1.1. Background

Fellowes sources & manufactures office products which can be made of forest-derived commodities, such as wood, rubber, paper & cardboard. Fellowes does not source raw materials directly from forest areas, and does not conduct any extractive activities.

In addition, Fellowes has a significant presence in the EU market, and is in scope of the EUDR. The EUDR aims to curb the EU’s impact on global deforestation and forest degradation and reduce greenhouse gas emissions and biodiversity loss due to deforestation.

Fellowes’ EUDR compliance and deforestation assurance activities will be conducted though supply chain engagement and use of voluntary 3rd party certifications.

Following amendments to the EUDR, obligations are allocated according to the economic operator's role within the supply chain. For many products supplied by Fellowes, Fellowes may act as a downstream operator and rely on due diligence conducted by upstream operators. In such cases, Fellowes maintains traceability and retains, where applicable, the relevant Due Diligence Statement (DDS) reference information in accordance with the EUDR.

4.1. EUDR Compliance Approach

This due diligence process applies to all products placed on the EU market.

The EUDR covers the following seven commodities as well as a number of derived products: Cattle, Cocoa, Coffee, Oil palm, Rubber, Soya and Wood. Fellowes only supply wood-based and rubber-based products. The list of commodity codes and product groups can be found in Appendix I.

Fellowes commits to performing a structured due diligence process. Relevant products shall not be placed or made available on the market or exported, unless all of the following conditions are fulfilled:

• they are deforestation-free;
• they have been produced in accordance with the relevant legislation of the country of production; and
• they are covered by a due diligence statement which has been submitted to the EU prior to placing the product on the market.

Fellowes determines its obligations on a product-by-product basis according to its role under the EUDR. Where Fellowes acts as:

Upstream Operator / Importer

• Fellowes performs due diligence.
• Fellowes submits the required DDS through the EUDR Information System prior to placing products on the EU market.

First Downstream Operator

• Fellowes relies on DDS information received from upstream operators.
• Fellowes maintains the required traceability information and DDS references.
• Fellowes retains records for the legally required period and addresses any substantiated concerns regarding non-compliance.

Downstream Operator / Trader

• Fellowes maintains supplier and customer traceability information as required by the Regulation.
• Fellowes does not keep DDS records.

4.2. Due Diligence Process

The due diligence system consists of three key elements: information collection, risk assessment and risk mitigation.

4.2.1 Information Collection

The information and data that must be gathered as part of the due diligence process includes:

• a detailed description of the relevant products,
• the country of production,
• the geolocation of all plots of land where the relevant commodities that the relevant product contains, or has been made using, were produced,
• information about the supplier(s) and
• adequately conclusive and verifiable information that the relevant commodities have been produced in accordance with the relevant legislation of the country of production.

Fellowes will gather the necessary information through email exchanges and the collection of relevant evidence documents in order to submit the DDS in the NT-TRACES portal.

4.2.2. Risk Assessment

Fellowes’ risk assessment aims to establish whether there is a risk of deforestation. Products are only allowed to be placed on the market where the risk assessment reveals no or only a negligible risk that the relevant products are non-compliant.

Fellowes assesses deforestation risks based on a combination of two factors: the country risk as provided by the EU Commission (country benchmarking published in June 2025), and the presence of 3rd party certifications at the supplier sites & products.

Suppliers which have an FSC® or equivalent certification (for example, SFI or PEFC) for their facility, and who supply FSC-certified products will be deemed low risk. Fellowes verifies the FSC or SFI certificates by requesting the certificates and checking the validity directly on the websites of FSC or SFI. In case of doubts, for example due to the difference in company names (e.g. parent company and subsidiary), Fellowes can reach out directly to the applicable certification body to confirm the scope of the FSC/SFI/PFEC certificate.

Fellowes does not source products from high-risk countries (as per the EUDR benchmarking).

However, if any concern is raised by a stakeholder (for example, through the whistleblower line) or any information arises, a precautionary principle will be adopted, and the supplier will be considered medium risk while the situation is further investigated.

Where the risk assessment does not result in low or negligible risk, Fellowes will adopt risk mitigation measures set out in Article 11 of the EUDR before placing the products on the market.

4.2.3. Risk Mitigation

Fellowes follows a comprehensive supplier on-site audit process that scrutinizes a broad spectrum of a suppliers’ business practices — from manufacturing procedures to facilities security, social accountability, and environmental sustainability. The audits result in a graded score that determines whether Fellowes will further engage with that supplier:

• Green status suppliers require audits every two years
• Amber status suppliers require audits every year.
• Anyone scoring under 50% is red listed.

For all suppliers, regardless of the risk level, Fellowes has issued a Supplier Code of Conduct which needs to be signed by all suppliers. Fellowes tracks completion of the signatures.

4.3. Information Sharing

The NT-TRACES portal will be the main vehicle for sharing information. Fellowes will have a Due Diligence Statement (DDS) for each product group placed on the market where Fellowes’ role is Upstream Operator or Importer. Fellowes will include the DDS number, or the reason for EUDR exemption, in the invoices supplied to our customers. This is the primary means of information sharing.

Depending on Fellowes' role within the supply chain, customers may receive:

• a Fellowes DDS reference number;
• an upstream DDS reference number;
• confirmation that Fellowes is a Downstream Operator; or
• confirmation that the product is outside the scope of the EUDR.