RELEX Environmental Policy

Purpose and scope

The Environmental Policy (this “Policy”) applies to all employees of Retail Logistics Excellence – RELEX Oy and its subsidiaries (collective “RELEX Solutions”, the “Company”, “we”, or “our”, as applicable). This policy’s scope affects our company’s internal operations across all functions and our value chain including suppliers and customers.

The Environmental Policy was created to minimize negative environmental impacts in our internal operations and our value chain. Together with our Sustainable Procurement policy, it outlines our commitments to environmental responsibility.

Mechanism for policy review

This Environmental Policy is reviewed annually. The policy update process is led by the Head of Sustainability. The Policy owner reviews and approves the final version of the policy. Next policy review is scheduled for June 2026. The schedule can be changed due to special circumstances.

The Sustainability team re-evaluates the environmental focus areas and goals annually, and the results of the re-evaluation are reflected in the updated Environmental policy. The policy is also aligned with the outcomes of Double Materiality Assessment (DMA), which includes key stakeholder interviews to capture their interests on the environmental topics. The latest DMA was conducted in 2024. Information on the DMA methodology and outcomes is available in RELEX substantiality report (2025) online.

Respected third-party standards

The Environmental Policy respects and follows the following third-party standards and initiatives: GHG Protocol for greenhouse gas (GHG) emission inventory and reporting, and the 2030 Agenda for Sustainable Development and contribute to the goal #12-3 on reduction of food waste and goal #13 on climate action. In 2024, RELEX has joined the Science-Based Targets Initiative (SBTi) and committed to setting science-based emission reduction targets within two years of our commitment.

To comply with the Corporate Sustainability Reporting Directive (CSRD), we already switched to the European Sustainability Reporting Standards (ESRS) in our 2025 reporting. We disclose our sustainability information to Carbon Disclosure Project (CDP) and UN Communication on Progress (Global Compact). We also complete EcoVadis assessment annually to receive an independent rating for our sustainability efforts.

Allocation of responsibilities

The most senior level role in the organization that is accountable for the implementation of policy is the Chief Sustainability Officer. Together with the Head of Sustainability, the Chief Sustainability Officer is responsible for setting and reviewing the environmental objectives and targets, monitoring the implementation of the policy guidelines across the organization. In addition, our sustainability reporting and targets are reviewed by the Board of Directors.

Further responsibilities for implementing policy guidelines are distributed as follows. The VP of Cloud Platform is responsible for public cloud and co-location data centres, including related services like servers and storage systems. The VP of IT has global responsibility for internal IT devices and their lifecycle. Global Workplace Lead is responsible for RELEX’s office spaces globally including sustainability targets of the office spaces and category-related procurement. The function leads are responsible for the implementation of responsible travel guidelines within their function. The Head of Procurement is responsible for the implementation of sustainable procurement guidelines, which are documented in a standalone Sustainable Procurement policy.

Contents

1. Policy objectives and commitments
2. Carbon emission inventory and key emission categories
3. Resource use and waste in RELEX’s operations
4. Environmental advocacy and awareness in our value chain

1. Policy objectives and commitments

We are committed to minimizing our negative environmental impacts, both in our internal operations and in our value chain. This policy sets our environmental targets, and lists the actions and guidelines that we, as a company and individuals, are undertaking to reach these.

At RELEX, we are proud to be driving a positive impact by helping our customers reduce their carbon footprints. Based on our estimates, the yearly positive environmental impact is over 1 200 000 tons CO2e, calculated on food waste prevention in retail and wholesale alone. That does not mean that we can overlook the impacts of our own operations, which in 2024 caused 9751.7 tons of CO2e. For details, please see our latest Sustainability Report 2025.

In 2024, RELEX has evaluated the Science-Based Targets initiative and committed to setting the targets aligned with the goals of the Paris Agreement by the year 2026. This commitment will change our approach to environmental target setting.

