Sustainability Report

Our emissions data is compiled annually using verified internal records.

Scope 1 includes fuel use from fleet and on-site operations; Scope 2 reflects electricity consumption reported on a location-based basis, with market-based adjustments where REGOs are held. Scope 3 is being developed through Gemisoft Green, our internal tool calculating emissions from waste freighting on a project-by-project basis.

The most emission-intensive process was loading and unloading, responsible for around 73% of Scope 1 emissions, followed by shredding (10.1%) and fueling/support activity (9.4%). The hub with the highest emissions was Hull, and the most emission-intensive month was October, reflecting peak operational activity.

Our reduction efforts will therefore focus on improving the efficiency and electrification of loading, handling and shredding equipment at high-activity hubs.

To strengthen data-driven emissions management through the development of Gemisoft Green and hub-level dashboards, enabling informed, sustainable decisions across Geminor's operations and partnerships.

Measured by:

• Verified Scope 1 and Scope 2 coverage at all hubs
• Hub-level emissions dashboards in PBI reporting
• Year-on-year reduction in emissions intensity per tonne processed

During 2024 and 2025, Geminor improved its ESG data collection and emissions calculation methods. Increased automation and stronger reporting controls helped identify previous data gaps, making the 2025 figures more complete and reliable. As a result, some historical figures are not fully comparable.

Scope 1 and 2 emissions increased from 1,245.8 tCO₂e in 2024 to 2,237.2 tCO₂e in 2025, a 79.6% increase. This was predominantly driven by higher Scope 2 market-based emissions, which rose from 603.4 tCO₂e to 1,408.1 tCO₂e.

In Denmark, our Aalborg hub facility was closed for parts of 2024 following a fire and only returned to operation in the latter part of the year, while activity levels also increased in 2025. In Poland, emissions increased due to the establishment of a new and larger office facility in Warsaw, where energy consumption is primarily related to heating.

Scope 1 emissions also increased from 642.4 tCO₂e to 829.1 tCO₂e. In contrast, location-based Scope 2 emissions decreased by 31.4%, reflecting differences between market-based electricity factors and national grid-average factors.

Emissions intensity increased from approximately 0.43 to 0.81 tCO₂e per MNOK turnover, reflecting both higher reported emissions and lower turnover from 2,900 MNOK to 2,761 MNOK.

• Our Scope 1 emissions totaled 829.1 tCO₂e in 2025, reflecting the inclusion of detailed activity-level emissions data and operational equipment emissions across our sites.
• Loading/Unloading remains the largest source of emissions, accounting for approximately 82% of total Scope 1 emissions, driven by fuel consumption by material-handling equipment.
• Fueling/support activities (9%) and baling/wrapping (8%) represent the next largest emission sources, highlighting opportunities to improve fuel efficiency and optimise operational processes.

Market-based Drivers: In 2025, the Danish Hub (GWT DK ApS) remained the primary driver of market-based Scope 2 emissions, with a significant increase linked to higher operational activity and electricity consumption. The UK Hub (Geminor UK Ltd) continued to represent a substantial share of total emissions, while smaller increases were also observed across office operations.

Location-based emissions: Emissions decreased compared with 2024 and remained significantly lower than market-based emissions. This mainly reflects the low-carbon electricity mix in several operating regions, particularly in the Nordics, where hydropower and other renewable electricity sources reduce grid emission intensity.

Our indirect emissions are dominated by waste transport across the value chain, with the majority of tonnage moved by road and sea and a small share historically carried by rail. As a waste trading business, these emissions are strongly influenced by logistics choices, transport distances and recovery destinations rather than our own operations.

Following changes to CSRD requirements, our approach has shifted toward aligning with RED III and partner expectations. As a minimum, this requires the ability to provide reliable input data for emissions calculations, including:

• Distance travelled
• Transport mode
• Vehicle and fuel type used

This data forms the basis for credible emissions reporting and informed decision-making across the value chain.

To improve how value chain emissions are managed and understood, we are focusing on:

• Using Gemisoft to maintain strong traceability of transport routes and logistics choices
• Prioritising case-specific data over generic Scope 3 factors
• Working with selected partners to improve primary data quality over time
• Linking waste quality, logistics and recovery routes to climate impact
• Exploring opportunities to increase lower-emission transport options where viable
• Strengthening value chain due diligence, including compliance, transparency and welfare standards

All waste volumes are captured and traced digitally through Gemisoft, Geminor’s internal logistics and reporting system.

