incidents, Human Resources and Health & Safety at local

operations were also included in the data gathering scope in 2025 (see table “Number of

reported cases”).


Number of reported cases	2025
Discrimination (SpeakUp)	5
Work-related complaints (SpeakUp)	7
Severe human rights incidents (SpeakUp and local operations)	1
Related financial transactions, in MEUR	0

More information about the remedy process at Outokumpu is given in this chapter in the

Engagement under “Remedy”. (S1-17-MDR-M-75) The methodologies and assumptions behind

the metrics were evaluated while categorizing the aforementioned cases reported via the

group SpeakUp channel. (S1-17-MDR-M-77-(a)). Consequently, it was decided that no other

external bodies than the assurance provider is required to evaluate these metrics. The

need to do this will be re-evaluated in 2026 when developing the data gathering process

further to cover also Human Resources and Health and Safety in local operations. (S1-17-

MDR-M-77-(b))

Incidents and complaints of discrimination and harassment

The data gathering process development on incidents and complaints is coordinated by

Group Sustainability together with other key Group functions, including Human Resources,

Health & Safety, Legal, Ethics & Compliance, and Internal Audit.

In 2025, the focus was on discrimination incidents and work-related complaints reported

through the group-wide SpeakUp channel, which serves as Outokumpu’s global grievance

mechanism and also covers cases related to social sustainability and human rights. These

reported cases were analyzed and categorized according to the Disclosure Requirement


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S1-17. The SpeakUp channel was updated and launched in 2025 in co-operation with

Group Ethics and Compliance and Internal Audit.

In 2026, Outokumpu will continue to develop the data collection process to ensure reliable

and comparable information from both local operations and group functions. Currently,

discrimination incidents and work-related complaints are handled on a case-by-case basis

at local operations. To ensure a consistent approach, Human Resources and Health &

Safety teams managing local cases will be closely engaged in the process development.

(S1-17-103-(a)), (S1-17-103-(b)), (S1-17-103-(d))

Severe human rights incidents

During 2025, Outokumpu continued to develop a group-level approach for systematic

identification of severe human rights issues and incidents concerning its own workforce,

value chain workers and affected communities. The categorization of these incidents was

introduced to the reports received through group-level SpeakUp channel and identification

of these incidents was advanced through the data gathering process development regarding

own operations. The suspected cases are currently assessed on a case-by-case basis but

the process will be further elaborated in 2026 as part of the Outokumpu’s sustainability

due diligence development.

In 2025, one severe human rights accident was reported in connection with Outokumpu’s

own operations. The fatal accident involved the loss of an employee at Outokumpu’s

manufacturing site in San Luis Potosí, Mexico, during electrical work. A comprehensive

investigation was conducted with the involvement of external experts, and corrective

measures were implemented across the organization to prevent recurrence. (S1-17-104-(a))

Fines, penalties and compensation

In 2025, no paid fines, penalties or compensation for damages as a result of the cases of

discrimination and/or harassment, work-related incidents, complaints or severe human

rights incidents was reported (see table “Number of reported cases”). The data gathering

scope for these financial transactions covered group functions and Human Resources and

Health & Safety at local operations. A formal group-wide process to track this data will be

finalized in 2026. (S1-17-103-(c)), (S1-17-104-(b))


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audi

S2 – Workers in the value chain

By producing stainless steel and ferrochrome,

Outokumpu is part of the global metals value

chain. From production and delivery of raw

materials to services supporting its operations,

the company values human rights across the

supply chain and is committed to advancing

human rights.

TARGETS

Share of spend with high-

impact suppliers that have

signed the Supplier Code of

Conduct by the end of 2030

100%

PROGRESS

Share of spend with high-

impact suppliers that have

signed the Supplier Code of

Conduct by the end of 2025

92%

Material impacts, risks and opportunities


Health and safety

Negative impact	Potential	Occupational health and safety issues from poor working conditions


Working time, Work-life balance

Negative impact	Potential	Excessive working time


Adequate wages

Negative impact	Potential	Inadequate living income and wages


Freedom of association, Collective bargaining

Negative impact	Potential	Lack of freedom of association


Forced labour, Child labour

Negative impact	Potential	Forced and bonded labour, human trafficking, child labour


Working conditions, Other work-related rights

Opportunity		Supply chain resilience from effective due diligence processes, human rights guidance and demands for suppliers
Risk		Fines, penalties, and loss of business licenses, and related reputational damages from core labour rights violations in value chain

(S2-ESRS2-SBM-3-48-(a))

Potential impacts on value chain workers, as identified in ESRS2-IRO-1, are connected to

Outokumpu's strategy and business models as raw materials availability is tied to

geographical occurrence and sourcing has to be done also from countries with identified

human rights risks. As a part of the new growth-focused strategy and to decrease the

negative impacts, Outokumpu is building partnerships with suppliers showing commitment


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to sustainability and human rights and putting strong focus on the supplier due diligence

process to identify, prevent and mitigate any negative impacts. (S2-ESRS2-SBM-3-10-(a)-(i)), (S2-

ESRS2-SBM-3-10-(a)-(ii)), (S2-ESRS2-SBM-3-10-(b))

According to Outokumpu’s double materiality assessment updated in 2025, value chain

workers subjected to material impacts are particularly those involved in the extraction,

refining, and processing of metals and minerals. Vulnerable groups within these categories

include young workers and migrant workers. (S2-ESRS2-SBM-3-11-(a)), (S2-ESRS2-SBM-3-11), (S2-

ESRS2-SBM-3-11-(a-v)).

As part of its supply chain due diligence, Outokumpu assesses human rights risks on

country level based on TDi AIRS country data supported by Verisk Maplecroft’s Child Labour

Index, and the Global Slavery Index by WalkFree. Heightened human rights risks such as

forced or child labour exist in certain regions, such as Northern South America, parts of

mid-Africa, and the Far East. (S2-ESRS2-SBM-3-11-(b))

In the metals and mining industry, poor working conditions can cause systemic negative

impacts on value chain workers, particularly in high-risk countries where labour regulations

are inadequate or poorly enforced. There is also the possibility of severe human rights

abuses, such as child labour, forced or bonded labor, and human trafficking, occurring in

this upstream value chain. (S2-ESRS2-SBM-3-11-(c))

There are financial risks relating to poor working conditions in the upstream value chain.

Proceedings against Outokumpu and its partners and third-party intermediaries can lead to

fines, penalties and sanctions. In addition, where Outokumpu would have contributed to the

negative impacts, the remediation of such impacts can cause financial effects on

Outokumpu. Failure to require business partners to follow ethical standards leading to

human and labor rights breaches can cause reputational damage and thus financial losses

to Outokumpu. Effective due diligence with Outokumpu’s partners and third-party

intermediaries can improve supply chain resilience and decrease operational costs.(S2-

ESRS2-SBM-3-11-(e))

Through supplier surveys and impact assessments, Outokumpu gains insight into how

workers with particular characteristics, those working in particular contexts, or those

undertaking particular activities may be more vulnerable to harm. High-risk countries and

value chains are a focus of these assessments, and data gathered through upstream value

chain mapping, supplier onboarding, desktop assessments and on-site evaluations informs

this process. (S2-ESRS2-SBM-3-12)

The opportunity to increase resilience in the supply chain through effective due diligence

comes from addressing impacts on value chain workers in the metals and mining industry

in high-risk countries. This includes addressing the vulnerabilities of specific worker groups,

such as young workers at risk of child labor and migrant or minority workers at risk of forced

labor. (S2-ESRS2-SBM-3-13)

Policies

The key policies related to value chain workers are Outokumpu’s Supplier Code of Conduct

and Supplier Requirements. Other supporting policies are the Human Rights Policy,

Sustainability Policy and Code of Conduct. These policies relate to all the impacts, risks

and opportunities on environmental, social and governance topics with a connection to

upstream value chain workers. (S2-1-16)

The Supplier Code of Conduct outlines the standards and expectations Outokumpu sets for

its suppliers to ensure ethical, sustainable and responsible practices throughout the value

chain. The policy covers a safe and healthy workplace, a sustainable future, human rights

and dignity, and good corporate citizenship, following the four key ethical principles in the

Outokumpu Code of Conduct. The policy expects suppliers to:

• take all necessary actions to keep their workforce and surrounding communities safe

and healthy,

• reduce negative impacts on the environment, especially on climate and biodiversity, and

reduce the use of energy and minimize waste and emissions into air, water and soil,

• respect and protect internationally recognized human rights and have proper grievance

and remedy processes, and

• comply with all applicable laws and regulations as well as adhere to similar ethical

standards as Outokumpu.

It is stated, that alongside any other actions Outokumpu may take, if a supplier causes or

contributes to human rights or environmental violations, they are expected to cease those

violations immediately, provide remedies to the affected individuals, and implement a

corrective action plan.

The Supplier Requirements describe the minimum requirements for suppliers. Outokumpu

expects its suppliers to minimize these potential adverse impacts in their own operations

and in their value chain:

• occupational health and safety,

• freedom of association and collective bargaining,

• adequate living income and wage,

• gender equality and equal pay,

• reasonable working hours,

• discrimination and harassment,

• migrant workers, and

• adverse impacts on biodiversity including deforestation, impacts on water, air, and soil,

and impacts on communities.


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Outokumpu expects its suppliers to have or work toward a due diligence system that follows

the UN Guiding Principles on Business and Human Rights. Suppliers are expected to co-

operate in a transparent manner with Outokumpu, including granting Outokumpu or a third

party authorized by Outokumpu the possibility to conduct audits in their facilities.

Outokumpu monitors its suppliers’ compliance with the Supplier Code of Conduct and

Supplier Requirements through self-assessments, screenings, media monitoring and audits.

As stated in Outokumpu’s Human Rights Policy and Sustainability Policy, Outokumpu

expects its employees, business partners and other parties, whose own impacts may be

directly linked to our operations, products, or services, to respect and not infringe upon

human rights. More information on the Human Rights Policy can be found in the Affected

communities (S3) chapter in the Policies section and on the Sustainability Policy in the

Climate change chapter (E1), in the Policies section.

In addition, responsible purchasing and knowing business partners is part of the

Outokumpu Code of Conduct. As stated in the Code of Conduct, suppliers are expected to

co-operate in a transparent manner with Outokumpu and must also evaluate and monitor

their own supply chain. Outokumpu wants to know who its business partners are to ensure

Outokumpu is not involved in any unethical, illegal or criminal activities. Outokumpu

employees must follow Outokumpu’s risk-based due diligence approach, which considers

and verifies the basic facts about our business partners. Outokumpu employees shall

regularly monitor the activities of their business partners to ensure Outokumpu can

continue business with them. More information on the Code of Conduct can be found in the

Governance (G1-1) chapter in the Policies section.

More information specifically on commitments to address trafficking, and forced and child

labor is provided below in this chapter under “Addressing trafficking, forced and child

labor”. (S2-MDR-P-65-(a))

Compliance with the Supplier Code of Conduct and Supplier Requirements is formally

integrated into agreements and general terms and conditions with suppliers. Since the

Supplier Code of Conduct and Supplier Requirements were launched, signed confirmations

have been obtained from high-impact suppliers to ensure they commit to and implement

principles aligned with the Outokumpu’s policies in their operations. To promote

transparency and awareness, all relevant policies are publicly accessible on the company’s

website and regularly communicated to external stakeholders through various engagement

channels. (S2-MDR-P-65-(f))

Scope, accountability and stakeholders

The Outokumpu Supplier Code of Conduct is applicable to all suppliers and their

workforces, that deliver materials, products and/or services to any Outokumpu legal entity,

regardless of their position in the supply chain, meaning whether they are direct suppliers

or are further upstream. Outokumpu expects its direct suppliers to ensure that their

suppliers comply with the Outokumpu Supplier Code of Conduct as well.

The Supplier Requirements are generally applicable to all suppliers, but certain exceptions

can be allowed based on the risk profile of a specific value chain and supplier category.(S2-

MDR-P-65-(b))

As many of the identified salient human rights risks and impacts and also certain

environmental impacts are connected to Outokumpu’s sourcing activities, the related

responsibility for ensuring the implementation of policies and engagement in the upstream

value chain cascades from the CEO to the CFO and from there to the Head of Raw

Materials and further to the Head of Supplier Sustainability, who has operational

responsibility. More information about accountability is available in the Affected

communities (S3) chapter in the Policies section. (S2-MDR-P-65-(c))

Outokumpu has collected views from stakeholders through various channels, and these

have an influence on how to set its policies. In 2025, Outokumpu continued elaborating on

its group-wide approach on stakeholder engagement, including workers in the value chain,

as part of the company’s sustainability due diligence process development. More

information on stakeholder engagement at Outokumpu can be found in the General

Disclosures chapter. (S2-MDR-P-65-(e))

Third-party standards and alignment with internationally

recognized instruments

Outokumpu’s Human Rights Policy outlines the company’s commitments to address the

rights and working conditions of value chain workers and affected stakeholders. The policy

is aligned with internationally recognized instruments, including the Universal Declaration of

Human Rights, the International Covenant on Civil and Political Rights, the International

Covenant on Economic, Social and Cultural Rights, the European Convention on Human

Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding

Principles on Business and Human Rights, the OECD Guidelines for Multinational

Enterprises, and the Ten Principles of the UN Global Compact.

The Human Rights Policy also supports the achievement of the UN Sustainable

Development Goals and follows relevant UN frameworks protecting vulnerable groups such

as women, children, migrant workers, and indigenous peoples. In addition, Outokumpu is

committed to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals

from Conflict-Affected and High-Risk Areas and is a signatory to the UN Global Compact.

These commitments are operationalized through the Supplier Code of Conduct and the

accompanying Supplier Requirements document, which translate international human rights

and labour standards into concrete expectations for suppliers. Together, they set out

requirements for upholding internationally recognized human rights, such as safe and fair

working conditions, freedom of association, non-discrimination, and the prohibition of


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forced, bonded, and child labour. Outokumpu’s supplier due diligence process, including

assessments and audits, follows the steps of the OECD due diligence framework, enabling

the identification, assessment, and mitigation of risks affecting value chain workers.

Outokumpu reinforces these commitments through participation in the ResponsibleSteel

initiative. All European manufacturing sites are certified under the ResponsibleSteel

Standard, which integrates key international labour and human rights principles. As a

chromium mining operator, Outokumpu is also a certified member of the Finnish Network

for Sustainable Mining, which supports continuous improvement in responsible mining

practices relevant to value chain workers. Further details on the Human Rights Policy are

provided in the Affected Communities (S3) chapter. (S2-MDR-P-65-(d)), (S2-1-19),(S2-1-17)

General approach to respecting human rights of value chain workers

Outokumpu is dedicated to collaborating with partners, suppliers, sub-suppliers, and

customers to proactively address and mitigate potential and actual adverse impacts on

human rights, including those related to the environment and affected communities. The

company’s Supplier Due Diligence process forms an integral part of its human rights due

diligence system and covers the entire supplier lifecycle – from onboarding and risk

screening to ongoing monitoring and periodic assessments – to ensure responsible

business conduct across its value chain.

Sustainability due diligence process

SustainabilityStatementInfographs_v3 (1).jpg


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Outokumpu applies a risk-based approach to supplier management to identify, assess, and

prioritize potential and actual impacts, risks, and opportunities related to workers in the

value chain. Setting the right priorities starts from upstream value chain mapping, where

high-risk value chains and salient topics are identified. This mapping guides the

prioritization of due diligence activities and ensures a focus on areas with the highest

potential for adverse impacts.

The country-level risk assessment is essential for mapping supplier and supply chain

impacts and risks. It follows Outokumpu’s Know Your Business Partner Instruction and

incorporates country-level sustainability and compliance risk indices. Suppliers' operating

countries are evaluated against the Dodd Frank Act Section 1502, conflict-affected and

high-risk areas (CAHRAs) defined by the European Union, Outokumpu’s trade sanctions list,

and TDi Sustainability’s Alert Index for Responsible Sourcing (AIRS), which includes indices

for conflict, legal conditions, human rights, and environmental risks.

Before suppliers are added to Outokumpu's portfolio, they undergo a qualification process.

to identify and evaluate potential risks and opportunities. The process ensures that

suppliers comply with Outokumpu’s requirements and are capable of consistently providing

conforming raw materials, products and services. The identification of impacts and risks

follows Outokumpu’s Know Your Business Partner instruction and utilizes country-level

sustainability and compliance risk indices.

During the business relationship Outokumpu monitors suppliers on an ongoing basis

through self-assessments, media monitoring, screenings and audits. Most suppliers go

through regular compliance screening for sanctions. Outokumpu uses mainly EcoVadis for

self-assessments, which focus on the environment, labor and human rights, ethics, and

sustainable procurement criteria. Based on the self-assessment results, improvement

opportunities and non-conformities are identified, and corrective actions are agreed and

followed up with suppliers.

Suppliers go through annual desktop reviews, in which they are assessed against, for

example, available certifications, spend, previous audit and self-assessments results and

overall performance scorecard results. Based on these indicators, suppliers are selected for

on-site reviews. Those reviews vary from an on-site visit to an audit or human rights impact

assessment, depending on the identified impacts and risks. Identified non-conformities and

improvement areas are discussed with the suppliers. Needed actions are agreed and

followed up. If a supplier fails to meet Outokumpu’s requirements at any stage, Outokumpu

may terminate the contract and/or exclude the supplier from future business opportunities.

This structured, impact and risk-focused supplier due diligence process identifies and

prioritizes areas with the highest potential for severe human rights and environmental

impacts and aligns with Outokumpu’s commitment to fostering responsible and ethical

practices throughout its value chain in compliance with the UN Guiding Principles on

Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at

Work, and OECD Guidelines for Multinational Enterprises. (S2-1-17-(a))

Engagement with value chain workers

Upstream value chain workers are engaged before and during a sustainability audit or

human rights assessment via interviews. Typical candidates for worker interviews are:

• a directly employed male site worker,

• a directly employed female site worker,

• a site worker engaged in the workers’ council or union,

• a young worker or trainee,

• a sub-contracted site worker,

• a temporary site worker,

• a worker belonging to a minority,

• a security worker,

• a driver,

• a cleaning worker,

• a canteen worker and

• a union representative.

The human rights impact assessment includes, in addition, interviews with the community

and non-governmental organizations. (S2-1-17-(b))

Remedy

More information on remedy for human rights impacts can be found in the Own workforce

(S1) chapter, in the Policies section. (S2-1-17-(c))

Addressing trafficking, and forced and child labor

Trafficking, and forced and child labor are addressed in several Outokumpu policies: the

Supplier Code of Conduct, Human Rights Policy and Sustainability Policy.

Outokumpu’s Supplier Code of Conduct states that Outokumpu expects its suppliers,

regardless of their position (direct suppliers or further upstream) in the supply chain, to

respect and protect internationally recognized human rights, respect and protect the rights

of children, comply with international labor treaties and condemn all forms of modern

slavery, forced labor, and the use of child labor. The Supplier Code of Conduct include

provisions addressing the safety of workers, equal opportunities and pay, freedom of


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association, human trafficking, and the use of forced or child labor. These provisions are

fully in line with the applicable ILO standards.

Outokumpu’s Human Rights Policy states that Outokumpu condemns all forms of forced or

bonded labor, modern slavery, and human trafficking. The company does not permit or

tolerate practices such as restrictions on freedom of movement, recruitment fees,

confiscation of identity documents or passports, debt bondage, or withholding of wages.

Outokumpu is committed to preventing child labor in all its forms and does not allow it in

its own operations or anywhere in its value chain, without exception. These commitments

apply globally and are monitored through Outokumpu’s human rights due diligence process.

In the Sustainability Policy, it is stated that at Outokumpu, the human rights and dignity

commitment mean that Outokumpu condemns the use of child labor, forced or bonded

labor or any kind of slavery. In addition, business conduct with high integrity means that

Outokumpu ensures that modern slavery and human trafficking play no part in the supply

chain or in any part of the business. (S2-1-18)

Cases of non-respect and aligning with international instruments

For 2025, there has been no reported cases of non-respect of UNGPs, the ILO Declaration

on Fundamental Principles and Rights at Work or OECD Guidelines involving workers in the

value chain based on Outokumpu’s internal and external data sources. Outokumpu

understands the meaning of “a case of non-respect” as a situation in which a severe

human rights impact, such as a fatality, has happened despite the human rights due

diligence process and/or other measures based on the aforementioned frameworks.

Outokumpu will start to develop a more systematic process to track and monitor the cases

of non-respect of these guidelines in its own operations or in its value chain in 2026. More

information on tracking severe human rights incidents can be found in disclosures

regarding the company’s own workforce (S1) chapter of this Sustainability statement .

In addition, Outokumpu’s Procurement organization has a separate process to identify and

manage ESG incidents in the supply chain. ESG (environment, social and governance)

incidents in the supply chain are cases of non-compliance that are identified by or reported

to the Procurement organization. An investigation is coordinated and documented by the

Procurement organization. The main purpose of the ESG incident management process is

to meet obligations under the UNGPs. The process includes desktop research, potential

purchasing stops, decisions about on-site assessments, a human rights impact and risk

assessment, Outokumpu’s attribution to the identified impacts and risks, defining and

agreeing on improvement actions, internal and external stakeholder information, and

documentation of the case.

Engagement

Upstream value chain workers perspectives are canvassed during supplier audit interviews.

Outokumpu’s sustainability audits focusing on worker interviews and human rights impact

assessments include interviews with the value chain workers, community, and non-

governmental organizations (NGOs). In addition to the current management processes

focused on the upstream value chain, Outokumpu continued to develop during 2025 a

general process for stakeholder engagement. As part of this process, internal guidelines

were published in December 2025 to address both general and specific stakeholders

affected by the company’s impacts. (S2-2-22)

The engagement of workers in the value chain happens via on-site reviews as described

above in the sections “General approach to respecting human rights of value chain

workers” and “Engagement with value chain workers”.

The purpose of the on-site assessments is to determine the maturity level of the supplier’s

human rights due diligence processes and environmental management, assess how the

supplier addresses selected specific issues, and identify and assess specific potential and

actual human rights and environmental risks in the supplier’s own operations or its value

chain (e.g. working conditions, water and waste management, biodiversity).

Furthermore, the purpose of the on-site assessments is to define recommendations for

improvement of the supplier’s human rights due diligence processes and to suggest

mitigation actions for potential and actual human rights and environmental impacts. Typical

human rights risks assessed during visits include working conditions (wages, overtime,

health and safety, freedom of association), access to whistleblower channels, forced and

child labor, housing and hygiene. Environmental topics include, for example, water

management (consumption, recycling, water flow/management plan), pollution of air and

water, biodiversity, and waste management (hazardous waste, recycling).

The Outokumpu sustainability visit includes management interviews and a site tour but

does not include direct involvement of the supplier’s workers. The sustainability audit

includes worker interviews and the human rights impact assessment as well as interviews

with communities and non-governmental organizations.

Interviewees for audits and assessment are selected based on the potential to encounter

negative impacts and to ensure the inclusion of the perspectives of those who are

particularly vulnerable to such impacts or marginalized (for example, female workers,

workers in menial tasks, immigrant workers). (S2-2-23)

The information and perspectives of the interviewed value chain workers and their

representatives are taken into consideration when the final report and improvement

recommendations are prepared. The results are communicated to the supplier, and needed


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improvement actions are agreed upon together. The results are also evaluated internally

and utilized in the supplier sustainability impact and risk assessment. (S2-2-22-(a))

An audit plan is created annually based on the supplier sustainability impact and risk

assessment. In 2025, Outokumpu conducted six on-site sustainability assessments; one

(1) sustainability audit (2024: 3) and five sustainability visits. (S2-2-22-(b))

In terms of how effectiveness of engagement with value chain workers is assessed, based

on findings during on-site audits and assessments, improvement actions are agreed

together with the supplier. Outokumpu then follows the progress of actions by keeping

regular contact with the supplier. In severe cases, re-audit can be executed to validate

actions. In 2025, 27 actions (2024: 26) were agreed. (S2-2-22-(e))

The information on accountability and responsibility for human rights in Outokumpu is

disclosed in this chapter in the Policies section under “Accountability, availability and

stakeholders.” Significant deviations or findings from these visits are reviewed with the

Head of Raw Materials and, if necessary, escalated to the CFO, the group Sustainability

team, and the CEO for decision-making. (S2-2-22-(c))

Outokumpu has not made a global framework agreement with any global union federation.

(S2-2-22-(d))

In addition to the current management processes focused on the upstream value chain,

Outokumpu started to develop a group-wide approach to ensure engagement with various

types of stakeholders affected by its operations during 2025. More information about

Outokumpu’s stakeholder engagement processes can be found in the General disclosures

section. (S2-2-22-(a-e)), (S2-2-24)

Remediation

During 2025, Outokumpu started to develop a group-wide approach to provide and enable

remedy as part of the company’s sustainability due diligence process. The approach will be

further developed in 2026 to define more specific processes for remedial actions for

various situations. More information about Outokumpu’s remedy process development can

be found in the Own work force (S1) chapter, in the Processes section under “Remedy”.

(S2-3-27-(a))

On specific channels for value chain workers to raise concerns, more information can be

found in the chapter G1 Business conduct. In addition, in relation to workers in the value

chain, Outokumpu’s website contains contact details of key persons responsible for

sustainability, human rights and supplier sustainability. Company representatives also

provide their contact details to upstream value chain workers during onsite audits and

assessments, for further questions or for reporting any concerns. (S2-3-27-(b))

With regard to value chain workers, the Outokumpu Supplier Code of Conduct states that

the supplier shall ensure that its employees and stakeholders have an opportunity to raise

concerns through appropriate channels. Outokumpu expects its suppliers to have or work

toward having a grievance mechanism. Additional information on the processes by which

Outokumpu supports the availability of channels to raise concerns related to its own

operations and value chain can be found in the chapter G1 Business conduct. (S2-3-27-(c))

Outokumpu monitors and tracks its own channels, including SpeakUp and the ESG incident

management system, but for the time being, it does not collect data from upstream value

chain actors. Outokumpu has not yet comprehensively discussed with the value chain

workers about the effectiveness of the channels. (S2-3-27-(d))

As to how value chain workers are aware of and trust the structures and processes as a way

to raise their concerns or needs and have them addressed, Outokumpu does not currently

have an approach in place. The Supplier Code of Conduct states that Outokumpu does not

tolerate retaliation against any individual who reports a concern in good faith. The company

also highlights to its suppliers during assessments that no retaliation against interviewed

workers or communities will be tolerated. Outokumpu also has a Reporting Misconduct

Instruction, which includes a section on protection against retaliation. (S2-3-28)

Outokumpu advanced its approach to grievance mechanisms by publishing internal

guidance on identifying and providing effective channels for raising concerns in December

2025. Development work will continue in 2026 to ensure that channels to raise concerns

provided by Outokumpu offer meaningful opportunities for all stakeholders affected by

company’s operations, recognizing that the existing SpeakUp channel may not be the most

suitable alternative in all cases.(S2-3-29)

Actions

Key actions taken in the reporting year:

• Outokumpu set a corporate level target for supplier sustainability: 100% of spend with

high-impact suppliers will be covered by suppliers committed to Outokumpu’s Supplier

Code of Conduct by 2030.

• Outokumpu renewed and released a new version of Supplier Requirements in December

2025. The long-term goal is to have 100% of high-impact suppliers commit also to

Outokumpu’s Supplier Requirements.

• On-site assessments remained a key action for managing material human rights and

other sustainability impacts. In 2025, Outokumpu conducted one sustainability audit

(2024: 3) and five sustainability visits. These assessments aim to address human rights

and environmental impacts at the site, within the supplier’s operations and across their

supply chains, resulting in agreed actions to mitigate identified risks.

• Outokumpu analyzed the upstream value chain in selected additional sourcing

categories to deepen its understanding of impacts beyond direct suppliers. This effort


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helped to identify the most salient sustainability impacts in the value chain and address

improvement needs within these areas:

• Occupational health and safety

• Freedom of association and collective bargaining

• Adequate living income and wage

• Gender equality and equal pay

• Reasonable working hours

• Discrimination and harassment

• Migrant workers

• Adverse impacts on biodiversity including deforestation, impacts on water, air, and

soil, and its impacts on communities

• Heightened focus on grievance mechanisms and remedy: Outokumpu has developed

further its processes on grievance and remedy during 2025, covering its own workforce,

value chain workers and affected communities.

Key actions planned for coming years include:

• Develop grievance mechanisms and remedy: Outokumpu will continue developing its

grievance and remedy processes to get better visibility of potential and actual human

rights infringements and to proactively address, prevent and mitigate the negative

impacts related to Outokumpu’s own workforce, value chain workers and affected

communities.

• Improve value chain data quality and transparency: Outokumpu will initiate the process

of identifying and implementing a supplier data management solution to strengthen ESG

management and due diligence across the value chain. The objective is to select a

system that centralizes supplier and ESG data, enhances visibility and transparency

regarding working conditions, human rights practices, and environmental performance,

and streamlines data collection and reporting. The solution is expected to support more

effective identification, prevention, and mitigation of impacts, risks, and opportunities

(IROs) related to both social and environmental topics, strengthen supplier engagement

and collaboration, and improve traceability of sourcing practices and materials. In

addition, it will facilitate informed decision-making, continuous improvement, and

performance benchmarking in supplier sustainability management.

• Enrich environmental value chain data: Outokumpu plans to analyze the upstream value

chain in selected additional sourcing categories to deepen its understanding of

environmental impacts (e.g. biodiversity and water pollution risk indices). This effort

builds on previous value chain mapping. The expected outcome is to gain information to

help in understanding where the biggest risks lie, to address, prevent, and mitigate

these impacts more effectively. (S2-MDR-A-68-(a-c))

The operational expenditures and capital expenditures for the implementation of the

previously described action plan are part of Outokumpu’s business-as-usual expenditure.

(S2-MDR-A-69)

Preventing, mitigating or remediating material negative impacts

To prevent, mitigate and remedy material negative impacts on value chain workers,

Outokumpu applies the due diligence approach. The process is described in the section

“General approach to respecting human rights of value chain workers”. (S2-4-32-(a))

In 2025, Outokumpu has not identified any incidents in the supply chain where it would

have caused or contributed to an actual impact. There has been no action to provide or

enable remedy in relation to impacts that were identified on a general level in the double

materiality assessment. (S2-MDR-A-68-(d-e)), (S2-4-32-(b))

During 2025, Outokumpu continued capacity building on sustainability topics and the

supplier sustainability team has attended advanced training courses on biodiversity and

environmental impacts. The team has been engaged in supporting the human rights of

value chain workers, through sustainability-focused meetings and speaking at trade shows

and seminars. Regular internal training in various topical subjects has been given to

category managers and buyers, such as on the Supplier Code of Conduct, the onboarding

process, conflict minerals, emission data collection, supplier performance evaluation, and

the audit process. (S2-4-32-(c))

In cases in which Outokumpu has audited or assessed suppliers and aligned the next steps

with them, the company stays in close contact with them in order to follow up on the status

of the improvement actions. (S2-4-32-(d))

Identification process and approach to taking action

Outokumpu applies an impact and risk-based approach in its supplier management stages.

Upstream value chain and country-level risk assessments are key tools for supplier and

supply chain risk mapping. To address especially the material negative impacts on workers

in its value chain, Outokumpu requires its suppliers to adhere to international labor and

human rights standards through its Supplier Code of Conduct and Supplier Requirements.

To further evaluate, prevent and mitigate the impacts, these topics are also covered as part

of the sustainability audits and human rights impact assessments Outokumpu conducts in

its supply chain. In the case of observed deficiencies, improvement actions are required

from the supplier. The supplier due diligence process is disclosed in more detail in “General

approach to respecting human rights of value chain workers”.

In addition, the ESG incident management process is used to identify needed actions. Any

incidents in the upstream value chain are defined, identified, managed, and documented by

the Procurement organization. The process includes desktop research, potential purchasing

stops and decisions about on-site assessments or a human rights risk assessment. The

process also includes defining Outokumpu’s attribution to the identified impacts and

improvement actions, internal and external stakeholder information, and documentation of

the case. More information on audits and assessments as well as incidents, can be found

above in this Actions section. (S2-4-33-(a)), (S2-4-33-(b))


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In December 2025, Outokumpu published internal guidance on enabling and providing

remedy. The approach will be further developed in 2026 to establish detailed processes for

remedial actions in different situations. Until then, suspected incidents are addressed case

by case in line with the published internal guideline. More information about Outokumpu’s

remedy process development can be found in the Own workforce (s1) chapter, in the

Processes section under “Remedy”. (S2-4-33-(c))

Addressing material risks, opportunities and negative impacts

The work on monitoring supply chain sustainability and impacts on value chain workers is

continuous, for example, through regular desktop reviews and sustainability audits. In

addition to identified material risks, Outokumpu anticipates the continuous evolution of

regulations related to supply chain transparency, ethical sourcing, and environmental

impact. Outokumpu’s plan involves staying informed of these changes and proactively

adapting its practices to align with emerging legislation. (S2-4-34-(a))

Outokumpu continues to foster material opportunities for value chain workers by promoting

high social standards across its supply chain. This approach strengthens the resilience of

its supply chain, enabling greater stability and long term success.

In December 2025, Outokumpu published its updated Supplier Requirements. Also the

Supplier Code of Conduct was revised to incorporate clearer sustainability standards and

due diligence requirements. By encouraging suppliers to adopt these standards,

Outokumpu aims to drive improvements in working conditions and ethical practices across

the value chain. This approach puts positive pressure on suppliers to integrate

sustainability into their core operations.

As sustainability is a core value for Outokumpu, human rights are not compromised, and

the company strives to avoid any negative impacts concerning its own operations and value

chain through execution of its’ Supplier Due Diligence process. (S2-4-35) There were no

severe cases reported for workers in the value chain in 2025. (S2-4-36)

In 2025 Outokumpu’s supplier sustainability management team consisted of three full-time

employees dedicated to upstream value chain sustainability impact and risk identification

and management. Outokumpu has included financial planning for supplier sustainability as

part of its procurement financial planning. (S2-4-38)

Targets

In 2025, Outokumpu set a target to have 100 % share of spend with high-impact suppliers

that have signed the Supplier Code of Conduct by the end of 2030. Outokumpu’s Supplier

Code of Conduct defines the standards and expectations set for suppliers to ensure ethical,

sustainable and responsible practices throughout the value chain. Compliance with the

Supplier Code of Conduct is a minimum requirement for engaging in business with

Outokumpu. By obtaining signed confirmations from high-impact suppliers, Outokumpu

aims to ensure that they commit to and implement principles aligned with the Outokumpu’s

policies in their own operations and reduce negative impacts, advance positive impacts and

decrease risk related to value chain workers.

The measurable target is that by the end of 2030, all spend (100%) will be on high-impact

suppliers that have confirmed with a signature their compliance with the Outokumpu

Supplier Code of Conduct or after the assessment of the supplier’s own policies and

principles, Outokumpu may agree that compliance with their own code of conduct is

sufficient for the purpose of complying with the Outokumpu Supplier Code of Conduct.

Progress toward this target is tracked through monthly monitoring of the spend share of

suppliers that have confirmed the Supplier Code of Conduct. Outokumpu defines

high‑impact suppliers as those that provide the raw materials used in its products. These

suppliers represent the largest share of total purchasing and strongly affect environmental,

social and business impacts. An external third party has not validated the KPI.

The first Outokumpu Supplier Code of Conduct was released in 2022, followed by its

introduction to suppliers and the initiation of monitoring of confirmation progress. The

baseline year is 2022, when the confirmation rate was at zero percent as the process was

newly launched. An operative target of 70% was set in 2023, and the official target of

100% by 2030 was approved in 2025 by the ESG Steering Group.

Outokumpu is committed to conducting business with high integrity and ensuring that all

suppliers globally are aware of the company’s key ethical principles regarding respect for

human rights and environmental protection. The target and related practices are aligned

with the OECD Guidelines for Multinational Enterprises and the UN Global Compact

principles. Outokumpu’s Supplier Sustainability team, together with the Raw Material

Procurement team, facilitates the implementation of the Supplier Code of Conduct and

manages supplier communication.

By 2025, 92% of spend with high-impact suppliers was with suppliers that had signed the

Supplier Code of Conduct. Signature rates are monitored by the Supplier Sustainability

team, and the signature requirement is integrated into the onboarding process for all new

suppliers. For existing suppliers who have not yet signed, the topic remains an active part

of negotiations during contract renewals. Suppliers who refuse to commit to the Supplier

Code of Conduct may face termination of their business relationship with Outokumpu.(S2-

MDR-T-80-(a-j)), (S2-MDR-M-77(a)), (S2-5-39)


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S3 – Affected communities

Through its complex supply chains, Outokumpu

impacts people locally, nationally and globally.

The company is committed to respecting the

human rights of all communities impacted by

its operations or business relationships.

KEY ACTIONS IN 2025

Continued implementation of

sustainability due diligence for

own operations and value chain

Developing group-wide

approach on grievance

mechanisms, remedy,

stakeholder engagement and

affected communities

Introducing program on closed

mines with focus on dialogue

with affected communities

Sustained commitment to

international standards and

frameworks safeguarding the

rights of affected communities,

such as the UNGPs,

ResponsibleSteel and Towards

Sustainable Mining Finland.

PLAN FOR 2026

Systematic identification of

affected communities and

related salient impacts, risks

and opportunities with special

focus on vulnerable groups.

Further development of

engagement methods,

grievance mechanisms and

remedy process and approach

on affected communities.

Defining actions and targets

for continued sustainability

due diligence monitoring and

implementation.

Material impacts, risks and opportunities


Communities’ economic, social and cultural rights

Positive impact	Actual	Community development around own sites based on taxes paid, other funding and support initiatives (incl. sponsorships, school collaboration)


Land related impacts

Negative impact	Potential	Environmental degradation (water, air, soil, deforestation) of communities in supply chain
Negative impact	Potential	Environmental degradation (water, air, soil, deforestation) around own sites


Rights of indigenous people

Negative impact	Potential	Violation of rights of indigenous people in the supply chain including land, forests and waters

(S3-ESRS2-SBM-3-48-(a))

Outokumpu’s impacts on affected communities primarily stem from the nature of its core

operations, stainless steel production and mining. These activities require skilled workforce

and are highly regulated, permit-dependent, and reliant on global supply chains for

production inputs.

Prior to focussing on stainless steel, Outokumpu operated across multiple sectors,

including mining. As a result, the company has historical ties to various mining sites.

Outokumpu continues to monitor these closed mining areas, including those with ongoing

or concluded obligations. In 2025, Outokumpu launched a closed mines program, aimed at

long-term rehabilitation and reducing environmental impacts through research-driven

restoration efforts. The program also emphasizes transparency and enhanced stakeholder

engagement, particularly with affected communities residing near former mining sites, as

well as other relevant stakeholders.

Outokumpu’s operations are long-established and tied to specific geographic locations.

These activities generate positive impacts on affected communities by supporting local

economic and social wellbeing through employment, tax contributions, sponsorships, and

donations, among others. These contributions not only enhance the resilience of local

communities but also support Outokumpu’s business continuity by strengthening its social

license to operate and securing access to skilled labor. Outokumpu’s operations may result


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in negative impacts on the local natural and living environment. These include production-

related emissions and other environmental pressures leading to environmental degradation

that may affect water, air, and soil quality in the areas surrounding Outokumpu’s

operational sites.

The availability of Outokumpu’s raw materials is geographically determined, leading to

sourcing from regions where human rights risks have been identified. These risks affect not

only workers across the value chain but also local communities. Negative impacts may

arise in situations where human rights are not respected or environmental harm occurs,

with particular concern for the rights of indigenous peoples, including their access to land,

forests, and water. (S3-ESRS2-SBM-3-8-(a)-(i))

Affected communities – both those near Outokumpu’s own operations and those connected

to upstream value chain activities – play a vital role in supporting business continuity.

Collaboration with local communities around the company’s own operations helps to secure

the legal and social license to operate, ensure access to skilled labor, and foster long-term

stability. In value chain upstream sourcing regions, human rights conditions and the state

of the local ecological environment directly influence supply chain reliability and raw

material availability. Ensuring resilience in the supply of key raw materials, particularly from

high-risk countries and societies, is a consideration that informs Outokumpu’s business

model. Consequently, the characteristics and conditions of affected communities

contribute to Outokumpu’s strategy and business model by helping to mitigate the related

risks and identify opportunities. (S3-ESRS2-SBM-3-8-(a)-(ii))

In 2025, Outokumpu started to define a process to consider the various affected

communities that can be materially impacted by its own operations or in its value chain. An

internal guideline on stakeholder engagement in general with special focus on affected

communities was published in December to support this work. Further process development

is based on this guideline, coordinated by Outokumpu’s Sustainability Due Diligence

Working Group. The interaction between affected communities and Outokumpu’s strategy

and business model will be further examined as part of this process in 2026. More

information can be found in the General disclosures chapter of this Sustainability

statement. (S3-ESRS2-SBM-3-8-(b)), (S3-ESRS2-SBM-3-9)

Types of affected communities

In 2025, Outokumpu started to develop a systematic approach to identify the main types of

communities that are or might potentially be affected by its operations directly or indirectly.