Before we set the science-based targets, RELEX has been tracking the effectiveness of our actions through an emission intensity reduction target (metric tons of CO2e / M€ revenue). Our key environmental target is to reduce the emission intensity by 5% on a yearly basis. In the reporting year 2024, the emission intensity has gone down by 9.9% compared to the year before (2023). We also see reduced emission intensity in our largest emission category, business travel by 8.0%. In the reporting year 2025, we will again evaluate our progress by measuring the emission intensity and comparing the progress to the intensity in the year 2024.

The policy outlines concrete objectives and targets and the measures in place for us to reach them. The policy tackles three focus areas: 1) carbon emissions inventory, 2) resource use and waste in RELEX’s operations, and 3) environmental awareness in our value chain.

2. Carbon emission inventory and key emission categories

As a SaaS company, we mainly deal with non-physical goods and services. Scope 1 and 2 account for only 1.1% of our emissions, whereas 98.9% of our emissions occur in our value chain in Scope 3.

2.1. GHG emission inventory practices at RELEX

RELEX is committed to conduct GHG emission inventory annually and publicly disclose the outcomes. Our carbon emission accounting practices follow the standards and guidelines of the GHG Protocol Corporate Accounting, The Corporate Value Chain (Scope 3) Standard, and other relevant supplementing guidelines published by Greenhouse Gas Protocol. The GHG accounting calculations cover all RELEX offices globally. We have adopted the operational control consolidating approach in RELEX’s GHG emissions accounting. The reporting period applied to calculate the GHG emissions is the same as the company’s own financial reporting period. Our emissions are calculated and verified by a third party.

In 2024, we have expanded the boundaries of RELEX’s GHG emission accounting to include total spend. RELEX has also completed an acquisition process during 2024, and the emissions of the acquired company are now part of the consolidated GHG emission reporting. For these reasons, we restated RELEX’s emissions for the year 2023 in the Sustainability Repot 2025. The updated boundaries were also used to calculate the emissions for the year 2024. The restated emissions calculations from the year 2023 will be used as a base year for setting science-based reduction targets.

2.2. Use of energy

As a software company, we rely on the use of energy to develop and offer our products and services to our clients.

2.2.1. Optimizing energy use for cloud computing

Our objective is to minimize the climate impact of our SaaS offering by increasing the use of renewable energy for our software product and engaging with our cloud infrastructure providers for adopting more environmentally friendly practices. We have already reached the aim of 100% renewable energy use by RELEX Solutions in co-location data centres, and our target is to maintain this level. Our servers meet EnergyStar / EU 2019/424 requirements.

We are committed to using co-location data centre service providers that have selected renewable energy or buy energy attribute certificates or, if such suitable vendors cannot be identified in a specific geographical area, purchasing the energy attribute certificates corresponding to our energy consumption in that data centre ourselves and working with the data centre service provider to support them in increasing their use of renewable energy. Through this, we have reached 100% renewable energy use by RELEX Solutions in co-location data centres.

Our public cloud infrastructure providers are consistently increasing their use of renewable energy, some of them having reached 100% already, and all are already currently reporting their carbon footprints and water use and have goals and roadmaps to reduce their climate impact.

We also recognize that we can reduce cloud energy consumption and thus emissions by making sure we utilize cloud resources in an optimal way. In our Technology function we are increasingly incorporating GreenOps and FinOps practices to achieve both environmental and financial benefits. Last year alone, our emission intensity in our biggest public cloud provider declined by 24%, with the help of cloud optimization actions.

2.2.2. Use of renewable energy in RELEX’s offices

We choose renewable electricity in all locations where we as the tenants have this opportunity to do so. In some locations we reach this target by purchasing Guarantee of Origin (GO, REGO) and Renewable Energy Certificates (REC, I-REC). We have already reached our target that 100% of RELEXians work in offices where we have secured renewable electricity and are committed to keeping it this way.

