Environmental Impact Statement & Sustainability Commitment

Date: February 15, 2026 Reporting Period: Calendar Year 2025 Location: Utrecht, The Netherlands

1. Company Overview

Guideways B.V. is a specialized Artificial Intelligence software provider focused on accelerating regulatory approval, compliance and reimbursement for medical devices.

As a “cloud-native” organization based in the Netherlands, our operations are designed to decouple business growth from environmental impact. We operate with a minimal physical footprint, relying on shared infrastructure and public transportation to maintain a near-zero operational carbon intensity.

2. Sustainability Methodology

We track, document, and report our Scope 1, 2, and significant Scope 3 Greenhouse Gas (GHG) emissions.

Our methodology aligns with the GHG Protocol Corporate Standard:

• Operational Boundary: We apply the control approach, accounting for emissions from operations over which we have financial or operational control.
• Scope 3 Materiality: Given our software-as-a-service (SaaS) business model, we have identified “Cloud Computing Services” and “Business Travel” as our only material Scope 3 categories. Upstream manufacturing and downstream distribution categories are not applicable to our operations.

3. Emissions Data (2025)

Scope	Category	Emissions (tCO2e)	Source & Methodology
Scope 1	Direct Emissions	0.00	N/A. We do not own or lease fleet vehicles, nor do we operate combustion facilities (generators, boilers).
Scope 2	Purchased Energy (Electricity & Heat)	0.00	Market-Based. Our operations are housed in Spaces (IWG) facilities in Utrecht. IWG workspaces are certified Carbon Neutral as of 2023 through 100% renewable procurement and offsetting programs.
Scope 3	Category 6: Business Travel	< 0.10	Negligible. >95% of business travel is conducted via NS (Dutch Railways), which has been powered by 100% wind energy since 2017.
Scope 3	Category 1: Purchased Goods & Services (Cloud)	0.10	Primary Source. Aggregated carbon footprint data from AWS, Microsoft Azure, and Google Cloud Platform dashboards.
Total		0.10

*Note: Scope 3 Cloud emissions data is based on the “Location-Based” method provided by hyperscale cloud providers.

4. Science-Based Targets & Future Commitment

Guideways is committed to the goals of the Paris Agreement. Our strategy to maintain low emissions intensity includes:

1. Infrastructure Selection: Prioritizing cloud regions with >90% carbon-free energy (CFE) scores.
2. Circular Workplace: Utilizing shared service offices to eliminate the need for redundant building materials, heating, and lighting assets.
3. Low-Carbon Transport: Maintaining a “Public Transport First” policy for all employee commuting and client visits within the Benelux region.

5. Labour & Human Rights

We confirm our adherence to the labour standards set forth in the RBA Code of Conduct.

• Wages: All employees and contractors are compensated according to liveable wage standards which “may exceed minimum wage standards.
• Health & Safety: Our operations are conducted in a fully compliant, Grade-A office environment.
• Freedom of Association: We respect the rights of all employees to form or join trade unions and bargain collectively, in accordance with Dutch law.