On a general level, these communities can be categorized accordingly: (S3-ESRS2-SBM-3-9-(a))

• communities around Outokumpu's own operating sites and/or more remote communities

affected by these activities,

• communities along Outokumpu’s upstream value chain related to metals and minerals

extraction, mining and processing activities, and

• communities along Outokumpu’s downstream value chain.

These affected communities include also indigenous peoples and other especially

vulnerable groups. (S3-ESRS2-SBM-3-9-(a)-(i-iv))

Identifying material impacts, risks and opportunities

Outokumpu’s material negative impacts on the environment and human rights may affect

communities around its own operations or along the value chain. In 2025, Outokumpu

continued to develop its sustainability due diligence process with a focus on the potential

and actual adverse impacts that were revised in 2024. Initiating a structured mapping of

these impacts, based on how widespread, systemic or case-specific they are, will follow in

2026. Respectively, Outokumpu will initiate categorizing these material negative impacts

on various affected communities and, when possible, evaluate their occurrence. (S3-ESRS2-

SBM-3-9-(b))

In Outokumpu’s own operations, positive impacts on affected communities are primarily

linked to contributions that support local economic and social development, such as tax

payments, sponsorships for targeted initiatives and collaboration with educational

institutions. In the upstream value chain, positive impacts and opportunities are more

indirect and linked to advancing sustainability due diligence among suppliers with focus on

value chain workers (see the chapter S2). However, a systematic approach to initiating and

evaluating these activities regarding all or specific affected communities is yet to be

developed.

Outokumpu distinguishes between two types of affected communities:

• Local communities directly impacted by Outokumpu’s operational sites, typically located

in regions with well-established regulatory frameworks for environmental and human

rights protection.

• Upstream value chain communities indirectly affected through raw material sourcing,

often situated in high-risk countries with less-developed regulatory environments.

The nature of impacts, risks, and opportunities varies significantly between these two

groups, largely due to differences in societal structures and governance. Accordingly,

Outokumpu’s ability to exert influence is typically greater in the communities surrounding

its own operations, while leverage in upstream supply chains is more limited due to their

complexity and geographic dispersion. (S3-ESRS2-SBM-3-9-(c))

In 2025, Outokumpu started to define an approach to evaluate the material risks and

opportunities that arise from the impacts and dependencies on its affected communities.

This work is based on the internal guideline on stakeholder engagement that was published

in December 2025 and initial identification of various affected communities and will

continue in 2026 as part of Outokumpu’s sustainability due diligence process, covering

both its own operations and the upstream value chain. Through this process, Outokumpu

will also evaluate the need to introduce and maintain social dialogue with affected

communities to support these efforts. (S3-ESRS2-SBM-3-9-(d))


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Actions for 2026 include also examining suitable ways to define and identify affected

communities with particular characteristics, living in particular contexts or undertaking

particular activities with a related greater risk of harm. Besides these specific groups

among the affected communities, the related impacts will also be evaluated from 2026

onwards. This work is essential part of the ongoing development of Outokumpu’s

sustainability due diligence process. (S3-ESRS2-SBM-3-11), (S3-ESRS2-SBM-3-10)

Policies

Outokumpu’s work on human rights due diligence, including engagement with affected

communities, is based on the company’s Human Rights Policy. Other supporting policies

include the Sustainability Policy, described in the Climate change chapter (E1), the Code of

Conduct, described in the Governance chapter (G1), and the Supplier Code of Conduct with

the related Supplier Requirements, described in the Workers in the value chain chapter

(S2).

In 2025, Outokumpu continued to develop its group-wide due diligence process on human

rights and environment. The scope covers both its own operations and the value chain and

is based on Outokumpu’s previous work on risk-based sustainability due diligence according

to UN Guiding Principles.

Outokumpu’s Human Rights Policy was reviewed in December 2025 to better address

material impacts, risks and opportunities related to affected communities, including

specific affected communities. Additional internal guideline on stakeholder engagement

was published in December 2025 to support the identification of and acting on targeted at

various communities affected directly or indirectly by Outokumpu’s operations. (S3-1-14).

The updated Human Rights Policy defines the company’s commitment to respect all

internationally recognized human rights and provides a framework for embedding this

commitment across its operations and value chain. Additionally, it explains Outokumpu’s

most salient human rights and the related principles to address them. The Policy aligned

with international frameworks, including the UN Guiding Principles on Business and Human

Rights, the OECD Guidelines for Multinational Enterprises, and the Ten Principles of the UN

Global Compact. Outokumpu adheres also to relevant internationally recognized

conventions, such as the UN Universal Declaration of Human Rights, the International

Covenant on Civil and Political Rights, the International Covenant on Economic, Social and

Cultural Rights and the ILO Declaration on Fundamental Principles and Rights at Work. (S3-

MDR-P-65-(a))

Scope and accountability

The Human Rights Policy must be followed globally by all Outokumpu businesses,

companies, directors, officers, and employees. The CEO has the most senior level of

oversight and accountability for human rights at Outokumpu. Responsibilities cascade down

via the Executive Vice President – Strategy, Sustainability and People, who represents

sustainability in Outokumpu’s Leadership Team, to the Vice President – Sustainability, who

is responsible for the overall sustainability agenda at Outokumpu, and further to the Head

of Human Rights in the Group sustainability team. The Human Rights Policy is approved

and signed by the Executive Vice President – Strategy, Sustainability and People. (S3-MDR-

P-65-(b-c))

Third-party standards

Through the Human Rights Policy, Outokumpu respects and takes into account the following

third-party standards and initiatives to evaluate and manage risks and impacts: Universal

Declaration of Human Rights, the International Covenant on Civil and Political Rights, the

International Covenant on Economic, Social and Cultural Rights, the European Convention

on Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the

UN Guiding Principles on Business and Human Rights, the OECD Guidelines for

Multinational Enterprises, and the Ten Principles of the UN Global Compact. The Human

Rights Policy also supports the achievement of the UN Sustainable Development Goals and

covers relevant UN frameworks protecting vulnerable groups such as women, children,

migrant workers and indigenous peoples.

Additionally, Outokumpu's manufacturing operations in Europe are certified according to

the ResponsibleSteel standard and mining operations in Kemi, Finland, according to the

Towards Sustainable Mining Finland scheme. Both standards have solid requirements on

stakeholder engagement and local community engagement. (S3-MDR-P-65-(d))

Stakeholders and availability

Through local community engagement, Outokumpu aims to maintain open, constructive

relationships with its affected stakeholders and contribute positively to the well‑being and

resilience of the communities in which it operates. Outokumpu collects views from its

stakeholders through various channels, ranging from day-to-day interaction to targeted

feedback processes. Depending on the topic, these views have varying degrees of influence

on how the company sets its policies. More information on the engagement topics in

section General Disclosures (Stakeholder Views and interests, SBM-2). (S3-MDR-P-65-(e))

In 2025, Outokumpu started to elaborate on a more structured group-wide approach on

stakeholder engagement as part of the sustainability due diligence process development.

An internal guideline was published in December 2025 to support this work with specific

focus on affected communities. More information on the work on stakeholder engagement

at Outokumpu can be found in the General information chapter in this Sustainability

statement. (S3-MDR-P-65-(e))

Outokumpu’s Human Rights Policy and supporting policy documentation – the Code of

Conduct, Sustainability Policy and Supplier Code of Conduct – are publicly available on the

company’s website and also communicated to the company’s external stakeholders on


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different occasions. They are also available internally to all Outokumpu employees.

(S3-MDR-P-65-(f))

Policy provisions and indigenous peoples

Preventing and addressing impacts on indigenous peoples is based on Outokumpu’s Human

Rights Policy, Sustainability Policy, Code of Conduct and Supplier Code of Conduct, with

related Supplier Requirements.

Outokumpu’s Human Rights Policy, that was updated in December 2025, defines the

company’s commitment to respect all internationally recognized human rights and embeds

these principles across Outokumpu’s own operations and its value chain. In line with this

commitment, Outokumpu expects all business partners, suppliers, sub-suppliers, and

customers to uphold the rights of indigenous peoples as outlined in the Indigenous and

Tribal Peoples Convention, 1989 (No. 169) and the UN Declaration on the Rights of

Indigenous Peoples. These rights include, but are not limited to, the right to land and the

right to free, prior, and informed consent (FPIC) when exploration or resource use on

indigenous lands is considered or undertaken.

These provisions are also reflected in Outokumpu’s Sustainability Policy. Respecting and

promoting indigenous people’s rights is also mentioned in the company’s Supplier Code of

Conduct. To strengthen engagement with affected communities, Outokumpu published an

internal guideline on stakeholder engagement in December 2025, with a specific focus on

vulnerable and indigenous groups. This guideline aligns with UN Guiding Principles and

OECD Guidelines and sets principles for meaningful, rights-respecting engagement. It

emphasizes early and continuous dialogue, cultural sensitivity, and safeguards such as non-

retaliation and informed consent. The guideline forms the basis for further process

development coordinated by Outokumpu’s Sustainability Due Diligence Working Group.

(S3-1-15)

Outokumpu’s Human Rights Policy commitments relevant to affected communities are

listed in the Human Rights Policy section above in this chapter. (S3-1-16)

General approach to respecting human rights of communities and

indigenous people specifically

Outokumpu’s general approach in relation to respect for human rights of communities, and

indigenous peoples specifically, are based on Outokumpu’s Human Rights Policy

commitments relevant to affected communities, and the international human rights

commitments listed above. Outokumpu is also committed, and also expects all its business

partners, suppliers, sub-suppliers, and customers, to protect the rights of indigenous

peoples as laid out in the policy provisions listed above. (S3-1-16-(a))

Outokumpu’s general approach in relation to engagement with affected communities is

based on its Human Rights Policy, Sustainability Policy, Code of Conduct and Supplier Code

of Conduct with related Supplier Requirements. In December 2025, Outokumpu introduced

a group-wide guideline for engaging stakeholders and affected communities to strengthen

its sustainability due diligence process. This guideline establishes a structured approach

aligned with the UN Guiding Principles on Business and Human Rights (UNGPs) and OECD

Guidelines for Multinational Enterprises. It applies globally across Outokumpu’s operations

and value chain. The approach emphasizes the following aspects:

• Meaningful Engagement: Two-way, good-faith dialogue that is inclusive, culturally

appropriate, and timely, ensuring that stakeholder input influences decisions.

• Special Focus on Vulnerable Groups and Indigenous Peoples: Engagement processes

respect self-determination and traditional decision-making systems. Where applicable,

Outokumpu seeks Free, Prior, and Informed Consent (FPIC) before activities that may

affect indigenous lands, resources, or cultural heritage.

• Safeguards and Principles: Non-retaliation, privacy, informed consent, and security

protocols to ensure safe participation.

• Integration into Sustainability Due Diligence: Stakeholder engagement is embedded in

impact identification, risk management, grievance mechanisms, and remediation

processes.

• Continuous Improvement: The guideline forms the basis for further process development

coordinated by the Sustainability Due Diligence Working Group, ensuring alignment with

international standards and regulatory requirements.

This structured approach supports Outokumpu’s commitment to respecting human rights,

minimizing adverse impacts on communities, and promoting positive societal outcomes

across its operations and value chain. The approach will be further elaborated in 2026.

(S3-1-16-(b))

With regard to a general approach to providing and/or enabling a remedy for human rights

impacts, more information is in the Own workforce (S1) chapter of this Sustainability

statement. (S3-1-16-(c))

Tracking and monitoring cases of non-respect

For 2025, there has been no reported cases of non-respect of UNGPs, the ILO Declaration

on Fundamental Principles and Rights at Work or OECD Guidelines involving affected

communities based on Outokumpu’s internal and external data sources. Outokumpu

understands the meaning of “a case of non-respect” as a situation in which a severe

human rights impact, such as a fatality, has happened despite the human rights due

diligence process and/or other measures based on the aforementioned frameworks.

Outokumpu will start to develop a more systematic process to track and monitor the cases

of non-respect of these guidelines in its own operations or in its value chain in 2026,


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including affected communities. More information on tracking severe human rights

incidents can be found in disclosures regarding the company’s own workforce (S1) chapter

of this Sustainability statement. (S3-1-17)

Policy documentation, cross-reference and updates

Outokumpu’s Human Rights Policy was revised in December 2025 to correspond the

updated salient human rights impacts related to own operations and value chain upstream

and to address affected communities in a more explicit manner. Alongside the Policy

update, an internal guideline on stakeholder engagement was released in December 2025

to support the implementation of Outokumpu’s sustainability due diligence process, with a

particular focus on the communities affected by company’s operations. Other relevant

policies related to managing Outokumpu’s material impacts on affected communities or the

associated material risks and opportunities are the Sustainability Policy, Code of Conduct

and Supplier Code of Conduct. No significant changes to these were adopted in 2025.

(S3-1-AR-9)

Engagement

In 2025, Outokumpu initiated the development of a group-wide approach on engaging with

affected communities. The approach is documented in an internal guideline on stakeholder

engagement that was published in December 2025. The guideline contributes to identifying

and managing Outokumpu’s impacts on the communities around its own operations and

along the upstream value chain. The related approach will be developed further in 2026 as

part of Outokumpu’s sustainability due diligence process. Due to Outokumpu’s long-

established local operations, the company is already accustomed to interacting with the

surrounding communities close to its production sites. More information on how

Outokumpu engages with its stakeholders can be found in the General disclosures chapter.

(S3-2-24)

Remediation

More information about Outokumpu’s general approach to and processes for providing or

enabling remedy when the company has identified that it is connected with a material

negative impact on affected communities is in the Own work force (S1) chapter. (S3-3-27-(a))

Additional information about specific channels to raise concerns is also in the Own

workforce (S1) chapter. In addition, in relation to affected communities, Outokumpu’s local

operations and Group functions can be directly contacted via email or phone. (S3-3-27-(b))

More information on the processes by which Outokumpu supports the availability of

channels to raise concerns related to its own operations and value chain, can be found in

the Own workforce (S1) chapter. Outokumpu will assess the need to establish mechanisms

that encourage or support the availability of such channels through its business

relationships. This will be done in 2026 as part of the sustainability due diligence process

implementation. (S3-3-AR-19), (S3-3-27-(c))

More information on how issues raised and addressed are tracked and monitored and how

the effectiveness of these channels is ensured is in the Own workforce (S1) chapter.

(S3-3-27-(d))

Awareness and trust in the remedy structures

Outokumpu has a policy to protect those individuals who raise concerns using the available

channels in good faith against retaliation. More information can be found in the

Governance chapter. In 2025, Outokumpu continued to implement its sustainability due

diligence process, including aspects on affected communities. This work will continue in

2026, including assessing the need for additional methods to evaluate how the affected

communities are aware of and trust the existing structures and processes as a way to raise

their concerns or needs and have them addressed.

In 2025, awareness of Outokumpu’s SpeakUp channel as a way to raise concerns was

evaluated during the ResponsibleSteel surveillance audits of its European operations. This

was done as sample interviews with local community representatives. The findings

indicated that the channel is not yet fully known among these stakeholders. Hence, in

2026, Outokumpu will continue to identify ways to increase affected communities’

awareness of and trust in structures and processes as a way to raise their concerns or

needs. (S3-3-28)

Third-party mechanisms

The need to introduce third-party grievance mechanisms to ensure proper access globally to

the communities affected by Outokumpu’s own operations and value chain will be reviewed

at earliest in 2026 as the sustainability due diligence process provides more in-depth and

systematic knowledge of various affected communities. (S3-3-AR-20)

Actions

Outokumpu does not currently have any systematic actions in place to address material

impacts on affected communities. An approach to support the identification and

implementation of these actions will be defined in 2026 and onwards as the sustainability

due diligence process at Outokumpu covering its own operations and value chain is further

developed. However, the sustainability audits and human rights impact assessments

conducted as part of Outokumpu’s supplier due diligence process already now consider

also local communities. More on this approach is in the S2 on Value chain workers chapter

of this Sustainability statement. Additionally, the actions described in this Sustainability

Statement to prevent and reduce environmental degradation caused by Outokumpu’s own

operations contribute to minimizing impacts on affected communities. More on these

actions in in the section on Environmental information. (S3-MDR-A-62)


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Incidents and issues

In 2025, no severe human rights issues or incidents were reported connected to affected

communities related to Outokumpu’s own operations or value chain. Outokumpu started to

develop a group-level approach to systematically identify severe human rights issues and

incidents connected to the aforementioned communities during 2025. The categorization

of these incidents was introduced to SpeakUp channel investigations and a more

systematic approach to gather data from internal and external sources will be developed

further in 2026. Currently, if such cases emerge, they are investigated on a case-by-case

basis. Outokumpu defines a severe human rights issue to mean, for example, loss of life,

detention, human trafficking, forced labor, and/or child labor. (S3-4-36)

Resource allocation

The global Head of Human Rights at the Group Sustainability function leads Outokumpu’s

group-level work on human rights and sustainability due diligence and the Supplier

Sustainability function is responsible for these topics in the upstream raw material value

chain. In 2025, the Head of Human Rights in the Group Sustainability team and the

Supplier Sustainability team continued implementing Outokumpu’s work on human rights

due diligence based on the UN Guiding Principles, covering Outokumpu’s own operations

and value chain. Besides using its own resources, the company also uses external experts

to assess and support sustainability due diligence process development when needed. No

specific allocated financial resources for mitigating the related material impacts exist as

this is included in the Group functions financial planning regarding Outokumpu’s

sustainability due diligence implementation. (S3-4-38)

The operational expenditure and capital expenditure for the implementation of the

described actions related to affected communities are part of Outokumpu’s business-as-

usual expenditure. (S3-MDR-A-69)

Targets

In 2025, Outokumpu continued developing its sustainability due diligence process covering

own operations and value chain. Outokumpu’s impacts on various affected communities as

well as related actions to prevent, mitigate and bring these impacts to an end were

included in this process. During 2025, a general approach regarding affected communities

was developed which forms the basis for continued work in 2026. Therefore, no group-wide

targets have yet been defined for this purpose but the need to set such targets will be

evaluated in 2026. (S3-ESRS2-72) (S3-MDR-T-81-(a))

Similarly, elaborating on practices and processes to track the effectiveness of policies and

actions related to the identified impacts will also be part of this development work for

2026. Additionally, the need to define an approach to evaluate actions and policies

regarding risks and opportunities will be considered. Based on the increasing knowledge of

its impacts related to affected communities, Outokumpu will assess the need to establish

selected qualitative and/or quantitative indicators for monitoring purposes. (S3-MDR-T-81-(b))

Outokumpu has already now certain practices in place to track the effectiveness of its

policies and actions related to the impacts, risks and opportunities concerning affected

communities. For example, Outokumpu is committed to global initiatives such as the UN

Global Compact and the UN Guiding Principles on Business and Human Rights. Together

with the UN Sustainable Development Goals, these provide a general framework for setting

targets and defining the company’s actions toward the various affected communities.

Outokumpu’s European operations are ResponsibleSteel certified, and the mining

operations in Finland follow the Towards Sustainable Mining Finland standard. In addition,

environmental and social aspects related to affected communities are included in various

internal audit and evaluation schemes as well as in the supply chain due diligence process.

The need to integrate these aspects further in the existing internal management tools to

support sustainability due diligence purposes will be considered in 2026. (S3-MDR-T-81-(b)-(i))


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Governance information

Outokumpu’s governance work enhances

business conduct policies and corporate culture

as well as promotes sustainable practices

throughout the supply chain. Outokumpu is

committed to conducting business with high

integrity. This means conducting business in an

ethical and responsible way. Outokumpu

believes that every employee has a role to play

in making ethical choices that help to build a

world that lasts forever.


G1 Business conduct	117


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Outokumpu is committed to conducting

business with high integrity. The company’s

Code of Conduct provides the principles and

rules that all employees need to follow and

commit to in their daily work. It guides

employees by setting examples and giving

practical advice so that everyone is able to

make the right choices and conduct business in

an ethical and responsible manner.

TARGETS

Targeted completion rate of

the Code of Conduct e-

learning by administrative

employees and managers of

operators

100%

PROGRESS

Achieved completion rate of

the Code of Conduct e-

learning by administrative

employees and managers of

operators

99%

G1 – Business conduct

Material impacts, risks and opportunities


Business conduct policies and corporate culture


Positive impact	Potential	Robust policies and related engaging training help employees to conduct business with high integrity.
Positive impact	Potential	Corporate culture anchored in transparency and ethical, responsible and sustainable business practices offers employees a safe place to work where raising concerns is also encouraged.
Negative impact	Potential	If Outokumpu fails to conduct business in an ethical and responsible manner and maintain a corporate culture where everyone has a role in doing the right thing, it can lead to non-compliant and unethical business practices.
Risk		Non-compliance with laws and regulations and the company’s business conduct policies as well as other unethical behavior, can weaken the operations and result in adverse legal, financial and reputational consequences.


Management of relationships with suppliers


Positive impact	Potential	By promoting social, environmental and ethical business practices for suppliers Outokumpu can potentially improve their sustainability performance and have a positive impact on these topics in the upstream value chain.

(G1-ESRS2-SBM-3-48-(a))

Business conduct policies and corporate culture

Outokumpu has formulated policies that address the identification and management of the

company’s material impacts, risks, and opportunities related to business conduct matters.

At Outokumpu, the most important business conduct policy is the group-wide Code of

Conduct which is the core element of Outokumpu’s group-wide Ethics and Compliance

(E&C) program. The aim of the Code of Conduct is to ensure that all Outokumpu employees

live up to Outokumpu’s ethics and compliance rules and act with high integrity.

Key contents of the policies

The Outokumpu Ethical Principles are part of the Code of Conduct and they are issued by

the Outokumpu Board of Directors. As per these principles, Outokumpu respects and

promotes human rights and conducts business in a safe, sustainable, ethical and compliant

manner. These key Ethical Principles guide how to act towards employees, customers, other

business partners and society at Outokumpu.


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The Outokumpu Code of Conduct has been structured based on the company’s Ways of

Working; we operate safely, always; we leverage the power of one Outokumpu; we deliver;

we value and grow people; we act sustainably; and we are a trusted partner. These Ways of

Working have united the company and created a common understanding of how Outokumpu

does business, treats people and works towards a world that lasts forever. As part of

Outokumpu’s new strategy, EVOLVE, the new Outokumpu Way was introduced in June 2025

replacing the previous Ways of Working. The Outokumpu Way is a set of guiding principles –

ABCs – Ambition beyond the obvious, Better together and Customer success – that help

Outokumpu deliver on the strategy in everyday decisions and actions. Revision of the

Outokumpu Code of Conduct was initiated in 2025 to reflect the new Outokumpu Way and

current practices at Outokumpu. The plan is that the renewed Code of Conduct will be

launched for all employees in 2026.

The Code of Conduct provides the key principles and rules that all employees need to follow

and commit to in their daily work. It guides employees by setting examples and giving

practical advice so that everyone is able to make the right choices in their everyday work.

The Code of Conduct contains information about the following key areas: health and safety,

working together as one Outokumpu, responsible purchasing, protecting assets, information

and personal data, safeguarding insider information, communicating with external

audiences, corporate governance, avoiding conflicts of interest, financial integrity,

preventing money laundering, respectful employment practices, working conditions and

rights of employees, sustainable operations and co-operation with communities, anti-

corruption including using agents, consultants and distributors as well as reasonable gifts,

hospitality and travel expenses, knowing our business partners, competition law

compliance, responsibility to comply with the Code of Conduct, co-operation in audits and

investigations, and raising concerns including information about Outokumpu’s SpeakUp

channel.

In addition to the Code of Conduct, there are other business conduct related policies and

instructions in place as part of Outokumpu’s operating principles framework, including

policies around the areas of health and safety, anti-corruption, know your business partner,

and data protection as well as competition law compliance. Furthermore, there are a

Supplier Code of Conduct and Supplier Requirements available for Outokumpu’s suppliers.

Policies and instructions, including the Code of Conduct, are implemented through training,

communications, and internal control activities. (G1-MDR-P-65-(a))

Scope and approval process

The Outokumpu Code of Conduct is applicable to all Outokumpu employees globally.

Outokumpu also expects all its business partners to follow similar ethical standards to

Outokumpu.

Outokumpu’s suppliers globally are expected to comply with the Outokumpu Supplier Code

of Conduct and Supplier Requirements. More information can be found in the Management

of relationships with suppliers (G1-2) and Workers in the value chain (S2) chapters. (G1-MDR-

P-65-(b))

The Outokumpu Board of Directors determines Outokumpu’s Ethical Principles, which are

part of the Outokumpu Code of Conduct. The Outokumpu Ways of Working and the

Outokumpu Way are determined by the CEO and the Outokumpu Leadership Team, and the

Outokumpu Human Resources function facilitates their implementation. The CEO of

Outokumpu approves and monitors the implementation of the Code of Conduct. (G1-MDR-

P-65-(c))

Third-party standards

As stated in the Code of Conduct, Outokumpu honors and is committed to the International

Bill of Human Rights, United Nations Global Compact, UN Guiding Principles on Business

and Human Rights, and ILO Declaration on Fundamental Principles and Rights at Work.

(G1-MDR-P-65-(d))

Availability and implementation

Outokumpu’s Legal and Compliance function drives the implementation and further

development of the group-wide E&C program. Implementing the Outokumpu Code of

Conduct is facilitated by the Group E&C team and the Code of Conduct and the related e-

learning have been drafted in co-operation with internal stakeholders. (G1-MDR-P-65-(e))

The Code of Conduct is available internally in eleven (11) languages. There is a dedicated

Code of Conduct page on the company’s intranet where the Code of Conduct and its

language versions can be found. There are also communication materials available related

to the Code of Conduct, such as posters that can be posted on the walls of Outokumpu’s

sites globally. The English version of the Code of Conduct can also be found on

Outokumpu’s external website.

Outokumpu expects its business partners to follow similar ethical standards to Outokumpu.

In addition, Outokumpu expects its suppliers globally to comply with the Supplier Code of

Conduct and Supplier Requirements. Furthermore, training can be organized for business

partners on key ethics and compliance topics, as needed.

(G1-MDR-P-65-(f))

Establishing, developing, promoting and

evaluating the corporate culture

Outokumpu is committed to fostering a corporate culture that is anchored in transparency,

integrity and ethical, responsible and sustainable business practices. Outokumpu wants to

act as a reliable and trusted partner towards all its stakeholders, including customers,

employees, investors and the communities in which Outokumpu operates. Outokumpu’s

corporate culture is established and developed through the vision, the Outokumpu Code of

Conduct and other policies and commitments that are implemented through training,


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communications and internal control activities. Outokumpu’s corporate culture is evaluated

regularly to ensure it aligns with the company’s commitment to conduct business with high

integrity, and that it fosters a safe and welcoming work culture.

Sustainability is an integral part of Outokumpu’s strategy, making it an important element

of Outokumpu’s corporate culture. At Outokumpu, ethical and compliant business practices

are at the heart of conducting a sustainable business where everyone can contribute by

making ethical and responsible choices as part of the daily activities at work.

Outokumpu has instituted robust business conduct policies that serve to guide the behavior

and operations of the company in an ethical and responsible manner. These policies are

embedded in the corporate culture, promoting responsible behavior at every level of the

organization.

Outokumpu is committed to complying with applicable laws and regulations, Ethical

Principles, the Outokumpu Code of Conduct and other company policies and instructions,

as well as the Ways of Working (applicable until June 2025) and the Outokumpu Way, which

form the basis of Outokumpu’s actions, operations and corporate culture. They unite the

company and create a common understanding and corporate culture on how the company

does business and treat its people and business partners including customers.

At Outokumpu, safety and security takes priority over all other activities. This affects

Outokumpu’s corporate culture and emphasizes the importance of health and safety as well

as security. Everyday actions at work are based on Outokumpu’s safety principles.

Outokumpu’s Cardinal Safety rules, which are the foundation for instructions and standard

operating procedures, ensure strict compliance with the safety principles. In addition, the

Outokumpu security rules protect the company’s assets, resources and operations by

creating a strong security culture. Furthermore, Outokumpu is committed to create a work

environment where everyone feels safe and welcomed, regardless of their background.

Additionally, the company fosters a collaborative working culture, embracing fairness and

belonging.

The business conduct policies are implemented through training, communications and

internal control activities. For Code of Conduct and related ethics and compliance matters,

the Group Ethics and Compliance team conducts e-learning modules and other engaging

training and communications to help employees do the right thing. The senior management

of Outokumpu also has an important role in setting the tone from the top down and

communicating the importance of ethical and compliant business practices. One example

of such communications is the monthly safety call led by the CEO. These calls regularly

promote one of the key elements of Outokumpu’s corporate culture: health and safety.

Outokumpu’s policies and practices are regularly reviewed and updated to ensure that they

also account for more recent developments in the business environment. Business conduct

topics and how employees perceive the various elements of the company’s actions,

operations and corporate culture are also regularly evaluated and measured through

various means, such as employee engagement surveys targeted at all employees. There

were two employee engagement surveys conducted in 2025. These surveys included

questions around the key themes of corporate culture – ethical behavior, well-being, health

and safety, fairness and belonging and raising concerns.

At Outokumpu, integrity is part of the annual performance management process,

highlighting the importance of complying with the Outokumpu Code of Conduct and other

policies. For administrative employees, there is a reminder and consequence management

process in place for the mandatory ethics and compliance e-learning modules. The process

underlines the importance of completing the trainings on time – everyone needs to do their

part in knowing the rules and doing the right thing.

Finally, Outokumpu is committed to fostering a corporate culture of speaking up. This

means that Outokumpu encourages all employees, business partners and other

stakeholders to raise concerns, if they suspect a violation of the Outokumpu Code of

Conduct or other misconduct. (G1-1-9)

Mechanism for reporting misconduct

Outokumpu aims to foster a transparent and open culture. The company encourages all

employees, business partners and other stakeholders to raise concerns, if they suspect a

violation of its Code of Conduct or other misconduct. Any activity that is against applicable

laws, regulations or Outokumpu’s policies, or any activity that can cause direct or indirect

financial or other damage to Outokumpu, its employees or other stakeholders, is

considered misconduct. Outokumpu employees are expected to protect Outokumpu’s

reputation, take action to prevent harm from occurring, and raise concerns if they suspect

misconduct. Furthermore, internal audits and assessments conducted by external,

independent parties aim and help to identify possible inappropriate conduct.

All available reporting channels are detailed in the Outokumpu Code of Conduct. Employees

shall report suspected misconduct to their immediate manager, manager’s manager or

other members of the company management. If this is not possible due to the

confidentiality or the nature of the matter, suspected misconduct shall be reported to

Outokumpu Internal Audit, Legal and Compliance or Human Resources. When other

channels do not feel comfortable, concerns shall be reported via the Outokumpu SpeakUp

channel. SpeakUp is a confidential communication channel hosted by a third-party service

provider, which enables employees and also external stakeholders to report alleged

misconduct confidentially and anonymously, if allowed by the local laws and regulations.

The SpeakUp channel is available in different languages. An updated version of the

SpeakUp channel was launched in 2025.

When concerns are reported, they will be treated with strict confidence, and assessed and

reviewed in accordance with the internal investigations procedure. The internal


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investigations procedure was led by the Group Internal Audit until October 2025 and

thereafter by the Group E&C team. (G1-1-10-(a))

Protecting whistleblowers

Outokumpu aims to foster a corporate culture that upholds the highest standards of ethics,

encourages the culture of speaking up and protects whistleblowers.

Outokumpu has an internal Group-level reporting channel called SpeakUp in place, where

concerns can be raised confidentially and anonymously, if allowed by the local laws and

regulations. SpeakUp is hosted by a third-party service provider. The channel can be used

internally, and it is also available for external parties. In certain countries within the

European Union (EU), Outokumpu has established a possibility to use a local SpeakUp

channel as required by the EU Whistleblower Protection Directive (EU) 2019/1937 and the

consequent local laws and regulations.

Outokumpu has a strict non-retaliation policy for reports made in good faith. This means

that the reporter shall not face negative consequences if they have reported the suspected

misconduct in good faith. Furthermore, if the misconduct report is within the scope of the

EU Whistleblower Protection Directive (EU) 2019/1937 and the consequent local laws and

regulations, the reporter receives protection based on these laws and regulations.

The Outokumpu Code of Conduct contains information about how to raise concerns at

Outokumpu. In addition, the internal Reporting Misconduct Instruction contains more

information about misconduct reporting and Outokumpu’s internal investigations procedure,

including information about the designated functions that receive the reports and

investigate the alleged misconduct, as needed. Furthermore, due to the EU Whistleblower

Protection Directive (EU) 2019/1937 and the consequent local laws and regulations, the

Reporting Misconduct Instruction can be supplemented with country-specific guidelines for

Outokumpu entities operating in certain EU countries.

Employees are informed and trained on the topic of misconduct reporting through e-

learning modules, such as the Code of Conduct e-learning applicable for all employees, as

well as other training. There is also specific training organized for the persons who receive

and handle misconduct reports, to ensure professional handling of the reported concerns.

In addition to the trainings, employees are informed about misconduct reporting through

communications, such as SpeakUp posters. There is also a separate misconduct reporting

page available on Outokumpu’s intranet. A link to the SpeakUp channel can be found on

the intranet as well as on Outokumpu’s external website. A link to the SpeakUp channel is

also included in the Outokumpu Supplier Code of Conduct, encouraging suppliers to report

suspected misconduct or unethical behavior related to their business relationship with

Outokumpu. (G1-1-10-(c))

Investigating incidents

Outokumpu has an internal investigations procedure in place to investigate business

conduct incidents, including incidents of corruption and bribery. The company is committed

to handling misconduct reports independently, objectively and as promptly as reasonably

possible.

Reports are assessed and reviewed in accordance with Outokumpu’s internal investigations

procedure, led by Group Internal Audit until October 2025 and thereafter by the Group E&C

team. In those countries where locally managed misconduct reporting procedures have

been implemented due to the EU Whistleblower Protection Directive (EU) 2019/1937 and

the consequent local laws and regulations, there are local employees appointed to manage

the assessment and review of the reported concerns locally in co-operation with the Group

Internal Audit and Group E&C team, if permitted by the local laws and regulations. As a

consequence of internal investigations, management can be given recommendations on

remedial actions, including corrective, preventative and disciplinary actions. The

Outokumpu E&C Steering Group, the Outokumpu Leadership Team and the Board of

Directors regularly receive updates on the reported concerns. (G1-1-10-(e))

Training on business conduct

The Group E&C team at Outokumpu conducts training and shares information on a regular

basis on various ethics and compliance topics, including the Code of Conduct, to help

ensure that Outokumpu’s employees globally know how to apply the policies and principles

on business conduct in their daily decision-making. At Outokumpu, training is given both

through mandatory e-learning modules and through face-to-face training, webinars and

discussions. A reminder and consequence management process is applied for the

mandatory ethics and compliance e-learning modules, as applicable, making sure that

employees complete the training on time.

In addition to the E&C training, there are other e-learning modules and training courses

available for employees in areas such as health and safety. (G1-1-10-(g))

Functions most at risk of corruption and bribery

Outokumpu has a strict zero tolerance policy for any form of corruption or bribery as stated

in the Outokumpu Code of Conduct. For this purpose, Outokumpu has a global anti-

corruption compliance program in place as part of the group-wide E&C program. The

purpose of the anti-corruption compliance program is to help to identify, assess and

mitigate risks related to corruption and bribery in the global environment where Outokumpu

operates. The program contains various elements to mitigate corruption and bribery risks,

such as a detailed internal guidance document, the Anti-Corruption Instruction, which

supplements the anti-corruption requirements as stated in Outokumpu’s Code of Conduct.

There are also other internal policies and know your business partner processes in place to


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mitigate corruption and bribery risks. Furthermore, the Outokumpu Supplier Code of

Conduct contains requirements for suppliers to comply with applicable anti-corruption rules.

Outokumpu employees are being trained on the anti-corruption topic through various

training courses, such as the Outokumpu Code of Conduct e-learning, which is applicable to

all Outokumpu employees. In addition, there is an anti-corruption e-learning in place for

administrative employees. Furthermore, there are other forms of anti-corruption- related

trainings and communications for employees.

At Outokumpu, certain functions are subject to elevated corruption and bribery risks as a

result of their tasks and responsibilities. Due to their role in financial transactions and

interactions with external stakeholders, the company has identified the sales and

procurement functions to be most at risk in respect of corruption and bribery. Outokumpu

will continue to implement and improve, where necessary, applicable anti-corruption

measures to mitigate any possible risks related to corruption and bribery. (G1-1-10-(h))

Key actions

The effective implementation and further development of Outokumpu’s group-wide E&C

Program continued in 2025.

The Outokumpu Code of Conduct is applicable to all Outokumpu employees globally. The

revision of the Code of Conduct was initiated in 2025 to reflect the new Outokumpu Way

and current practices at Outokumpu. The plan is to launch the renewed Code of Conduct

for all employees in 2026.

There is a Code of Conduct e-learning available for Outokumpu employees in order to

educate them about the key contents of the Code of Conduct and help them to make

ethical and responsible decisions as part of their responsibilities at work. As per the set

training schedule, the Code of Conduct e-learning was relaunched for administrative

employees and managers of operators in 2025. In addition, administrative employees

successfully completed other renewed E&C e-learning modules in the areas of anti-

corruption, competition law compliance, data protection and know your business partner.

The managers of operators also completed the data protection e-learning. There were

various awareness sessions conducted to support employees with the training efforts.

Furthermore, targeted E&C training modules were created and launched for managers by

the Group E&C team.

In addition to the various training activities, the Group E&C team continued risk mitigation

measures by conducting assessments and improving processes, documentation and

systems in key E&C areas including misconduct reporting where the updated Outokumpu

SpeakUp channel was implemented and launched in co-operation with Group Internal Audit.

Furthermore, since October 2025 Group E&C team has led the internal investigations

procedure. (G1-MDR-A-68-(a))

The operational expenditure and capital expenditure for the implementation of the

previously described action plan are part of Outokumpu’s business-as-usual expenditure.

(G1-MDR-A-69)

Scope and time horizon

Code of Conduct and related e-learning

The Code of Conduct is applicable to all Outokumpu employees.The revision of the Code of

Conduct was initiated in 2025 to reflect the new Outokumpu Way and current practices at

Outokumpu. The plan is to launch the updated Code of Conduct for all employees in 2026.

The Code of Conduct e-learning is an annual mandatory training for all administrative

employees and managers of operators. These employees completed the training in 2025.

The operators take the training every other year, or more often if there are material

changes to the Code of Conduct or the e-learning. The training is available in several

languages so that everyone can complete the training in their own language.

Other E&C training

In addition to the Code of Conduct e-learning, there are other mandatory ethics and

compliance e-learning modules in place in the areas of anti-corruption, competition law

compliance, data protection and know your business partner. These training modules are

targeted at administrative employees globally. Managers of operators globally complete the

data protection training. The training modules are available in several languages. These

training modules were fully renewed and launched at the end of 2024. All of these modules

were successfully completed by the said target group of employees in 2025.

In addition to e-learning, the Group E&C team actively conducted face-to-face and webinar

training sessions to the administrative employees on ethics and compliance topics during

2025. In addition, specific training materials were created and training sessions conducted

for various managers. It is the managers responsibility at Outokumpu to lead by example

and support their teams in complying with the Code of Conduct and other company

policies.

Other measures

The Group Ethics and Compliance team continued to implement various measures in the

areas of anti-corruption, competition law compliance, data protection, know your business

partner and misconduct reporting, for example through assessments, and improved

systems as well as internal processes and documentation. The purpose of these measures

was to further mitigate risks and improve the various elements of Outokumpu’s group-wide

E&C program. (G1-MDR-A-68-(b-c))

Prior progress

The Code of Conduct e-learning has been a mandatory training for Outokumpu employees

also earlier. In 2024, 97% of all employees completed the new Code of Conduct e-learning.


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Other ethics and compliance e-learning modules in the areas of anti-corruption, competition

law compliance, data protection and know your business partner have been mandatory for

administrative employees and managers of operators also in the previous years as per the

determined training schedule. The Group E&C team has also consistently conducted other

ethics and compliance training as well as gradually implemented various risk mitigation

measures and developed Outokumpu’s group-wide E&C Program. (G1-MDR-A-68-(e))

Metrics and targets

Tracking performance and effectiveness

Outokumpu uses the training completion status of the Code of Conduct e-learning as a

metric to evaluate the effectiveness of the implementation of the training. (G1-MDR-M-75)

Methodologies and assumptions

It is the assumption that all Outokumpu employees complete the Code of Conduct

e-learning as per the determined training schedule.

The training is available for employees through the central HR system and each employee

must log in to complete it. HR Learning Services supports with the technical

implementation of the training and regularly monitors the training statistics together with

other internal stakeholders. (G1-MDR-M-77-(a))

External validation

The measurement of the metrics (i.e., the training completion percentage of the Code of

Conduct e-learning) is validated by an external sustainability reporting assurance provider.