Every tonne collected, transported, and treated is recorded with its recovery route, enabling consistent KPIs for energy recovery, recycling, and landfill across markets. This ensures traceable, auditable data reflecting actual operational outcomes rather than estimates.

Geminor's strategy is to grow responsibly within its core fractions: RDF, SRF, biomass, hazardous waste and waste wood. Quality and regulatory compliance are critical across all of them. The primary objective is to identify waste quality risks and opportunities across these streams, with a focus in 2025 on ETS-related challenges for waste-to-energy and their implications for fuel quality, fossil carbon and cost. Post-consumer recycled fractions represent a smaller share of volumes but remain strategically important to Geminor's circular value chain.

Within this strategy, our operating objectives are to:

• maximise recovery at the highest viable treatment level, in line with the waste hierarchy
• maintain full regulatory compliance across all waste streams and shipments, in particular, the changes to POPs measurement in transboundary waste shipments
• improve waste quality insight to support ETS and carbon-cost navigation, building on the digital database developed through 2025
• increase recycling where material quality and markets allow
• minimise landfill, particularly for non-recoverable residues

• Stable Diversion: Over the past four years, our diversion rate has remained consistently high, with total volume peaking in 2023 at over 2.2M tonnes.
• In 2025, total treated waste amounted to approximately 2.14 million tonnes. Energy recovery remained the dominant treatment route, representing 86% of total volume, followed by recycling at 11% and landfill at 2.5%. This indicates continued high diversion from landfill, with only a small share of waste sent to landfill.

• Fuel Quality & Demand: RDF (70,7%) and SRF (13,8%) dominate our volumes. We are seeing a shift in the market in which RDF quality demands and technical knowledge requirements now mirror those of high-spec SRF.
• Market Maturity: Waste Wood remains our lead recycled fraction (65,7%), driven by a highly mature recycling infrastructure.
• The Plastic Gap: While Plastic and Rubber make up 2,7% of recycling, they remain a tiny fraction of total waste handled; a result of a difficult secondary market struggling to compete with virgin plastic prices.
• Biomass: Continues to be a stable pillar of our energy recovery portfolio, providing reliable renewable heat and power.
• The "Others" category (12,3%), mostly glass and metals, is a key focus area. We are investigating these residual streams to ensure valuable materials aren't being "wasted" when they could be recovered.

• Significant Landfill Reduction: Landfill volumes dropped drastically from 98,463 tonnes in 2023 to just 8,898 tonnes in 2024.
• Recovery Breakthrough: We achieved a significant shift in 2024, with energy recovery reaching 237,512 tonnes, a major increase compared to previous years.
• Basel & "PIC" Compliance: Every cross-border shipment follows the Prior Informed Consent (PIC) procedure, which requires written authorisation from all states through which it passes before movement begins.
• The "OECD Plus" Standard: We operate under "OECD Decision" rules, ensuring hazardous waste only moves between countries with equivalent environmental standards for recovery.
• Financial Security: As required by the Basel Convention, all shipments are covered by mandatory financial guarantees to protect against environmental risks during transit.
• Landfill Trends: While landfill remains a necessary route for specific residues (32,645 tonnes in 2024), our strategic focus is to continue transitioning these volumes toward high-efficiency energy recovery.

• ISO 9001, ISO 14001 and ISO 45001
  • Full recertification audits completed across Norway, Denmark, and the UK (including the inclusion of the Hull site within the group certification scope)
  • Successfully passed, with new certifications valid until 2029
  • Demonstrated continued strength in quality, environmental management, and occupational health and safety practices

• PEFC (Programme for the Endorsement of Forest Certification)
  • Newly achieved certification in 2025
  • Required implementation of robust supply chain controls and due diligence systems
  • Confirms alignment with recognised standards for the responsible sourcing of forestry-based materials

See our Certifications and Standards here

Geminor is strengthening its management system, Landax, to support more consistent governance as the business continues to grow. External support has been engaged to improve system usability, efficiency, and alignment with operational needs.

Key improvements include stronger document control processes to increase accountability and support ISO compliance. Reporting activities are also being automated, while the NCR module is being redeveloped to improve ease of use and data quality.

These improvements will make Landax a more intuitive and actively used system across the organisation, supporting management oversight, operational control, and continuous improvement in QHSE governance.