In 2023, we commenced our double materiality process, in accordance with the process set out in ESRS 1, which covers general requirements for reporting in accordance with CSRD. We mapped our value chain and identified the industries on which we depend across our value chain. Next, we identified impacts, risks, and opportunities (IROs) across our full value chain for all ESG sub-topics and sub-sub-topics contained in Appendix A of ESRS 1. To assess the materiality of different IROs and topics, we developed a scoring key from 0-5 for both impact and risk materiality and set a materiality threshold at 2 or above for materiality and 3 or above for highly material topics, where 2 represented low scale, concentrated scope, remediable with some effort and a low likelihood, while a 3 represented medium across the same variables. Through this process we assessed 31% of topics to be highly material and 21% of topics to be material for our own operations, and 45% of topics to be highly material and 35% of topics to be materials for our value chain. In 2024, we finalized our double materiality process through the following steps: We made updates to IROs and scoring based on further inputs from stakeholders and additional guidance from EFRAG. We set the reporting threshold at 3 or higher to focus reporting on the most material topics. We then mapped disclosure requirements and data points against material IROs to determine the contents of this Sustainability Statement, taking into account the specificity of IROs where needed to scope out data points where the IROs are limited to for example specific parts of our value chain, employee groups, or geographies.

Overall, like any other risk, our risks are integrated in our strategy and business model through enterprise risk management processes, whereas managing our impacts is anchored in compliance with relevant legislation, as well as integration of additional policies, actions, and targets of our strategy and our business model where managing the impact requires additional efforts. We have assessed the time horizon for impacts to be the strategy period until 2028, as we lack clarity beyond that to accurately assess the materiality of impacts. Through a high-level resilience analysis in which we assessed the implications of these IROs on the overall sustainability of our business for the same period, we assess that the nature and severity of our IROs do not require us to alter our strategy and business model at a scale and pace beyond our capacity to adjust if required. As described in more detail on the next page, we assess that generally we can manage IROs through policies, targets, and actions that fit within the context of our existing business model and strategy.

We have identified three actual, negative impacts related to climate. Even though we have also identified climate-related risks in accordance with the recommendations of the Taskforce for Climate-Related Financial Disclosures (TCFD), across other topics and integrated with non-ESG risks to the business, these were not assessed to be material in accordance with the threshold applied in our double materiality assessment (see pages 49-51). We have identified one actual, negative impact for our own operations (Scopes 1 and 2) and one specific to our value chain (Scope 3), related to the negative effects on climate change as a consequence of carbon emissions caused by every aspect of our core activity and value chain activities we depend on. We have identified one further actual, negative impact for our own operations and value chain, related to the consumption of fossil fuel energy. We respond to these impacts through our climate transition plan, which is integrated into our wider strategy. See pages 67-71 for further detail on the management of these impacts.

Overall, like any other risk, our risks are integrated in our strategy and business model through enterprise risk management processes, whereas managing our impacts is anchored in compliance with relevant legislation, as well as integration of additional policies, actions, and targets of our strategy and our business model where managing the impact requires additional efforts.

We have assessed the time horizon for impacts to be the strategy period until 2028, as we lack clarity beyond that to accurately assess the materiality of impacts.

We have identified nine IROs related to workers in the value chain. Overall, all these IROs reflect our dependence for our core activity of manufacturing electronic devices on suppliers in industries with documented negative social impacts, specifically mining, plastic and aluminum production, paper production, freight and logistics, electronics manufacturing, and e-waste treatment. We cannot accurately link the majority of these potential impacts to GN’s activities because they occur in industries that are at tier 2 or beyond supplier level in our upstream value chain. We directly or indirectly have business relations with a very large number of sub-suppliers, in a part of our value chain where we have limited visibility and no direct supplier relationships to leverage an assessment of potential social impacts. For this reason, it is also not possible for these impacts to identify very specific (groups of) people or geographies where GN’s activities lead to impacts. Workers we consider to be at high risk of impact and therefore in scope for this assessment include: Agency workers working on GN sites in countries with weak worker protection controls (this covers agency workers at our manufacturing site in Malaysia). Blue-collar workers working for upstream entities involved in mining, plastic, aluminum and paper production, and electronics manufacturing. Blue-collar workers working for downstream entities involved in freight and distribution, and electronic waste processing.

We have identified four material risks related to governance. Overall, these risks reflect GN’s dependence on a wide range of business relations across many geographies, which inherently create risks around business ethics in relation to third parties. We have identified one material risk related to culture, representing a potential failure of internal compliance culture leading to employees to not uphold our business ethics standards, as stipulated in our Ethics Guide or local laws. We have identified one material risk related to whistleblowers, representing a potential failure to adequately protect or support whistleblowers. We have identified one material risk related to third party relations, representing the potential consequences of a failure of third-party due diligence leading to GN doing business with disreputable entities. We have identified two material risks related to corruption and bribery, one representing the potential financial consequences of a failure to prevent or detect corruption and bribery, and it leading to incidents of corruption or bribery. We respond to these risks by ensuring robust business ethics, third-party due diligence and whistleblower processes within the context of our existing business model and strategy (see pages 103-104).

We have identified four material risks related to governance. Overall, these risks reflect GN’s dependence on a wide range of business relations across many geographies, which inherently create risks around business ethics in relation to third parties. We have identified one material risk related to culture, representing a potential failure of internal compliance culture leading to employees to not uphold our business ethics standards, as stipulated in our Ethics Guide or local laws. We have identified one material risk related to whistleblowers, representing a potential failure to adequately protect or support whistleblowers. We have identified one material risk related to third party relations, representing the potential consequences of a failure of third-party due diligence leading to GN doing business with disreputable entities. We have identified two material risks related to corruption and bribery, one representing the potential financial consequences of a failure to prevent or detect corruption and bribery, and it leading to incidents of corruption or bribery. We respond to these risks by ensuring robust business ethics, third-party due diligence and whistleblower processes within the context of our existing business model and strategy (see pages 103-104).

We have assessed the time horizon for impacts to be the strategy period until 2028, as we lack clarity beyond that to accurately assess the materiality of impacts. Through a high-level resilience analysis in which we assessed the implications of these IROs on the overall sustainability of our business for the same period, we assess that the nature and severity of our IROs do not require us to alter our strategy and business model at a scale and pace beyond our capacity to adjust if required. As described in more detail on the next page, we assess that generally we can manage IROs through policies, targets, and actions that fit within the context of our existing business model and strategy.

As this is our first year reporting based on IROs, there are no changes compared to previous reporting periods.