(G1-MDR-M-77-(b))

Relationship with policy objectives

The Outokumpu Code of Conduct is the core element of Outokumpu’s group-wide E&C

program, setting the ethical standards for Outokumpu’s operations globally. The Code of

Conduct e-learning supports the target that employees would know and understand the key

content of the Code of Conduct and would be able to conduct business in an ethical and

responsible manner. At Outokumpu, every employee has a role in making ethical choices

that help to build a world that lasts forever. (G1-MDR-T-80-(a))

Measurable target

The target was that all administrative employees and managers of operators complete the

Code of Conduct e-learning within the set time frame in 2025. The target was measured

through the training statistics (training completion %) of the Code of Conduct e-learning.

(G1-MDR-T-80-(b))

Scope

Since the actions were aimed at Outokumpu's internal stakeholders, the target was aligned

with this scope. (G1-MDR-T-80-(c))

Milestones

The Code of Conduct e-learning was relaunched for administrative employees and

managers of operators in May 2025. The deadline to complete the training was in June

2025, meaning that there was approximately a one month time period to complete the

training. In addition, the Code of Conduct e-learning is part of the onboarding program for

all new employees joining the company. (G1-MDR-T-80-(e))

Methodologies and assumptions

Outokumpu is committed to conducting business with high integrity and wants to make

sure that all employees globally know the company’s key rules on how to do the right thing.

In addition to the company’s own expectations, there are expectations set by external

parties to conduct training for employees on ethical and compliant behavior.

The completion of the Code of Conduct e-learning by administrative employees and

managers of operators was a key target in 2025 in respect of the implementation of the

key content of the group-wide Code of Conduct at all Outokumpu sites. (G1-MDR-T-80-(f))

Target setting

Outokumpu’s Group E&C team facilitates the implementation of the Outokumpu Code of

Conduct and related e-learning. The target that administrative employees and managers of

operators complete the training in 2025 was supported by the E&C Steering Group. (G1-

MDR-T-80-(h))

Performance against disclosed target

99% of administrative employees and managers of operators completed the Code of

Conduct e-learning in 2025 (2024: 97% of all employees completed the Code of Conduct e-

learning). This includes all white-collar employees and managers of operators who were

active as of December 31, 2025.

The training completion rates were monitored by the HR Learning Services and the Group

E&C team. Outokumpu has a reminder and consequence management process in place for

the mandatory ethics and compliance e-learning modules, including the Code of Conduct e-

learning. This process applies to the administrative employees globally. As per the process,

administrative employees are expected to complete the training within the set timeline. In

the case of non-completions, there is a reminder and escalation process, and as a final

stage of the process, the Outokumpu user account of the administrative employee who has

not taken the training on time, will be temporarily disabled (this process step applies to


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administrative employees globally, except in Germany). The completion of the Code of

Conduct e-learning was monitored as per this process in 2025. (G1-MDR-T-80-(j))

Management of relationships with suppliers

Approach to relationships with suppliers

Outokumpu's supplier relationships management pursues fostering a resilient and ethical

supply chain, balancing sustainability, quality, and reliability as well as cost-efficiency. By

promoting sustainable practices, Outokumpu aims to create a positive impact throughout

the supply chain, while creating the best value for its operations.

Management of relationships with suppliers includes a structured due diligence process

covering the full supplier lifecycle. New suppliers undergo a qualification process that

evaluates compliance with Outokumpu’s Supplier Code of Conduct and Supplier

Requirements. These set expectations on human rights, labor conditions, environmental

protection, and ethical business conduct. A risk-based approach guides the prioritization of

suppliers for enhanced due diligence, focusing particularly on raw materials and sourcing

regions with elevated sustainability risks. Outokumpu actively monitors suppliers through

self-assessments, EcoVadis sustainability ratings, regular trade sanctions screening, and,

where needed, on-site audits and sustainability visits. Corrective action plans are required if

gaps are identified, and supplier relationships are based on continuous improvement and

collaboration. Suppliers must also evaluate and monitor their own supply chain and provide

proof of their practices if requested by Outokumpu. (G1-2-15(a))

Social and environmental criteria in selecting suppliers

All Outokumpu suppliers and subcontractors are expected to comply with Outokumpu’s

Supplier Code of Conduct or similar standards covering the following topics: safe and

healthy workplace, sustainable future, human rights and dignity, and good corporate

citizenship.

All Outokumpu suppliers will have to commit to and comply with the Supplier Requirements,

which set forth the minimum criteria regarding health and safety, the environment, quality

and risk management, self-assessments and audits, supplier selection and management,

supply chain and material requirements, product liability, protection of Outokumpu’s

confidential information, trade compliance, and sustainability due diligence. (G1-2-15(b))

Policies, actions, metrics and targets related to management of relationships with suppliers

are disclosed in the S2 Workers in the value chain chapter, in the sections Policies, Actions

and Targets. (G1-MDR-P-65-(a)), (G1-MDR-P-65-(c)), (G1-MDR-P-65-(d)), (G1-MDR-P-65-(e)), (G1-MDR-P-65-

(f)), (G1-MDR-A-68-(a)), (G1-MDR-A-68-(b-c)), (G1-MDR-A-68-(e), (G1-MDR-M-75), (G1-MDR-M-77-(a)), (G1-

MDR-M-77-(b)), (G1-MDR-T-80-(a)), (G1-MDR-T-80-(b)), (G1-MDR-T-80-(c)), (G1-MDR-T-80-(e)), (G1-MDR-T-80-

(f)), (G1-MDR-T-80-(h)), (G1-MDR-T-80-(j))


		124

Group key figures

Key figures


€ million, or as indicated	2025	2024	2023	2022	2021

Scope of activity
Sales	5,468	5,942	6,961	9,494	7,243
change in sales, %	-8.0	-14.6	-26.7	31.1	28.4
exports from and sales outside Finland, of total sales, %*	96.3	96.3	96.5	95.9	96.4

Capital employed on Dec 31 ^{* 1)}	4,032	4,250	4,204	4,751	3,828

Capital expenditure *	145	216	170	158	171
in relation to sales, %	2.7	3.6	2.4	1.7	2.4

Depreciation and amortization	215	220	242	245	249
Impairments	7	-7	274	11	45

Research and development costs	11	15	14	15	14
in relation to sales, %	0.2	0.2	0.2	0.2	0.2

Personnel on Dec 31, FTE²⁾	8,251	8,424	8,453	8,357	8,439
average for the year, FTE²⁾	8,328	8,443	8,412	8,683	8,714
Personnel on Dec 31, headcount	8,605	8,736	8,750	8,591	8,727

Alternative performance measures are marked with *. For more information, please see Reconciliation of

alternative performance measures section.

In year 2022, Outokumpu announced to divest majority of the Long Products business operations and

classified these businesses as assets held for sale and reported as discontinued operations. The

divestment was completed on January 3, 2023.

¹⁾ In 2022, including discontinued operations’ equity. In 2021, including discontinued operations.

²⁾Outokumpu has redefined personnel, full time equivalent (FTE) measure in year 2024. FTE is excluding

interim workforce as of year 2023.

³⁾ Until the year-end 2022, the balance sheet component is including discontinued operations except for

Sept 30 and Dec 31, 2022, where only the equity component of discontinued operations is included.

⁴⁾ Discontinued operations are impacting the comparative years’ numbers 2021–2022.


€ million, or as indicated	2025	2024	2023	2022	2021

Profitability
EBITDA*	88	162	416	1,248	968
Adjusted EBITDA*	167	177	517	1,256	980
in relation to sales, %	3.1	3.0	7.4	13.2	13.5

Adjusted EBITDA, including discontinued operations*	167	177	517	1,387	1,021

Operating profit (EBIT)*	-134	-51	-100	992	674
in relation to sales, %	-2.5	-0.9	-1.4	10.5	9.3
Adjusted EBIT*	-48	-43	274	1,010	728

Result before taxes	-174	-89	-133	933	610
in relation to sales, %	-3.2	-1.5	-1.9	9.8	8.4

Net result for the financial year	-137	-40	-111	1,086	526
in relation to sales, %	-2.5	-0.7	-1.6	11.4	7.3

Net result for the financial year, including discontinued operations	-137	-40	-106	1,140	553

Return on equity (ROE), % * ⁴⁾	-3.9	-1.1	-2.6	30.6	20.1
Return on capital employed (ROCE), %^{* 3)}	-3.2	-1.2	-2.1	22.6	17.6


		125


€ million, or as indicated	2025	2024	2023	2022	2021

Financing and financial position
Net financial expenses *	43	41	37	71	79
in relation to sales, %	0.8	0.7	0.5	0.7	1.1

Interest expenses *	54	64	60	44	64
in relation to sales, %	1.0	1.1	0.9	0.5	0.9

Gross debt *¹⁾	627	502	441	633	709
Net debt *¹⁾	265	189	-60	-10	408

Net debt adjusted EBITDA *¹⁾	1.6	1.1	-0.1	0.0	0.4

Share capital	311	311	311	311	311
Total equity	3,405	3,748	3,762	4,119	3,120

Equity-to-assets ratio, % *¹⁾	59.8	63.2	63.8	59.2	48.3
Debt-to-equity ratio (gearing), % *¹⁾	7.8	5.0	-1.6	-0.3	13.1

Net cash generated from operating activities ¹⁾	79	147	325	778	597
Free cash flow *¹⁾	-46	-71	290	619	448

Alternative performance measures are marked with *. For more information, please see Reconciliation of

alternative performance measures section.

In year 2022, Outokumpu announced to divest majority of the Long Products business operations and

classified these businesses as assets held for sale and reported as discontinued operations.

The divestment was completed on January 3, 2023.

¹⁾ Discontinued operations are impacting the comparative years’ numbers 2021–2022. Free cash flow

for year 2023 include discontinued operations i.e. proceeds from the sale of Long product business.


		126

Reconciliation of alternative performance measures

Certain financial key figures and ratios presented in Outokumpu’s Annual Report are not measures of financial performance, financial position or cash flows under IFRS and are therefore considered

as alternative performance measures. These measures are not defined by IFRS and therefore may not be directly comparable with financial measures and ratios used by other companies, including

those in the same industry. The reason for presenting these measures is that either they are statutory requirements applicable to the financial statements of the Group or the management believes

that these measures provide meaningful supplemental information on the underlying business performance or financial position of the Group. These financial measures should not be considered in

isolation from, or as a substitute for, financial information presented in compliance with IFRS. Alternative performance measures are marked with * in the Key figures table.


Key figure EUR million, or as indicated	Definition of the key figure or source in the consolidated Financial Statements	2025	2024

Exports from and sales outside Finland
Exports from and sales outside Finland is an indicator of the international nature of the Group’s business.

Sales	Consolidated statement of income	5,468	5,942
Sales by destination to Finland	Note 2.2	204	222
Exports from and sales outside Finland	Sales - Sales by destination to Finland	5,264	5,719
in relation to total sales, %	Comparison to sales	96.3	96.3

Capital expenditure
Capital expenditure indicates the investment in assets to generate future cash flows for the Group.
Purchases of property, plant and equipment	Consolidated statements of cash flows	119	173
Purchases of intangible assets	Consolidated statements of cash flows	25	38
Emission allowances	Note 4.1	—	-10
Investments in equity at fair value through other comprehensive income and associated companies	Consolidated statement of cash flows	2	16
Capital expenditure	Purchases of property, plant and equipment and intangible assets, other than emission allowances; and investments in equity at fair value through other comprehensive income and in associated companies and acquisitions of businesses	145	216
in relation to sales, %	Comparison to sales	2.7	3.6


Key figure EUR million, or as indicated	Definition of the key figure or source in the consolidated Financial Statements	2025	2024

Operating capital (segment reporting)
Operating capital is a measure for the amount of capital invested in Group’s operations. It is used as a measure for the business areas’ net assets.

Capital employed on Dec 31	Defined later in this section	4,032	4,250
Cash and cash equivalents	Consolidated statement of financial position	362	313
Lease receivables	Note 4.2	6	7
Investments in associated companies	Consolidated statement of financial position	79	77
Investments in equity at fair value through other comprehensive income	Consolidated statement of financial position	24	28
Investments at fair value through profit or loss	Note 5.5	27	28
Net deferred tax assets	Note 2.6	502	498
Net employee benefit obligations	Note 3.3	169	196
Operating capital on Dec 31	Capital employed – cash and cash equivalents – lease receivables– investments in associated companies – investments in equity at fair value through other comprehensive income – investments at fair value through profit or loss – net deferred tax asset – net asset held for sale + net employee benefit obligations	3,200	3,495


		127


Key figure EUR million, or as indicated	Definition of the key figure or source in the consolidated Financial Statements	2025	2024
Operating profit (EBIT) and adjusted EBIT
Operating profit (EBIT) and adjusted EBIT are measures of financial performance of the Group. The items affecting comparability in EBIT relate to material income and expense items of unusual nature, and their purpose is to improve comparability of financial performance between reporting periods.

Net result for the financial year	Consolidated statement of income	-137	-40
Income taxes	Consolidated statement of income	36	49
Total financial income and expenses	Consolidated statement of income	-43	-41
Share of results in associated companies	Consolidated statement of income	4	3
Operating profit (EBIT)	Consolidated statement of income	-134	-51
in relation to sales, %	Comparison to sales	-2.5	-0.9
Items affecting comparability in EBIT	Note 2.1	-86	-8
Adjusted EBIT	Operating profit (EBIT) - Items affecting comparability in EBIT	-48	-43

EBITDA and adjusted EBITDA
EBITDA and adjusted EBITDA are measures of the financial performance of the Group. Adjusted EBITDA is Outokumpu’s main performance indicator in financial reporting. The items affecting comparability in EBITDA relate to material income and expense items of unusual nature, and their purpose is to improve comparability of financial performance between reporting periods.
Operating profit (EBIT)	Consolidated statement of income	-134	-51
Depreciation and amortization	Note 2.3	215	220
Impairments	Note 2.4	7	-7
EBITDA	EBIT before depreciation, amortization and impairments	88	162
Items affecting comparability in EBITDA	Note 2.1	-79	-15
Adjusted EBITDA	EBITDA - Items affecting comparability in EBITDA	167	177
in relation to sales, %	Comparison to sales	3.1	3.0


Key figure EUR million, or as indicated	Definition of the key figure or source in the consolidated Financial Statements	2025	2024
Net financial expenses and interest expenses
Net financial expenses and interest expenses are measures for the cost of Group’s financing.

Net financial expenses	Total financial income and expenses in the Consolidated statement of income	43	41
in relation to sales, %	Comparison to sales	0.8	0.7

Interest expenses	Consolidated statement of income	54	64
in relation to sales, %	Comparison to sales	1.0	1.1


Capital employed
Capital employed is a measure for the amount of capital invested in Group’s operations.

Capital employed is the sum of:
Total equity:	Consolidated statement of financial position	3,405	3,748
Gross debt	Defined later in this section	627	502
Capital employed on Dec 31	Total equity + gross debt	4,032	4,250


		128


Key figure EUR million, or as indicated	Definition of the key figure or source in the consolidated Financial Statements	2025	2024
Return on equity (ROE)
Return on equity is an indicator of the value the Group generates to the capital the shareholders have invested in the Group.

Total equity on Dec 31 of previous year	Consolidated statement of financial position	3,748	3,762
Total equity on March 31		3,657	3,761
Total equity on June 30		3,498	3,697
Total equity on Sept 30		3,457	3,626
Total equity on Dec 31	Consolidated statement of financial position	3,405	3,748
Total equity (4-quarter average)	Average of the opening and 4 quarter-end values	3,553	3,719
Net result for the financial year	Consolidated statement of income	-137	-40
Return on equity (ROE), %	Net result for the financial year / Total equity (4-quarter average)	-3.9	-1.1

Return on capital employed (ROCE)
Return on capital employed is a measure for the value the Group generates to the capital invested in its operations.

Capital employed on Dec 31 of previous year	Defined earlier in this section	4,250	4,204
Capital employed on March 31		4,264	4,175
Capital employed on June 30		3,974	4,134
Capital employed on Sept 30		4,022	4,079
Capital employed on Dec 31	Defined earlier in this section	4,032	4,250
Capital employed (4-quarter average)	Average of the opening and 4-quarter-end values	4,108	4,168
Operating profit (EBIT)	Consolidated statement of income	-134	-51
Share of results in associated companies	Consolidated statement of income	4	3
Return on capital employed (ROCE), %	(Operating profit (EBIT) + Share of results in associated companies) / Capital employed (4-quarter average)	-3.2	-1.2


Key figure EUR million, or as indicated	Definition of the key figure or source in the consolidated Financial Statements	2025	2024
Gross debt
Gross debt is a measure for the level of debt financing in the Group.
Non-current debt	Consolidated statement of financial position	519	246
Current debt	Consolidated statement of financial position	108	256
Gross debt	Non-current + current debt	627	502
Net debt
Net debt is a measure for the level of debt financing in the Group.

Gross debt	Defined earlier in this section	627	502
Cash and cash equivalents	Consolidated statement of financial position	362	313
Net debt	Gross debt – cash and cash equivalents	265	189
in relation to sales, %	Comparison to sales	4.8	3.2

Net debt to adjusted EBITDA
Net debt to Adjusted EBITDA is an indicator of the Group’s indebtedness.

Net debt	Defined earlier in this section	265	189
Adjusted EBITDA	Defined earlier in this section	167	177
Net debt to Adjusted EBITDA	Net debt / Adjusted EBITDA	1.6	1.1

Equity-to-assets ratio
Equity-to-assets ratio shows the proportion the Group’s assets financed with equity. The equity-to- assets ratio indicates the financial risk level of the Group.

Total equity	Consolidated statement of financial position	3,405	3,748
Total assets	Consolidated statement of financial position	5,705	5,965
Advances received	Note 4.5	10	32
Equity-to-assets ratio, %	Total equity/(Total assets - advances received)	59.8	63.2

Debt-to-equity ratio (gearing)
Debt-to-equity ratio or gearing is an indicator of the financial risk level and the indebtedness of the Group.

Net debt	Defined earlier in this section	265	189
Total equity	Consolidated statement of financial position	3,405	3,748
Debt-to-equity ratio (gearing), %	Net debt / Total equity	7.8	5.0

Free cash flow
Free cash flow is an indicator of the cash flow that remains for e.g. payment of dividends and debt.
Free cash flow	Consolidated statement of cash flows, cash flow before financing activities	-46	-71


		129

Definitions of financial key figures


Key figure	Purpose	Definition

Operating profit (EBIT)	Operating profit (EBIT) is a measure of financial performance of the Group.	Net result for the period excluding income taxes, financial income and expenses and share of results in associated companies

EBITDA	EBITDA is a measure of financial performance of the Group.	EBIT before depreciation, amortization and impairments

Items affecting comparability (IAC) in EBITDA or in EBIT	Items affecting comparability in EBITDA or EBIT improves comparability of financial performance between reporting periods.	Material income and expense items which affect the comparability between periods because of their unusual nature, size or incidence resulting for example from group-wide restructuring programs, disposals of assets or businesses or items related to aftercare of old mines.

Adjusted EBITDA or EBIT	Adjusted EBITDA is Outokumpu’s main performance indicator in financial reporting.	EBITDA or EBIT +/- items affecting comparability

Capital employed	Capital employed is a measure for the amount of capital invested in the Group’s operations.	Total equity + gross debt

Operating capital (segment reporting)	Operating capital is a measure for the amount of capital invested in the Group’s operations. It is used as a measure for the business areas’ net assets.	Capital employed – cash and cash equivalents - lease receivables– investments in associated companies – investments in equity at fair value through other comprehensive income – investments at fair value through profit or loss – net deferred tax asset – net asset held for sale + net employee benefit obligations

Capital expenditure	Capital expenditure indicates the investment in assets to generate future cash flows for the Group.	Purchases of property, plant and equipment and intangible assets, other than emission allowances; and investments in equity at fair value through other comprehensive income and in associated companies and acquisitions of businesses

Free cash flow	Free cash flow is an indicator of the cash flow that remains for e.g. payment of dividends and debt.	Cash flow before financing activities

Return on capital employed (ROCE)	Return on capital employed is a measure for the value the Group generates to the capital invested in its operations.	Operating profit (EBIT) + Share of results in associated companies	× 100
Return on capital employed (ROCE)		Capital employed (4-quarter rolling average)	× 100

Return on operating capital (ROOC) (segment reporting)	Return on operating capital is an internal measure for the value the business areas generate to the capital invested in their operations.	Adjusted EBIT	× 100
Return on operating capital (ROOC) (segment reporting)		Operating capital (4-quarter rolling average)	× 100

Return on equity (ROE)	Return on equity is an indicator of the value the Group generates to the capital the shareholders have invested in the Group.	Net result for the financial period	× 100
Return on equity (ROE)		Total equity (4-quarter rolling average)	× 100

Gross debt	Gross debt is a measure for the level of debt financing in the Group.	Non-current debt + current debt

Net debt	Net debt is a measure for the level of debt financing in the Group.	Gross debt – cash and cash equivalents


		130


Key figure	Purpose	Definition

Equity-to-assets ratio	Equity-to-assets ratio shows the proportion of the Group’s assets financed with equity. It indicates the financial risk level of the Group.	Total equity	× 100
Equity-to-assets ratio		Total assets – advances received	× 100

Debt-to-equity ratio (gearing)	Debt-to-equity ratio or gearing is an indicator of the financial risk level and the indebtedness of the Group.	Net debt	× 100
Debt-to-equity ratio (gearing)		Total equity	× 100

Net debt to adjusted EBITDA	Net debt to adjusted EBITDA is an indicator of the Group’s indebtedness.	Net debt
Net debt to adjusted EBITDA		Adjusted EBITDA

Personnel, full-time equivalent		Headcount adjusted to full-time equivalent number of personnel, excluding personnel on sick leave or parental leave of more than 6 months and excluding personnel whose employment has been terminated and who are on notice period without requirement to work and excluding interim workforce.


		131

Share-related key figures¹⁾


		2025		2024	2023	2022	2021
Earnings per share	€	-0.31		-0.09	-0.24	2.52	1.26
Earnings per share continuing operations	€	-0.31		-0.09	-0.26	2.40	1.21
Diluted earnings per share	€	-0.31		-0.09	-0.24	2.33	1.17
Diluted earnings per share continuing operations	€	-0.31		-0.09	-0.26	2.22	1.13

Cash flow per share	€	0.17		0.35	0.75	1.72	1.36
Equity per share	€	7.23		8.85	8.73	9.27	6.89

Dividend per share	€	0.13	²⁾	0.26	0.26	0.35	0.15
Dividend payout ratio	%	-44.60		-278.43	-105.97	13.64	12.30
Dividend yield	%	2.90		8.95	5.80	7.40	2.70

Price / earnings ratio		neg.		neg.	neg.	1.88	4.37

Development of share price
Average trading price	€	3.59		3.59	4.77	4.69	4.96
Lowest trading price	€	2.70		2.77	3.60	3.51	3.36
Highest trading price	€	4.63		4.48	5.90	6.48	6.01
Trading price at the end of the period	€	4.48		2.91	4.48	4.73	5.50
Change during the period	%	54.2		-35.2	-5.2	-14.0	70.8

Change in the OMX Helsinki index during the period	%	30.2		-6.2	-6.6	-13.4	18.3

Market capitalization at the end of the period³⁾	€ million	2,111		1,231	1,933	2,101	2,489

Development in trading volume
Trading volume ⁴⁾	1,000 shares	404,741		385,456	386,008	720,801	880,092
In relation to adjusted weighted average number of shares	%	89.9		90.9	88.7	159.5	200.5

Adjusted weighted average number of shares³⁾		450,344,651		424,237,776	435,090,240	451,932,876	438,871,175
Adjusted diluted weighted average number of shares^{3) 5)}		472,339,560		470,977,109	475,843,726	493,535,712	479,163,509
Number of shares at the end of the period ³⁾		471,208,421		423,685,628	431,190,703	444,134,611	452,571,977

¹⁾ Discontinued operations impacted figures until year 2022. In year 2023 only impact of discontinued operations is the transactions related to the sale of Long Products business operations as divestment was completed

January 3, 2023.

²⁾ The Board of Directors’ proposal to the Annual General Meeting.

³⁾Excluding treasury shares.

⁴⁾ Includes only Nasdaq Helsinki trading.

⁵⁾The convertible bonds matured in July 2025. In total Outokumpu converted the convertible bond into 47,046,505 shares and cancelled the total of 30,836,205 own shares in connection with the conversions. More

information in note 5.2.


		132

Definitions of share-related key figures


Key figure	Definition

Earnings per share	Net result for the financial year attributable to the equity holders
Earnings per share	Adjusted weighted average number of shares during the period

Diluted earnings per share	Net result for the financial year attributable to the equity holders + interest expenses on convertible bonds, net of tax
Diluted earnings per share	Adjusted diluted weighted average number of shares during the period

Cash flow per share	Net cash generated from operating activities
Cash flow per share	Adjusted weighted average number of shares during the period

Equity per share	Equity attributable to the equity holders
Equity per share	Adjusted number of shares at the end of the period

Dividend per share	Dividend for the financial year
Dividend per share	Adjusted number of shares at the end of the period

Dividend payout ratio	Dividend for the financial year	× 100
Dividend payout ratio	Net result for the financial year attributable to the equity holders	× 100

Dividend yield	Dividend per share	× 100
Dividend yield	Adjusted trading price at the end of the period	× 100

Price/ earnings ratio (P/E)	Adjusted trading price at the end of the period
Price/ earnings ratio (P/E)	Earnings per share

Average trading price	EUR amount traded during the period
Average trading price	Adjusted number of shares traded during the period

Market capitalization at end of the period	Number of shares outstanding at the end of the period x Trading price at the end of the period

Development in trading volume	Trading volume	× 100
Development in trading volume	Adjusted weighted average number of shares during the period	× 100


		133

Financial Statements

In 2025, Outokumpu faced a weak economic environment, further intensified by escalating geopolitical tensions.

Outokumpu’s customer V-ZUG, a Swiss

premium home appliance producer, is

using the world’s first towards-zero

stainless steel. Outokumpu Circle

Green®, with up to 93% lower carbon

footprint than the industry average, to

produce parts of the V-ZUG Dishwasher

inner part. The collaboration supports

the ambitious climate targets of both

companies and accelerates the green

transition in the home appliance sector.

“Throughout the year we successfully

continued our profit improvement actions,

and despite the challenges, we kept our

net debt at a low level.”

– Marc-Simon Schaar, CFOCFO


		134

Financial Statements content


Consolidated Financial Statements, IFRS
Consolidated statement of income		135
Consolidated statement of comprehensive income		136
Consolidated statement of financial position		137
Consolidated statement of cash flows		138
Consolidated statement of changes in equity		139

Notes to the consolidated Financial Statements
1	Basis of reporting	141
1.1	Corporate information	141
1.2	Basis of preparation	141

2	Business result	144
2.1	Operating segments	144
2.2	Revenue	148
2.3	Cost of sales and selling, general and administrative expenses	149
2.4	Other operating income and expenses	150
2.5	Financial income and expenses	151
2.6	Income taxes	152
2.7	Earnings per share	155

3	Employee benefits	156
3.1	Employee benefit expenses	156
3.2	Employee benefits for key management	157
3.3	Employee benefit obligations	158
3.4	Share-based payments	162


4	Operating assets and liabilities	164
4.1	Intangible assets and property, plant and equipment	164
4.2	Leases	169
4.3	Goodwill impairment test	172
4.4	Inventories	173
4.5	Trade and other receivables and payables	174
4.6	Provisions	175

5	Capital structure and financial risk management	177
5.1	Net debt and capital management	178
5.2	Equity	182
5.3	Financial risk management and insurances	184
5.4	Derivative instruments	188
5.5	Financial assets and liabilities	190
5.6	Equity investments at fair value through other comprehensive income	193
5.7	Commitments and contingent liabilities	194

6	Group structure and other notes	195
6.1	Discontinued operations	195
6.2	Business acquisitions and disposals	195
6.3	Disputes and litigations	196
6.4	Related parties	196
6.5	Subsidiaries	197
6.6	Associated companies	198
6.7	New IFRS standards	199
6.8	Events after the balance sheet date	199

Parent company Financial Statements, FAS
Income statement of the parent company		200
Balance sheet of the parent company		201
Cash flow statement of the parent company		202
Notes to the parent company financial statements		203


		135

Consolidated Financial Statements, IFRS

Consolidated statement of income


€ million	Note	2025	2024

Sales	2.2	5,468	5,942

Cost of sales	2.3	-5,279	-5,710

Gross margin		189	232

Other operating income	2.4	28	57
Selling and marketing expenses	2.3	-68	-71
Administrative expenses	2.3	-263	-240
Research and development expenses	2.3	-11	-15
Other operating expenses	2.4	-9	-15

Operating profit (EBIT)		-134	-51

Share of results in associated companies	6.6	4	3

Financial income and expenses	2.5
Interest income and other financial income		9	13
Interest expenses		-54	-64
Market price gains and losses		12	20
Other financial expenses		-11	-10
Total financial income and expenses		-43	-41

Result before taxes		-174	-89

Income taxes	2.6	36	49

Net result for the period		-137	-40


€ million	Note	2025	2024

Earnings per share for result attributable to the equity holders of the parent company	2.7
Earnings per share, EUR		-0.31	-0.09
Diluted earnings per share, EUR		-0.31	-0.09

Net result for the financial year is fully attributable to the equity holders of the parent company. The notes

are an integral part of the Financial Statements.


		136

Consolidated statement of comprehensive income


€ million	Note	2025	2024
Net result for the period		-137	-40

Items that may be reclassified to profit or loss:
Exchange differences on translating foreign operations
Change in exchange differences		-205	108

Cash flow hedges	5.4
Fair value changes during the financial year		-13	12
Reclassification to profit or loss		-8	-13
Income taxes	2.6	4	0

Items that will not be reclassified to profit or loss:
Remeasurements on defined benefit plans	3.3
Changes during the financial year		20	12
Income taxes	2.6	-8	-4

Equity investments at fair value through other comprehensive income	5.6
Fair value changes during the financial year		-5	13

Share of other comprehensive income in associated companies	6.6	0	0

Other comprehensive income for the financial year, net of tax		-215	127

Total comprehensive income for the financial year		-352	88

Total comprehensive income for the financial year is fully attributable to the equity holders of the parent

company. The notes are an integral part of the Financial Statements.


		137

Consolidated statement of financial position


€ million	Note	2025	2024
ASSETS

Non-current assets
Intangible assets	4.1, 4.3	573	580
Property, plant and equipment	4.1	1,859	1,935
Right-of-use assets	4.2	173	179
Investments in associated companies	6.6	79	77
Equity investments at fair value through other comprehensive income	5.6	24	28
Deferred tax assets	2.6	502	504
Trade and other receivables	4.5	9	10
		3,219	3,313


Current assets
Inventories	4.4	1,608	1,764
Investments at fair value through profit or loss	5.5	27	28
Derivative financial instruments	5.4	17	39
Current tax receivables	2.6	14	16
Trade and other receivables	4.5	457	492
Cash and cash equivalents	5.1	362	313
		2,486	2,652

TOTAL ASSETS		5,705	5,965


€ million	Note	2025	2024
EQUITY AND LIABILITIES

Equity attributable to the equity holders of the parent company
Share capital		311	311
Premium fund and other restricted reserves		714	714
Invested unrestricted equity reserve		2,294	2,307
Treasury shares		-7	-159
Fair value reserves		2	21
Retained earnings		92	553

Total equity	5.2	3,405	3,748

Non-current liabilities
Non-current debt	5.1	519	246
Derivative financial instruments	5.4	2	0
Deferred tax liabilities	2.6	0	6
Employee benefit obligations	3.3	169	196
Provisions	4.6	76	52
Trade and other payables	4.5	10	13
		775	513

Current liabilities
Current debt	5.1	108	256
Derivative financial instruments	5.4	33	17
Provisions	4.6	57	33
Current tax liabilities	2.6	7	8
Trade and other payables	4.5	1,320	1,390
		1,525	1,704

TOTAL EQUITY AND LIABILITIES		5,705	5,965

The notes are an integral part of the Financial Statements.


		138

Consolidated statement of cash flows


€ million	Note	2025	2024
Cash flow from operating activities

Net result for the financial year		-137	-40

Adjustments for
Depreciation, amortization and impairments	2.3, 2.4, 4.1, 4.2	222	213
Gains/ losses on sale of non-current assets, Group companies and businesses	2.4	-7	-1
Financial income and expense	2.5	43	41
Income taxes	2.6	-36	-49
Other adjustments		-70	2
		151	205

Change in net working capital
Change in trade and other receivables		20	139
Change in inventories		119	-165
Change in trade and other payables		-28	53
		112	27

Interest and dividends received		7	13
Interest paid		-48	-52
Other financial items		3	-8
Income taxes paid		-9	2

Net cash from operating activities		79	147


	Note	2025	2024
Cash flow from investing activities
Equity investments at fair value through other comprehensive income	5.6	-2	-2
Purchases of property, plant and equipment	4.1	-119	-173
Purchases of intangible assets	4.1	-25	-38
Investments in associated companies	6.6	—	-13
Proceeds from sale of property, plant and equipment and intangible assets	4.1	18	4
Proceeds from disposal of shares in Group companies and businesses, net of cash	6.2	1	5
Other investing cash flow		1	-1

Net cash from investing activities		-125	-218

Cash flow before financing activities		-46	-71

Cash flow from financing activities
Dividends paid	5.2	-116	-110
Repurchase of treasury shares	5.2	—	-34
Borrowings of non-current debt	5.1	300	—
Repayments of non-current debt	5.1	-15	-15
Change in current debt	5.1	-30	79
Repayments of lease liabilities	4.2	-42	-38

Net cash from financing activities		97	-118

Net change in cash and cash equivalents		51	-189

Cash and cash equivalents at the beginning of the financial year		313	502
Net change in cash and cash equivalents		51	-189
Foreign exchange rate effect on cash and cash equivalents		-2	1
Cash and cash equivalents at the end of the financial year	5.1	362	313

The notes are an integral part of the Financial Statements.


		139

Consolidated statement of changes in equity


€ million	Note	Share capital	Premium fund	Other restricted reserves	Invested unrestricted equity reserve	Treasury shares	Fair value reserve from equity investments	Fair value reserve from derivatives	Cumulative translation differences	Remeasure- ments of defined benefit plans	Other retained earnings	Total equity
Equity on January 1, 2024		311	714	0	2,307	-169	1	5	-38	-139	770	3,762
Net result for the period		—	—	—	—	—	—	—	—	—	-40	-40
Other comprehensive income		—	—	—	—	—	13	-1	108	8	0	127
Total comprehensive income for the financial year		—	—	—	—	—	13	-1	108	8	-40	88
Transactions with equity holders of the parent company
Contributions and distributions
Dividends	5.2	—	—	—	—	—	—	—	—	—	-110	-110
Share-based payments	3.4	—	—	—	—	6	—	—	—	—	-6	0
Repurchase of treasury shares¹⁾	5.2	—	—	—	—	4	—	—	—	—	—	4
Fair value transfer to inventory	5.4	—	—	—	—	—	—	4	—	—	—	4
Other		—	—	—	—	—	—	—	—	0	0	—
Equity on December 31, 2024		311	714	0	2,307	-159	14	8	70	-131	615	3,748
Net result for the period		—	—	—	—	—	—	—	—	—	-137	-137
Other comprehensive income		—	—	—	—	—	-5	-17	-205	12	0	-215
Total comprehensive income for the financial year		—	—	—	—	—	-5	-17	-205	12	-138	-352
Transactions with equity holders of the parent company
Contributions and distributions
Dividends²⁾	5.2	—	—	—	—	—	—	—	—	—	-116	-116
Conversion of convertible bond ²⁾	5.1, 5.2	—	—	—	125	—	—	—	—	—	0	124
Share-based payments	3.4	—	—	—	—	3	—	—	—	—	-4	-1
Cancellation of treasury shares ²⁾	5.2	—	—	—	-138	149	—	—	—	—	-10	—
Fair value transfer to inventory	5.4	—	—	—	—	—	—	2	—	—	—	2
Other³⁾		—	—	—	—	—	—	—	89	—	-89	—
Equity on December 31, 2025		311	714	0	2,294	-7	9	-7	-46	-119	257	3,405

The notes are an integral part of the Financial Statements.

Equity is fully attributable to the equity holders of the parent company. See note 5.2 for more information on equity.

¹⁾ On February 29, 2024, Outokumpu completed its up to EUR 50 million share buyback program which was announced on November 29, 2023. Due to the nature of the contract with a third party, Outokumpu recognized a

EUR 38 million financial liability in December 2023 related to this share buyback program and the maximum amount of EUR 50 million impacted Group equity in 2023. During the program, Outokumpu repurchased a total

of 11,000,000 of its own shares and used a total of EUR 46 million for the repurchase of shares. As the original commitment was higher, a EUR 4 million impact was recognized in equity in relation to this program.

²) In 2020, Outokumpu issued unsecured convertible bonds of EUR 125 million maturing on July 9, 2025. During 2025, the company converted a total of EUR 125 million of the bonds into 47 million shares. The company

issued 47 million new shares as conversion shares and cancelled 31 million of its own shares, amounting to a total value of EUR 149 million. As a result of these conversions, the number of shares outstanding increased,

which impacted on the dividend distribution by EUR 6 million.

³⁾ Other is related to reclassification of cumulative translation differences with no impact in total retained earnings.


		140

Notes to the consolidated Financial Statements

Outokumpu presents the notes to the consolidated Financial Statements as grouped in the

following six sections.

1. Basis of reporting

2. Business result

3. Employee benefits

4. Operating assets and liabilities

5. Capital structure and financial risk management

6. Group structure and other notes


Note	Accounting principles	Management judgments	Risk information
1 Basis of reporting
1.1 Corporate information
1.2 Basis of preparation
2 Business result
2.1 Operating segments
2.2 Revenue
2.3 Cost of sales and selling, general and administrative expenses
2.4 Other operating income and expenses
2.5 Financial income and expenses
2.6 Income taxes
2.7 Earnings per share
3 Employee benefits
3.1 Employee benefit expenses
3.2 Employee benefits for key management
3.3 Employee benefit obligations
3.4 Share-based payments
4 Operating assets and liabilities
4.1 Intangible assets and property, plant and equipment
4.2 Leases
4.3 Goodwill impairment test
4.4 Inventories
4.5 Trade and other receivables and payables
4.6 Provisions

The basis of preparation, accounting principles and management judgments applicable to the

entire consolidated Financial Statements are presented in the Basis of reporting section, but

the accounting principles, management judgments, and risks related to each disclosure item

are presented in the related note. The table outlines the notes structure and indicates which

notes include accounting principle, management judgment and risk information, and the

following icons are used to indicate these topics within the notes.



Note	Accounting principles	Management judgments	Risk information
5 Capital structure and financial risk management
5.1 Net debt and capital management
5.2 Equity
5.3 Financial risk management and insurances
5.4 Derivative instruments
5.5 Financial assets and liabilities
5.6 Equity investments at fair value through other comprehensive income
5.7 Commitments and contingent liabilities
6 Group structure and other notes
6.1 Discontinued operations
6.2 Business acquisitions and disposals
6.3 Disputes and litigations
6.4 Related parties
6.5 Subsidiaries
6.6 Associated companies
6.7 New IFRS standards
6.8 Events after the balance sheet date


		141

1. Basis of reporting

1.1 Corporate information

Outokumpu Corporation is a Finnish public limited liability company organized under the laws of

Finland and domiciled in Helsinki, Finland. The company has been listed on the Nasdaq Helsinki

since 1988. Outokumpu Corporation is the parent company ("parent company", "Outokumpu

Corporation") of the Outokumpu Group (the "Group", "Outokumpu", the "company").

Outokumpu’s vision is to pioneer materials and technologies that power tomorrow. As the global

leader in sustainable stainless steel, we are accelerating the green transition, and we lead the

development of low-CO₂ metals and solutions across the stainless steel value chain – and

beyond.

Our business is based on the circular economy: our products are made from more than 90%

recycled materials, which we turn into fully recyclable stainless steel with up to 75% lower

carbon footprint than the industry average. This steel is utilized in various applications across

society, including infrastructure, energy, industrial applications and household appliances. With

our new EVOLVE strategy, we focus on maximizing value in sustainable stainless steel while

expanding our offering in advanced materials and alloys, ferrochrome and innovative

technologies.

We operate production sites in Finland, Germany, Sweden, the Netherlands, the United States,

and Mexico whilst our mine in Kemi, Finland is the only chrome mine within the European

Union.

In 2025, Outokumpu’s revenue was EUR 5.5 billion. Outokumpu employs approximately 8,600

professionals in nearly 30 countries, with headquarters in Helsinki, Finland. Our shares are

listed on Nasdaq Helsinki. Read more: www.outokumpu.com.

Outokumpu’s consolidated Financial Statements according to ESEF regulations are published in

XHTML format at www.outokumpu.com/reports. Financial Statements presented in other

reports and formats, such as in the Annual report PDF or print, do not constitute as reports

according to the ESEF regulations.