2.3. Business travel and employee commute

Our objective is to foster a responsible travel culture among the RELEX employees. It is our most significant emission category, and at the same time the category which individual RELEXians can influence the most.

2.3.1. Business travel and flights

In the year 2024, RELEX has introduced a bonus component for the leadership team on business travel emission reduction justified by the fact that travel emissions are the largest emission category for RELEX. Meeting the target results in a bonus component corresponding to 1% of the base salary.

We encourage all RELEXians to be thoughtful when it comes to business traveling. We acknowledge that while traveling can often be replaced by online meetings, sometimes face-to-face interactions are necessary. Traveling on-site for very short meetings should be avoided. If there is a true need for travel, it is recommended to make the most of the business trip, by e.g. booking several meetings or visiting the local office to connect with other RELEXians. The train should be chosen over air travel whenever feasible. Often air travel is the only feasible option, but when booking flights, direct flights should be favored over stopover flights.

In addition, we acknowledge that internal events such as department kickoffs form a substantial part of our business travel emissions. The guiding principle is that events should be hosted where most participants are located. When organizing events from most/all RELEX geographies, the following aspects should be considered:

• The destination should be on the continent where most of the participants are from
• The destination should have good flight accessibility so that the participants can arrive with direct flights

2.3.2. Employee commute and use of office spaces

Our objective is to reduce our emissions from employee commuting and from our use of office spaces. In addition to our supporting hybrid and even fully remote work, we aim to further reduce emissions by emphasizing 1) commuting-friendly locations, 2) energy-efficient buildings demonstrated by certificates (LEED and Breeam), and 3) use of renewable energy in our assessment of new own office space leases.

Our aim is to relocate our largest by employee count office, the RELEX Solutions headquarters, to a more energy-efficient and accessible location by 2027. The new RELEX Solutions headquarters in Espoo, Finland with an estimated completion date in 2026, is aimed to be a flagship project for sustainable office design. Key tenets of this project are 1) salvaging elements of the previous existing building that can be used in the new building from a usability, safety, and financial point of view, 2) designing the office for flexible use that also serves the local community, 3) leveraging existing furniture and opting for reusing or using upcycled furniture when possible from a usability and availability point of view, and 4) energy-efficiency (LEED Platinum). This approach requires more work from our staff and extensive collaboration with our design, furnishing, and real estate partners, but it is a commitment we see very much worthwhile. We are also committed to sharing information and lessons learned from this unique project, with the goal of helping and inspiring other businesses to take similar steps.

To minimize unnecessary commutes, RELEX supports hybrid work and provides support for employees that choose to work from home. We provide IT equipment and home office furniture to help our employees create an ergonomic work-from-home environment.

3. Resource use and waste in RELEX’s operations

In our operations, waste is primarily generated from two sources: IT hardware and equipment that reaches its end of life & office waste. This section outlines our commitments to properly manage the waste generated in these two categories.

3.1. Lifecycle management of IT equipment

Our goal is to extend the lifecycle of electronic products and ensure their proper end-of-use and end-of-life treatment. To achieve this goal, we adopted a leasing scheme for our personal IT equipment (laptops, mobile phones, monitors). For IT equipment, expanding product lifecycles and ensuring proper end-of-life treatment are key. Our procurement and IT departments continuously assess the most appropriate lease period lengths for different types of leased equipment to find the right balance between sustainability and performance. For example, in 2023, we updated our mobile phone leasing lifecycles from two to three years.

Leased equipment is typically returned to the leasing company after the leasing period, except when equipment is purchased for extended use. For end-of-life purchased goods, Vendor Asset Resale & Recovery (ARR) services are used. Our leasing and equipment partners either resell or reuse the returned equipment or recycle it responsibly in accordance with local regulations.

We also handle the servers’ end-of-life recycling responsibly/according to WEEE Directive 2012/19/EU standards.