On February 12, 2026, the Board of Directors of Outokumpu Corporation approved the

publishing of these consolidated Financial Statements. According to the Finnish Companies Act,

the General Meeting of Shareholders is entitled to decide on the adoption of the Financial

Statements.

1.2 Basis of preparation

These consolidated Financial Statements of Outokumpu have been prepared on a going concern

basis for the financial year 2025 covering the period from January 1 to December 31, 2025.

The consolidated Financial Statements have been prepared in accordance with IFRS Accounting

Standards as adopted by the European Union including SIC and IFRIC interpretations in force on

December 31, 2025. The consolidated Financial Statements also comply with the regulations of

Finnish accounting and company legislation complementing the IFRS.

The consolidated Financial Statements are presented in millions of euros and have been

prepared under the historical costs convention unless otherwise stated in the accounting

principles. All figures presented have been rounded, and consequently the sum of individual

figures may deviate from the presented aggregate figure. Key figures have been calculated

using exact figures.


Corporate information
Company name	Outokumpu Corporation
Legal form	Public limited liability company
Country of incorporation	Finland
Domicile and principal place of business	Helsinki, Finland
Company address	P.O. Box 245, 00181 Helsinki, Finland
Ultimate parent company	Outokumpu Corporation


		142

Risk information

Global economy and geopolitical conflicts

Outokumpu is exposed to a range of risks and uncertainties that may adversely affect its

business and operations. To mitigate these risks, the company applies continuous and

comprehensive risk management across its operations.

Global economic activity, shifts in trade and economic policies, and geopolitical tensions

expose Outokumpu to risks and uncertainties in its operating environment. These factors could

have an adverse impact on the company's operations, financial performance, and overall

financial position.

The main short-term risks relate to the development in trade policies and increased

geopolitical tensions, which could disrupt global trade, increase inflation, and slow economic

growth, ultimately leading to possible weakening of demand and pressure on stainless steel

prices, even with their broad range of end uses.

The U.S. administration’s shifts in trade policies has created uncertainties in global trade

flows and imposed duties of 50% on steel imports in 2025. As a result, high volumes of low-

priced Asian imports risk being diverted into Europe, continuing to burden the European

stainless steel market. To address this, the European Commission has proposed more effective

safeguards to strengthen the industry’s competitive position, with measures expected by

mid-2026. Since Outokumpu operates in both the US and Europe, imposed tariffs may support

US operations while potentially negatively impacting European operations if effective safeguards

are not implemented.

Starting January 2026, the Carbon Border Adjustment Mechanism (CBAM) aims to ensure

that imported carbon-intensive goods face the same carbon costs as those produced within the

EU. However, uncertainties remain regarding the effectiveness of these measures in preventing

circumvention, ensuring a level playing field in climate action and preventing carbon leakage.

The company remains exposed to risks related to volatile metal prices, especially nickel.

Financial derivatives are used to manage the impacts of nickel price changes.

Although Outokumpu has implemented mitigation actions, the risks and uncertainties

described above may still materialize and lead to disruptions affecting Outokumpu, its

employees, markets, suppliers, and customers. Such disruptions could have a material adverse

impact especially on demand. Prolonged periods of reduced demand or other adverse impact on

business performance could, in turn, negatively affect the valuation of non‑current assets,

including deferred tax assets and goodwill.

Cyber security threats and dependencies on critical suppliers and machinery expose

Outokumpu to the risk of operational disruption and additional costs.

For more information on risks and uncertainties see Review of Board of Directors and

Financial Statement note 5.3 for financial risks. For more information on the valuation of the

deferred taxes and goodwill impairment see notes 2.6 and 4.3 respectively.

Climate matters

One of Outokumpu’s EVOLVE strategy’s pillars is sustainability leadership and therefore climate

matters play an important part in Outokumpu’s business. Outokumpu’s low carbon footprint

stainless steel provides emission reduction possibilities to its customers and improves

Outokumpu’s ability to meet climate-related investor and regulatory requirements. In line with

its business strategy, Outokumpu aims to reduce its carbon emission intensity by 42% by the

end of 2030 compared to the 2016 level, which is Outokumpu’s Science-Based Target initiative

(SBTi) 1.5-degree climate target.

Outokumpu has assessed physical climate risks and mitigation measures for all sites and

included them in its general risk assessment. Risk evaluations show that climate-related

physical risks do not currently have material effects to the Group's capital or operating

expenditure. Financial effects of climate-related transition risks are significant and have been

considered for the target period until 2030.

To be able to attain the 1.5 degree climate target, the company has created and committed

to a low carbon roadmap and many carbon emission reduction projects have been initiated

already. Capital expenditure related to the low carbon roadmap has been considered in the

cash flow forecasts used in goodwill impairment testing. In 2025, investments to support smart

decarbonization amounted to EUR 8.3 million. More information about the Goodwill impairment

testing in note 4.3.

Avoided direct emissions of Outokumpu’s smart decarbonization projects at it’s European

sites in the period 2026-2030 would correspond to European emission allowances estimated to

be worth in total approximately EUR 57 million¹⁾. See more information about climate related

risks and it’s transition plan in the Sustainability Statement in the Review of Board of Directors.

More information about emission allowances and their impact in the Financial Statements of

the Group in note 4.1.

Outokumpu’s long-term incentive plan, the Performance Share Plan, includes sustainability-

related criteria for the ongoing plan periods 2023–2025, 2024–2026, 2025–2027 and

2026-2028 which was approved by the Board of Directors in December 2025. The performance

share plan sets the compensation criteria for each period and is a part of the regular

compensation of top executives.

As of 2022, 20% of the Performance Share Plans awarded to the top management have

been tied to a greenhouse gas emission reduction target, according to Outokumpu’s Science

Based Targets initiative (SBTi) commitment to keep global warming below 1.5°C. Specifically,

Outokumpu’s greenhouse gas emissions per tonne of crude steel produced must reach a

reduced level each year. More information about the share-based payments in note 3.4.

Outokumpu signed during 2025 a committed unsecured EUR 800 million revolving credit

facility replacing its existing and currently unused unsecured revolving credit facilities of EUR

700 million and EUR 100 million. The margin of the new facility is linked to emission reductions

in line with the approved emission reduction target by the Science Based Targets initiative for

2030. More information on the revolving credit facility in note 5.1.

¹⁾ The financial impact is evaluated with an assumed carbon price of 100 EUR per ton of CO2.


		143

Management judgments

The preparation of the Financial Statements in accordance with IFRS requires management to

make judgments, estimates and assumptions that affect the reported amounts of assets and

liabilities and the disclosure of contingent assets and contingent liabilities at the reporting

date, as well as the reported amounts of income and expenses during the reporting period.

Management’s estimates and judgments are continuously evaluated and they are based on

prior experience and other factors, such as future expectations assumed to be reasonable

considering the circumstances. Although these estimates are based on management’s best

knowledge of the circumstances at the end of the reporting period, actual results may differ

from the estimates and the assumptions.

The table in the beginning of the notes to the consolidated Financial Statements outlines

the notes that include material management judgments.

Accounting principles

Principles of consolidation

The consolidated Financial Statements include the parent company Outokumpu Corporation

and all subsidiaries controlled by Outokumpu Corporation either directly or indirectly. The Group

controls an entity when it is exposed to, or has rights to, variable returns from its involvement

with the entity and has the ability to affect those returns through its power over the entity.

The Financial Statements of subsidiaries are included in the consolidated Financial

Statements from the date on which control commences until the date on which control ceases.

Changes in the parent company’s ownership interest in a subsidiary are accounted for as equity

transactions if the parent company retains control of the subsidiary.

All intra-group transactions, receivables, liabilities and unrealized margins, as well as

distribution of profits within the Group, are eliminated in the preparation of consolidated

Financial Statements.

Foreign currency transactions

Transactions of each subsidiary included in the consolidated Financial Statements are

measured using the currency that best reflects the economic substance of the underlying

events and circumstances relevant to that subsidiary (“the functional currency”). The functional

currency is mainly the subsidiary’s local currency except for subsidiary in Mexico who uses the

US dollar as their functional currency.

The consolidated Financial Statements are presented in euros which is the functional and

presentation currency of the parent company. Group companies’ foreign currency transactions

are translated into local functional currencies using the exchange rates prevailing at the dates

of the transactions. Receivables and liabilities in foreign currencies are translated into

functional currencies at the exchange rates prevailing at the end of the reporting period.

Foreign exchange differences arising from interest-bearing assets and liabilities and related

derivatives are recognized in financial income and expenses in the consolidated statement of

income. Foreign exchange differences arising in respect of other financial instruments are

included in operating profit under other operating expenses. The effective portion of

accumulated exchange differences arisen from hedges of net investments in foreign operations

are recognized in equity.

For those subsidiaries whose functional and presentation currency is not the euro, the items

in the statements of income and comprehensive income, and in the statement of cash flows

are translated into euro using monthly average exchange rates. The assets and liabilities in the

statement of financial position are translated using the exchange rates prevailing at the

reporting date. The translation differences arising from the use of different exchange rates

explained above are recognized in the Group’s equity through other comprehensive income.

Any goodwill arising on acquisitions of foreign operations and any fair value adjustments to

the carrying amounts of assets and liabilities arising on acquisitions of those foreign operations

are treated as assets and liabilities of those foreign operations. They are translated into euro

using the exchange rates prevailing at the reporting date. When a foreign operation is sold, or is

otherwise partially or completely disposed of, the translation differences accumulated in equity

are reclassified in profit or loss as part of the gain or loss on the sale.

Adoption of new and amended IFRS standards

As of January 1, 2025, Outokumpu has applied the following new and amended standards,

interpretations and decisions.

• Amendments to IAS 21 - Lack of Exchangeability. The amendments aim to improve IAS 21 by

adding requirements to help entities to determine whether a currency is exchangeable into

another currency, and the spot exchange rate to use when it is not. Prior to these

amendments, IAS 21 set out the exchange rate to use when exchangeability is temporarily

lacking, but not what to do when lack of exchangeability is not temporary. Outokumpu has

not operated with currencies that lack exchangeability during the financial year, but will

follow these amendments if such transactions occur.

The new and amended standards, interpretations and decisions did not have material impact

on Outokumpu’s consolidated Financial Statements.


		144

2. Business result

2.1 Operating segments

Outokumpu has three business areas – Europe, the Americas, and Ferrochrome. Business areas

are organized so that Europe and the Americas include both coil and plate stainless steel

operations in their market area, while Ferrochrome focuses on the chrome mine and

ferrochrome operations. The business areas have responsibility for commercial activities, supply

chain management and operations and they are Outokumpu’s operating segments under IFRS.

In addition to the business area structure, Group Functions cover Legal and compliance, Health

and safety, Procurement, Finance, Treasury, IR, Strategy, M&A and Corporate Development, HR,

Group communications, R&D, Technology, Sustainability and Group IT.

Europe consists of both coil and plate operations. In sustainable stainless steel operations

Outokumpu combines unmatched cost competitiveness, sustainability of our products, highest

level of reliability and quality to a unique customer experience. Sustainable stainless steel is

used in numerous different industries, for example in architecture and construction,

transportation, automotive and home appliances. In advanced materials and alloys, Outokumpu

provides industrial tailored stainless and nickel-based alloy solutions for demanding

environments in the process industry, oil and gas, and electric vehicles, for example. The

production facilities are located in Finland, Germany, Sweden and Netherlands. The business

area has an extensive service center and sales network across Europe, Middle East, Africa and

APAC region.

Americas produces standard austenitic and ferritic grades as well as tailored products. Its

largest customer segments are automotive and transport, consumer appliances, oil and gas,

chemical and petrochemical industries, food and beverage processing, as well as building and

construction industry. The business area has production units in the US and Mexico.

Ferrochrome produces charge grade of ferrochrome and runs the chrome mine in Kemi and

ferrochrome smelter in Tornio, Finland.

Other operations consist of activities outside the three operating segments, as well as

industrial holdings, non-core businesses, strategic group level investments and new business

development. Such business development expenses, Corporate Management expenses and

other extraordinary costs that are not part of business area performance assessment and not

allocated to the business areas are also reported under Other operations. Sales of Other

operations consist of sales of electricity to the Group’s production facilities in Finland and in

Sweden, sales of non-core businesses and internal services.

Sales EUR

5.5

billion

Sales, € million

Adjusted EBITDA EUR

167

million

Adjusted EBITDA, € million

Net result EUR

-137

million

Earnings per share, €

Earnings per

share EUR

-0.31


		145


				Reconciliation
2025 € million	Europe	Americas	Ferrochrome	Operating segments total	Other operations	Eliminations	Group
External sales	3,557	1,675	217	5,449	19	—	5,468
Internal sales	43	1	245	289	140	-429	—
Sales	3,600	1,676	462	5,738	159	-429	5,468

Adjusted EBITDA	-46	102	138	194	-24	-3	167
Items affecting comparability in EBITDA
Restructuring costs	-65	0	-1	-66	-5	—	-71
Litigation provisions	—	-6	—	-6	—	—	-6
Environmental	—	0	—	0	-1	—	-2
EBITDA	-111	95	137	121	-31	-3	88
Depreciation and amortization	-114	-34	-52	-201	-14	—	-215
Impairments	-7	—	—	-7	—	—	-7
Operating profit (EBIT)	-233	61	85	-87	-45	-3	-134
Items affecting comparability in EBIT	-72	-7	-1	-80	-7	—	-86
Adjusted operating profit (EBIT)	-160	67	86	-7	-38	-3	-48

Capital expenditure	68	22	13	102	42	—	145

Assets in operating capital	2,751	854	967	4,572	296	-164	4,704
Other assets							499
Deferred tax assets							502
Total assets							5,705

Liabilities in operating capital	902	423	132	1,457	194	-146	1,504
Other liabilities							796
Deferred tax liabilities							0
Total liabilities							2,300

Operating capital	1,849	431	835	3,116	102	-18	3,200
Return on operating capital (ROOC), %	-8.5	13.0	10.0
Personnel at end of period, FTE	5,646	1,744	454	7,843	407	—	8,251


		146


				Reconciliation
2024 € million	Europe	Americas	Ferrochrome	Operating segments total	Other operations	Eliminations	Group
External sales	4,044	1,707	180	5,930	11	—	5,942
Internal sales	58	—	289	347	175	-522	—
Sales	4,102	1,707	469	6,277	186	-522	5,942

Adjusted EBITDA	58	59	106	223	-46	-1	177
Items affecting comparability in EBITDA
Loss on disposal of shares in Group companies and businesses	—	—	—	—	-3	—	-3
Litigation provisions	—	-2	—	-2	—	—	-2
Restructuring costs	-5	—	—	-5	-2	—	-7
Inventory revaluations	2	—	—	2	—	—	2
Environmental	—	-5	—	-5	—	—	-5
EBITDA	55	51	106	212	-50	-1	162
Depreciation and amortization	-115	-33	-58	-206	-14	—	-220
Impairments	7	0	—	7	—	—	7
Operating profit (EBIT)	-52	18	48	14	-64	-1	-51
Items affecting comparability in EBIT	4	-8	—	-3	-4	—	-8
Adjusted operating profit (EBIT)	-56	25	48	17	-60	—	-43

Capital expenditure	117	30	27	174	42	—	216

Assets in operating capital	2,948	944	986	4,879	297	-168	5,008
Other assets							453
Deferred tax assets							504
Total assets							5,965

Liabilities in operating capital	989	370	123	1,482	182	-152	1,513
Other liabilities							698
Deferred tax liabilities							6
Total liabilities							2,217

Operating capital	1,959	574	863	3,396	115	-16	3,495
Return on operating capital (ROOC), %	-3.0	4.2	5.5
Personnel at end of period, FTE	5,757	1,784	472	8,012	412	—	8,424


		147

Items affecting comparability in EBITDA and EBIT


€ million	2025	2024
Restructuring costs	-71	-7
Litigation provisions	-6	-2
Environmental	-2	-5
Loss on disposal of shares in Group companies and businesses	—	-3
Inventory revaluations	—	2
Items affecting comparability in EBITDA	-79	-15
Impairments on non-current assets	-7	7
Items affecting comparability in EBIT	-86	-8

In 2025, items affecting comparability in EBIT mainly related to the restructuring provisions of

which EUR 34 million arising from personnel negotiations, primarily in the Europe business area

and Group functions, as announced on October 1, 2025 and EUR 29 million and non-current

asset impairments EUR 7 million in relation to strategy, EVOLVE announced on June 10, 2025.

Restructuring costs also include EUR 6 million related to the remaining actions of German site

closures and transfers of operations as announced in 2023. Litigation provisions EUR 6 million

relate to an increase of provision related to legal proceedings against Outokumpu Stainless

USA, LLC. More information on the litigation can be found in note 6.3.

In 2024, the German restructuring provisions of 2023 were revised which led to an increase of

EUR 5 million. At the same time, the impairment of EUR 5 million recognized in 2023 was

reversed. The environmental items of EUR 5 million are related to flooding that was caused by

torrential rains in San Luis Potosí, Mexico. The loss on the disposal of shares in Group

companies and businesses of EUR 3 million is due to a final escrow account agreement relating

to the sale of Long Products businesses in 2023.

Accounting principles

Outokumpu’s CEO, supported by the Leadership Team, is the Group’s chief operating decision

maker. The segments are reviewed regularly for the purpose of assessing performance and

allocating resources to segments. The review is based on internal management reporting on

IFRS based financial information.

Adjusted EBITDA, adjusted operating profit (EBIT) and capital expenditure are alternative

performance measures, meaning that they are not IFRS-defined measures. They are defined

also in the Reconciliation of alternative performance measures section within the Review by the

Board of Directors and reconciled to the consolidated statement of income. Alternative

performance measures are unaudited.

Adjusted EBITDA

Adjusted EBITDA is Outokumpu’s main performance indicator in financial reporting, and is also

used to assess the segments’ performance. Adjusted EBITDA is defined as EBIT before

depreciation, amortization and impairment charges, and excluding such material income and

expense items which affect the comparability between periods due to their unusual nature, size

or incidence resulting from, for example, Group-wide restructuring programs or disposals of

assets or businesses.

Adjusted operating profit (EBIT)

Adjusted operating profit (EBIT) is a measure of financial performance of the Group. Adjusted

EBIT is defined as net result for the period excluding income taxes, financial income and

expenses and share of results in associated companies and excluding such material income

and expense items which affect the comparability between periods due to their unusual nature,

size or incidence resulting from, for example, Group-wide restructuring programs or disposals of

assets or businesses.

Capital expenditure

Capital expenditure indicates the investment in assets to generate future cash flows for the

Group.

Operating capital and ROOC

Segment assets and liabilities resulting in the operating capital are allocated to the segments

based on the operations and the physical location of the assets and are measured the same

way as in the Financial Statements.

Return on operating capital (ROOC) is a key figure for the segment reporting and it is an

internal measure for the value the business areas generate to the capital invested in their

operations. The formula for calculating Return on operating capital (ROOC) is presented in the

Review by the Board of Directors section Definitions of financial key figures.

Personnel at end of period, FTE

Personnel at end of the period, FTE as a key figure reflects the true amount of workforce

capacity available to the organization. The formula for calculating Personnel at end of period,

FTE is presented in the Review by the Board of Directors section Definitions of financial key

figures.


		148

2.2 Revenue

External sales by geographical destination


€ million	Finland	Germany	Italy	The UK	Poland	Other Europe	North America	APAC region	Other countries	Group
2025
Operating segment
Europe	180	898	590	189	163	1,105	101	272	59	3,557
Americas	—	—	—	1	—	—	1,668	3	2	1,675
Ferrochrome	12	17	14	10	—	93	36	34	0	217
Other operations	13	3	—	0	—	2	1	0	0	19
	204	918	604	200	163	1,201	1,807	309	62	5,468

2024
Operating segment
Europe	199	1,124	704	235	195	1,156	92	291	48	4,044
Americas	—	—	—	0	—	—	1,691	6	10	1,707
Ferrochrome	14	22	14	7	0	89	21	11	1	180
Other operations	9	3	—	0	—	0	—	—	—	11
	222	1,148	718	243	195	1,244	1,805	307	59	5,942

Accounting principles

Outokumpu generates revenue mainly from sales of stainless steel and ferrochrome.

Outokumpu ships these goods to customers under a variety of Incoterms, and considers the

physical possession as well as risks and rewards related to the ownership of the goods

to be transferred accordingly. This also signifies the transfer of control of the goods to the

customer.

Outokumpu’s performance obligations related to sale of stainless steel and ferrochrome are

satisfied and revenue from contracts with customers recognized at a point of time. Only revenue

from the performance obligation related to transportation of the goods is recognized over a

period of time, and the period under which the revenue is recognized is relatively short.

Moreover, the timing of revenue recognition does not have an impact when assessing the

uncertainty associated with future cash flows, as the sales of goods and transportation service

are billed from the customer on the same invoice. Outokumpu acts as a principal with regards

to transportation of goods. The amount of the remaining performance obligations related to the

transportation service was immaterial at the end of 2025.

Outokumpu has bill-and-hold arrangements with selected European customers. Under these

arrangements, based on a customer request, Outokumpu holds the readily available material at

its own stock locations for the customer for up to a period of three months before the actual

delivery of the material. Outokumpu has transferred control of these materials to the customer

as Outokumpu is not able to direct the material to another customer, and consequently

recognizes the revenue for the material sales. The revenue related to Outokumpu’s

transportation service performance obligation to deliver the material is recognized over the time

when the delivery takes place. At the end of 2025, the amount of revenue recognized under the

bill-and-hold arrangements for products not yet delivered was immaterial.

Stainless steel and ferrochrome sales prices are mainly fixed before delivery, and volume

discounts estimated and accrued in the revenue recognition are the only variable component in

pricing. In individual cases, the sales price of ferrochrome is based on the period of time when

the customer uses the purchased ferrochrome. The payment terms vary from advance payment

to 90 days payment term, and do not include any significant financing component.

Liabilities related to customer contracts are presented in note 4.5.

Outokumpu does not have individual significant customers as defined in IFRS 8.


		149

2.3 Cost of sales and selling, general and administrative expenses


€ million	2025	2024
Cost of sales	-5,279	-5,710
Selling and marketing expenses	-68	-71
Administrative expenses	-263	-240
Research and development expenses	-11	-15
Total	-5,622	-6,035

Cost of sales and selling, general and administrative expenses by nature


€ million	2025	2024
Materials	-2,871	-3,094
Supplies	-611	-619
Energy	-325	-360
Maintenance	-231	-239
Freight	-242	-250
Employee benefits	-782	-714
Depreciation and amortization	-215	-220
Other	-344	-539
Total	-5,622	-6,035

Depreciation and amortization by function


€ million	2025	2024
Cost of sales	-205	-211
Selling and marketing expenses	0	0
Administrative expenses	-8	-8
Research and development expenses	-1	-1
Total	-215	-220

Auditor fees


€ million	2025	2024
Audit	-2.8	-2.9
Audit-related services	-0.3	—
Tax advisory	0.0	-0.1
Other services	-0.4	-0.2
Total	-3.4	-3.2

PricewaterhouseCoopers has provided non-audit services to Outokumpu in total of EUR 0.6 million during

2025 (2024: EUR 0.3 million). These services comprised of Sustainability Statement audit and other

agreed-upon procedures.

Accounting principles

Cost of sales

Cost of sales includes expenses related to materials and supplies, energy, maintenance and

freight. Employee benefit expenses, depreciation and amortization and other expenses are

included to the extent they relate to operational activities.

Research and development costs

As a main rule, research and development costs are expensed as incurred. If development is

expected to generate future economic benefits for the Group, related costs are capitalized as

intangible assets and amortized on a systematic basis over their useful lives.

Repairs and maintenance costs

Ordinary repairs and maintenance is carried out to maintain operating conditions of the mills

and the equipment, and the related costs are expensed as they are incurred.

The costs of major repairs and renovations are included in the asset’s carrying amount as

capital expenditure when these activities are expected to generate future economic benefits for

the Group, for example in form of a longer useful life, a wider product range, a higher output, or

an improved quality, in excess of the originally assessed standard performance level.

Depreciation and amortization methods and useful lives of non-current assets

Depreciation and amortization methods as well as estimates for useful lives of different types of

intangible asset and property, plant and equipment items are described in note 4.1.


		150

2.4 Other operating income and expenses

Other operating income


€ million	2025	2024
Exchange gains and losses from foreign exchange derivatives	—	12
Market price gains and losses from commodity derivatives	3	11
Market price gains and losses from derivative financial instruments	3	23
Sale of services and rental income	8	9
Gains on sale of non-current assets	11	5
Gains from disposal of subsidiaries and businesses	—	3
Insurance compensation	1	1
Other income items	5	16
Total	28	57

Other operating expenses


€ million	2025	2024
Exchange gains and losses from foreign exchange derivatives	-3	-6
Market price gains and losses from commodity derivatives	0	-1
Market price gains and losses from derivative financial instruments	-3	-7
Impairments and impairment reversals in non-current assets	-7	7
Loss on disposal of shares in Group companies and businesses	—	-3
Loss on sale of non-current assets	-3	-4
Other expense items	5	-9
Total	-9	-15

In year 2025, gains on sale of non-current assets include the sale of a land area in Pori, Finland

and the sale of emission allowances.

In year 2025, the line Other expense items under Other operating expenses includes exchange

gains and losses on trade receivables and trade payables.

In 2024, other operating income includes EUR 3 million of gains from disposal of subsidiaries

and businesses, which is related to the sale of Mexico branch distribution business in Mexico

City, Guadalajara and Monterrey. More information on the disposal in note 6.2.

In 2024, other operating expenses include EUR 7 million of impairments and impairment

reversals in non-current assets, which is related to impairment reversals of right-of-use assets in

Germany.

Accounting principles

Other operating income and expenses include items such as gains or losses from disposals of

non-current assets or businesses, foreign exchange differences arising in respect of other

financial instruments than interest-bearing assets and liabilities and gains or losses from

derivative financial instruments that are not hedge accounted or do not relate to the Group’s

financing activities. Other operating income also includes rental and lease income, insurance

compensations and government and other grants and support. Other operating expenses

include also costs related to emission allowances and impairment losses related to non-current

assets.

Grants and other support are recognized as income over the same periods as the costs they

are intended to compensate. Investment grants related to purchases of non-current assets are

deducted from the cost of the asset and recognized as income on a systematic basis as a

reduction in depreciation or amortization over the useful life of the asset.


		151

2.5 Financial income and expenses


€ million	2025	2024
Interest income	7	11
Other financial income	3	2
Interest income and other financial income	9	13

Interest expenses
Debt at amortized cost	-15	-17
Factoring	-17	-22
Lease liabilities	-12	-13
Employee benefit obligations	-7	-7
Other interest expenses	-2	-6
Interest expenses	-54	-64

Fees related to committed credit facilities	-8	-7
Other fees	-3	-3
Other financial expenses	-11	-10

Exchange gains and losses
Derivatives	-93	64
Cash, loans and receivables	106	-50
Other market price gains and losses
Derivatives	2	5
Other	-3	1
Market price gains and losses	12	20

Total	-43	-41

Exchange gains and losses in the consolidated statement of income


€ million	2025	2024
In sales	—	-5
In purchases	—	-17
In other operating income and expenses¹⁾	-3	6
In financial income and expenses	13	14
Total	10	-2

¹⁾Year 2025 include exchange gains and losses on trade receivables and trade payables.

Exchange gains and losses

Outokumpu’s most significant foreign exchange transaction risk exposures are in US dollars and

Swedish krona.

Exchange gains and losses include EUR 96 million of net exchange loss on derivative financial

instruments (2024: EUR 71 million net exchange gain) of which a loss of EUR 3 million (2024:

EUR 6 million gain) has been recognized in other operating income and expenses and a loss of

EUR 93 million (2024: EUR 64 million gain) in financial income and expenses.

More information on foreign exchange positions in note 5.3.

Accounting principles

Financial income includes mainly interest income on cash and cash equivalents and defined

benefit plans.

Financial expenses include mainly interest expenses of borrowings, lease liabilities, factoring

and defined benefit plans.

Other income and expenses include fees related to commitment credit facilities and other

financial fees.

Exchange gains and losses include exchange and other market price gains and losses on

cash, debt and receivables and derivatives related to Group’s financing activities.

Exchange and other market price gains and losses on operative items and related derivative

instruments are recognized in EBIT. Exchange and other market price gains and losses on

financing items and related derivative instruments are recognized in financial income and

expenses.


		152

2.6 Income taxes

Income taxes in the consolidated statement of income


€ million	2025	2024
Current taxes	-9	-10
Deferred taxes	46	59
Total	36	49

Reconciliation of income taxes in the consolidated statement of income


€ million	2025	2024
Result before taxes	-174	-89
Income taxes at Finnish tax rate of 20%	35	18
Difference between Finnish and foreign tax rates	7	-1
Non-deductible expenses and tax exempt income	1	-5
Current year result for which no deferred tax asset has been recognized	—	0
Changes in deferred tax recognition	2	37
Group company disposals	—	-1
Taxes for prior years	0	1
Tax rate changes and other changes in tax laws	-9	0
Associated companies	1	1
Total	36	49

Accumulated deferred taxes recognized in equity


€ million	2025	2024
Deferred tax on convertible bonds equity component	—	0
Net investment hedging	-4	-4
Remeasurements of the net defined benefit liability	57	65
Derivatives	2	-2
Total	54	58


		153

Deferred tax assets and liabilities


	Jan 1, 2025	Movements				Dec 31, 2025
€ million	Net deferred tax assets (+) and liabilities (-)	Reclassifications	Recognized in profit or loss	Recognized in other comprehensive income or directly in equity	Translation differences	Net deferred tax assets (+) and liabilities (-)
Intangible assets	7	—	-2	—	0	5
Property, plant and equipment	-90	6	16	—	2	-66
Right-of-use assets	-34	-6	3	—	0	-37
Inventories	2	—	-1	—	0	0
Net derivative financial assets	-1	—	-3	4	0	0
Other financial assets	9	—	-1	—	0	8
Employee benefit obligations	21	0	-1	-8	0	12
Other financial liabilities	6	—	-2	—	0	4
Lease liabilities	44	—	-3	—	0	41
Provisions	13	0	3	—	0	16
Tax losses and tax credits	520	—	35	—	-38	518
Net deferred tax assets	498	0	46	-4	-37	502
Deferred tax assets	504					502
Deferred tax liabilities	-6					0


	Jan 1, 2024	Movements				Dec 31, 2024
€ million	Net deferred tax assets (+) and liabilities (-)	Reclassifications	Recognized in profit or loss	Recognized in other comprehensive income or directly in equity	Translation differences	Net deferred tax assets (+) and liabilities (-)
Intangible assets	8	—	-1	—	0	7
Property, plant and equipment	-97	-1	8	—	-1	-90
Right-of-use assets	-25	1	-10	—	0	-34
Inventories	-11	—	12	—	0	2
Net derivative financial assets	-3	—	2	0	0	-1
Other financial assets	6	—	3	—	0	9
Employee benefit obligations	26	—	-1	-4	0	21
Other financial liabilities	5	1	1	—	0	6
Lease liabilities	38	-1	7	—	0	44
Provisions	14	0	-1	—	0	13
Tax losses and tax credits	461	0	39	—	21	520
Net deferred tax assets	423	0	59	-5	21	498
Deferred tax assets	454					504
Deferred tax liabilities	-31					-6


		154

Tax losses and related deferred tax assets


	Tax losses carried forward		Recognized deferred tax assets		Unrecognized deferred tax assets
€ million	2025	2024	2025	2024	2025	2024
Expire in 2-5 years	0	—	0	—	—	—
Expire later than in 5 year	1,063	1,093	245	253	7	12
Never expire	1,107	1,056	273	267	—	—
Total	2,171	2,150	519	520	7	12

Tax losses by country


€ million	2025	2024
Finland	221	79
Germany	336	234
Sweden	206	197
The US	1,183	1,400
The UK	174	186
Other countries	50	54
Total	2,171	2,150

As of December 31, 2025, Outokumpu Group has recognized a deferred tax asset on all

material tax losses. The tax attributes of the Outokumpu Group for which no deferred tax asset

has been recognized relate to a portion of the US state tax losses which are estimated to expire

before utilization.

No deferred tax liabilities were recorded on undistributed profits of foreign subsidiaries, as such

profits are not to be distributed in the foreseeable future.

Outokumpu Group has remeasured its deferred tax due to an enacted corporate income tax rate

change in Germany. The tax rate change has a total effect of EUR -12 million on the deferred

tax assets as of December 31, 2025. For more information about the tax rate change see the

following section, management judgments.

Management judgments

Outokumpu operates and earns income in numerous countries and is subject to changes in tax

laws in multiple jurisdictions. When recognizing income tax liabilities, material judgments and

estimates need to be made on tax uncertainties.

In deferred tax asset recognition, the management assesses whether the realization of

future tax benefits is sufficiently probable to support the recognition. This assessment requires

judgment regarding, for example, realizable benefits from future taxable income, available tax

strategies, as well as other positive and negative factors. The recorded amount of deferred tax

assets could be reduced as a result of changes in these estimates or in tax regulations

imposing restrictions on the utilization of future tax benefits.

In year 2025 a change in the federal corporate income tax rate from 15% to 10% was

enacted in Germany. Reduction of tax rate will be implemented gradually, 1 %-point each year,

during 2028-2032. Since the tax rate change is enacted, Outokumpu is obliged to remeasure

the deferred tax balances taken into consideration the enacted future tax rate changes. This

calculation includes estimates and judgments by management.

Accounting principles

Current and deferred income taxes are determined on entity level to the extent an entity is

subject to income taxation. The income taxes in the consolidated statement of income include

the Group companies’ current income taxes based on taxable profit for the period, tax

adjustments for previous periods, and the change in deferred income taxes. In several countries

(Finland, Germany, the Netherlands, Sweden, and the US) Outokumpu companies are included

in income tax consolidation groups or group taxation systems. The share of results in

associated companies is reported in the statement of income based on the net result and thus

including the income tax effect.

Deferred income taxes are stated using the balance sheet liability method to reflect the net

tax effects of temporary differences between the assets and liabilities’ carrying amounts in the

Financial Statements and the corresponding tax basis at the reporting date, as well as for

unused tax loss or credit carry forwards.

Deferred tax assets are recognized for all deductible temporary differences to the extent that

it is probable that future taxable profits will be available for utilization of these differences. A

valuation allowance is recognized if the realization of the tax benefits is not probable. The

ability to recognize deferred tax assets is reviewed at the end of each reporting period.

Deferred tax liabilities are usually recognized in the statement of financial position in full.

As an exception, deferred tax liabilities are not recognized if they arise from initial

recognition of an asset or a liability in a transaction that is not a business combination and that

does not affect the accounting nor taxable profit at the time of the transaction.

Deferred taxes are calculated at the enacted or substantially enacted tax rates that are

expected to apply by the end of the reporting period. Generally, deferred tax is recognized to

the statement of income. However, if the taxes are related to items of other comprehensive

income or to transactions or other events recognized directly in equity, the related income taxes

are also recognized either in other comprehensive income or directly in equity, respectively.

The Group is within the scope of the OECD Pillar Two model rules. Pillar Two legislation was

implemented in Finland, the jurisdiction in which Outokumpu Corporation is incorporated, based

on the EU Directive, and is effective from January 1, 2024. The Group has not recognized any

tax expense related to the top-up tax in 2025. The Group has applied a temporary mandatory

relief from deferred tax accounting for the potential impacts of the top-up tax and would

account for it as a current tax if it would incur. Management assesses that the risk for any

future exposure to top-up tax for the Group is limited.


		155

2.7 Earnings per share


	2025	2024
Net result attributable to the equity holders of the parent company, € million	-137	-40
Interest expenses on convertible bonds, net of tax, € million	2	8
Adjusted net result attributable to the equity holders of the parent company, € million	-136	-31

Adjusted weighted average number of shares, in thousands	450,345	424,238
Adjusted diluted weighted average number of shares, in thousands	472,340	470,977

Earnings per share, €	-0.31	-0.09
Diluted earnings per share, €	-0.31	-0.09

Diluted earnings per share equals to earnings per share as potential ordinary shares have

antidilutive impact.

In 2025, Outokumpu cancelled a total of 30,836,205 own shares in relation to its convertible

bond conversions and converted the convertible bond into 47,046,505 shares, of which 67,916

shares were converted during the year 2023. More information is presented in note 5.1 and in

note 5.2.

In 2024, Outokumpu repurchased 8,357,545 treasury shares as part of share buyback program

which started in year 2023. More information on the program is presented in note 5.2.

Accounting principles

Basic earnings per share is calculated by dividing the net result attributable to

the equity holders of the company by the adjusted weighted average number of shares

outstanding during the period, excluding shares held by Outokumpu as treasury shares.

In a share issue, when shares are offered at discount compared to market price, the pro-

portion of the issue representing the discount is retrospectively adjusted to the weighted

average number of shares.

Diluted earnings per share is calculated by adjusting the adjusted weighted average number

of ordinary shares outstanding with the assumption that convertible instruments are converted.

The profit or loss used in the calculation is adjusted for the interest expense related to the

instrument and recognized in the period, net of tax. In addition, the shares estimated to be

delivered based on the share-based incentive programs are taken into account. However,

potential ordinary shares are only dilutive if the adjustments decrease the earnings per share

ratio.


		156

3. Employee benefits

3.1 Employee benefit expenses


€ million	2025	2024
Wages and salaries	-557	-547
Termination benefits	-60	-4
Social security costs	-99	-97
Post-employment and other long-term employee benefits
Defined benefit plans	-4	-3
Defined contribution plans	-52	-50
Other long-term employee benefits	-6	-7
Share-based payments	-1	-2
Other employee benefit expenses	-3	-4
Total	-782	-714

Total employee benefit

expenses EUR

-782 million

Number of personnel

at the end of period (FTE)

8,251

Employee benefit expenses, € million

Personnel on December 31, FTE

Outokumpu has redefined personnel, full time equivalent (FTE) measure in year 2024. FTE is excluding

interim workforce as of year 2023.


		157

3.2 Employee benefits for key management


€ thousands	2025	2024
Short-term employee benefits	4,624	4,677
Post-employment benefits¹⁾	669	614
Share-based payments	331	506
Remuneration to the Board of Directors	888	948
	6,512	6,745

¹⁾ Contains only supplementary pensions.

Key management includes nine (nine) positions in the Outokumpu Leadership Team and eight

(seven) members of the parent company Outokumpu Corporation’s Board of Directors. On

December 31, 2025, President and CEO, CFO, Presidents of the core business areas and

business lines, Chief Technology Officer and Executive Vice President, General Counsel are part

of the Outokumpu Leadership Team. The position of Executive Vice President, People,

Sustainability & Corporate Relations remains vacant until end of January 2026.

At the end of March 2025, Niklas Wass, President Business Line Stainless Europe, left

Outokumpu. His successor Matthieu Jehl started in August. Johann Steiner, Executive Vice

President, Sustainability, Strategy and People, moved to a new assignment in October. He

replaced Tamara Weinert in the role of President, Business Area Americas. Johann Steiner’s

previous role was adapted to Executive Vice President, People, Sustainability & Corporate

Relations and organized with interim arrangements until the start of the appointed successor

Anouk de Graaf in February 2026.

Key management shareholdings can be found in the Corporate Governance statement.


Employee benefits for the CEO	Recognized in profit or loss		Remuneration paid
€ thousands	2025	2024	2025	2024
Salaries and short-term benefits	930	964	930	964
Short-term incentives	200	106	—	622
Post-employment benefits	322	330	322	330
Share-based payments	249	35	225	507
	1,701	1,435	1,477	2,423

The CEO participates in the Finnish TyEL pension system. The post-employment benefits consist of the

statutory pension and the supplementary pension.

Remuneration paid to Board of Directors


€ thousands	2025	2024
Chairman Kari Jordan	202	203
Vice Chairman Jyrki Mäki-Kala	114	113
Vice Chairman Kati ter Horst, until September 30, 2024	—	121
Member Hilde Merete Aasheim, as of April 3, 2025	95	—
Member Heinz Jörg Fuhrmann	97	104
Member Olavi Huhtala, as of April 3, 2025	87	—
Member Päivi Luostarinen	91	92
Member Karl-Petter Söderström	91	92
Member Pierre Vareille, until April 3, 2025	8	107
Member Julia Woodhouse	105	117
Total	888	948

Remuneration of the CEO

The remuneration of the CEO consists of a base salary, benefits and an annually determined

short-term incentive plan. In addition, the CEO participates in long-term incentives comprising

performance share plans launched on a yearly basis.

In 2025, the CEO’s short-term incentive earning opportunity stayed unchanged at 50% of the

annual gross base salary on a target level and 100% on a maximum level. Kati ter Horst did not

receive a short-term incentive for 2024 results. She was paid a sign-on bonus in 2024.

In 2025, the long-term incentive target and maximum levels remained at 50% and respectively

75% of the annual base salary at time of grant. The CEO did not receive a share reward based

on the performance from 2022 to 2024. In 2025, she was delivered 50,000 restricted shares

(gross) and an additional 100,000 shares are to be delivered in 2026 and 2027, recognizing

lost incentives from her previous assignment. Long-term incentive will not be paid to the CEO

for the performance cycle 2023 to 2025.

The members of Outokumpu’s Leadership Team, including the CEO, are expected to own

Outokumpu shares they receive in the company’s share-based incentive programs

corresponding to at least the value of their annual gross base salary. Half of the net shares

received from the share-based incentive programs must be used to fulfil that ownership

recommendation.

The service contract of the CEO is valid until further notice. The notice period is 9 months for

Kati ter Horst. For the company, the notice period is 6 months, and the severance payment in

such a case is 12 months. Kati ter Horst’s retirement age is 65 years. Besides the

supplementary pension, she participates in the Finnish statutory pension system.


		158

Remuneration of the Board of Directors

Outokumpu’s Annual General Meeting approved the annual remuneration to the members of the

Board of Directors. 40% of the annual fee was paid in the company’s own shares using treasury

shares, unless a Board member already owned shares for a value exceeding the annual

remuneration and choose to increase their cash portion. The annual fee is paid once a year,

and in addition to the annual remuneration, all the members of the Board of Directors are paid

a fee for each meeting they attend. The members of the Board are not entitled to any other

share-based rewards. The Board members are not eligible for any pension schemes.

Accounting principles

Employee benefits for the key management include the benefits to each Leadership Team or

Board of Directors member for the time they hold these positions.

Employee benefits are presented based on expenses recognized in profit or loss during the

year on accrual basis except for the CEO whose remuneration is presented also based on paid

benefits during the year. The remuneration to Board of Directors is also presented on paid

basis.

Short-term incentives are recognized to profit or loss during the period they relate to whereas

bonuses are typically paid out during the following financial year. Expenses on share-based

payments are recognized to profit or loss at the share price on the grant date of the benefit and

over the period when the benefit is earned. Share-based benefits are reported as paid when

delivered and at the share price on the delivery date.

3.3 Employee benefit obligations

Outokumpu has several defined benefit and defined contribution plans in various countries. The

most significant defined benefit plans are in Germany and the UK, representing 43% and 53%

of the Group’s total defined benefit obligation, respectively.

Funding requirements of the defined benefit plans are generally based on the pension fund’s

actuarial measurement framework set out in the funding policies and local regulation.

Germany

Outokumpu has several defined benefit plans in Germany, of which major plans include a

management plan, open pension plans for other staff, and other pension obligations, which are

nearly all closed for new entrants. Basis to all pension obligations in Germany are bargaining

agreements and/or individual contracts (management obligations). The management plan and

other pension obligations are based on annuity payments, whereas plans for other employees

are based on one lump sum payment after retirement.

In addition, all the obligations in Germany are embedded in the BetrAVG law. The law contains

rules for vested rights, pension protection scheme and regulations for the pension adjustments.

In Germany, no funding requirements exist, and the plans are funded only for a small part with a

CTA model (Contractual Trust Arrangement) that was introduced in 2019.

The UK

The AvestaPolarit Pension Scheme (the Scheme) is registered under UK legislation and is

contracted out of the State Second Pension. The Scheme is subject to the funding

requirements outlined in UK legislation. The Scheme’s trustee is responsible for the operation

and governance of the Scheme, including decisions regarding the Scheme’s funding and

investment strategy.

In December 2021, a GBP 390 million buy-in contract was implemented. This buy-in completed

the Scheme’s de-risking process which began with an initial buy-in in 2020, when a GBP 110

million buy-in insurance solution was implemented.

A buy-in removes risks of investment, longevity, interest rate changes and inflation for the

Scheme and is held as a Scheme asset. Until a buy-out is secured, the Scheme ultimately

remains the responsibility of Outokumpu Stainless Ltd.

However, as a result of the buy-in arrangement, the risks related to the Scheme’s obligation are

now significantly reduced and mostly covered by insurance. Outokumpu has agreed with the

trustees to hold cash in an escrow account to provide for small mismatches in the insurance

coverage and liquidity to the scheme.

At year-end 2025, the escrow balance was GBP 11 million (2024: GBP 12 million). The

actuarial gains in 2025 amounted to EUR 4.1 million (2024 EUR 2.1 million actuarial gains).

Due to the buy-in solutions, no further contributions are expected to be required because of the

triennial valuations. The latest valuation for this purpose was completed in 2024.


		159

Outokumpu has decided to commence with the buy out of the scheme with a targeted

completion at the end of 2027. Outokumpu will formally trigger the process in 2026 based on

pension scheme requirements, but initial project work has already commenced to ensure an

effective transition.

Defined benefit cost in profit or loss and other comprehensive income


€ million	2025	2024
In employee benefit expenses in operating profit (EBIT)	-4	-3
In financial income and expenses	-6	-7
Defined benefit cost in profit or loss	-10	-9
In other comprehensive income	20	12
Total defined benefit cost	10	3

Gross defined benefit obligations and plan assets


€ million	2025	2024
Present value of funded defined benefit obligations	468	506
Present value of unfunded defined benefit obligations	1	1
Fair value of plan assets	-324	-333
Net defined benefit liability	146	174

Amounts recognized in the consolidated statement of financial position


€ million	2025	2024
Net defined benefit liability	146	174
Other long-term employee benefit liabilities	22	22
Employee benefit obligations in statement of financial position	169	196

Gross defined benefit obligations and plan assets are presented in the statement of financial position

netted per plan either as a liability or an asset depending on nature of the netted item.

Movement in net defined benefit liability


			2025		2024
€ million	Present value of obligation	Fair value of plan assets	Net defined benefit liability	Present value of obligation	Fair value of plan assets	Net defined benefit liability
Total on Jan 1	507	-333	174	524	-330	193
Current service cost	3	—	3	3	—	3
Past service cost	—	—	—	0	—	0
Interest expense/(income)	22	-15	6	21	-15	7
Remeasurements arising from
Return on plan assets	—	-4	-4	—	10	10
Demographic assumptions	0	—	0	-3	—	-3
Financial assumptions	-20	—	-20	-39	—	-39
Experience adjustment	4	—	4	20	—	20
Exchange differences	-14	13	-1	13	-13	0
Employer contributions	0	-17	-17	0	-17	-17
Benefits paid	-32	32	—	-31	31	—
Settlements	0	1	1	0	—	0
Total on Dec 31	470	-324	146	507	-333	174

Germany on Dec 31	204	-72	132	224	-67	157
The UK on Dec 31	249	-248	1	266	-262	4

The weighted average duration of the overall defined benefit obligation is 11.4 years (2024:

12.4 years). In Germany and in the UK, the weighted average durations are 9.8 and 13 years

(2024: 10.8 and 14.0 years) respectively.

Discount rates, rising inflation and increasing retirement age have material impact on financial

assumptions and remeasurement amounts.

The expected contributions to be paid to the defined benefit plans in 2026 are EUR 16 million

and relate mainly to the German plans.


		160

Allocation of plan assets


€ million	2025	2024
Cash and cash equivalents	5	2
Insurance policies	247	264
Other assets	72	67
Total plan assets	324	333

On December 31, 2025, 1.5% of the plan assets were invested in quoted instruments (Dec 31, 2024:

0.7%).

Significant actuarial assumptions


		Germany	The UK	Other countries
Discount rate, %	2025	3.94	5.50	7.65
	2024	3.36	5.50	8.09
Future salary increase, %	2025	—	—	4.50
Future salary increase, %	2024	—	—	4.50
Inflation rate, %	2025	2.20	2.85	3.48
Inflation rate, %	2024	2.30	3.15	3.46
Future benefit increase, %	2025	2.20	2.40	2.06
Future benefit increase, %	2024	2.30	2.65	2.05
Medical cost trend rate, %	2025	—	—	7.90
Medical cost trend rate, %	2024	—	—	9.20
Life expectancy	2025	RT 2018 G mortality tables	96% SAPS All Pensioner Amounts tables with CMI Core Projection Model - 2024	Standard mortality tables
Life expectancy	2024	RT 2018 G mortality tables	96% SAPS All Pensioner Amounts tables with CMI Core Projection Model - 2023	Standard mortality tables

Sensitivity analysis of significant actuarial assumptions


	Change in assumption	Germany, %			The UK, %			Other countries, %
2025
Discount rate	+/-0.5%	-5	/	+5	-6	/	+6	-3	/	+3
Future benefit increase ¹⁾	+/-0.5%	+2	/	-2	+4	/	-4	+2	/	-2
Medical cost trend rate	+/-0.5%	—	/	—	—	/	—	+9	/	-8
Future salary increase ¹⁾	+/-0.5%	—	/	—	—	/	—	+3	/	-3
Life expectancy	+ 1 year	—	/	+2	—	/	+3	—	/	+7

2024
Discount rate	+/-0.5%	-5	/	+5	-6	/	+7	-3	/	+3
Future benefit increase ¹⁾	+/-0.5%	+2	/	-2	+5	/	-5	+2	/	-2
Medical cost trend rate	+/-0.5%	—	/	—	—	/	—	+9	/	-8
Future salary increase ¹⁾	+/-0.5%	—	/	—	—	/	—	+3	/	-3
Life expectancy	+ 1 year	—	/	+3	—	/	+3	—	/	+7

Sensitivity is presented for reasonably possible change at the reporting date in one of the principal

assumptions, while holding all other assumptions constant.

¹⁾Significant actuarial assumption inflation rate is linked to future benefit and future salary increase.

Other long-term employee benefits

Other long-term employee benefits mainly relate to early retirement provisions in Germany and

long-service remunerations in Finland.

Under the German early retirement regulations, employees are able to retire a certain number

of years prior to their earliest pensionable age (passive phase). During a period equal in length

to the passive phase they will be working full-time with their net salary cut to 50% of their

former regular salary (active phase). During both phases the employer supplements the net

salary to match a defined percentage of the employee‘s former regular net salary. Under the

long-service remunerations in Finland, the employees are entitled to receive a one-time

indemnity every five years after 20 years of service.

Multi-employer defined benefit plans

ITP pension plans operated by Alecta in Sweden and plans operated by Stichting

Bedrijfspensioenfonds voor de metaalindustrie in the Netherlands are multi-employer defined

benefit pension plans. However, it has not been possible to get sufficient information for the

calculation of obligations and assets by employer from the plan operators, and therefore these

plans have been accounted for as defined contribution plans in the consolidated Financial

Statements.


		161

Risk information

Through its defined benefit plans, Outokumpu is exposed to a number of risks, the most

significant of which are detailed below.

Asset volatility: The level of equity returns is a key factor in the overall investment return. If a

plan holds significant proportion of equities, which are expected to outperform corporate bonds

in the long-term, it might face higher volatility and risk in the short-term. The investment

portfolio might also be subject to a range of other risks typical of the assets held, in particular

credit risk on bonds and exposure to the property market.

Change in bond yields: A decrease in corporate bond yields will increase plan liabilities,

although this will be partially offset by an increase in the value of the plan’s bond holdings (if

any). In a situation where the return on plan assets is lower than the corporate bond yields, a

plan may face a shortfall which might lead to increased contributions.

Inflation risk: Inflation rate is linked to both future pension and salary increase, and higher

inflation will lead to higher liabilities.

Longevity: The majority of Outokumpu’s defined benefit obligations are to provide benefits

for the life of the member, so increases in life expectancy will result in an increase in the plans’

liabilities.

The buy-in solutions implemented in the UK in 2021 and 2020 significantly reduce the

earlier-mentioned risks for the Scheme, which is mostly covered by insurance.

Management judgments

The present value of pension obligations is subject to actuarial assumptions which are used in

calculating these obligations. These assumptions include, among others, discount rate, the

annual rate of increase in future compensation levels, inflation rate and employee turnover

rate. The assumptions are proposed by external independent actuaries separately for each

defined benefit plan or each country where Outokumpu has defined benefit plan and approved

by the management.

Accounting principles

The Group companies in different countries have various post-employment benefit plans in

accordance with local conditions and practices. The plans are classified as either defined

contribution plans or defined benefit plans.

The fixed contributions to defined contribution plans are recognized as expense in the period

to which they relate. The Group has no legal or constructive obligation to pay further

contributions if the receiving party is not able to pay the benefits in question. All such

arrangements that do not meet these requirements are defined benefit plans.

Defined benefit plans are funded with payments to the pension funds or insurance

companies. The present value of the defined benefit obligations is determined separately for

each plan by using the projected unit credit method. The liability recognized in the statement of

financial position is the defined benefit obligation less the fair value of plan assets at the

closing date. When the fair value of plan assets exceeds the value of the obligation, the net

amount is recognized as defined benefit plan assets.

Current service costs, past service costs and gains or losses on settlements are recognized

in functional costs above EBIT. Net interest expense or income is recognized in financial items

under interest expense or interest income. All remeasurements of the net defined benefit

liability (asset) are recognized directly in other comprehensive income.

Buy-in contract in the UK does not result in a settlement because Outokumpu remains

responsible for the benefit obligation. The buy-in contract is effectively an investment by which

the plan can receive payments from the insurer corresponding to the benefits due to the

participants, but ultimately the primary obligation to pay benefits has not been transferred.

For other long-term employee benefits, all service costs and remeasurements are recognized

immediately in the statement of income. Interest expenses are recognized in financial items

under interest expenses.

The significant actuarial assumptions are presented separately for the most significant

countries, and for other countries a weighted average of the assumptions is presented.


		162

3.4 Share-based payments

Share-based programs are part of the Group’s incentive and commitment-building system for

key employees. The objectives are to align the interests between key employees and

shareholders, promote shareholder value creation and the achievement of long-term strategic

targets.

Outokumpu operates two share-based programs. The Performance Share Plan (PSP) includes an

earning criterion and is part of the regular compensation of top executives, with a maximum

number of participants of 200. The Restricted Share Pool (RSP) does not have any specific

earning criterion and it is used for a limited number of employees, for key recruitments,

exceptional performance, high potential, retention needs and other individual specific

situations.

For the financial year 2025, the share-based payment expenses included in the employee

benefit expenses were EUR 1 million (2024: EUR 2 million). The total estimated value of the

share-based payment plans is EUR 4 million on December 31, 2025 (2024: EUR 7 million). This

value is recognized as an expense in the statement of income during the vesting periods.

Outstanding programs

During 2025, Outokumpu's share-based payment programs include Performance Share Plan

(periods 2023–2025, 2024–2026 and 2025–2027) and Restricted Share Pool (periods 2023–

2025, 2024–2026 and 2025–2027).

In December 2025, the Board of Directors has approved the commencement of Outokumpu’s

share-based programs, Performance Share Plan and Restricted Share Pool, for the period

2026–2028. The plans commence at the beginning of 2026.

Vested programs

In 2025, the Performance Share Plan 2022–2024 ended with the targets achieved by 85.4%,

and after deduction for the applicable taxes, a total of 328,765 shares were delivered to the

89 participants. From the Restricted Share Pool 2022–2024, after deductions for applicable

taxes as the last installment of three, in total 106,949 shares were delivered to the 64

participants. From the Restricted Share Pool 2023–2025, after deductions for applicable taxes

as the second installment of three, in total 35,997 shares were delivered to the 52

participants. From the Restricted Share Pool 2024–2026, after deductions for applicable taxes

as the first installment of three, in total 72,493 shares were delivered to the 72 participants.

Shares were delivered in February 2025, and Outokumpu used its treasury shares for the

reward payments.

Share-based payment opportunity


Maximum number of shares Dec 31, 2025	2026	2027	2028	Total

PSP 2023-2025	2,022,450	—	—	2,022,450
RSP 2023-2025	51,102	—	—	51,102
	2,073,552	—	—	2,073,552

PSP 2024-2026	—	2,532,750	—	2,532,750
RSP 2024-2026	161,083	141,084	—	302,167
	161,083	2,673,834	—	2,834,917

PSP 2025-2027	—	—	3,520,050	3,520,050
RSP 2025-2027	74,201	74,201	84,198	232,600
	74,201	74,201	3,604,248	3,752,650

Total	2,308,836	2,748,035	3,604,248	8,661,119


		163

The general terms and conditions of the outstanding share-based incentive programs


	Performance Share plan
	PSP 2023-2025	PSP 2024-2026	PSP 2025-2027
Grant date	March 10, 2023	March 11, 2024	March 21, 2025
Vesting period	Jan 1, 2023-Mar 31, 2026	Jan 1, 2024-Mar 31, 2027	Jan 1, 2025-Mar 31, 2028
Number of participants	164	185	192
Share price at grant date, €	5.68	3.83	3.78
Exercised	In shares and cash in 2026	In shares and cash in 2027	In shares and cash in 2028
Vesting conditions
Non-market	Return on capital employed (80%), CO2 emissions per ton of crude steel produced (20%)	Return on capital employed (80%), CO2 emissions per ton of crude steel produced (20%)	Return on capital employed (80%), CO2 emissions per ton of crude steel produced (20%)
Other relevant conditions	Continuation of employment until the shares are delivered, a salary based limit for the maximum benefits

	Restricted Share Pool Program
	RSP 2023-2025	RSP 2024-2026	RSP 2025-2027
Grant date	March 10, 2023	March 11, 2024	March 21, 2025
Vesting period	Jan 1, 2023-Mar 31, 2026	Jan 1, 2024-Mar 31, 2027	Jan 1, 2025-Mar 31, 2028
Number of participants	49	72	59
Share price at grant date, €	5.68	3.83	3.78
Exercised	In shares and cash in 3 installments in 2024, 2025 and 2026	In shares and cash in 3 installments in 2025, 2026 and 2027	In shares and cash, either in full in 2028 or in 3 installments in 2026, 2027 and 2028
Vesting conditions	Continuation of employment until the shares are delivered, a salary-based limit for the maximum benefits

Detailed information of the share-based incentive programs can be found in Outokumpu’s home page www.outokumpu.com.

Management judgments

In valuing the share-based payment plans, the management estimates the likelihood of

achieving the non-market performance criteria and the number of participants remaining in the

plan when the vesting period ends.

The evaluation of the likelihood of achieving the non-market performance criteria uses

mainly external financial forecasts but also internal forecasts are used. The number of

participants remaining in plans at the end of the vesting period is estimated based on historical

forfeit ratios of similar plans. Also potential impacts from restructuring activities carried out in

the Group are considered in the estimate.

Accounting principles

The share-based payments are settled net of tax withholding, and they are accounted as fully

equity-settled. The expense of the programs recognized over vesting periods is based on the

grant date fair value and is reported as employee benefit expenses within the administrative

expenses in profit or loss.

Applicable statistical models are used in valuation, and the valuation is revised at the end of

each reporting period based on the likelihood of achieving the non-market performance criteria

and the estimated retention rate of the participants.

The salary-based maximum limits for the pay-outs have been taken into account in the

valuation of the benefits.


		164

4. Operating assets and liabilities

4.1 Intangible assets and property, plant and equipment

Intangible assets


2025 € million	Goodwill	Other intangible assets	Total
Historical cost on Jan 1, 2025	473	370	843
Translation differences	-1	-1	-1
Additions	—	17	17
Disposals	—	-79	-79
Reclassifications	—	-11	-11
Historical cost on Dec 31, 2025	473	296	769

Accumulated amortization and impairment on Jan 1, 2025	-16	-247	-263
Translation differences	1	0	1
Amortization	—	-14	-14
Disposals	—	69	69
Reclassifications	—	11	11
Accumulated amortization and impairment on Dec, 31, 2025	-16	-180	-196

Carrying value on Dec 31, 2025	457	116	573
Carrying value on Jan 1, 2025	457	123	580

In 2025, additions to the other intangible assets are mainly related to the ERP implementation

project. Disposals include IT system disposals and the sale of emission allowances.

Capital expenditure, € million

Inventories, € million

Return on capital employed, %


		165

Emission allowances

Outokumpu had the following active sites operating under EU’s Emissions Trading Scheme (EU

ETS) in 2025: production plants in Tornio, Finland; Avesta, Degerfors and Nyby in Sweden; as

well as Krefeld together with Dillenburg in Germany. All Outokumpu sites met the compliance

requirements on time in 2025.

The pre-verified carbon dioxide emissions under EU ETS were approximately 0.9 million tonnes

in 2025 (2024: 0.8 million tonnes). For its 2025 emission allowance delivery, Outokumpu will

use allowances received for free and allowances acquired from the market in prior years. The

cost of usage has been recognized as other operating expenses. During 2025, Outokumpu

Corporation sold externally 150,000 tons of emission allowances with selling value of EUR 13

million. During 2025, Outokumpu did not buy externally emission allowances (2024: 173,861

tons with purchase value of EUR 10 million)

The Group’s emission position is composed of realized and forecasted carbon emissions netted

against confirmed and forecasted emission allowances granted by governments. All relevant

Outokumpu sites applied for free emission allowances for Phase IV trading period according to

the efficiency-based benchmarks and historical activity. The allocations for the second part of

the trading period (2026-2030) are currently pending for approval by EU Commission. The pre-

verified number of free allowances combined with the allowances held from prior period are

adequate to cover the forecasted needs of EU emission allowances for the rest of the trading

Phase IV (2021–2030).

The emission allowance price risk is presented in note 5.3 under Energy price risk.


2024 € million	Goodwill	Other intangible assets	Total
Historical cost on Jan 1, 2024	472	332	804
Translation differences	1	0	1
Additions	—	39	39
Disposals	—	-3	-3
Reclassifications	—	2	2
Historical cost on Dec 31, 2024	473	370	843

Accumulated amortization and impairment on Jan 1, 2024	-15	-234	-249
Translation differences	-1	0	-1
Amortization	—	-14	-14
Disposals	—	1	1
Reclassifications	—	-1	-1
Accumulated amortization and impairment on Dec, 31, 2024	-16	-247	-263

Carrying value on Dec 31, 2024	457	123	580
Carrying value on Jan 1, 2024	457	98	556

In 2024, additions to other intangible assets are mainly related to ERP implementation project

and purchases of emission allowances.


		166

Property, plant and equipment


2025 € million	Land	Mine properties	Buildings	Machinery and equipment	Other tangible assets	Advances paid and construction work in progress	Group
Historical cost on Jan 1, 2025	70	326	1,261	4,296	137	256	6,345
Translation differences	-2	—	-20	-76	1	-4	-101
Additions	—	1	0	9	4	120	134
Disposals	0	—	-1	-62	-4	0	-68
Reclassifications	0	36	-11	71	28	-115	9
Other	0	—	0	0	—	0	0
Historical cost on Dec 31, 2025	67	363	1,230	4,237	165	257	6,320

Accumulated depreciation and impairment on Jan 1, 2025	-6	-73	-908	-3,325	-98	—	-4,410
Translation differences	0	—	12	51	-1	—	62
Disposals	—	—	1	59	4	—	63
Depreciation	—	-11	-35	-110	-5	—	-161
Impairments	—	—	—	-7	—	—	-7
Reclassifications	0	—	-4	21	-25	—	-8
Other	—	—	0	0	0	—	0
Accumulated depreciation and impairment on Dec 31, 2025	-6	-84	-934	-3,312	-124	—	-4,461

Carrying value on Dec 31, 2025	61	279	296	925	41	257	1,859
Carrying value on Jan 1, 2025	63	253	353	971	39	256	1,935

Reclassifications include transfers from advances paid and construction work in progress to other asset classes as well as transfers between other assets classes.

Cash flow item Purchases of property, plant and equipment includes grants received amounting to EUR 9 million.


		167


2024 € million	Land	Mine properties	Buildings	Machinery and equipment	Other tangible assets	Advances paid and construction work in progress	Group
Historical cost on Jan 1, 2024	70	307	1,228	4,240	131	174	6,150
Translation differences	1	—	10	37	0	3	51
Additions	—	0	1	9	1	172	184
Disposals	-1	—	-2	-39	-1	0	-43
Reclassifications	-1	19	23	48	7	-93	3
Other	—	—	0	0	0	0	0
Historical cost on Dec 31, 2024	70	326	1,261	4,296	137	256	6,345

Accumulated depreciation and impairment on Jan 1, 2024	-7	-56	-847	-3,246	-88	—	-4,244
Translation differences	0	—	-6	-25	0	—	-30
Disposals	—	—	1	35	1	—	37
Depreciation	—	-17	-40	-105	-6	—	-168
Impairments	—	—	0	0	—	—	0
Reclassifications	1	—	-16	17	-6	—	-4
Other	—	—	0	0	0	—	0
Accumulated depreciation and impairment on Dec 31, 2024	-6	-73	-908	-3,325	-98	—	-4,410

Carrying value on Dec 31, 2024	63	253	353	971	39	256	1,935
Carrying value on Jan 1, 2024	63	251	381	994	43	174	1,905

Reclassifications include transfers from advances paid and construction work in progress to other asset classes as well as transfers between historical cost and accumulated depreciation and impairment.

Intangible assets and property, plant and equipment by geographical region


€ million	2025	2024
Finland	1,544	1,563
Other Europe	515	518
North America	366	426
APAC region	6	8
Other countries	0	0
	2,432	2,515

Capitalized interest expenses

There were no capitalization of borrowing costs on investment projects during 2025 nor in

comparison year. Total capitalized interests on December 31, 2025 were EUR 21 million (Dec

31, 2024: EUR 22 million).

Management judgments

Management estimates relating to useful lives and recoverable amounts affect significantly the

intangible asset and property, plant and equipment values in the consolidated statement of

financial position, and different assumptions and assigned lives could have a material impact

on the reported amounts.

Carrying amounts of intangible asset and property, plant and equipment items are regularly

reviewed for any indication of impairment. If any such indication emerges, the asset’s

recoverable amount is assessed, which requires estimation of future cash flows attributable to

the asset and related valuation parameters.

Indications for changes in useful lives are reviewed annually, and if changes to previous

estimates are identified, the useful lives are revised accordingly. If an impairment loss is

recognized, the estimated useful life of the asset is also reassessed.


		168

Accounting principles

Intangible assets other than goodwill include capitalized development costs, patents, licenses

and software. These assets comprise mainly acquired assets that typically have definite useful

lives. An intangible asset is recognized if it is probable that the asset will generate future

economic benefits to the Group and the cost of the asset can be measured reliably.

Property, plant and equipment consist mainly of facilities, machinery and equipment used in

stainless steel and ferrochrome production.

Intangible assets and property, plant and equipment are recognized initially at cost. Cost

comprises of the asset’s purchase price and all costs directly attributable to bringing the asset

ready for its intended use. Government grants received for investment purposes are deducted

from the asset’s cost. Intangible assets and property, plant and equipment acquired in a

business combination are measured at fair value at the acquisition date.

Borrowing costs (mainly interest costs) directly attributable to the acquisition of an asset are

capitalized in the statement of financial position as part of the asset’s carrying amount, when it

takes a substantial period of time to get the asset ready for its intended use.

After initial recognition, intangible assets and property, plant and equipment are measured

at cost less accumulated amortization, depreciation and impairment losses. Intangible assets

and property, plant and equipment, other than land and mine properties, are amortized or

depreciated on a straight-line basis over their expected useful lives. Assets tied to a certain

fixed period are amortized over the contract term.

Amortization of intangible assets is based on the following estimated useful lives:

Softwareup to 10 years

Capitalized development costs up to 10 years

Intangible rightsup to 20 years

Depreciation of property, plant and equipment items is based on the following estimated useful

lives:

Buildings25–40 years

Heavy machinery15–30 years

Light machinery and equipment 3–15 years

Self-owned land is not depreciated, as the useful life of land is assumed to be indefinite.

Mine properties include preparatory work to utilize an ore body or a portion thereof, such as

shafts, ramps, ventilation and other infrastructure necessary for mining operations. Mine

properties are depreciated using the units-of-production method, which allocates the

depreciable amount based on the extraction of proven and probable ore reserves over their

estimated useful lives. Reserve estimates are reviewed annually, and depreciation rates are

adjusted prospectively to reflect changes in expected production or reserve quantities.

Other tangible assets include items such as land improvements, asset retirement obligations

related to landfill areas and infrastructure within the facilities, such as roads and railroads.

Recognition of amortization or depreciation on an asset is ceased when the item is classified

as held for sale.

If indication regarding an impairment of an asset is identified, the asset’s recoverable

amount is estimated as the higher of the fair value less costs to sell or the value in use. If the

carrying amount of an asset exceeds its recoverable amount, an impairment loss is recognized.

A previously recognized impairment loss is reversed if there is a change in the recoverable

amount. However, the reversal must not result in a higher carrying amount than what it would

have been if no prior impairment loss had been recognized. Impairment losses are presented as

other operating expenses in the consolidated statement of income.

Gains or losses on disposals of property, plant and equipment or intangible assets are

determined as the difference between the net proceeds received and the carrying amount of

the asset. These gains or losses are presented in other operating income or expenses.

Goodwill

Goodwill arises from business combinations and is recognized at the acquisition date

at the amount excess of the consideration transferred over the fair value of the identifiable

assets acquired, liabilities assumed and any non-controlling interest and any previously held

equity interests in the acquiree. Goodwill is not amortized but tested for impairment. Goodwill is

measured at cost less accumulated impairment losses. Impairment losses on goodwill cannot

be subsequently reversed.

See note 4.3 for goodwill impairment testing.

Emission allowances

Emission allowances are reported as other intangible assets. They are measured at cost and

initially recognized when control is obtained. Allowances received free of charge are recognized

at nominal value, i.e. at zero carrying amount. Emission allowances are derecognized against

the actual emissions, or when the emission allowances are sold.

Emission allowance expense is recognized when emission allowances received free of charge

do not cover the annual emissions for the difference based on the cost of the purchased

allowances. In case the Group does not hold sufficient allowances to cover the actual

emissions, a provision regarding the obligation to return the emission allowances is recognized

at fair value at the end of the reporting period. The expenses are presented as other operating

expenses. Gains from the sale of emission allowances are recognized as other operating

income.


		169

4.2 Leases

Outokumpu leases land, buildings, and machinery and equipment used in the Group’s

operations. Outokumpu has also entered into service and supply contracts that contain lease

elements. Approximately 70 percent of the Group’s right-of-use assets are linked to an index or

a rate, making the related lease payments variable. The terms of new vehicle leases are

typically 3 to 5 years, and lease terms for other machinery and equipment range up to 15

years. Lease terms for land and buildings can be significantly longer with the remaining terms

for individual contracts on land of approximately 40–90 years. Leases for machinery and

equipment include also contracts with variable lease payments based on usage of the

equipment. Machinery and equipment are also hired with daily rates for temporary use, in which

case they are reported as short-term leases. Most of the right-of-use assets are in Finland,

totaling EUR 118 million.

Right-of-use assets


2025 € million	Land	Buildings	Machinery and equipment	Advances paid and other tangible assets	Total
Historical cost on Jan 1, 2025	36	39	223	1	299
Additions	—	9	17	0	26
Reclassifications	—	0	0	—	1
Other changes	0	0	3	0	3
Historical cost on Dec 31, 2025	36	49	243	1	329

Accumulated depreciation and impairment on Jan 1,2025	-6	-24	-89	0	-119
Depreciation and impairments	-1	-4	-36	0	-41
Reclassifications	—	0	0	—	-1
Other changes	0	0	5	0	5
Accumulated depreciation and impairment on Dec 31, 2025	-7	-28	-120	-1	-156

Carrying value on Dec 31, 2025	29	20	123	1	173
Carrying value on Jan 1, 2025	30	15	134	1	179


		170


2024 € million	Land	Buildings	Machinery and equipment	Advances paid and other tangible assets	Total
Historical cost on Jan 1, 2024	36	41	179	1	257
Additions	—	5	51	0	56
Reclassifications	1	1	0	0	1
Other changes	0	-9	-7	-1	-16
Historical cost on Dec 31, 2024	36	39	223	1	299

Accumulated depreciation and impairment on Jan 1, 2024	-5	-30	-75	-1	-110
Depreciation and impairments	-1	3	-33	0	-31
Reclassifications	-1	-1	0	0	-1
Other changes	—	4	19	1	23
Accumulated depreciation and impairment on Dec 31, 2024	-6	-24	-89	0	-119

Carrying value on Dec 31, 2024	30	15	134	1	179
Carrying value on Jan 1, 2024	30	11	104	1	147

In 2024, Outokumpu took into use three cargo vessels leased from Langh Ship. Additions include EUR 39 million related to these contracts.

Lease receivables


€ million	2025	2024
Non-current	5	6
Current	1	1
Total	6	7

Lease liabilities


€ million	2025	2024
Non-current	156	167
Current	43	38
Total	199	206

Maturity analysis of lease liabilities is presented in note 5.1.

Lease expenses


€ million	2025	2024
Depreciation	-41	-38
Impairments and impairment reversals	0	7
Interest expenses	-12	-13
Expenses on short-term and low-value leases	-23	-25
Total	-76	-68

In 2024, the impairment reversal of EUR 7 million is related to a lease contract in Germany.

Lease cash flows


€ million	2025	2024
Repayments	-42	-38
Interest paid	-12	-13
Total	-54	-50


		171

Management judgments

Management judgment and estimates relate mainly to incremental borrowing rates of the Group

companies, the probabilities of utilizing extension options in lease contracts and lease terms

applied for contracts that are valid until further notice, which impact the reported amounts of

lease liabilities and right-of-use assets.

The incremental borrowing rates are defined as part of the process to determine interest

rates for intra-group lending, in which Outokumpu defines synthetic ratings for the subsidiaries.

The incremental borrowing rate takes into account the currency, the maturity of the lease

liability, the credit risk of the lessee based on the synthetic rating, and country risk.

The contracts with extension options are reviewed regularly to evaluate the probability of

utilization based on information available.

Contracts that are valid until further notice represent only a small amount of Group’s lease

contracts, as most contracts have a fixed term. The lease terms for the contracts that are valid

until further notice are either defined based on the Group’s mid-term planning cycle of 3 years

or treated as short-term depending of the type of the asset.

The Group applies materiality in defining low-value items for lease accounting purposes.

Accounting principles

Group as a lessee

Lease liabilities measured at the present value of future lease payments are recognized to the

statement of financial position. In determining the present value of the lease liabilities, the

fixed and index/rate-based lease payments are discounted with the interest rate implicit to the

lease when available, or with the incremental borrowing rate of the company.

Lease payments are divided into interest expense and repayment of the lease liability. Lease

contracts may include options to extend the contract term or purchase the leased asset at the

end of the lease term. Lease term is determined as the non-cancellable period of the lease

taking into consideration the options to extend and terminate if it is reasonably certain that the

Group will exercise the extension option or will not exercise the termination option.

Leased assets are presented in the balance sheet as a separate line item. Right-of-use

assets recognized to the statement of financial position are measured at the amount of lease

liability and lease payments made in advance, less accumulated depreciation and impairments.

Right-of-use assets are depreciated on a straight-line basis over the lease term, or over the

expected useful life of the asset in case the asset will transfer to Outokumpu at the end of the

lease term or it is highly probable that a purchase option will be used.

Lease liabilities are presented as part of non-current and current debt in the consolidated

statement of financial position. Lease liabilities are part of the net debt calculation.

Lease liabilities or right-of-use assets relating to short-term leases, leases of low value items,

or intangible assets are not recognized to the statement of financial position. Instead, related

payments are recognized as expense to the profit or loss.

Sale and lease-back

So-called sale and lease-back transactions by the Group in 2019 or later (i.e. in accordance

with IFRS 16) do not typically meet the IFRS 15 criteria of a sale, as Outokumpu typically

retains the control of the asset. Consequently, they do not meet the criteria of sale and lease-

back, either. The asset remains in Outokumpu’s property, plant and equipment at cost less

accumulated depreciation and impairments. The proceeds of the transaction are recognized as

other loans under non-current or current debt.

Sale and lease-back transactions carried out prior to 2019 have been treated according to

the accounting principles prevailing at the time.

Group as a lessor

At inception of a lease contract, an assessment is made whether the lease is a finance lease or

an operating lease. If the lease transfers substantially all of the risks and rewards incidental to

ownership of the asset, it is considered to be a finance lease, otherwise the lease is considered

to be an operating lease. The Group has no material finance lease contracts.

Rental income received from property, plant and equipment leased out by the Group under

operating leases is recognized on a straight-line basis over the lease term. Rental income is

presented as other operating income. The Group has no material income from operating lease

contracts.


		172

4.3 Goodwill impairment test

Goodwill by operating segment


	Goodwill
€ million	2025	2024
Europe	343	343
Ferrochrome	114	114
Total	457	457

Assumptions by operating segment


	Europe	Ferrochrome
2025
Weighted average cost of capital (WACC), pre-tax, %	9.9	10.0
Weighted average cost of capital (WACC), after-tax, %	7.9	8.1
Terminal growth rate, %	0.5	0.5

2024
Weighted average cost of capital (WACC), pre-tax, %	9.1	9.1
Weighted average cost of capital (WACC), after-tax, %	7.1	7.4
Terminal growth rate, %	0.5	0.5

Test results and sensitivities by operating segment


2025	Europe	Ferrochrome
Headroom, € million	685	122
After-tax WACC increase leading to impairment, %-points	2.6	1.2
EBITDA decrease leading to impairment, %	22	10
Terminal growth rate of zero leading to impairment	No	No

Headroom is the amount by which the recoverable amount determined based on the value-in-use analysis

exceeds the segment’s operating capital amount as at the impairment testing date.

Goodwill impairment testing

In 2025 and 2024, as a result of the impairment testing performed to Group’s cash-generating

units, no goodwill impairment losses were recognized. Goodwill impairment testing is carried out

on an operating segment level, as they correspond to the Group’s cash-generating units (CGUs)

and the goodwill allocation level.

The recoverable amounts of the cash-generating units are based on value-in-use calculations

that are prepared using discounted cash flow projections. These long-term projections are

based on the Group’s strategy approved by the Board of Directors and Outokumpu Leadership

team. The estimates include cash flow forecasts for the period 2026–2030 after which the

terminal value is calculated. The carrying amount to which the recoverable amount is compared,

is the operating capital of the segment.

The value-in-use calculation is highly sensitive to changes in key assumptions such as

estimated delivery volumes and estimated sales prices contributing to EBITDA estimates, as

well as discount rate.

Management judgments

Key assumptions of the value-in-use calculations include the discount rate, sales prices,

delivery volumes and the terminal value growth rate. Assumptions also include estimates on

capital expenditure development including decarbonization related investments, and impacts

related to on-going EVOLVE-strategy-implementation related initiatives.

Cash flow forecasts are discounted using the pre-tax weighted-average cost of capital

(WACC) as defined for Outokumpu. The components of WACC are the risk-free rate,

Outokumpu’s credit margin, the equity market risk premium, the equity beta for a peer group,

and the industry's median capital structure.

In general, management believes that the assumptions used in the value-in-use calculations

are conservative based on the current economic circumstances. Growth rates assumed for

stainless steel deliveries are generally lower than independent analysts’ view on long-term

market development.

Accounting principles

Goodwill is allocated to and tested for impairment on operating segment level, which

corresponds to the Group’s cash-generating units (CGUs), and the lowest level goodwill is

monitored. Impairment test is carried out on an annual basis, or more frequently if indication of

goodwill impairment exists.

In goodwill impairment testing, the recoverable amounts are based on value in use

determined by discounted future net cash flows expected to be generated by the cash-

generating unit. The discount rate used is a pre-tax rate that reflects the current market view on

the time value of money and the CGU-specific risks.

An impairment loss is the amount by which the carrying amount of the segment’s assets

exceeds its recoverable amount. Impairment losses are recognized first on goodwill and after

that on other intangible and tangible assets on a pro-rata basis. In the consolidated statement

of income impairments are presented in other operating expenses. Impairment losses related to

goodwill cannot be subsequently reversed.


		173

4.4 Inventories


€ million	2025	2024
Raw materials and consumables	613	684
Work in progress	612	723
Finished goods and merchandise	367	333
Advanced payments	16	25
Total	1,608	1,764

Reversal of write-downs related to net realizable value of EUR 3 million were recognized in the

profit or loss during 2025 (2024: reversal of write-downs of EUR 11 million).

In 2025, Outokumpu applies cash flow hedge accounting for three selected nickel hedging

programs out of which one impacts also inventory values. More details on commodity price risk

and hedge accounting are presented in notes 5.3 and 5.4.

Management judgments

Management judgment and estimates are applied in net realizable value (NRV) and inventory

obsolescence analysis.

NRV calculation requires estimates on sales prices for products to be sold in the future to

the extent the prices are not known, which can be a significant part of the future prices. Due to

fluctuations in nickel and other alloy prices, which are the most important commodity price

risks for Outokumpu, the realized prices can deviate significantly from the estimates used in

NRV calculations.

The alloy surcharge clause as well as daily fixed pricing of stainless steel reduce the risk

arising from the time difference between raw material purchase and product delivery. However,

the risk is still significant because the delivery cycle in production is longer than the alloy

surcharge mechanism expects and the daily fixed pricing can also deviate from this cycle

depending on the timing of the delivery.

Inventory obsolescence for stainless steel products is estimated based on internal guidelines

on slow-moving inventory.

Accounting principles

Inventories are stated at the lower of cost and net realizable value. These are defined with

different methodologies depending on the type of inventory.