3.2. Recycling at the office

Our objective is to foster waste recycling practices among RELEX’s employees in all our offices. We have already reached a very good level, and our goal is to maintain this level. In 2023, we have made further improvements in our offices worldwide, introducing recycling bins in offices that did not yet meet local standards, and educating and informing our employees on proper recycling practices. Our offices have only reusable dishware and cutlery in use.

Our selection of RELEX’s merchandise products includes items made from recycled cotton and plastic. In addition, many of our offices have during 2023 introduced schemes for swapping items that the employees no longer use, such as clothing, books, and toys.

Our objective is to rely on internal business practices that enable us to work efficiently while being environmentally friendly. To reduce use of paper, RELEX adopted paper-free business practices which rely on cloud document management and e-signature tools. The environmental benefits from using these tools (for example, DocuSign) are associated with reduced paper use in our business transactions and opportunity to influence paper usage habits over time.

4. Environmental advocacy and awareness in our value chain

We are supporting our clients in their sustainability journey by offering a solution that can prevent food waste in our clients’ supply chains. In addition, we work on establishing dialogue with our value chain partners to increase awareness of environmental sustainability and together build capacity for impactful improvements.

4.1. Our clients: carbon handprint

For years, RELEX has helped its customers to reduce waste throughout the supply chain. This is achieved through more accurate planning of demand, inventory, space, promotions and manufacturing, and through information sharing across the supply chain. In addition to reducing waste, better supply chain planning leads to reduced transport emissions.

It is estimated that 8-10% of global greenhouse gas emissions come from food waste alone, and we are very proud of the results we have achieved in reducing these emissions. Our solution is already helping hundreds of food retailers and wholesale companies reduce their food waste by up to 40%. Even a 15% reduction across our customer base means preventing over 350 000 kilograms of food waste on a yearly basis. That translates to a carbon handprint equivalent to 1 200 000 metric tons of CO2 equivalents in 2024.

Together with our customers, we can play a big part in mitigating climate change, and we are thus committed to continuously developing our solutions to innovate new ways of decarbonizing the supply chains of our customers, across all industries.

4.2. Our internal operations

We aim to inform our employees about sustainability agenda at RELEX and to educate our employees on reducing our company’s carbon handprint and increasing positive impact.

In 2024, we introduced an introductory course on sustainability for all new employees. The course is a part of the onboarding program recommended to all new employees and has an objective to increase internal awareness of sustainability issues among the RELEX employees. This basic course introduces new employees with RELEX’s carbon handprint and major carbon footprint categories. It demands our new employees familiarize themselves with the Environmental Policy. We expect all our employees to read and comply with the Environmental Policy as part of the bi-annual company-wide mandatory Business Ethics certification course. Our target is to maintain a 100% compliance rate among our employees with the Environmental policy.

In addition, our digital platform RELEX Skills Academy offers a comprehensive sustainability course for more in-depth knowledge on the subject.

RELEX also encourages its employees to participate in the charitable initiatives that are close to their hearts including those that target environmental issues. RELEX adopted the Charitable Volunteering policy that allows everyone at RELEX to use up to 2 paid workdays for volunteering.

RELEX regularly issues internal communication on sustainability topics for its employee in the format of online blog posts and as part of a monthly company-wide newsletter.

4.3. Supplier engagement

99% of our emissions come from our value chain. It is therefore crucial that our suppliers are committed to climate targets as well. We are conducting vendor assessments, with the near-term goal of collecting more accurate emission data from our value chain.

Our objective is to build capacity by assessing the level of ESG maturity of our targeted vendors with a focus on climate measures and goals. We invite RELEX’s targeted suppliers to respond to an online questionnaire. Our goal is to achieve or exceed the response rate of 90% by 2028. By adopting this measure, we also aim to improve the data quality in RELEX’s GHG inventory and increase the availability of data obtained directly from our suppliers on the emissions that arise from RELEX’s use of their products and services.