The cost of raw materials is determined as the monthly weighted average of the actual raw

material cost. The cost of self-produced finished goods and work in progress comprises of raw

materials, direct labor, other direct costs and related production and procurement overheads.

Cost of purchased products includes all purchasing costs including direct transportation,

handling and other costs.

NRV is calculated as the estimated selling price in the ordinary course of business, less the

estimated costs of completion and the estimated costs attributable to the sale.

Obsolete stainless steel products are valued at scrap value. Spare parts are carried as

inventory and their cost is recognized in profit or loss as consumed.

Major spare parts are recognized in property, plant and equipment when they are expected

to be used over more than one year.


		174

4.5 Trade and other receivables and payables

Trade and other receivables


€ million	2025	2024
Non-current
Non-current receivables and accruals	9	10

Current
Trade receivables	329	389
VAT receivables	75	53
Escrow deposits	13	14
Prepaid insurance expenses	5	3
Other accruals	21	21
Other receivables	14	12
Total	457	492

Loss allowance on trade receivables
On Jan 1	6	5
Additions in loss allowance	4	2
Reclassifications	0	—
Reduction in loss allowance	0	0
On Dec 31	10	6

Age analysis of trade receivables
Not overdue	301	349
Past due 1–30 days	20	25
Past due 31–60 days	7	6
More than 60 days	0	9
Total	329	389

Factored trade receivables

Outokumpu uses factoring to finance its working capital. Under these arrangements,

Outokumpu has on December 31, 2025 derecognized trade receivables totaling EUR 357

million (Dec 31, 2024: EUR 426 million), which represents the fair value of the assets. Net

proceeds received amounted to EUR 357 million (2024: EUR 426 million). The underlying

assets have a maturity of less than one year.

The maximum amount of loss related to derecognized assets is estimated to be EUR 15 million

(2024: EUR 17 million). This estimate is based on insurance policies and contractual

arrangements between factoring companies and Outokumpu. The analysis does not include the

impact of any operational risk related to Outokumpu’s contractual responsibilities.

Trade and other payables


€ million	2025	2024
Non-current
Accruals	10	13

Current
Trade payables	1,006	1,129
Accrued employee-related expenses	81	74
Accrued interest expenses	3	7
VAT payable	42	50
Withholding tax and social security liabilities	19	20
Advance payments received	10	32
Accruals relating to customer rebates	42	32
Factoring arrangements related payables	39	4
Tax on mined minerals	8	7
Other accruals	45	31
Other payables	25	4
Total	1,320	1,390

Other payables include subsidies received.

Liabilities related to customer contracts and advance payments received

On December 31, 2025, accrued volume discounts related to customer contracts amounted to

EUR 42 million (Dec 31, 2024: EUR 32 million).

The liabilities related to unperformed transportation services were not material on December

31, 2025, and these liabilities are expected to be recognized as revenue over the following

three months.

Advance payments received are related to customer contracts which are expected to be

recognized as revenue over the following three months.


		175

Risk information

Credit risk

Outokumpu’s sales are covered by approved credit limits or secured payment terms. Most of

the outstanding trade receivables have been secured by trade credit insurances, which typically

cover some 95% of the insured amount. Part of the credit risk related to trade receivables is

managed with letters of credit, advance payments and guarantees.

On December 31, 2025, the maximum exposure to credit risk of trade receivables was EUR

329 million (2024: EUR 389 million). The portion of unsecured receivables during 2025 has

been approximately 5–11% of all trade receivables. During 2025, credit limits have remained

available from the insurer and there is no significant change in the insurance cover. Outokumpu

has frequently monitored customer credit risk and the overdue situation and continued its close

co-operation with the insurers.

Outokumpu uses factoring, which transfers most risks and rewards to the buyer of the

receivables. At the end of the year 2025, most of the receivables were generated by a large

number of customers and there were only few risk concentrations.

Country risk

Exposure to country risk is monitored and mitigated by having a credit insurance that provides

cover against political risks on external account receivables. However, there is some exposure

on certain countries where insurance was unavailable.

Accounting principles

Trade and other receivables and payables include financial assets or liabilities measured at

amortized cost. After initial recognition, they are measured at amortized cost by using the

effective interest rate method. Trade and other receivables are valued net of accumulated

impairments.

Factored trade receivables

Factored trade receivables have been derecognized from the statement of financial position

when the related risks and rewards of ownership have materially been transferred to the

counterparty of the factoring transaction.

Expected credit losses

Outokumpu applies a simplified model in assessing and recognizing loss allowance for expected

credit losses on trade receivables. The calculation model is based on overdue statistics and

counterparty-specific credit ratings linked with loss probabilities for each rating. Loss

allowances are recognized in selling and marketing expenses in the consolidated statement of

income.

Liabilities related to customer contracts

Liabilities related to customer contracts include accrued volume rebates, advance payments

received and liabilities related to transportation service not yet performed. Accrued volume

discounts have been recognized as reductions in revenue during the financial year.

4.6 Provisions


2025 € million	Environmental provisions	Restructuring provisions	Other provisions	Total
Provisions on Jan 1, 2025	48	1	35	84
Translation differences	0	0	-2	-2
Increase in provisions	9	65	7	81
Utilized during the financial year	-2	-2	-17	-21
Unused amounts reversed	-1	-5	-1	-7
Reclassifications	—	-3	—	-3
Other changes	0	1	—	1
Provisions on Dec 31, 2025	54	56	23	134


2024 € million	Environmental provisions	Restructuring provisions	Other provisions	Total
Provisions on Jan 1, 2024	48	24	38	110
Translation differences	0	0	1	1
Increase in provisions	2	8	3	13
Utilized during the financial year	0	-27	-1	-28
Unused amounts reserved	-2	-6	-6	-14
Reclassifications	—	2	0	2
Provisions on Dec 31, 2024	48	1	35	84


€ million	2025	2024
Non-current provisions	76	52
Current provisions	57	33
Total	134	84

Environmental provisions

The majority of the environmental provisions are for closing costs of production facilities and

landfill areas, removal of problem waste and landscaping in facilities in Finland and Germany,

and aftercare of closed mines in Finland. The outflow of economic benefits related to

environmental provisions is expected to take place mainly over a period of more than 10 years.

Due to the nature of these provisions, there are uncertainties regarding both the amount and

the timing of the outflow of economic benefits.

Restructuring provisions

As part of the restructuring program announced in October 1, 2025, Outokumpu recorded a

restructuring provision of EUR 34 million mainly focusing on business area Europe and global

group functions. The majority of the EUR 34 million cash flow impact is anticipated in 2026.

The planned measures are expected to affect approximately 650 Outokumpu full-time positions

by the end of 2027. In relation to the new EVOLVE strategy, announced on June 10, 2025 and


		176

due to the various cost efficiency improvement initiatives in business area Europe, Outokumpu

recorded a restructuring provision of EUR 29 million. The cash flow impact from this provision is

anticipated to take place during the years 2025-2028.

In 2024, the utilization mainly relates to the restructuring measures in Germany that were

planned at the end of 2023. Outokumpu has transferred it’s precision strip operations from

Dahlerbrück to Dillenburg and closed its coil service center in Hockenheim. These restructuring

measures impacted close to 200 people in Germany.

Other provisions

Other provisions comprise for example provisions for litigations, product and other claims and

are mainly current in nature. More information on disputes and litigations in note 6.3.

Management judgments

Provisions are based on management’s best estimates at the end of the reporting period.

Regarding environmental provisions, the management judgments and estimates relate

mainly to the timing and the scope of the activities to be carried out as well as the costs of

such activities in the future. Environmental expenditure related to dismantling an entire

production facility and restoring the area are generally estimated when decision on a site

closure is made.

As actual outflows can differ from estimates due to changes in law, regulations, public

expectations, technology, prices and conditions, and can take place in many years in the future,

the provisions are regularly reviewed to take such changes into account.

Regarding restructuring provisions, the judgments and estimates mainly relate to the

amounts of termination benefits to employees.

Accounting principles

A provision is recognized when Outokumpu has a present legal or constructive obligation as a

result of a past event, and it is probable that an outflow of economic benefits will be required to

settle the obligation and the amount can be reliably estimated. Provisions relate mainly to

environmental liabilities, restructuring plans, onerous contracts and litigations. Non-current

provisions are discounted to present value at the end of the reporting period using risk-free

discount rates.

Outokumpu aims at minimizing negative impacts of its present and discontinued operations

on the environment, and aims to remediate any material negative impacts that have occurred

where viable. Environmental expenditure arising from restoring the conditions caused by past

operations are recognized as expenses when they are incurred. Environmental provision is

recognized when the Group has a legal or constructive obligation to decommission or remove a

facility or equipment, rehabilitate environmental damage, or landscape and restore an area. The

recognition of environmental provisions is based on current interpretation of the effective

environmental laws and regulations together with Outokumpu’s Code of Conduct.

When environmental expenditure will arise from future asset retirement obligations, an item

of property, plant and equipment corresponding to the amount of the provision is recognized,

and it will be depreciated over the asset’s useful life. Subsequent adjustments to the provision

are deducted from or added to the cost of the corresponding asset in a symmetrical manner.

A restructuring provision is recognized when a detailed restructuring plan has been prepared

and its implementation has been started or the main parts of the plan have been

communicated to those, who are impacted by the plan. Restructuring provision mainly comprise

of employee termination benefits.

Any potential compensation from a third party is not included in the amount of the provision

but recognized as a separate asset when it is virtually certain that the compensation will be

received.


		177

5. Capital structure and financial risk management

Outokumpu maintained a strong financial position in 2025. Despite weaker profitability and

cashflow, net debt increased only moderately and liquidity remained strong. In November 2025,

credit rating agency Moody’s affirmed Outokumpu’s corporate family rating at Ba2 and changed

the outlook from stable to negative.

The capital structure is regularly monitored by management with focus on the company’s

leverage ratio (net debt to adjusted EBITDA) and liquidity. The target is to have Net debt to

EBITDA ratio of 1.0x with disciplined financial flexibility to support strategic investments and

manage cyclical market conditions, allowing it only temporarily to exceed 2.0x.

The main objective of capital management is to secure the ability to operate on a going concern

basis to enhance value to shareholders and to optimize the cost of capital. Outokumpu seeks

to maintain access to loan and capital markets at all times and to preserve sufficient liquidity.

The Board of Directors reviews the Group’s capital structure on a regular basis. Capital

structure and debt capacity are taken into account e.g. in investment, dividend and debt

decisions.

Equity is managed through the dividend policy, share buybacks and issuances of equity or

equity-linked securities.

Tools to manage debt in order to optimize the maturity structure of the debt portfolio and to

minimize finance costs include raising new debt in various forms, establishing financing

facilities, prepaying and cancelling loans, notes and other financing facilities.

Capital structure


€ million	2025	2024
Total equity	3,405	3,748

Gross debt	627	502

Total capitalization	4,032	4,250

Net debt	265	189

Net debt, € million*

Net debt to adjusted EBITDA*

Debt-to-equity, %*

*Including discontinued operations until 2022.


		178

5.1 Net debt and capital management

Debt management in 2025 continued to focused on ensuring sufficient liquidity, keeping net

debt level within the set target, and at the same time monitor financing costs. Net debt

increased to EUR 265 million at the year-end of 2025 driven by negative free cash flow and the

dividend payout. During 2025, Outokumpu completed two bank financings in the form of an

EUR 200 million club loan and an EUR 100 million bilateral loan. In November, Outokumpu

refinanced its main liquidity facility by entering into a new EUR 800 million committed

unsecured revolving credit facility, replacing its previous committed liquidity facilities of similar

size. The new facility, maturing in February 2030, includes two 12-month extension options,

which can be exercised in 2027 and 2028 respectively, potentially extending maturity to 2032.

The margin of the new facility is linked to emission reductions in line with the approved

emission reduction target by the Science Based Targets initiative for 2030.

The EUR 125 million convertible bond transaction was repaid in full in July 2025. Almost all

bonds were converted into shares prior to the final maturity date. See more information on the

conversion of the convertible bonds in note 5.2.

Net debt


€ million	2025	2024
Non-current
Loans from financial institutions	356	71
Lease liabilities	156	167
Other loans	7	8
	519	246
Current
Convertible bonds	—	123
Loans from financial institutions	14	14
Lease liabilities	43	38
Commercial papers	50	79
Other loans	1	1
	108	256
Cash and cash equivalents
Cash at bank and in hand	357	308
Short-term bank deposits and cash equivalents	5	5
	362	313

Net debt	265	189

Net debt development


€ million	2025	2024
Net cash flow from operating activities	79	147
Net cash flow from investing activities	-125	-218
Cash flow before financing activities	-46	-71
Dividends paid	-116	-110
Treasury share purchase	—	-34
Cash flow impact on net debt	-163	-216

Net debt on Jan 1	189	-60
Cash flow impact on net debt	163	216
Share buyback financial liability	—	-38
Convertible bond conversion to shares, non-cash	-124	—
Reclassification to operating activities	-1	—
Change in net debt, non-cash	39	72
Net debt on Dec 31	265	189

Average effective interest rate of cash and cash equivalents at the end of 2025 was 2.0% (Dec 31, 2024:

3.0%).


		179

Changes in non-current and current debt


2025 € million	Non-current debt	Current portion of non- current debt	Non-current lease liabilities	Current portion of lease liabilities	Current debt	Total
On Jan 1	79	138	167	38	79	502
Financing cash flows	300	-15	0	-42	-30	213
Transfer to current debt	-16	16	-38	38	—	—
Other non-cash movements	0	2	27	—	—	29
Convertible bond conversion to shares, non-cash	—	-124	—	—	—	-124
Other	—	-1	—	8	—	7
On Dec 31	363	15	156	43	50	627


2024 € million	Non-current debt	Current portion of non- current debt	Non-current lease liabilities	Current portion of lease liabilities	Current debt	Total
On Jan 1	213	15	146	29	38	441
Financing cash flows	—	-15	—	-38	45	-8
Transfer to current debt	-136	136	-47	47	—	—
Other non-cash movements ¹⁾	2	2	68	—	-4	68
On Dec 31	79	138	167	38	79	502

¹⁾Other non-cash movements in debt consist mainly of the share buyback program related impact in equity as the original commitment was higher than the realized one and effective interest including accrued arrangement

fees. Other non-cash movements in lease liabilities consist of new lease agreements and changes in terms of existing agreements.

Convertible bonds


		Outstanding amount
€ million	Interest rate, %	2025	2024
2020 fixed rate bonds maturing on July 9, 2025	5.0	—	125

The EUR 125 million convertible bonds matured on July 9, 2025. During the conversion period,

which commenced on August 19, 2020, and ended on June 25, 2025 convertible bonds were

converted in a total of 47,046,505 Outokumpu shares. The final conversion price was set at

EUR 2.6544 per ordinary share. The remaining part of the convertible bonds totaling EUR 0

million, that was not converted into Outokumpu shares, was paid on the final maturity date July

9, 2025. See more information on the the convertible bonds in note 5.2.


		180

Contractual cash flows


	2025							2024
€ million	2026	2027	2028	2029	2030	2031	—	2025	2026	2027	2028	2029	2030	—
Convertible bonds	—	—	—	—	—	—		125	—	—	—	—	—
Loans from financial institutions	14	14	114	214	14	—		14	14	14	14	14	14
Other loans	1	1	0	0	0	4		1	1	1	0	0	5
Commercial papers	50	—	—	—	—	—		79	—	—	—	—	—
Interest payments on debt and facility charges	19	18	17	7	2	1		17	9	4	2	1	2
Lease liabilities ¹⁾	43	34	33	25	9	54		38	31	30	29	22	56
Interest payments on lease liabilities ¹⁾	11	8	6	4	3	119		12	10	8	6	4	124
Trade and other payables	1,052	—	—	—	—	—		1,144	—	—	—	—	—
	1,190	76	171	252	29	178		1,430	64	57	51	42	200

Contractual cash flows related to derivative instruments are presented in note 5.4.

¹⁾ Contractual cash flows are impacted by the index or rate changes related to lease contracts.

Credit facilities


		2025			2024
€ million	Maturity	Total	Utilized	Available	Total	Utilized	Available
Committed revolving credit facility	Feb 2030	800	—	800	—	—	—
Committed revolving credit facility	Nov 2025	—	—	—	700	—	700
Committed Finnvera facility	Nov 2025	—	—	—	100	—	100
Committed facilities total		800	—	800	800	—	800
Uncommitted Finnish Commercial paper program	N/A	800	50	750	800	79	721

Overall liquidity reserves at Dec 31, 2025 were EUR 1.2 billion (Dec 31, 2024: EUR 1.1 billion). The liquidity reserves include cash and cash equivalents and EUR 800 million of outstanding

committed credit facility, which was fully unutilized.


		181

Risk information

Liquidity and refinancing risk

Outokumpu raises most of its funding centrally and in co-ordination by the Treasury function

(“Treasury”). The Group seeks to reduce its liquidity and refinancing risk by having sufficient

amount of cash and committed long-term credit lines available and by maintaining a balanced

debt maturity profile with diversified sources of funding. Efficient daily cash and liquidity

management and the use of instruments such as commercial papers and currency swaps, also

reduce the liquidity risk. To finance its working capital, the Group is also selectively selling its

trade receivables on a continuous basis.

Finance and liquidity plans are prepared and reviewed regularly with a focus on forecasted

cash flows, projected funding requirements, planned funding transactions and financial

covenant headroom. The adequacy of liquidity reserves, the amounts of scheduled annual

repayments of non-current debt compared to EBITDA as well as forecasted gearing and leverage

ratios are key measures being considered.

Outokumpu is exposed to changes in credit margins as the development of the leverage ratio

has an impact on the interest rate margin definition in some of the Group’s loan agreements

and as such on its interest and other financial expenses. In addition, some of the Group´s loan

agreements include a financial covenant, but a breach is unlikely as there is ample headroom

in the financial covenant.

Accounting principles

Bonds, loans from financial institutions, pension and other loans are recognized at the

settlement date and measured initially at fair value net of direct transaction costs.

Subsequently they are carried at amortized cost using the effective interest rate method.

Transaction costs are amortized over the maturity of the borrowing using the effective

interest rate method. A financial liability (or part of the liability) is derecognized when the

liability ceases to exist, that is, when the obligation identified in a contract has been fulfilled or

cancelled or is no longer effective.

The fair value of non-current and current debt is determined based on quoted prices for

listed instruments. For loans the fair value is determined using the discounted cash flow

method based on yields at the reporting date. The fair values of non-current and current debt

are presented in note 5.5.

Fees related to revolving credit facilities are amortized over the expected facility term.

Convertible bonds

Convertible bonds are compound instruments with components of the bonds classified

separately as financial liabilities and equity in accordance with the substance of the

arrangement.

The liability component is recognized initially at fair value of a similar liability. The equity

component is recognized initially at the difference between the fair values of the full bond and

the liability component. Transaction costs are allocated to the components in proportion to

their initial carrying amounts. The fair value includes the value of conversion rights.

Subsequently the liability component is measured at amortized cost with the effective

interest method. At conversion or on expiry the equity component is reclassified within equity.

Lease liabilities

Accounting principles related to lease liabilities are presented in note 4.2.

Cash and cash equivalents

Cash and cash equivalents comprise cash in hand, deposits held at call with banks and other

highly liquid investments with original maturities of three months or less. These are readily

convertible to a known amount of cash with a low risk of any changes in the value.

Bank overdrafts are reported as current debt.


		182

5.2 Equity

Shares and related movements in equity


€ million	Number of shares, 1,000	Share capital	Premium fund	Invested unrestricted equity reserve	Treasury shares	Total
On Jan 1, 2024	431,191	311	714	2,307	-169	3,163
Shares delivered from the share-based payment programs	852	—	—	—	6	6
Repurchase of treasury shares	-8,358	—	—	—	4	4
Shares outstanding on Dec 31, 2024	423,686	311	714	2,307	-159	3,173
Shares delivered from the share-based payment programs	544	—	—	—	3	3
Cancellation of treasury shares ¹⁾	—	—	—	-138	149	10
Conversion of convertible bond	46,979	—	—	125	—	125
Shares outstanding on Dec 31, 2025	471,208	311	714	2,294	-7	3,311
Treasury shares	1,808
Total number of shares on Dec 31, 2025	473,017

¹⁾ Cancellation of 30,836,205 treasury shares did not affect the number of shares outstanding.

2025

In 2020, Outokumpu issued senior unsecured convertible bonds of EUR 125 million maturing

on July 9, 2025. The bonds were convertible into new and/or existing ordinary shares in

Outokumpu at a set conversion price. In total, Outokumpu converted the convertible bond into

47,046,505 shares, of which 46,978,589 shares amounting to EUR 125 million were converted

during the year 2025. 67,916 shares amounting to EUR 0 million were converted already in

year 2023. EUR 0 million was not converted into Outokumpu shares and was paid in cash on

the final maturity date July 9, 2025.

Outokumpu cancelled the total of 30,836,205 own shares for the value of EUR 149 million in

connection with the conversions. The cancelled number of shares was equalling to number of

repurchased shares during the Outokumpu’s share buyback programs during the periods 2022–

2023 and 2023–2024. Cancellation of shares impacted invested unrestricted equity, treasury

shares and retained earnings but had no impact to total equity.

After the delivery of new shares and cancellation of own shares, the total number of shares

increased by 16,142,384. As a result of the conversions the number of shares outstanding

increased and impacted the dividend distribution by EUR 6 million.

On December 31, 2025, Outokumpu held 1,808,411 treasury shares, which represented 0.4%

of the company’s total number of shares.

2024

Through share buyback programs, Outokumpu was seeking to mitigate and manage the possible

dilutive impact of the company’s convertible bonds issued in 2020. Outokumpu purchased a

total of 30,836,205 shares during share buyback programs in 2022–2023 and 2023–2024.

On February 29, 2024, Outokumpu completed its up to EUR 50 million share buyback program

which was announced on November 29, 2023 and commenced on December 1, 2023. During

this program, Outokumpu repurchased a total of 11,000,000 of its own shares and used a total

of EUR 46 million for the share repurchases. The average price per share was approximately

EUR 4.15.

During the year 2024, Outokumpu purchased a total of 8,357,545 of its own shares. As the

original commitment recognized in year 2023 was higher, a EUR 4 million impact was

recognized in equity during the year 2024 in relation to this program. After the completion of

the share buyback program and on December 31, 2024, Outokumpu held a total of

33,188,820 treasury shares, representing 7.3 % of the company’s total number of shares.


		183

Dividend policy and distributable funds

According to its dividend policy, Outokumpu aims to distribute a stable and growing dividend

over time, while maintaining the flexibility to invest in transformative initiatives that yield a

minimum internal rate of return (IRR) of 20% and accounting for market cyclicality. On

December 31, 2025, the distributable funds of the parent company totaled EUR 2,652 million

of which retained earnings including the net result of the year were EUR 341 million.

The Board of Directors proposes to the Annual General Meeting to be held on March 26, 2026,

that a dividend of EUR 0.13 per share will be paid for the year 2025, corresponding to EUR 61

million based on the number of shares outstanding on December 31, 2025. The dividend will

be paid in two installments.

In 2025, Outokumpu paid for the financial year 2024 a dividend of EUR 0.26 per share, a total

of EUR 116 million.

Accounting principles

Shares and share capital

According to the Articles of Association, Outokumpu has one single class of shares and all

shares have equal voting rights at General meetings. The shares do not have a nominal value.

Premium fund

Premium fund includes proceeds from share subscriptions and other contributions based on the

old Finnish Limited Liability Companies Act for the part the contributions exceeded the account

equivalent value allocated to share capital.

Other restricted reserves

Other restricted reserves include amounts transferred from the distributable equity under the

Articles of Association or by a decision of the General Meeting of Shareholders, and other items

based on the local regulations of the Group companies.

Invested unrestricted equity reserve

The reserve for invested unrestricted equity comprises the portion of the subscription price for

issued shares that, in accordance with the share issue decision, is not recorded as share

capital. It also includes other equity contributions that are not recorded to some other reserve.

In Outokumpu, invested unrestricted equity reserve includes the net proceeds from the rights

issues in 2012 and 2014, the directed share issue in 2021 as well as conversion of convertible

bond in 2025.

Fair value reserves

Fair value reserves include movements in the fair values of equity securities and hedge

accounted derivative instruments.

Retained earnings

Retained earnings include remeasurements of defined benefit plans, cumulative translation

differences and other retained earnings and losses.

Treasury shares

When the parent company or its subsidiaries purchase the parent company’s own shares, the

consideration paid, including any attributable transaction costs, net of taxes, is deducted from

the parent company’s equity as treasury shares until the shares are cancelled. When such

shares are subsequently sold or reissued, any consideration received is recognized directly in

equity.

Dividends

The dividend proposed by the Board of Directors is not deducted from distributable equity until

approved by the Annual General Meeting of Shareholders. For the time period between the

approval and the payment, the dividend to be paid is presented in current trade and other

payables.


		184

5.3 Financial risk management and insurances

The main objectives of financial risk management are to reduce the volatility of the net result

and to secure sufficient liquidity to avoid financial distress. Other objectives include the

reduction of cash flow volatility and the maintenance of the debt-to-equity and leverage ratios

within set targets. The main objectives of insurance management are to provide mitigation

against catastrophe risks and to reduce variation of the net result.

The Board of Directors has approved the risk management policy, which defines responsibilities,

the process and other main principles of risk management. The Board of Directors oversees risk

management on a regular basis and the Chief Financial Officer (CFO) is responsible for the

implementation and development of financial risk management. The CFO leads relevant

steering groups, such as the Risk Management Steering Group for enterprise risk management

and the Financial Risk Steering Group for financial risk management. The Energy Steering Group

for energy risk management is led by Senior Vice President (SVP) General Procurement,

reporting to the CFO.

Financial risks consist of market, country, credit, liquidity and refinancing risks. Outokumpu

subsidiaries hedge their currency and commodity price risk with the parent company

Outokumpu Corporation, which does most of the Group’s foreign exchange and commodity

derivative contracts with banks and other financial institutions. The Treasury function

(“Treasury”) is responsible for managing foreign exchange, metal, interest rate, liquidity and

refinancing as well as emission allowance price risk. Credit controlling has been mainly

centralized to Finance Services, and Treasury oversees credit risk management globally.

Customer credit risk is presented in note 4.5. The procurement function is responsible for

managing the electricity and fuel price risks.

Treasury sources all global insurances. The main insurance lines are related to property,

business interruption, liabilities and credit risk. The captive insurance company Visenta

Försäkringsaktiebolag contributes to the Outokumpu’s global insurance program.

Exposure to financial risks is identified in connection with the Group’s risk management

process. This approach aims to ensure that any emerging risks are identified early and that

significant risks are described, quantified, managed and communicated appropriately.

Sensitivity of financial instruments to market risk


	Dec 31, 2025		Dec 31, 2024
€ million	In profit or loss	In other comprehensive income	In profit or loss	In other comprehensive income
+/-10% change in EUR/USD exchange rate	-4/+5	—	+7/-9	—
+/-10% change in EUR/SEK exchange rate	-4/+5	—	-3/+4	—
+/-10% change in nickel price in USD	-1/+1	-5/+5	-1/+1	-4/+4
+/-1% parallel shift in interest rates	-0/+0	—	-1/+1	—

The sensitivity analyses apply to financial assets and liabilities only. Other assets and liabilities, including defined benefit pension plan assets and liabilities, as well as off balance sheet items such as sales and purchase

orders, are not in the scope of these analyses. The calculations are net of tax. During the year the volatility for nickel price has been in the range of 11-23%. With +/–30% change in dollar denominated price, the effect in

profit or loss is about EUR -2/+2 million and in other comprehensive income EUR -14/+14 million for nickel derivatives.


		185

Risk information

Market risk

Outokumpu’s main market risks are foreign exchange risk, interest rate risk, security price risk

as well as commodity price risk, namely in metals, fuels, energy and emission allowances. The

price changes in the before mentioned risks may have a significant impact on the Group’s net

result, cash flow and capital structure. Due to the cyclicality of the stainless steel business,

Outokumpu’s exposure to market risks may change significantly from one period to another.

Consequently, derivative positions to mitigate market risks change due to the cyclical business

environment.

Note 5.4 details the fair values and nominal amounts of derivative instruments while the

sensitivity of financial instruments to market risks is described in the table of the previous

page.

The strategy for market risk management is based on identifying, evaluating and mitigating

relevant risks in committed business transactions, balance sheet items and selected forecasted

items for each of the market risk categories. The use of derivatives to mitigate market risks

may cause timing differences between derivative gains or losses and the impact of the

underlying exposure on the net result. In order to reduce such timing differences in net result,

hedge accounting can be applied selectively as part of the commodity and foreign exchange

hedging activities. Most of the derivatives are short-term, however, interest rate hedges typically

have a maturity in excess of one year.

Foreign exchange rate risk

Outokumpu is exposed to foreign exchange rate risk as its business and operations are global.

The risk arises from changes in exchange rates and may have effects on net result, cash flow

and balance sheet. The foreign exchange exposure consists of risks associated with foreign

currency cash flows (transaction risk), translation risk and economic risk, such as the change in

competitiveness resulting from changes in foreign exchange rates.

The transaction risk arises from committed and forecasted transactions and payments in

currencies other than the functional currency of the entity and from changes in fair value of

foreign currency denominated items recognized on the balance sheet.

The fair value risk consists of foreign currency denominated accounts receivables, accounts

payables, debt, cash, loan receivables and the currency position from commodity derivatives.

The transaction and fair value risks are, with a few exceptions, hedged in full in major

currencies. Forecasted and probable cash flows are not typically hedged, but can be hedged

selectively. The Group’s fair value foreign exchange position in currencies and in major EUR and

SEK based Outokumpu companies is presented in more detail in the following table. The

committed and forecasted transactions are excluded from the table.

In 2025, there was no hedge accounting applied in foreign exchange hedging activities.

Foreign exchange positions of EUR based companies


	Dec 31, 2025				Dec 31, 2024
€ million	SEK	USD	GBP	Other	SEK	USD	GBP	Other
Trade receivables and payables	-45	-85	5	3	-8	-257	9	11
Loans and bank accounts ¹⁾	114	-765	-36	0	156	-829	-59	7
Derivatives	-48	913	20	-11	-145	996	38	-30
Net position	20	64	-11	-9	3	-90	-13	-12

Foreign exchange positions of SEK based companies


	Dec 31, 2025				Dec 31, 2024
€ million	EUR	USD	GBP	Other	EUR	USD	GBP	Other
Trade receivables and payables	-7	7	1	0	11	15	5	2
Loans and bank accounts ¹⁾	4	1	1	2	10	2	1	1
Derivatives	-31	-18	-21	-6	-58	-25	-19	-7
Net position	-34	-10	-19	-5	-36	-8	-13	-4

¹⁾ Includes cash and cash equivalents, loan receivables and debt.

Currency distribution and re-pricing of outstanding net debt


€ million	Dec 31, 2025
Currency	Net debt¹⁾	Derivatives²⁾	Rate sensitivity³⁾	Gross debt	Average rate, %⁴⁾	Duration, year⁵⁾
EUR	523	721	10.8	-627	4.5	1.5
SEK	-32	114	0.8	—	—	—
USD	-186	-792	-9.8	—	—	—
Others	-39	-39	-0.8	—	—	—
	265	4	1.1


€ million	Dec 31, 2024
Currency	Net debt¹⁾	Derivatives²⁾	Rate sensitivity³⁾	Gross debt	Average rate, %⁴⁾	Duration, year⁵⁾
EUR	399	760	9.8	-502	6.2	2.0
SEK	-32	151	1.2	—	—	—
USD	-115	-865	-9.8	—	—	—
Others	-63	-58	-1.2	—	—	—
	189	-12	0.0

¹⁾Includes cash and cash equivalents and debt.

²⁾ Net derivative liabilities include nominal value of currency forwards earmarked to debt and interest rate

derivatives at Dec 31,2024. There were no interest rate derivatives at Dec 31,2025.

³⁾ The effect of one percentage point increase in interest rates to financial expenses over the following year

from net debt and derivatives.

⁴⁾ Includes gross debt. Currency forwards are not included in average rate calculation.

⁵⁾Duration calculation includes both debt and interest rate derivatives. There were no interest rate

derivatives at Dec 31,2025.


		186

Outokumpu’s largest foreign exchange transaction risk exposures are in US dollars and

Swedish krona. A major part of the Group’s sales is in Euros and US dollars and thus the local

currency denominated production costs in Sweden cause foreign exchange risk. The main US

dollar cash flow risks origin from sales in the ferrochrome operations as chromium is priced in

US dollars and US dollar priced raw material purchases in the European stainless steel

business. Internal financing denominated in Swedish krona and US dollar cause significant fair

value foreign exchange rate risk, which is hedged with forward contracts and, if possible, with

matching of external debt or investment.

Translation risk consists of current net investment in foreign entities and future foreign

currency denominated profits and losses, which eventually will have an impact on Group’s net

result and balance sheet through consolidation. Outokumpu’s net result and net investment

translation risk is mainly in US dollars and Swedish krona. The equity translation risk is not

typically hedged, although, according to the Treasury policy, this risk can be hedged selectively.

In 2025, there were no hedges of net result or net investment exposures. However, the

effective portion of gains (EUR 17 million, net of tax) on earlier financial years’ net investment

hedges is recognized in equity.

Economic risk relates to foreign exchange rates, commodity and energy prices, or any other

market price risks, which impact the long-term competitive position. Hedging of economic risk in

the Group is seen as a strategic decision approved by the CFO. In 2025, there were no hedges

related to economic risks.

Interest rate risk

Changes in interest rates expose Outokumpu to interest rate risk with effects on Group’s net

interest expense (i.e. cash flow risk) and value of assets and liabilities (i.e. fair value risk). The

objective of the Group’s interest rate risk management is to have a significant share of net debt

effectively with a short-term interest rate as a reference rate. This approach may help to reduce

the average interest rate of debt. Approximately 98% (2024: 65%) of the Group’s debt has an

interest period of less than one year and the average interest rate of non-current debt on

December 31, 2025 was 4.6% (Dec 31, 2024: 5.8%).

The interest rate risk exposure is composed of the Group’s net debt including all interest-

bearing assets and liabilities as well as derivatives that hedge these items. Interest rate

derivatives, such as interest rate swaps, are used to adjust the share of net debt effectively

repricing in different maturities according to limits defined in the Treasury policy. At the end of

2025 there were no open hedges related to interest rate.

Euro, Swedish krona and US dollar have a substantial contribution to the Group’s interest

rate risk exposure. The interest rate risk exposure in Swedish krona and US dollar primarily

originates from cash balances and foreign exchange derivatives. The interest rate position for

the Group is presented in more detail in the table on the previous page.

Metal price risk

The Metal price risk arises from changes in metal market prices and may have effects on net

result, cash flow and balance sheet.

The Group’s most significant exposures in metals price risk arise from chromium and nickel,

while other alloy metals with metal price risk include for example iron and molybdenum.

Outokumpu is exposed to metal price risk for example through the purchase of raw materials as

well as sale of stainless steel products where the price of alloy metals is based on market

prices. The timing difference in such commercial purchases and sale transactions as well as its

inventory position expose the Group to metal price risk alongside the Group’s capability to pass

on price changes in raw materials to end-product prices.

Outokumpu’s underlying metal net position (in the following alloy metals: nickel, iron and

molybdenum) consists of fixed price purchase orders, inventories of alloy metal containing

materials and fixed price sales orders. The metal net positions (in tons of metal) are

continuously calculated in order to manage the underlying positions.

Metal market prices are based on prices determined in regulated markets, such as the

London Metal Exchange (LME). Also, derivatives contracts to mitigate metal price risk are based

on, for example, LME prices. Chromium does not have an established financial derivatives

market and, consequently, is not included in the scope of the Treasury policy. Financial

derivatives mainly in nickel are used to manage the impacts of metal price changes on the

Group’s net result, whereas efficient working capital management helps to reduce cash flow

variations caused by metal prices. Outokumpu has continued to apply cash flow hedge

accounting programs on nickel hedging in order to reduce the timing differences between

derivative gains or losses and the net result impact of the underlying exposure. The hedge

accounting covers a material part of the Group’s nickel derivatives hedges. The Group’s

financial derivatives fair values and nominal amounts are presented in more detail in the table

5.4 Derivative instruments.

In addition to hedging with financial derivatives, the metal price risk is also mitigated

through other measures such as pricing decisions. A part of the Group’s stainless steel sales

contracts include an alloy surcharge clause, with the aim of reducing the risk arising from the

timing difference between alloy metal purchase and stainless steel pricing and delivery.

Energy and emission allowance price risk

Outokumpu manages energy price risk centrally and mitigates the risks by guidance from the

Energy Procurement policy. Energy price risk is hedged with long-term agreements, fixed price

supply contracts, partial ownerships in power utilities and derivatives. See more information in

note 5.4. Market developments and the company’s overall energy risk positions are actively

monitored in review meetings by the Outokumpu Energy Steering Group, ensuring timely and

informed decisions that support stable and responsible business performance.

Overall, Outokumpu’s energy spend decreased around 5%–10% compared to last year. For

2026, Outokumpu’s energy portfolio has been hedged with roughly 65%–75% of the estimated

consumption.

Outokumpu has initiated and carried out multiple actions to prevent risk from materializing.

As the volatility in the market persists, Outokumpu has continued its focus on daily optimization

to reduce overall energy costs. Outokumpu has also started several initiatives to accelerate the

improvement in energy efficiency. See more information on energy in the Climate change

chapter in the Sustainability Statement (part of Review of Board of Directors), especially under

“Energy consumption and mix”.

Outokumpu is exposed to changes in emission allowance prices as the Group’s main

production sites are located in Europe and thus participating in the EU Emissions Trading

Scheme (EU ETS). All Outokumpu sites met the compliance requirements regarding returning of


		187

emissions to local authorities on time in 2025. The Group’s emission allowances positions are

composed of realized and forecasted emissions netted against confirmed and forecasted

emission allowances granted by the authorities. The general economic outlook, the prices of

fuels and power as well as decisions on the EU ETS have a significant impact on the price of

emission allowances. The current trading phase of the EU ETS refers to the period 2021–2030.

Outokumpu forecasts to have adequate amount of EU emission allowances until the end of this

decade. However, the future decisions on EU ETS may have a significant impact on this

forecast.

Security price risk

Outokumpu has equity investments and fixed income securities. On December 31, 2025, the

main investments were in OSTP Holding Oy (investment in associated company of EUR 33

million) and Voimaosakeyhtiö SF (investment in associated company of EUR 0 million). For more

information on the investments presented in notes 5.6 and 6.6.

The captive insurance company Visenta Försäkringsaktiebolag has investments totaling EUR

27 million in fixed income and equity funds in order to optimize return for assets and to

manage the risk prudently.

Country and counterparty credit risk

Treasury monitors credit risk related to financial institutions. Outokumpu seeks to reduce these

risks by limiting the counterparties to banks and other financial institutions with good credit

standing. For derivative transactions, Outokumpu prefers to have the ISDA framework

agreements in place.

Exposure to country risk is monitored and mitigated by having a credit insurance that

provides cover against political risks on external account receivables. However, there is some

exposure on certain countries where insurance was unavailable.

Insurances

As part of risk mitigation activities, Outokumpu aims to secure its assets and business

continuity by arranging insurances against financial losses arisen from unexpected risk events.

Risks related to property, business interruption, liabilities and credit risk are covered by

insurances as per policy terms and conditions. Outokumpu continued its systematic property

and marine cargo loss prevention programs, focusing on execution of the mitigating and

preventive actions.

Outokumpu has a captive insurance company, Visenta Försäkringsaktiebolag (Visenta), for

optimizing insurance arrangements as part of the Group’s risk management. The captive

insurance company is registered in Sweden and can operate as a direct insurer and reinsurer

for covering risk of Outokumpu Group entities only. Visenta has to comply with capital adequacy

requirements set by the financial supervisory authority in Sweden and European Insurance and

Occupational Pensions Authority (EIOPA). During the reporting period Visenta was well

capitalized to meet other externally imposed requirements, which are based on, e.g., the

Solvency II framework. There were no significant changes in Visenta’s assets during the year.


		188

5.4 Derivative instruments


	2025			2024	2025	2024
€ million	Positive fair value	Negative fair value	Net fair value	Net fair value	Nominal amounts	Nominal amounts
Currency and interest rate derivatives
Currency forwards	4	-11	-7	14	1,735	2,013
Interest rate swaps	—	—	—	-2	—	125

					Tonnes	Tonnes
Metal derivatives
Forward nickel contracts, hedge accounted	10	-14	-4	5	18,152	16,984
Forward nickel contracts	4	-4	0	1	5,502	8,592

					MWh	MWh
Gas derivatives
Forward gas contracts, hedge accounted	0	-5	-5	4	973,118	917,408
Total derivatives	17	-34	-17	22

Less long-term derivatives
Forward nickel contracts, hedge accounted	0	—	0	0
Forward gas contracts, hedge accounted	0	-2	-2	1
Short-term derivatives	17	-33	-16	22

Contractual cash flows


2025 € million	2026	2027
Currency derivatives
Outflows	1,733	—
Inflows	-1,737	—
	-4	—


2024 € million	2025	2026
Currency derivatives
Outflows	2,021	—
Inflows	-2,006	—
Interest derivatives	-5	—
	10	—

Hedge accounted cash flow hedges (commodity derivatives)


	2025	2024
Fair value of nickel derivatives, € million	-4	5
Nominal amount of nickel derivatives, tonnes	18,152	16,984
Fair value of gas derivatives, € million	-5	4
Nominal amount of gas derivatives, MWh	973,118	917,408
Hedge ratio	1:1	1:1
Fair value reserve in other comprehensive income, € million	-9	10
Reclassified to sales in profit or loss, € million	9	13
Reclassified to cost of sales in profit or loss, € million	-5	-6
Recognized in inventory, € million	1	2

The nickel hedge accounting programs implemented for business area Americas and business

area Europe cover a material part of the Group’s sales and purchase contracts. Forwards, which

correspond to the pricing model of the underlying items, are used as derivative instruments.

Only the spot component of nickel derivatives is under hedge accounting, the forward element

is recognized in profit or loss. The effectiveness is tested regularly. Management estimates that

the possible ineffectiveness that could arise relates to credit risk or timing of transactions, but

these are estimated to be immaterial.

The LNG gas hedge accounting program implemented for Outokumpu Stainless Oy covers a

substantial part of the purchases of LNG gas contracts. The derivative instrument used in

hedging is a forward which pricing corresponds to the pricing of the underlying item. The

effectiveness is tested regularly. Management estimates that the possible ineffectiveness that

could arise relates to credit risk or timing of transactions, but these are estimated to be

immaterial.


		189

Master netting agreements and similar arrangements


€ million	2025	2024
Derivative assets
Gross amounts of recognized financial assets in the statement of financial position	17	39
Related financial instruments that are not offset	17	16
	0	23
Derivative liabilities
Gross amounts of recognized financial liabilities in the statement of financial position	34	17
Related financial instruments that are not offset	17	16
	17	1

Outokumpu enters into derivative transactions with most counterparties under ISDA

agreements. In general, the amounts owed by each counterparty on a single day in respect of

all transactions outstanding in the same currency are aggregated into a single net amount that

is payable by one party to the other. In certain circumstances, e.g. when a credit event such as

a default occurs, all outstanding transactions under the agreement are terminated. The

termination value is assessed and only a single amount is payable in settlement of all

transactions. ISDA agreements do not meet the criteria for offsetting the balances in the

statement of financial position, but the right to offset is enforceable only on the occurrence of

future credit events. The table above sets out the carrying amounts of recognized financial

instruments that are subject to the agreements described above.

Accounting principles

Derivatives are initially recognized at fair value on the trade date, when the Group enters into a

derivative contract, and are subsequently measured at fair value.

The presentation of the gains or losses arising from the fair value measurement depends on

the purpose of the derivative. The gains or losses arising from fair value changes of effective

hedge-accounted derivative contracts are presented in profit or loss congruent with the hedged

item. Changes in fair value of derivative contracts, where hedge accounting is not applied, are

recognized in EBIT in other operating income and expenses. Changes in fair value of derivatives

designated for financing activities are presented within financial income and expenses.

The fair value measurement is based on quoted market prices and rates as well as on

discounted cash flows at the end of the reporting period. Fair values of derivatives can in

certain cases be based on valuations of external counterparties.

Hedge accounting

Outokumpu applies cash flow hedge accounting on certain commodity derivatives. For each

hedging arrangement the relationship between the hedging instrument and the hedged item,

the objectives of risk management and the strategy of the hedging arrangement are

documented.

The effectiveness of the hedge relationship is documented and assessed when hedging is

started and at least in the end of each reporting period. Hedge effectiveness is calculated and

assessed between the changes in the fair value or cash flows of the hedged item attributable to

the hedged risk and the changes in the fair value or cash flows of the hedging instrument to

ensure that these impacts offset one another. Hedge accounting is discontinued if the

requirements of hedge accounting are no longer met.

Fair value changes of derivatives designated to hedge forecasted cash flows are recognized

in other comprehensive income and presented within the fair value reserve in equity to the

extent that the hedge is effective. Such fair value changes accumulated in equity are

reclassified in profit or loss, and presented in sales or cost of sales in the period when the

hedge accounted cash flows affect the profit or loss. In the certain hedge accounted

transaction, the realized gains or losses of the nickel derivatives are first reclassified from fair

value reserves in equity to the inventory for a certain period and finally recognized in profit or

loss. The fair value changes related to the ineffective portion of the hedging instrument are

recognized immediately in profit or loss.


		190

5.5 Financial assets and liabilities

Carrying values and fair values of financial assets and liabilities by measurement category


	Measured at
2025 € million	Amortized cost	Fair value through other comprehensive income	Fair value through profit or loss	Carrying amount	Fair value	Fair value hierarchy level
Non-current financial assets
Equity investments	—	24	—	24	24	1,3
Trade and other receivables	9	—	0	9	0	3
Hedge accounted derivatives	—	—	0	0	0	2

Current financial assets
Other investments	—	—	27	27	27	1
Trade and other receivables	330	—	—	330
Hedge accounted derivatives	—	—	10	10	10	2
Derivatives held for trading	—	—	7	7	7	2
Cash and cash equivalents	362	—	—	362
	701	24	45	769

Non-current financial liabilities
Non-current debt	519	—	—	519	519	2
Hedge accounted derivatives	—	—	2	2	2	2

Current financial liabilities
Current debt	108	—	—	108	108	2
Trade and other payables	1,052	—	—	1,052
Hedge accounted derivatives	—	—	18	18	18	2
Derivatives held for trading	—	—	15	15	15	2
	1,679	—	34	1,713

There were no transfers between levels 1, 2 and 3 during the years. A major part of equity investments at fair value through other comprehensive income at hierarchy level 3 relates to investments in unlisted energy

producing companies.


		191


	Measured at
2024 € million	Amortized cost	Fair value through other comprehensive income	Fair value through profit or loss	Carrying amount	Fair value	Fair value hierarchy level
Non-current financial assets
Equity investments	—	28	—	28	28	1,3
Trade and other receivables	10	—	0	10	0	3
Hedge accounted derivatives	—	—	1	1	1	2

Current financial assets
Other investments	—	—	28	28	28	1
Trade and other receivables	390	—	—	390
Hedge accounted derivatives	—	—	15	15	15	2
Derivatives held for trading	—	—	23	23	23	2
Cash and cash equivalents	313	—	—	313
	714	28	67	809

Non-current financial liabilities
Non-current debt	246	—	—	246	247	2
Hedge accounted derivatives	—	—	0	0	0	2

Current financial liabilities
Current debt	256	—	—	256	273	2
Trade and other payables	1,144	—	—	1,144
Hedge accounted derivatives	—	—	7	7	7	2
Derivatives held for trading	—	—	10	10	10	2
	1,646	—	17	1,663


		192

Reconciliation of changes on level 3


€ million	Investments at fair value through profit or loss	Equity investments at fair value through other comprehensive income
Carrying value on Jan 1, 2025	0	23
Additions	3	2
Fair value changes	-3	-10
Carrying value at the end of the period	0	14


€ million	Investments at fair value through profit or loss	Equity investments at fair value through other comprehensive income
Carrying value on Jan 1, 2024	0	7
Additions	3	1
Fair value changes	-3	15
Carrying value at the end of the period	0	23

In 2023, Outokumpu Corporation agreed to participate in a convertible loan offered by

associated company Voimaosakeyhtiö SF to its shareholders. Outokumpu’s share of the

convertible loan is EUR 14 million. The first call of the loan was in August 2023 amounting to

EUR 5 million, the second one in October 2024 totaling to EUR 3 million and the third one in

August 2025 totaling to EUR 3 million. At the end of December 2025, the loan is valued at EUR

0 million. The change in value is presented in the other market price gains and losses in the

consolidated statement of income, for more information see note 2.5. For more information on

Voimaosakeyhtiö SF, see note 5.7 and 6.6.

Accounting principles

The Group’s financial assets and liabilities are classified as items at fair value through profit or

loss, items at fair value through other comprehensive income and items at amortized cost.

The classification is based on Group’s business model for financial assets and liabilities, and

their contractual cash flow characteristics.

If a financial asset is not measured at fair value through profit or loss, significant transaction

costs are included in the initial carrying amount of the asset. Financial assets are derecognized

when the Group loses the rights to receive the contractual cash flows on the financial asset or it

transfers substantially all the risks and rewards of ownership outside the Group. Accounting

principles related to transaction costs and derecognition of borrowings are presented in note

5.1.

Financial assets and liabilities measured at amortized cost

Financial assets measured at amortized cost include trade and other receivables and

cash and cash equivalents. These assets are measured initially at fair value. After initial

recognition, they are measured at amortized cost by using the effective interest rate method

less accumulated impairments. The accounting principles related to factored receivables and

expected credit losses are presented in note 4.5.

Financial liabilities measured at amortized cost include the borrowing and trade and other

payables. See note 5.1 for further accounting and fair valuation principles for borrowings and

note 4.5 for accounting principles for trade and other payables.

Financial assets at fair value through other comprehensive income

Financial assets at fair value through other comprehensive income include equity investments

in listed and unlisted companies. Accounting principles are presented in note 5.6.

Financial assets and liabilities at fair value through profit or loss

Financial assets and liabilities at fair value through profit or loss include derivative instruments.

Financial assets at fair value through profit or loss include also investments in debt instrument

or money market funds held for trading purposes and intended to be sold within a short period

of time. In some cases, also equity investments can be classified in this category.

These financial assets and liabilities are recognized at the trade date at fair value and

subsequently remeasured at fair value at the end of each reporting period. The fair value

measurement is based on quoted rates and market prices as well as on appropriate valuation

methodologies and models.

Realized and unrealized gains and losses arising from changes in fair values of non-

derivative financial assets are recognized in market price gains and losses under financial

income and expenses in the reporting period in which they are incurred. Accounting principles

related to derivatives are described in more detail in note 5.4.

Measurement of fair values

Several accounting policies and disclosures require the measurement of fair values.

Financial assets and liabilities measured at fair value are classified to fair value hierarchy levels

based on the source information and inputs used in the fair valuation. In level one, fair values

are based on public quotations for identical instruments. In level two, fair values are based on

market rates and prices and discounted future cash flows. For assets and liabilities in level

three, there is no reliable market source available and thus the fair value measurement is not

based on observable market data. Therefore, the measurement methods are chosen taking into

account the information available for the measurement and the characteristics of the measured

item.


		193

5.6 Equity investments at fair value through other comprehensive income


€ million	2025	2024
Carrying value on Jan 1	28	12
Additions	2	2
Fair value changes	-5	13
Carrying value on Dec 31	24	28

Fair value reserve in equity


€ million	2025	2024
Fair value on Dec 31	24	28
Fair value at acquisition	15	14
Fair value reserve from equity investments	9	14

Equity investments at fair value through other comprehensive income include unlisted and

listed strategic holdings mainly in energy companies in which Outokumpu does not have control,

joint control or significant influence.

These energy companies produce energy to their shareholders on a cost-price basis (Mankala

principle) which is a widely used business model among Finnish energy companies. Under the

Mankala principle, shareholders are entitled to receive energy in proportion to the ownership,

and each shareholder is severally responsible for its respective share of the costs of the energy

company as set out in the articles of association.

The additions of EUR 2 million in 2025 are mainly related to the increase in investments in EPV

Energia Oy.

Outokumpu is an owner in nuclear utility by provider Pohjolan Voima Oy (PVO), with an

ownership share of 0.1%. PVO is a shareholder in Teollisuuden Voima Oy (TVO). TVO, where

Outokumpu does not have a direct ownership, operates Olkiluoto 3 (OL3) a nuclear power plant

in Eurajoki, Finland. Outokumpu has indirect ownership in Tornion Voima Oy, a combined heat

and power plant in Tornio, Northern Finland. This indirect ownership is through EPV Energia Oy,

with an ownership share of 0.5%. In addition, Outokumpu has a direct ownership in Rajakiiri Oy

with a share of 19.9%. Rajakiiri Oy is a wind power company in Tornio. The total estimated fair

value of the aforementioned three utility assets was EUR 13 million at the year end (Dec 31,

2024: EUR 22 million). The remaining EUR 11 million (Dec 31, 2024: EUR 6 million) are other

share holdings.

Management judgments

Unlisted strategic energy companies

The valuation model of the other unlisted strategic energy companies include among others

discount rate derived from risk free rate (Germany 10 year bond yield), growth factor depending

the nature of the power plant or wearing out of the mill and contractual factors which may have

an impact on the valuation. Discounted cash flow models include also adjustments based on

the latest information regarding the power plants and potential energy production.

Accounting principles

Equity investments at fair value through other comprehensive income consists of investments

which are not held for trading, and which the Group has irrevocably elected at initial recognition

to recognize in this category. These are mainly strategic investments, so this classification is

considered relevant.

The investments and divestments are recognized at the trade date. They are included in non-

current assets unless there is an intention to dispose of the investment within 12 months from

the reporting date.

The investments are measured at fair value, and fair value changes are recognized through

other comprehensive income and presented net of tax in fair value reserve in equity. The

valuation is based on quoted rates and market prices at the end of the reporting period, as well

as on appropriate valuation techniques, such as cash flow discounting. Observable market data

is used in the valuation when available but also entity-specific management estimates are

applied.

Dividends are recognized in profit or loss. When equity investment is disposed, the

accumulated fair value changes are reclassified from fair value reserve to retained earnings.

The premium paid over the FPX Nickel Corp. share's market price at the acquisition date has

been treated as part of the inventory and will be released at the time of the nickel purchase.


		194

5.7 Commitments and contingent liabilities


€ million	2025	2024
Mortgages and pledges on Dec 31
Mortgages	156	156
Other pledges	13	13

Guarantees on Dec 31
On behalf of subsidiaries for commercial and other commitments	31	34

Other commitments for financing on Dec 31	8	4

Outokumpu has issued business mortgages over movable assets in Kemi to secure an

outstanding project loan maturing in September 2030.

Other pledges, EUR 13 million, relate to Outokumpu's responsibility for certain debts of the

associated company Manga LNG Oy, the amount of which was EUR 7 million at the end of the

reporting period (December 31, 2024: EUR 9 million).Outokumpu Corporation is, in relation to

its shareholding in EPV Energia Oy, liable for the costs, commitments and liabilities relating to

electricity provided by Tornion Voima Oy. These commitments are reported under other

commitments for financing.

The Group's other off-balance sheet investment commitments totaled EUR 76 million on

December 31, 2025 (December 31, 2024: EUR 42 million).

Contingent liabilities

Outokumpu is a minority shareholder in its associated company Voimaosakeyhtiö SF, which is

the majority shareholder of Fennovoima Oy. In February 2025 the Arbitral Tribunal confirmed

that it does not have jurisdiction to adjudicate claims brought by RAOS Project Oy and JSC

Rosatom Energy International (JSC REIN) against Outokumpu in arbitration proceedings over a

dispute between Fennovoima Oy and Rosatom entities related to the termination of the

Engineering, Procurement and Construction (EPC) contract in May 2022, into which Outokumpu

Corporation was joined in 2023. Therefore, the arbitration proceedings with respect to

Outokumpu have ended and there are no contingent liabilities at the end of the reporting

period.

Accounting principles

Unrecognized commitments are disclosed when the Group has an obligation or a pledge to

assume a financial liability at a future date.

A contingent liability is a possible obligation that arises from past events and the existence

of which will be confirmed by uncertain future events that are not wholly within the control of

the entity. Obligations that are not considered probable or where the amounts cannot be

reliably measured are also considered as contingent liabilities. Contingent liabilities are not

recognized in the statement of financial position but disclosed as off-balance sheet

commitments.


		195

6. Group structure and other notes

6.1 Discontinued operations

Long Products as discontinued operations in 2022

During the year 2022, Outokumpu signed an agreement to divest the majority of the Long

Products business operations to Marcegaglia Steel Group and reported it as assets held for sale

and discontinued operations. The divestment was completed on January 3, 2023. The final

escrow account settlement related to this transaction remained for the year 2024 and was

settled with a minor impact on the financial statements. The impact from the release of the

escrow account was booked to the net result in continuing operations in 2024. In 2025,

Outokumpu did not have any impacts from discontinued operations.

Accounting principles

Non-current assets or a disposal group are classified as held for sale if their carrying amount

will be recovered principally through the disposal of the assets and the sale is highly probable.

If their carrying amount will be recovered principally through their disposal rather than through

their continuing use, they are measured at the lower of carrying amount and fair value less cost

to sell. Property, plant and equipment and intangible assets are not depreciated or amortized

once classified as held for sale.

Result from the discontinued operations is reported separately from income and expenses

from continuing operations in the consolidated statement of income and prior periods are

restated accordingly. Assets and liabilities related to the discontinued operations are presented

as separate line items in the statement of the financial position and the comparative period is

not restated. The statement of cash flows consists of total group figures including the dis-

continued operations.

Intra-group revenues and expenses between continuing and discontinued operations are

eliminated in continuing operations only when the revenues and expenses are not considered to

continue after the disposal of the discontinued operations.

6.2 Business acquisitions and disposals

2025

In 2025, Outokumpu did not have any business acquisitions or disposals.

2024

Disposals

In 2024, Outokumpu divested its Mexico branch distribution business in Mexico

City, Guadalajara and Monterrey – formerly known as Outokumpu Mexinox Distribution. Prominox,

the largest stainless steel distributor in Mexico, acquired the ongoing business operations

and customer base from Outokumpu. They were reported under the operation of Outokumpu's

business area Americas. The net asset value was EUR 1 million and the gain on sale was EUR 3

million. The transaction had a positive cash impact for Outokumpu amounting to EUR 4 million.

Accounting principles

The disposed companies are included in the consolidated Financial Statements up to

the date when the control is lost. The gain or loss on disposal together with cumulative

translation adjustments related to disposed companies are recognized in the consolidated

statement of income at the date control is lost.


		196

6.3 Disputes and litigations

Fennovoima project

In May 2025, Outokumpu commented on unconfirmed news about a possible legal process

initiated in Moscow by Rosatom against Outokumpu, among other parties. By the end of the

reporting period, Outokumpu has not received any official notification regarding the reported

claim or the process. From the beginning, Outokumpu has denied and continues to deny all

grounds for liability related to the terminated Fennovoima nuclear power plant project, including

the existence of any contractual relationship or obligation between Outokumpu and any

Rosatom company. Rosatom has already previously and groundlessly attempted to involve

Outokumpu in the arbitration proceedings concerning the termination of the Engineering,

Procurement and Construction (EPC) contract regarding the Fennovoima nuclear power plant

project. As we communicated on February 14, 2025, the arbitral tribunal confirmed that it does

not have jurisdiction to adjudicate claims brought by RAOS Project Oy and JSC Rosatom Energy

International (JSC REIN) against Outokumpu. This decision terminated the arbitral proceedings

with respect to Outokumpu. There may be attempts in the future to join Outokumpu in legal

disputes arising out of the terminated project.

Dispute over payment of wages in the US

On July 16, 2018, a class of plaintiffs, consisting of former and current Outokumpu Calvert mill

employees, brought a suit against Outokumpu Stainless USA, LLC in the U.S. federal district

court, alleging that the company failed to pay full wages for regular work and overtime work they

performed. The district court entered a default judgment against Outokumpu in 2021 with

respect to liability without Outokumpu having the opportunity to argue the merits of the

allegations and subsequently found Outokumpu liable to the plaintiffs for approximately USD 13

million in the aggregate, plus attorney’s fees. Outokumpu unsuccessfully appealed the district

court’s decision and the matter was remanded to the district court for a final judgment. On July

2, 2025, the district court issued a partial judgment requiring Outokumpu to pay the plaintiffs

approximately USD 13 million plus post-judgment interest and notify certain individuals, who

were not previously notified at the initial stages of the case, that they have a right to opt-in to

the class and receive damages payments for the relevant period. Outokumpu is now awaiting

the district court’s further ruling on the damages for these additional opt-in plaintiffs,

Outokumpu’s previously argued defenses, and the amount Outokumpu must pay the plaintiffs’

attorneys for their fees. Outokumpu now has an approximately USD 11 million provision in

respect of this matter as approximately half of the provision was settled in July 2025.

Claim in Germany related to expired lease agreement

On January 19, 2018, Outokumpu Nirosta GmbH was served with a claim in the district court of

Krefeld for a declaratory judgment by the owner of a warehouse in Krefeld that Outokumpu had

leased until the end of 2016. The claim related to the responsibility for maintenance and repair

of the warehouse and amounted to EUR 19 million. The parties reached a settlement which the

court confirmed on June 4, 2025, and according to which Outokumpu has agreed to pay the

claimant in total approximately EUR 6 million in three equal installments in 2025, 2026 and

2027. The first installment was paid in June 2025. Outokumpu has an appropriate provision in

place for the remainder.

6.4 Related parties

Balances and transactions within Group including parent company and its subsidiaries have

been eliminated on consolidation and are not disclosed in this note. Related party transactions

disclosed in this note include transactions with associated companies, Solidium Oy and the key

management of the company as well as their related persons and companies in which they

have control or joint control. Key management includes Leadership Team members and

members of the parent company’s Board of Directors, and their remuneration is presented in

note 3.2. Commitments related to associated companies are presented in note 5.7. Principal

subsidiaries and associated companies are listed in notes 6.5 and 6.6.

Solidium Oy, a limited company fully owned by the State of Finland, owned 15.0% of Outokumpu

on December 31, 2025. Solidium’s mission is to strengthen and stabilize Finnish ownership in

nationally important companies and increase the value of its holdings in the long run.

Transactions with related parties are carried out at arms-length principles.

Transactions and balances with related companies


€ million	2025	2024
Sales and other operating income	97	87
Purchases	-117	-93
Dividend income	1	1

Trade and other receivables	27	25
Trade and other payables	10	11

All the transactions and balances with related companies are related to associated companies.

In 2023, Outokumpu Corporation agreed to participate in a convertible loan offered by

associated company Voimaosakeyhtiö SF to its shareholders. Outokumpu’s share of the

convertible loan is EUR 14 million. The first call of the loan was in August 2023 amounting to

EUR 5 million, the second one in October 2024 totaling to EUR 3 million and the third one in

August 2025 totaling to EUR 3 million. At the end of December 2025, the loan is valued at EUR

0 million.


		197

6.5 Subsidiaries


December 31, 2025	Country	Group holding, %
Europe
Outokumpu AS	Norway	100
Outokumpu Distribution France S.A.S.	France	100
Outokumpu Distribution Hungary Kft.	Hungary	100
Outokumpu Distribution Polska Sp. z o.o.	Poland	100
Outokumpu Europe Oy ¹⁾	Finland	100
Outokumpu India Private Limited	India	100
Outokumpu Management (Shanghai) Co., Ltd ¹⁾	China	100
Outokumpu Middle East FZCO	United Arab Emirates	100
Outokumpu Nirosta GmbH	Germany	100
Outokumpu N.V.	Belgium	100
Outokumpu Prefab AB	Sweden	100
Outokumpu Press Plate AB	Sweden	100
Outokumpu PSC Finland Oy	Finland	100
Outokumpu (Pty) Ltd	South Africa	100
Outokumpu S.A.	Spain	100
Outokumpu (S.E.A.) Pte. Ltd	Singapore	100
Outokumpu Shipping Oy	Finland	100
Outokumpu S.r.l.	Italy	100
Outokumpu Stainless AB	Sweden	100
Outokumpu Stainless B.V.	The Netherlands	100
Outokumpu Stainless Ltd	The United Kingdom	100
Outokumpu Stainless Oy	Finland	100
Outokumpu Stainless Pty Ltd	Australia	100
Outokumpu Stainless Steel (China) Co., Ltd	China	100
Outokumpu Tornio Infrastructure Oy	Finland	100


December 31, 2025	Country	Group holding, %
Americas
Outokumpu Brasil Comércio de Metais Ltda	Brazil	100
Outokumpu Mexinox S.A. de C.V.	Mexico	100
Outokumpu Stainless USA, LLC	The United States	100
ThyssenKrupp Mexinox CreateIT, S.A. de C.V.	Mexico	100
Ferrochrome
Outokumpu Chrome Oy ¹⁾	Finland	100
Other operations
Outokumpu Americas, Inc.	The United States	100
Outokumpu Distribution Benelux B.V.	The Netherlands	100
Outokumpu EvoCarbon GmbH	Germany	100
Outokumpu Holding Germany GmbH ¹⁾	Germany	100
Outokumpu Holding Nederland B.V. ¹⁾	The Netherlands	100
Outokumpu Mining Oy	Finland	100
Outokumpu Stainless Holding GmbH	Germany	100
Outokumpu Stainless UAB	Lithuania	100
Viscaria AB ¹⁾	Sweden	100
Visenta Försäkrings AB	Sweden	100

This list does not include all dormant companies. In addition, Outokumpu has branch offices in Portugal,

South Korea, Taiwan, Thailand, the United Kingdom, Turkey and Vietnam.

¹⁾ Shares and stock fully held by the parent company


		198

6.6 Associated companies


	Industry	Domicile	Ownership, %
CRONIMET North-East GmbH	Scrap metal trading	Germany	10
Envigas AB	Energy	Sweden	21
Manga LNG Oy	Energy	Finland	45
OSTP Holding Oy	Metals processing	Finland	49
Voimaosakeyhtiö SF	Energy	Finland	23

Investments in associates


€ million	2025	2024
Investments in associated companies on Jan 1	77	62
Additions	—	13
Dividends	-1	-1
Share of the profit (+) /loss (-) for the period	4	3
Other comprehensive income	0	0
Translation differences	0	0
Investments in associated companies on Dec 31	79	77

See the commitments related to the associated companies in note 5.7.

The carrying amounts of individual associated companies are immaterial in the Group's

consolidated Financial Statements.

Outokumpu is a minority shareholder in its associated company Voimaosakeyhtiö SF, which is

the majority shareholder of Fennovoima Oy. The value of the investment in Voimaosakeyhtiö SF

is EUR 0 million at the end of December 2025 (Dec 31, 2024: EUR 0 million).

In January 2024, Outokumpu acquired a 10% shareholding in the German company CRONIMET

North-East GmbH. CRONIMET is reported as an associated company using the equity

accounting method.

Management judgments

Significant influence

Management judgment is applied when assessing whether Outokumpu has significant influence

over another company. Consideration is given to whether Outokumpu has the ability to

participate in significant financial and operating policy decisions through contractual

arrangements or agreements, and whether such arrangements confer significant influence.

Accounting principles

Companies where Outokumpu generally holds voting rights of 20–50% or in which Outokumpu

otherwise has significant influence, but not control, are included in the consolidated Financial

Statements as associated companies, and they are accounted for using the equity method from

the date significant influence was obtained until it ceases.

The Group’s share of the associated company’s net result for the period is separately

disclosed below Operating profit (EBIT) in the consolidated statement of income. Outokumpu’s

share of changes recognized in the associated company’s other comprehensive income is

recognized in the Group’s other comprehensive income.

If Outokumpu’s share of the associated company’s losses exceeds the carrying amount of

the investment, the investment is recognized at zero value in the statement of financial position

and recognition of further losses is discontinued, except to the extent that the Group has

incurred obligations in respect of the associated company. The interest in an associated

company comprises the carrying amount of the investment under the equity method together

with any long-term interest that, in substance, forms a part of the net investment in the

associated company.


		199

6.7 New IFRS standards

Adoption of new and amended IFRS standards

Certain new accounting standards, amendments to or interpretations of accounting standards

have been published that came into effect only after the reporting period started on January 1,

2025. These standards and amendments have not been early adopted nor are expected to

have a material impact on Outokumpu’s current or future reporting periods nor foreseeable

future transactions. These new accounting standards and amendments are:

• Classification and Measurement of Financial Instruments - Amendments to IFRS 9 and IFRS

7, effective from January 1, 2026 - accounting policy choice of Outokumpu is not to apply

the possibility to derecognize a liability from the balance sheet earlier than the settlement

date.

• Contracts Referencing Nature-dependent Electricity - Amendments to IFRS 9 and IFRS 7,

effective from January 1, 2026 - Outokumpu applies the own use exception on these

contracts

• Annual Improvements to IFRS Accounting Standards - Volume 11, effective from January 1,

2026

• IFRS 19 Subsidiaries without Public Accountability: Disclosures, effective from January 1,

2027

The IFRS 18 Presentation and Disclosure of Financial Statements will come into effect on January 1,

2027. Outokumpu is currently assessing the impact the amendments will have on the Group’s

consolidated financial statements. The following potential impacts have been identified so far:

• The adoption of IFRS 18 will have no impact on the Group’s net profit, but the new

categories of grouping income and expenses in the statement of profit or loss will impact

how operating profit is calculated and reported. Based on a preliminary assessment, the

Group has identified the following items that may have an impact on operating profit: foreign

exchange gains and losses and related derivatives, as well as other financing‑related items,

including factoring and the revolving credit facility expenses.

• The concept of “useful structured summary” and the enhanced principles on aggregation

and disaggregation might change the line items presented on the primary financial

statements. However, the information presented will follow the same requirements of

disclosing material information as earlier and Outokumpu is not expecting to have a

significant change in information presented.

• Significant new disclosures are required for:

◦ management-defined performance measures;

◦ a breakdown of the nature of expenses for line items presented by function in the

operating category of the statement of profit or loss; and

◦ for the first annual period of applying IFRS 18, a reconciliation of each line item in

the statement of profit or loss between the restated amounts presented by applying

IFRS 18 and the amounts previously presented when applying IAS 1.

• The statement of cash flows will be changed from the net result to operating profit as the

starting point for calculating cash flows from operating activities. Interest paid will be

presented as financing cash flows and interest received as investing cash flows instead of

the current presentation as part of operating cash flows. Also dividends received will be

presented in investing cash flows instead of operating cash flows.

Outokumpu will apply IFRS 18 from the mandatory effective date of January 1, 2027.

Retrospective application is required, meaning the comparative information for the financial

year ending December 31, 2026 will be restated in accordance with IFRS 18.

6.8 Events after the balance sheet date

On January 19, 2026, Outokumpu announced the proposals of the Shareholders' Nomination

Board to the Annual General Meeting 2026. The Shareholders’ Nomination Board proposes that

the Board of Directors would consist of 10 members or, if one or more of the candidates

proposed are unavailable, a correspondingly smaller number. The Nomination Board proposes

that the current members of the Board of Directors Hilde Merete Aasheim, Heinz Jörg

Fuhrmann, Olavi Huhtala, Kari Jordan, Päivi Luostarinen, Jyrki Mäki-Kala, Petter Söderström and

Julia Woodhouse would be re-elected, and that Timo Ritakallio and Jenni Lukander would be

elected as new members, all for the term of office ending at the end of the next Annual General

Meeting. The Nomination Board also proposes that Kari Jordan would be re-elected as the

Chairman and Timo Ritakallio elected as the Vice Chairman of the Board of Directors.

On January 8, 2026, Outokumpu announced it has signed a Memorandum of Understanding

with Norsk e-Fuel, a Nordic pioneer in Power-to-Liquid project development, to work together

towards realizing a CO-to-SAF (Sustainable Aviation Fuel) production plant. Norsk e-Fuel starts a

feasibility study in 2026 and anticipates taking an investment decision around 2028, with

production start planned for 2032. Outokumpu would provide carbon monoxide (CO) side

streams from its ferrochrome production as a feedstock for the production of 80,000-100,000

tons of eSAF annually. The plant would be located next to Outokumpu’s stainless steel mill in

Koivuluoto, Tornio, Finland and once operational, it would create financial value for Outokumpu

through increased side stream utilization. The project will support Outokumpu’s decarbonization

journey by allowing the company to reduce direct CO₂ emissions by 200,000 tons annually,

representing 20% of Outokumpu's global direct emissions.


		200

Parent company Financial Statements, FAS

Income statement of the parent company


€ million	Note	2025	2024

Sales		286	303

Cost of sales	4	-180	-209

Gross margin		107	93

Other operating income	5	11	10
Administrative expenses		-155	-146
Other operating expenses	6	-1	-5

Operating profit (EBIT)		-38	-48

Financial income and expenses	8	41	112

Result before appropriations and taxes		3	64

Appropriations
Group contribution		91	46
Change in depreciation difference		-6	0

Income taxes		0	0

Net result for the financial year		88	110


		201

Balance sheet of the parent company


€ million	Note	2025	2024

ASSETS

Non-current assets

Intangible assets	9	109	115

Property, plant and equipment	10	3	2

Financial assets
Shares in Group companies	11	4,433	4,033
Loan receivables from Group companies	11	—	507
Shares in associated companies	11	13	13
Other shares and holdings	11	3	2
Other financial assets	11,13	4	1
		4,453	4,556

Total non-current assets		4,565	4,673

Current assets

Current receivables
Cash pool receivables	14	366	230
Loan receivables	14	93	22
Trade receivables	14	63	60
Prepaid expenses and accrued income	14	14	15
Other receivables	13,14	135	102
		670	428

Cash and cash equivalents		326	267

Total current assets		996	695

TOTAL ASSETS		5,561	5,368


€ million	Note	2025	2024

EQUITY AND LIABILITIES

Shareholders’ equity
Share capital	15	311	311
Premium fund	15	720	720
Invested unrestricted equity reserve	15	2,311	2,186
Retained earnings	15	253	259
Result for the financial year	15	88	110
		3,683	3,587

Untaxed reserves
Accumulated depreciation difference		6	0

Provisions
Other provisions	16	4	—

Liabilities

Non-current liabilities
Loans from financial institutions	17	300	—
Other non-current liabilities	13	2	1
		302	1

Current liabilities
Cash pool liabilities	17	891	861
Other current loans	17	460	565
Commercial papers	17	50	79
Convertible bonds	17	—	125
Trade payables	17	92	86
Accrued expenses and prepaid income	17	15	13
Other current liabilities	13,17	58	51
		1,567	1,780

Total liabilities		1,868	1,781

TOTAL EQUITY AND LIABILITIES		5,561	5,368


		202

Cash flow statement of the parent company


€ million	2025	2024

Cash flow from operating activities

Net result for the financial year	88	110
Adjustments
Depreciation and amortization	12	13
Gain/loss on sale of intangible assets, and property, plant and equipment	-9	-6
Unrealized exchange gains/losses	1	-3
Financial income and expenses	-41	-112
Group contribution	-91	-46
Change in provisions and depreciation difference	8	0
Taxes	0	0
	-120	-155

Change in working capital
Trade and other receivables increase (-)/decrease (+)	-3	31
Trade and other payables increase (+)/decrease (-)	21	-24
	18	7

Dividends received	49	0
Interest received and other financial income	149	54
Interest paid and other financial expenses	-159	-89
Income taxes paid	0	0
	39	-36

Net cash from operating activities	25	-74


€ million	2025	2024

Cash flow from investing activities
Investments in subsidiaries and other shares and holdings	-1	-1
Purchases of intangible assets	-25	-27
Purchases of intangible rights	—	-10
Proceeds from disposal of subsidiaries and returns	—	49
Purchases of property, plant and equipment	0	0
Proceeds from sale of property, plant and equipment	5	—
Proceeds from sale of intangible rights	16	8
Decrease in Group loans receivables (+)	41	—
Loans given	-3	—

Net cash from investing activities	33	19

Cash flow before financing activities	58	-55

Cash flow from financing activities
Dividends paid	-116	-110
Treasury shares purchase	—	-34
Borrowings of non-current debt	300	—
Change in current debt, net increase (+)/decrease (-)	-123	247
Group contributions received (+)/paid (-)	46	17
Change in In-house cash account	-105	-267

Net cash from financing activities	1	-148

Net change in cash and cash equivalents, increase (+)/ decrease (-)	59	-203

Cash and cash equivalents in the beginning of the year	267	470
Cash and cash equivalents at the end of the year	326	267


		203

Notes to the parent company Financial Statements

1. Accounting principles

Outokumpu Corporation’s Financial Statements have been prepared in accordance with the

Finnish accounting standards, and related laws and regulations that are effective for the

financial year ending on December 31, 2025.

Foreign currency transactions and derivative financial instruments

Foreign currency transactions are recognized using the exchange rates prevailing at the

dates of the transactions. Receivables and liabilities in foreign currencies are translated

into euro at European Central Bank exchange rates prevailing at the end of the reporting

period. Advance payments paid and received are presented at the exchange rates

prevailing at the payment dates.

Exchange rate, interest rate and metal derivatives are recognized to the balance sheet at

fair value on the trade date, and they are subsequently valued at fair value using market

rates and prices, discounted cash flows and option valuation models.

The realized and unrealized gains and losses arising from fair value changes of derivative

instruments are recognized in other operating income and expenses, or, in case the

derivative instrument is related the financing activities, in financial income and expenses.

Sales

Sales includes sales of electricity to the Group’s Nordic production facilities, consulting and

other services to subsidiaries. Revenue is recognized when the goods have been transferred

or the services performed. Sales are presented net of indirect taxes and rebates.

Cost of sales

Cost of sales includes expenses related to energy, IT services and supplies. Depreciation

and other expenses are included to the extent they relate to operational activities.

Administrative expenses

Administrative expenses include mainly costs related to salaries and social costs, IT and

other external services, rents and depreciation.

Other operating income and expenses

Other operating income and expenses include items not belonging to main business such

as rental income from real estate, gains and losses from disposals of businesses, property,

plant and equipment, and intangible assets, impairments, and gains and losses from

derivative financial instruments, other than from instruments relating to financing activities.

Appropriations

Appropriations include group contributions and the depreciation difference.

Income taxes

Income taxes include the income taxes for the current financial year as well as adjustments

to prior year taxes.

Non-current assets

Intangible assets and property, plant, and equipment are measured in the balance sheet at

cost less accumulated amortization, depreciation, and impairment losses. Lease payments

are recognized into profit or loss as rental or lease expenses, and leased assets are not

presented in the balance sheet. The planned amortization and depreciation of intangible

assets and property, plant and equipment is based on cost and estimated useful life, and

are calculated on straight-line basis or as a percentage of residual value.

The estimated useful lives are as follows:

• Intangible assets 5–10 years

• Other long-term expenses 5–10 years

• Buildings 20–40 years

• Machinery and equipment 5–20 years

• Other tangible assets 4–40 years

Impairment of property, plant and equipment, as well as certain intangible assets are

evaluated, when events or changes in circumstances indicate that future cash flows may

not be sufficient to cover the asset book values. In an event of an impairment, the asset

book values are impaired to the level of discounted future cash flows.

Financial assets include investments and receivables that are estimated to be held for

longer than one year. Investments are valued at cost or at a lower probable value.

The subsidiary share values are reviewed as part of the asset impairment testing at the

Group level, where cash flow forecasts based on value-in-use have been prepared for the

Group’s cash generating units. In subsidiary share impairment testing, these cash flow

forecasts are further allocated to amounts recoverable from different sub-groups and

subsidiaries. When permanent, an impairment is recognized if the total of the subsidiary

share value, the net loan receivables from the subsidiary or sub-group, and the net Group

external debt in the subsidiary or sub-group exceeds the recoverable amount attributed to

this subsidiary or sub-group. A previously recognized impairment loss is reversed if there is

a permanent increase in the recoverable amount.


		204

Emission allowances

Emission allowances are intangible assets valued at cost. Gains and losses from sales of

emission allowances are presented in other operating income and expenses.

Issue of equity

Proceeds from equity issues are recognized into equity in their entirety on gross basis.

Costs related to related issues of equity are recognized as financial and administrative

expenses.

Share buyback program

The share repurchases are funded by using funds from the invested unrestricted equity

reserve.

Debt

Debt, including bonds and convertible bonds, is recognized in the balance sheet at nominal

value. Arrangement fees are recognized as accrued expenses in the balance sheet and

expensed to profit or loss over the arrangement period.

Changes in current receivables

The presentation of current receivables has been updated to more accurately reflect the

nature of the underlying receivables. The comparative year’s numbers have been adjusted

accordingly.

Cash and cash equivalents

Cash and cash equivalents include cash at hand, cash in bank accounts, deposits maturing

in three months or less, and other cash equivalent assets.

2. Personnel expenses


€ million	2025	2024
Wages and salaries	-24	-22
Pension contributions	-3	-4
Personnel restructuring provision	-2	—
Other personnel expenses	-1	1
Personnel expenses on income statement	-29	-24

Information about employee benefits of the CEO and the remuneration of Board of

Directors is presented in the consolidated Financial Statements note 3.2.


	2025	2024
Average number of personnel	202	185

3. Depreciation and amortization


€ million	2025	2024
Depreciation and amortization by group of assets
Patents, licenses and other intangible rights	-1	-1
IT systems and other long-term expenditure	-11	-11
Buildings	0	0
Machinery and equipment	0	0
	-12	-13
Depreciation and amortization by function
Cost of sales	-9	-9
Administrative expenses	-4	-4
	-12	-13


		205

4. Cost of sales


€ million	2025	2024
Purchases of electricity	-145	-174
Depreciation	-9	-9
IT services and supplies	-26	-26
Other costs	0	0
	-180	-209

5. Other operating income


€ million	2025	2024
Other operating income
Market price gains and losses from derivatives	2	3
Gains on sale of intangible assets and property, plant and equipment and shares	9	6
Other income	1	0
	11	10

6. Other operating expenses


€ million	2025	2024
Other operating expenses
Market price gains and losses from derivatives	0	-1
Losses on disposals of intangible assets and property, plant and equipment	0	0
Other expenses	0	-4
	-1	-5

7. Audit fees


€ million	2025	2024
Audit	-1	-1
Audit-related services	0	—
Other services	0	0
	-2	-1

In year 2025, Audit-related services include fee for the Sustainability Statement and in year

2024 this was reported as Other services.

8. Financial income and expenses


€ million	2025	2024
Dividend income	49	—
Interest income on long-term financial assets	26	34
Interest income on current assets	17	21
Other financial income	1	2
Impairments and impairment reversals of subsidiary shares	—	130
Interest expenses	-60	-79
Impairments	-3	-3
Other financial expenses	-8	-8
Exchange gains and losses	19	15
	41	112

Financial income from and expenses to subsidiaries
Dividend income	49	—
Interest income on long-term financial assets	26	34
Interest income on current assets	11	10
Other financial income	1	2
Interest expenses	-48	-67
	39	-21

In 2023, Outokumpu Corporation agreed to participate in a convertible loan offered by

associated company Voimaosakeyhtiö SF to its shareholders. Outokumpu’s share of the

convertible loan is EUR 14 million. The first call of the loan was in August 2023 amounting

to EUR 5 million, the second one in October 2024 totaling to EUR 3 million and the third

one in August 2025 totaling to EUR 3 million. At the end of December 2025, the loan is

valued at EUR 0 million. Impairments in years 2025 and 2024 are related to this

Voimaosakeyhtiö SF loan write down.


		206

9. Intangible assets


€ million	Patents, licenses and other intangible rights	IT systems and other long-term expenditure	Construction work in progress	Emission allowances	Total
Historical cost on Jan 1, 2025	43	196	47	11	297
Additions	0	—	17	—	17
Disposals	-26	-39	—	-10	-75
Reclassifications	—	63	-64	—	0
Historical cost on Dec 31, 2025	17	221	—	1	238

Accumulated amortization and impairment on Jan 1, 2025	-38	-143	—	—	-181
Accumulated amortization on disposals	26	39	—	—	65
Amortization	-1	-11	—	—	-12
Accumulated amortization and impairment on Dec 31, 2025	-13	-116	—	—	-129

Carrying value on Dec 31, 2025	4	105	—	1	109
Carrying value on Jan 1, 2025	5	53	47	11	115

Historical cost on Jan 1, 2024	41	185	31	3	260
Additions	0	1	27	10	39
Disposals	0	0	—	-2	-2
Reclassifications	1	10	-11	—	0
Historical cost on Dec 31, 2024	43	196	47	11	297

Accumulated amortization and impairment on Jan 1, 2024	-37	-132	—	—	-169
Accumulated amortization on disposals	0	0	—	—	0
Amortization	-1	-11	—	—	-12
Accumulated amortization and impairment on Dec 31, 2024	-38	-143	—	—	-181

Carrying value on Dec 31, 2024	5	53	47	11	115
Carrying value on Jan 1, 2024	4	52	31	3	91


		207

10. Property, plant and equipment


€ million	Land	Buildings	Machinery and equipment	Other tangible assets	Total
Historical cost on Jan 1, 2025	0	4	1	0	6
Additions	—	0	0	—	0
Disposals	0	—	—	—	0
Reclassifications	—	—	0	—	0
Historical cost on Dec 31, 2025	0	4	2	0	6

Accumulated depreciation and impairment on Jan 1, 2025	—	-2	-1	0	-3
Depreciation	—	0	0	—	0
Accumulated depreciation and impairment on Dec 31, 2025	—	-2	-1	0	-4

Carrying value on Dec 31, 2025	0	1	1	0	3
Carrying value on Jan 1, 2025	0	1	1	0	2

Historical cost on Jan 1, 2024	0	4	2	0	6
Additions	—	—	0	—	0
Disposals	—	—	0	—	0
Reclassifications	—	0	—	—	0
Historical cost on Dec 31, 2024	0	4	1	0	6

Accumulated depreciation and impairment on Jan 1, 2024	—	-2	-1	0	-3
Accumulated depreciation on disposals	—	—	0	—	0
Depreciation	—	0	0	—	0
Accumulated depreciation and impairment on Dec 31, 2024	—	-2	-1	0	-3

Carrying value on Dec 31, 2024	0	1	1	0	2
Carrying value on Jan 1, 2024	0	1	1	0	3


		208

11. Non-current financial assets


€ million	Shareholdings in Group companies	Non-current loan receivables from Group companies	Shares in associated companies	Other shares and holdings	Other non-current financial assets	Total
Historical cost on Jan 1, 2025	4,033	507	13	2	1	4,556
Additions	400	—	—	1	3	404
Disposals and decreases	—	-507	—	—	—	-507
Historical cost on Dec 31, 2025	4,433	—	13	3	4	4,453

Carrying value on Dec 31, 2025	4,433	—	13	3	4	4,453
Carrying value on Jan 1, 2025	4,033	507	13	2	1	4,556

Historical cost on Jan 1, 2024	3,952	532	13	1	3	4,500
Additions	—	—	—	1	0	1
Disposals and decreases	-49	-25	—	—	-2	-76
Impairments (-) and reversals of impairments (+)	130	—	—	—	—	130
Historical cost on Dec 31, 2024	4,033	507	13	2	1	4,556

Carrying value on Dec 31, 2024	4,033	507	13	2	1	4,556
Carrying value on Jan 1, 2024	3,952	532	13	1	3	4,500

In 2025 Outokumpu Oyj injected capital to subsidiary Outokumpu Europe Oy by way of

converting internal loans into equity amounting to EUR 400 million.

There are no impairment reversals of subsidiary shares in 2025 (2024: EUR 130 million

relates to the Outokumpu Holding Nederland B.V. ).

The additions of EUR 1 million in 2025 are related to the increase in investments in EPV

Energia Oy.

Loan receivables from Group companies are carried out at arms-length principles.

Shareholdings in Group companies on December 31, 2025

The principal subsidiaries are listed in consolidated Financial Statements note 6.5.


		209

12. Financial instruments to market risks

The financial risk management of Outokumpu Group has been centralized to Outokumpu

Corporation’s Treasury and risk management function (“Treasury”). The Group’s

management of financial risks has been described in consolidated Financial Statements, in

note 5.

Outokumpu Corporation raises most of the Group’s debt and is mainly responsible for

arranging the internal funding. Interest rate risk management has also been centralized to

Outokumpu Corporation. Treasury is responsible for developing and maintaining the Group’s

bank account structure. The efficient payment processes and liquidity management of the

Group are enabled by bank account arrangements.

Subsidiaries hedge the foreign exchange and commodity risks with Treasury. Treasury

makes the derivative agreements with banks and other financial institutions according to

Treasury Policy. Outokumpu Corporation follows the price risk of emission allowances of the

Group and makes, when necessary, the emission trades with subsidiaries and with external

counterparties. The price risk of energy is followed centrally in Outokumpu Group according

to Energy Procurement policy and the Group’s price risk of energy can be hedged with

derivatives according to Treasury Policy.

Sensitivity of financial instruments to market risks


	2025	2024
€ million	In profit or loss	In profit or loss
+/-10% change in EUR/USD exchange rate	+0/-0	+0/-0
+/-10% change in EUR/SEK exchange rate	-0/+0	-0/+0
+/-1% parallel shift in interest rates	+0/-0	-0/+0

Foreign exchange position


	2025				2024
€ million	SEK	USD	GBP	Other	SEK	USD	GBP	Other
Trade receivables and payables	-9	3	0	-1	-5	3	-1	0
Loans and bank accounts	113	-790	-38	-1	151	-865	-61	4
Derivatives	-104	786	38	1	-145	862	61	-3
Net position	0	-1	0	-1	2	-1	-1	0

The sensitivity analyses apply to financial instruments only. Other assets, liabilities and off-balance sheet items such as net pension liabilities, sales and purchase orders, are not in the scope of these analyses. The

calculations are net of tax.


		210

13. Derivative instruments


	2025			2024	2025	2024
€ million	Positive fair value	Negative fair value	Net fair value	Net fair value	Nominal amounts	Nominal amounts
Currency and interest rate derivatives
Currency forwards with financial institutions	4	-11	-7	14	1,735	2,013
Currency forwards with subsidiaries	4	-4	1	-2	868	883
Interest rate swap with financial institutions	—	—	—	-2	—	125

					Tonnes	Tonnes
Metal derivatives
Forward nickel contracts with financial institutions	14	-18	-4	6	23,654	25,576
Forward nickel contracts with subsidiaries	18	-14	4	-6	23,894	27,284

					MWh	MWh
Gas derivatives
Forward gas contracts with financial institutions	0	-5	-5	4	973,118	917,408
Forward gas contracts with subsidiaries	5	0	5	-4	973,118	917,408
Total derivatives	45	-51	-6	10

Less long-term derivatives
Forward nickel contacts with financial institutions	0	—	0	0
Forward nickel contracts with subsidiaries	—	0	0	0
Forward gas contracts with financial institutions	0	-2	-2	1
Forward gas contracts with subsidiaries	2	0	2	-1
Short-term derivatives	43	-50	-6	10

All derivatives have been classified to hierarchy level 2. Short-term derivatives are presented as part of

other current receivables and other current liabilities.

14. Receivables


€ million	From subsidiaries	From others	Total
Current receivables

2025
Cash pool receivables	366	—	366
Loan receivables	93	—	93
Trade receivables	63	0	63
Prepaid expenses and accrued income	1	13	14
Other receivables	117	17	135
	641	30	670
Other receivables includes derivatives amounting to EUR 43 million and group contributions amounting to EUR 91 million.
Cash pool receivables and loan receivables with Group companies are carried out at arms- length principles.
Other receivables with Group companies do not include any special terms.

2024
Cash pool receivables	230	—	230
Loan receivables	22	—	22
Trade receivables	60	0	60
Prepaid expenses and accrued income	3	12	15
Other receivables	63	39	102
	378	50	428


€ million	2025	2024
Prepaid expenses and accrued income
Prepaid credit fees and commitment fees	1	2
Prepaid interest expenses and accrued interest income	1	3
Prepaid IT expenses	11	10
Other	1	0
	14	15


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15. Shareholders’ equity


€ million	2025	2024
Share capital on Jan 1 and Dec 31	311	311

Premium fund on Jan and Dec 31	720	720

Invested unrestricted equity reserve on Jan 1	2,186	2,220
Convertible bonds conversion	125	—
Treasury share purchase	—	-34
Invested unrestricted equity reserve on Dec 31	2,311	2,186

Retained earnings on Jan 1	259	294
Previous year’s result	110	75
Dividends paid	-116	-110
Retained earnings on Dec 31	253	259

Result for the financial year	88	110

Total shareholders’ equity on Dec 31	3,683	3,587

Distributable funds on Dec 31
Retained earnings	253	259
Result for the financial year	88	110
Invested unrestricted equity reserve	2,311	2,186
Distributable funds on Dec 31	2,652	2,555

16. Provisions


€ million	2025	2024

Environmental provision	2	—
Restructuring provision	2	—
	4	—

See more information on the restructuring provision mainly focusing on business area

Europe and global group functions in consolidated Financial Statements note 4.6.

17. Liabilities


€ million	Interest rate, %	2025	2024
	Outstanding amount
Convertible bonds
2020 fixed rate bond maturing on July 9, 2025	5.0	—	125

Loans from financial institutions
Nordea		200	—
SEB		100	—
		300	—

See more information on the convertible bonds, new loans and credit facilities in

consolidated Financial Statements notes 5.1 and 5.2.


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€ million	To subsidiaries	To others	Total
Current liabilities

2025
Cash pool liabilities	891	—	891
Other current loans	460	—	460
Commercial papers	—	50	50
Trade payables	8	84	92
Accrued expenses and prepaid income	6	10	15
Other current liabilities	17	41	58
	1,382	184	1,567
Other current liabilities includes derivatives amounting to EUR 50 million.
Cash pool liabilities and other current loans with Group companies are carried out at arms-length principles.
Other payables with Group companies do not include any special terms.

2024
Cash pool liabilities	861	—	861
Other current loans	565	—	565
Convertible bonds	—	125	125
Commercial papers	—	79	79
Trade payables	6	80	86
Accrued expenses and prepaid income	2	10	13
Other current liabilities	28	23	51
	1,462	318	1,780


€ million	2025	2024
Accrued expenses and prepaid income
Accrued interest expenses and prepaid interest income	4	8
Accrued employee-related expenses	6	4
Other	6	1
	15	13

18. Commitments and contingent liabilities


€ million	2025	2024
Other pledges on Dec 31	13	13
Guarantees on Dec 31
On behalf of subsidiaries
For financing	172	188
For commercial guarantees	0	0
For other commitments	20	33
Other commitments for financing on Dec 31	8	4
	213	238

Other pledges, EUR 13 million, relate to Outokumpu’s responsibility for certain debts of the

associated company Manga LNG Oy, the amount of which was EUR 7 million at the end of

the reporting period (December 31, 2024 EUR 9 million).

Outokumpu Corporation is, in relation to its shareholding in EPV Energia Oy, liable for the

costs, commitments and liabilities relating to electricity provided by Tornion Voima Oy.

These commitments are reported under other commitments for financing.

Minimum future lease payments on leases on Dec 31


€ million	2025	2024
Not later than 1 year	1	1
Later than 1 year	4	2
	5	3

18. Events after balance sheet date

See note 6.8 of the consolidated Financial Statements. Change to the proposals of the

Shareholders' Nomination Board to the Annual General Meeting 2026 and Memorandum of

Understanding with Norsk e-Fuel are events after the balance sheet date of the parent

company.


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Signatures of the Review by the Board of Directors and Financial Statements

We hereby state that

1) the Financial Statements prepared in compliance with the applicable accounting regulation give a true and fair view of the assets, obligations, financial position and profit or loss of both

the company and the consolidated Financial Statements;

2) the report by the board of directors includes a description that gives a truthful picture of the development and results of the business of the company and the group, and a description of

the most significant risks and uncertainties as well as other state of the company; and

3) the sustainability report included in the report by the board of directors has been prepared in compliance with the reporting standards referred to in Chapter 7 of the accounting act and

Article 8 of the taxonomy regulation.

Helsinki, February 12, 2026

Kari JordanJyrki Mäki-Kala

ChairmanVice Chairman

Hilde Merete AasheimHeinz Jörg Fuhrmann

MemberMember

Olavi HuhtalaPäivi Luostarinen

MemberMember

Karl-Petter SöderströmJulia Woodhouse

MemberMember

Kati ter Horst

CEO

Auditor signature

Our auditor´s report has been issued today.

Helsinki, February 25, 2026

PricewaterhouseCoopers Oy

Authorised Public Accountants

Samuli Perälä

Authorised Public Accountant (KHT)


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Audit and assurance


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Auditor’s Report

(Translation of the Finnish Original)

Report on the Audit of the Financial Statements

To the Annual General Meeting of Outokumpu Oyj

Opinion

In our opinion

• the consolidated financial statements give a true and fair view of the group’s financial

position, financial performance and cash flows in accordance with IFRS Accounting

Standards as adopted by the EU

• the financial statements give a true and fair view of the parent company’s financial

performance and financial position in accordance with the laws and regulations

governing the preparation of financial statements in Finland and comply with statutory

requirements.

Our opinion is consistent with the additional report to the Audit Committee.

What we have audited

We have audited the financial statements of Outokumpu Oyj (business identity code

0215254-2) for the year ended 31 December 2025. The financial statements comprise:

• the consolidated statement of income, consolidated statement of comprehensive

income, consolidated statement of financial position, consolidated statement of cash

flows, consolidated statement of changes in equity and notes to the consolidated

financial statements, which include material accounting policy information and other

explanatory information

• the income statement of the parent company, balance sheet of the parent company,

cash flow statement of the parent company and notes to the parent company financial

statements.

Basis for Opinion

We conducted our audit in accordance with good auditing practice in Finland. Our

responsibilities under good auditing practice are further described in the Auditor’s

Responsibilities for the Audit of the Financial Statements section of our report.

We believe that the audit evidence we have obtained is sufficient and appropriate to

provide a basis for our opinion.

Independence

We are independent of the parent company and of the group companies in accordance with

the ethical requirements that are applicable in Finland and are relevant to our audit, and

we have fulfilled our other ethical responsibilities in accordance with these requirements.

To the best of our knowledge and belief, the non-audit services that we have provided to

the parent company and group companies are in accordance with the applicable law and

regulations in Finland and we have not provided non-audit services that are prohibited

under Article 5(1) of Regulation (EU) No 537/2014. The non-audit services that we have

provided are disclosed in note 2.3 to the Financial Statements.

Our Audit Approach

Overview

Materiality

• Overall group materiality: € 35 million

Audit scope

• The audit scope includes parent company, and most

significant other companies, covering the vast majority of

sales, assets and liabilities.

Key Audit Matters

• Valuation of goodwill

• Valuation of Property, Plant and Equipment

• Valuation of inventories

• Status of IT system environment

• Valuation of subsidiary shares in the parent company’s

financial statements


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As part of designing our audit, we determined materiality and assessed the risks of material

misstatement in the financial statements. In particular, we considered where management

made subjective judgements; for example, in respect of significant accounting estimates

that involved making assumptions and considering future events that are inherently

uncertain.

Materiality

The scope of our audit was influenced by our application of materiality. An audit is designed

to obtain reasonable assurance whether the financial statements are free from material

misstatement. Misstatements may arise due to fraud or error. They are considered material

if individually or in aggregate, they could reasonably be expected to influence the economic

decisions of users taken on the basis of the financial statements.

Based on our professional judgement, we determined certain quantitative thresholds for

materiality, including the overall group materiality for the consolidated financial statements

as set out in the table below. These, together with qualitative considerations, helped us to

determine the scope of our audit and the nature, timing and extent of our audit procedures

and to evaluate the effect of misstatements on the financial statements as a whole.


Overall group materiality	€ 35 million
How we determined it	Based on 2025 sales
Rationale for the materiality benchmark applied	We chose sales as the benchmark because, in our view, it is a stable and an important benchmark in the group’s current situation, against which the performance of the group is measured by users of the financial statements.

How we tailored our group audit scope

We tailored the scope of our audit, taking into account the structure of the Outokumpu

group, the accounting processes and controls, and the industry in which the group

operates. The group audit scope was focused on the manufacturing companies in Finland,

Sweden, Germany, USA, Mexico, the UK and Italy. We obtained, through our audit

procedures at the aforementioned companies, combined with procedures at the parent

company group level, sufficient and appropriate evidence regarding the financial

information of the group as a whole to provide a basis for our opinion on the consolidated

financial statements.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most

significance in our audit of the financial statements of the current period. These matters

were addressed in the context of our audit of the financial statements as a whole, and in

forming our opinion thereon, and we do not provide a separate opinion on these matters.

As in all of our audits, we also addressed the risk of management override of internal

controls, including among other matters consideration of whether there was evidence of

bias that represented a risk of material misstatement due to fraud.


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Key audit matter in the audit of the group	How our audit addressed the key audit matter
Valuation of goodwill
Refer to notes 4.1 and 4.3 in the consolidated financial statements. As at 31 December 2025 the group’s goodwill balance amounted to € 457 million. Goodwill is tested by the management at least annually, irrespective of whether there is any indication of impairment. In goodwill impairment testing, the recoverable amounts are based on value in use determined by discounted future cash flows expected to be generated by the cash- generating unit. Key assumptions of the value-in-use calculations include the discount rate, sales prices, delivery volumes and the terminal value growth rate. Valuation of goodwill is a key audit matter due to the size of the goodwill balance and the level of management judgement involved in the estimation process.	Our audit of goodwill valuation focused on management’s judgement and estimates used. We assessed the appropriateness of these through the following procedures: • We tested the methodology applied in the value in use calculation by comparing it to the requirements of IAS 36, Impairment of Assets, and we tested the mathematical accuracy of the calculations. • We evaluated the reasonableness and consistency of the future cash flow forecast, including comparing them to medium term strategic plans and forecasts approved by the Board and testing the key underlying assumptions. • We tested the used discount rates, long- term growth rates and certain other assumptions made by, for example, comparing these data inputs to observable market data. • We compared the current year actual results to those included as estimates in the prior year impairment model to corroborate the reliability of management’s estimates. • We also considered the appropriateness of the related disclosures provided in notes 4.1 and 4.3 in the group financial statements.


Key audit matter in the audit of the group	How our audit addressed the key audit matter
Valuation of Property, Plant and Equipment
Refer to note 4.1 in the consolidated financial statements. As at 31 December 2025 the group’s Property, Plant and Equipment (PPE) amounted to € 1,859 million. The management assesses indicators of potential impairments on a regular basis and, if needed, tests the carrying amounts for impairments. Impairment testing requires estimations of future cash flows attributable to the asset and related valuation parameters. Valuation of Property, Plant and Equipment is a key audit matter due to the size of the balance and the level of management judgement involved in the estimation process.	We assessed the appropriateness of the group’s method and management’s judgement and estimates in the impairment calculations for Property, Plant and Equipment. We performed substantive audit procedures including e.g. testing of assets acquired, disposals and scrapings in the year and depreciation of the fixed assets mainly through analytical audit procedures. Our audit work also included testing the operating effectiveness of controls in place to ensure the appropriate valuation of Property, Plant and Equipment.


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Key audit matter in the audit of the group	How our audit addressed the key audit matter
Valuation of Inventories
Refer to note 4.4 in the consolidated financial statements. As at 31 December 2025 the group’s inventories amounted to € 1,608 million. Inventories are stated at the lower of cost and net realizable value (NRV). Net realizable value is the estimated selling price in the ordinary course of business, less the estimated costs of completion and the estimated costs attributable to the sale. Calculation of net realizable value requires estimates on sales prices for products to be sold in the future. Due to fluctuations for example in nickel and other alloy prices, the realized prices can impact the future sales prices significantly. Due to the level of management judgement and the significant carrying amounts, this is one of the key audit matters.	Our audit work included testing controls in place to ensure proper valuation of inventories. In addition, our audit procedures included, among other things, the following: • We performed tests over the prices of raw materials and verified items in the product costing of work in progress. • We performed tests over the NRV calculations and the assumptions used. • We assessed the adequacy of the obsolescence provision and the management judgement used.


Key audit matter in the audit of the group	How our audit addressed the key audit matter
Status of IT system environment
The group has historically had a fragmented system environment, which has been centralized and developed further during the financial year for example through updating and implementing new systems. The fragmented system environment and the ongoing system development impact the risks related to system access and change management, and we have accordingly designated this as a key audit matter.	We tested the group’s controls around access and change management related to the key IT systems. We performed tests of details utilizing data analysis to reduce the risks of material misstatement related to user access management to an acceptably low level. We tested the group’s controls related to the system updates and implementation. We tested the completeness and accuracy of data migrations relevant for financial reporting.


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Key audit matter in the audit of the parent company	How our audit addressed the key audit matter
Valuation of subsidiary shares in the parent company’s financial statements
As at 31 December 2025 the value of Outokumpu Oyj’s subsidiary shares amounted to € 4,433 million in the parent company’s financial statements. The valuation of subsidiary shares is assessed by the management as part of the group’s goodwill impairment testing based on the discounted cash flow model. The valuation of subsidiary shares in the parent company’s financial statements is a key audit matter due to the significant carrying amounts involved and the management judgement involved.	We assessed the appropriateness of the method and management’s judgement and estimates in the calculations through the following procedures: • We evaluated the reasonableness and consistency of the future cash flow forecast, including comparing them to medium term strategic plans and forecasts approved by the Board and testing the key underlying assumptions. • We tested the used discount rates, long- term growth rates and other assumptions made by, for example, comparing these data inputs to observable market data. • We compared the current year actual results included in the prior year impairment model to corroborate the reliability of management’s estimates.
There are no significant risks of material misstatement referred to in Article 10(2c) of Regulation (EU) No 537/2014 with respect to the consolidated financial statements or the parent company financial statements.

Responsibilities of the Board of Directors and the Managing Director

for the Financial Statements

The Board of Directors and the Managing Director are responsible for the preparation of

consolidated financial statements that give a true and fair view in accordance with IFRS

Accounting Standards as adopted by the EU, and of financial statements that give a true

and fair view in accordance with the laws and regulations governing the preparation of

financial statements in Finland and comply with statutory requirements. The Board of

Directors and the Managing Director are also responsible for such internal control as they

determine is necessary to enable the preparation of financial statements that are free from

material misstatement, whether due to fraud or error.

In preparing the financial statements, the Board of Directors and the Managing Director are

responsible for assessing the parent company’s and the group’s ability to continue as a

going concern, disclosing, as applicable, matters relating to going concern and using the

going concern basis of accounting. The financial statements are prepared using the going

concern basis of accounting unless there is an intention to liquidate the parent company or

the group or to cease operations, or there is no realistic alternative but to do so.

Auditor’s Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financial statements

as a whole are free from material misstatement, whether due to fraud or error, and to issue

an auditor’s report that includes our opinion. Reasonable assurance is a high level of

assurance, but is not a guarantee that an audit conducted in accordance with good

auditing practice will always detect a material misstatement when it exists. Misstatements

can arise from fraud or error and are considered material if, individually or in the aggregate,

they could reasonably be expected to influence the economic decisions of users taken on

the basis of these financial statements.

As part of an audit in accordance with good auditing practice, we exercise professional

judgment and maintain professional skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the financial statements,

whether due to fraud or error, design and perform audit procedures responsive to those

risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for

our opinion. The risk of not detecting a material misstatement resulting from fraud is

higher than for one resulting from error, as fraud may involve collusion, forgery,

intentional omissions, misrepresentations, or the override of internal control.

• Obtain an understanding of internal control relevant to the audit in order to design audit

procedures that are appropriate in the circumstances, but not for the purpose of

expressing an opinion on the effectiveness of the parent company’s or the group’s

internal control.

• Evaluate the appropriateness of accounting policies used and the reasonableness of

accounting estimates and related disclosures made by management.


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• Conclude on the appropriateness of the Board of Directors’ and the Managing Director’s

use of the going concern basis of accounting and based on the audit evidence obtained,

whether a material uncertainty exists related to events or conditions that may cast

significant doubt on the parent company’s or the group’s ability to continue as a going

concern. If we conclude that a material uncertainty exists, we are required to draw

attention in our auditor’s report to the related disclosures in the financial statements or,

if such disclosures are inadequate, to modify our opinion. Our conclusions are based on

the audit evidence obtained up to the date of our auditor’s report. However, future

events or conditions may cause the parent company or the group to cease to continue

as a going concern.

• Evaluate the overall presentation, structure and content of the financial statements,

including the disclosures, and whether the financial statements represent the underlying

transactions and events so that the financial statements give a true and fair view.

• Plan and perform the group audit to obtain sufficient appropriate audit evidence

regarding the financial information of the entities or business units within the group as a

basis for forming an opinion on the group financial statements. We are responsible for

the direction, supervision and review of the audit work performed for purposes of the

group audit. We remain solely responsible for our audit opinion.

We communicate with those charged with governance regarding, among other matters, the

planned scope and timing of the audit and significant audit findings, including any

significant deficiencies in internal control that we identify during our audit.

We also provide those charged with governance with a statement that we have complied

with relevant ethical requirements regarding independence, and to communicate with them

all relationships and other matters that may reasonably be thought to bear on our

independence, and where applicable, related safeguards.

From the matters communicated with those charged with governance, we determine those

matters that were of most significance in the audit of the financial statements of the

current period and are therefore the key audit matters. We describe these matters in our

auditor’s report unless law or regulation precludes public disclosure about the matter or

when, in extremely rare circumstances, we determine that a matter should not be

communicated in our report because the adverse consequences of doing so would

reasonably be expected to outweigh the public interest benefits of such communication.

Other Reporting Requirements

Appointment

We were first appointed as auditors by the annual general meeting on 21 March 2017.

Other Information

The Board of Directors and the Managing Director are responsible for the other information.

The other information comprises the report of the Board of Directors and the information

included in the Annual Report, but does not include the financial statements or our

auditor’s report thereon. We have obtained the report of the Board of Directors prior to the

date of this auditor’s report and the Annual Report is expected to be made available to us

after that date.

Our opinion on the financial statements does not cover the other information.

In connection with our audit of the financial statements, our responsibility is to read the

other information and, in doing so, consider whether the other information is materially

inconsistent with the financial statements or our knowledge obtained in the audit, or

otherwise appears to be materially misstated. With respect to the report of the Board of

Directors, our responsibility also includes considering whether the report of the Board of

Directors has been prepared in compliance with the applicable provisions, excluding the

sustainability report information on which there are provisions in Chapter 7 of the

Accounting Act and in the sustainability reporting standards.

In our opinion, the information in the report of the Board of Directors is consistent with the

information in the financial statements and the report of the Board of Directors has been

prepared in compliance with the applicable provisions. Our opinion does not cover the

sustainability report information on which there are provisions in Chapter 7 of the

Accounting Act and in the sustainability reporting standards.

If, based on the work we have performed on the other information that we obtained prior to

the date of this auditor’s report, we conclude that there is a material misstatement of this

other information, we are required to report that fact. We have nothing to report in this

regard.

Other statements based on law

Registration of the income tax report

Our responsibility is to, based on our audit, express an opinion on the registration and

publication of the income tax report required in Chapter 7 b of the Accounting Act.

The Board of Directors and the Managing Director are responsible for the registration and

the publication of the income tax report.

In our opinion, the company has not been obliged to register and publish an income tax

report referred to in Chapter 7 b of the Accounting Act for the financial year immediately

preceding the financial year.


		221

Other statements

The proposal by the Board of Directors regarding the distribution of profits is in compliance

with the Limited Liability Companies Act. We support that the Board of Directors and the

Managing Director of the parent company should be discharged from liability for the

financial period audited by us.

Helsinki, February 25, 2026

PricewaterhouseCoopers Oy

Authorised Public Accountants

Samuli Perälä

Authorised Public Accountant (KHT)


		222

Independent Auditor’s Report on the ESEF Financial Statements of Outokumpu Oyj

(Translation of the Finnish Original)

To the Board of Directors of Outokumpu Oyj

We have performed a reasonable assurance engagement on the financial statements

5493009YRUJJDCFF0R80-2025-12-31-1-fi.zip of Outokumpu Oyj (business identity code

0215254-2) that have been prepared in accordance with the Commission's regulatory

technical standard for the financial year 1 January-31 December 2025.

Responsibilities of the Board of Directors and the Managing Director

The Board of Directors and the Managing Director are responsible for the preparation of the

company's report of the Board of Directors and financial statements (the ESEF financial

statements) in such a way that they comply with the requirements of the Commission's

regulatory technical standard. This responsibility includes:

• preparing the ESEF financial statements in XHTML format in accordance with Article 3 of

the Commission's regulatory technical standard

• tagging the primary financial statements, notes and company's identification data in the

consolidated financial statements that are included in the ESEF financial statements

with iXBRL tags in accordance with Article 4 of the Commission's regulatory technical

standard and

• ensuring the consistency between the ESEF financial statements and the audited

financial statements.

The Board of Directors and the Managing Director are also responsible for such internal

control as they determine is necessary to enable the preparation of ESEF financial

statements in accordance with the requirements of the Commission's regulatory technical

standard.

The Board of Directors and the Managing Director are also responsible for such internal

control as they determine is necessary to enable the preparation of ESEF financial

statements in accordance with the requirements of the Commission's regulatory technical

standard.

Auditor’s Independence and quality management

We are independent of the company in accordance with the ethical requirements that are

applicable in Finland and are relevant to the engagement we have performed, and we have

fulfilled our other ethical responsibilities in accordance with these requirements.

The auditor applies International Standard on Quality Management (ISQM) 1, which requires

the firm to design, implement and operate a system of quality management including

policies or procedures regarding compliance with ethical requirements, professional

standards and applicable legal and regulatory requirements.

Auditor’s responsibilities

Our responsibility is to, in accordance with Chapter 7, Section 8 of the Securities Markets

Act, provide assurance on the financial statements that have been prepared in accordance

with the Commission's regulatory technical standard. We express an opinion on whether the

consolidated financial statements that are included in the ESEF financial statements have

been tagged, in all material respects, in accordance with the requirements of Article 4 of

the Commission's regulatory technical standard.

Our responsibility is to indicate in our opinion to what extent the assurance has been

provided. We conducted a reasonable assurance engagement in accordance with

International Standard on Assurance Engagements (ISAE) 3000 (Revised).

The engagement includes procedures to obtain evidence on:

• whether the primary financial statements in the consolidated financial statements that

are included in the ESEF financial statements have been tagged, in all material respects,

with iXBRL tags in accordance with the requirements of Article 4 of the Commission's

regulatory technical standard and

• whether the notes and company's identification data in the consolidated financial

statements that are included in the ESEF financial statements have been tagged, in all

material respects, with iXBRL tags in accordance with the requirements of Article 4 of

the Commission's regulatory technical standard and

• whether there is consistency between the ESEF financial statements and the audited

financial statements.

The nature, timing and extent of the selected procedures depend on the auditor’s

judgment. This includes an assessment of the risk of a material deviation due to fraud or

error from the requirements of the Commission's regulatory technical standard.

We believe that the evidence we have obtained is sufficient and appropriate to provide a

basis for our opinion.


		223

Opinion

Our opinion pursuant to Chapter 7, Section 8 of the Securities Markets Act is that the

primary financial statements, notes and company's identification data in the consolidated

financial statements that are included in the ESEF financial statements of Outokumpu Oyj

5493009YRUJJDCFF0R80-2025-12-31-1-fi.zip for the financial year 1 January-31

December 2025 have been tagged, in all material respects, in accordance with the

requirements of the Commission's regulatory technical standard.

Our opinion on the audit of the consolidated financial statements of Outokumpu Oyj for the

financial year 1 January-31 December 2025 has been expressed in our auditor's report

dated 25 February 2026. With this report we do not express an opinion on the audit of the

consolidated financial statements nor express another assurance conclusion.

Helsinki, February 25, 2026

PricewaterhouseCoopers Oy

Authorised Public Accountants

Samuli Perälä

Authorised Public Accountant (KHT)


		224

Assurance Report on the Sustainability Statement

(Translation of the Finnish Original)

To the Annual General Meeting of Outokumpu Oyj

We have performed a limited assurance engagement on the group sustainability report of

Outokumpu Oyj (business identity code 0215254-2) that is referred to in Chapter 7 of the

Accounting Act and that is included in the report of the Board of Directors for the reporting

period 1.1–31.12.2025.

Opinion

Based on the procedures we have performed and the evidence we have obtained, nothing

has come to our attention that causes us to believe that the group sustainability report

does not comply, in all material respects, with

1) the requirements laid down in Chapter 7 of the Accounting Act and the sustainability

reporting standards (ESRS), and

2) the requirements laid down in Article 8 of the Regulation (EU) 2020/852 of the

European Parliament and of the Council on the establishment of a framework to

facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (EU

Taxonomy).

Point 1 above also contains the process in which Outokumpu Oyj has identified the

information for reporting in accordance with the sustainability reporting standards (double

materiality assessment).

Our opinion does not cover the tagging of the group sustainability report with digital XBRL

sustainability tags in accordance with Chapter 7, Section 22, Subsection 1(2), of the

Accounting Act, because sustainability reporting companies have not had the possibility to

comply with that requirement in the absence of requirements for the tagging of

sustainability information in the ESEF regulation or other European Union legislation.

Basis for Opinion

We performed the assurance of the group sustainability report as a limited assurance

engagement in compliance with good assurance practice in Finland and with the

International Standard on Assurance Engagements (ISAE) 3000 (Revised) Assurance

Engagements Other than Audits or Reviews of Historical Financial Information.

Our responsibilities under this standard are further described in the Responsibilities of the

Authorised Group Sustainability Auditor section of our report.

We believe that the evidence we have obtained is sufficient and appropriate to provide a

basis for our opinion.

Authorised Group Sustainability Auditor's Independence and Quality

Management

We are independent of the parent company and of the group companies in accordance with

the ethical requirements that are applicable in Finland and are relevant to our engagement,

and we have fulfilled our other ethical responsibilities in accordance with these

requirements.

The authorised group sustainability auditor applies International Standard on Quality

Management ISQM 1, which requires the authorised sustainability audit firm to design,

implement and operate a system of quality management including policies or procedures

regarding compliance with ethical requirements, professional standards and applicable

legal and regulatory requirements.

Responsibilities of the Board of Directors and the Managing Director

The Board of Directors and the Managing Director of Outokumpu Oyj are responsible for:

• the group sustainability report and for its preparation and presentation in accordance

with the provisions of Chapter 7 of the Accounting Act, including the process that has

been defined in the sustainability reporting standards and in which the information for

reporting in accordance with the sustainability reporting standards has been identified,

• the compliance of the group sustainability report with the requirements laid down in

Article 8 of the Regulation (EU) 2020/852 of the European Parliament and of the

Council on the establishment of a framework to facilitate sustainable investment, and

amending Regulation (EU) 2019/2088, and for

• such internal control as the Board of Directors and the Managing Director determine is

necessary to enable the preparation of a group sustainability report that is free from

material misstatement, whether due to fraud or error.

Inherent Limitations in the Preparation of a Sustainability Report

In reporting forward-looking information in accordance with ESRS, management of the

Company is required to prepare the forward-looking information on the basis of

assumptions that have been disclosed in the sustainability statement about events that

may occur in the future and possible future actions by the Group. Actual outcomes are

likely to be different since anticipated events frequently do not occur as expected.


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Responsibilities of the Authorised Group Sustainability Auditor

Our responsibility is to perform an assurance engagement to obtain limited assurance

about whether the group sustainability report is free from material misstatement, whether

due to fraud or error, and to issue a limited assurance report that includes our opinion.

Misstatements can arise from fraud or error and are considered material if, individually or

in the aggregate, they could reasonably be expected to influence the decisions of users

taken on the basis of the group sustainability report.

Compliance with the International Standard on Assurance Engagements (ISAE) 3000

(Revised) requires that we exercise professional judgment and maintain professional

skepticism throughout the engagement. We also:

• Identify and assess the risks of material misstatement of the group sustainability report,

whether due to fraud or error, and obtain an understanding of internal control relevant to

the engagement in order to design assurance procedures that are appropriate in the

circumstances, but not for the purpose of expressing an opinion on the effectiveness of

the parent company’s or the group’s internal control.

• Design and perform assurance procedures responsive to those risks to obtain evidence

that is sufficient and appropriate to provide a basis for our opinion. The risk of not

detecting a material misstatement resulting from fraud is higher than for one resulting

from error, as fraud may involve collusion, forgery, intentional omissions,

misrepresentations, or the override of internal control.

Description of the Procedures That Have Been Performed

The procedures performed in a limited assurance engagement vary in nature and timing

from, and are less in extent than for, a reasonable assurance engagement. The nature,

timing and extent of assurance procedures selected depend on professional judgment,

including the assessment of risks of material misstatement, whether due to fraud or error.

Consequently, the level of assurance obtained in a limited assurance engagement is

substantially lower than the assurance that would have been obtained had a reasonable

assurance engagement been performed.

Our procedures included for example the following:

• We interviewed the company's management and the individuals responsible for

collecting and reporting the information contained in the group sustainability report at

the group level to gain an understanding of the sustainability reporting process and the

related internal controls and information systems.

• We familiarised ourselves with the background documentation and records prepared by

the company where applicable, and assessed whether they support the information

contained in the group sustainability report.

• We assessed the company's double materiality assessment process in relation to the

requirements of the ESRS standards, as well as whether the information provided about

the assessment process complies with the ESRS standards.

• We assessed whether the sustainability information contained in the group sustainability

report complies with the ESRS standards.

• Regarding the EU taxonomy information, we gained an understanding of the process by

which the company has identified the group's taxonomy-eligible and taxonomy-aligned

economic activities, and we assessed the compliance of the information provided with

the regulations.

• We performed a site visit to the company’s site in Avesta, Sweden and interviewed

persons responsible for the reporting process in Calvert, USA and Tornio, Finland.

Helsinki, February 25, 2026

PricewaterhouseCoopers Oy

Authorised Sustainability Auditors

Tiina Puukkoniemi

Authorised Sustainability Auditor


Review by the Board of Directors	2
Review by the Board of Directors	3
Sustainability statement	15
Group key figures	124

Financial Statements	133
Consolidated statement of income	135
Consolidated statement of comprehensive income	136
Consolidated statement of financial position	137
Consolidated statement of cash flows	138
Consolidated statement of changes in equity	139
Notes to the consolidated Financial Statements	140
Parent company Financial Statements, FAS	200

Signatures of the Review by the Board of Directors and Financial Statements	213
Auditor’s report and assurance report	214