Bilfinger SE

Governance roles

Reference: pages 87-89.

Bilfinger SE has a dual management and control structure: an Executive Board (CEO and CFO, both German, both male) and a twelve-member Supervisory Board (six employee representatives, six shareholder representatives) (page 89). Committees dealing with sustainability matters include Group Executive Management (GEM), the Bilfinger Risk Committee (BRC), the Safety Council, the Compliance Review Board (CRB), the Independent Allegation Management Committee (IAMC) and the Disciplinary Committee (page 88).

The Executive Board "conducts the business and manages the company and the Group independently...and is responsible for dealing with material impacts, risks and opportunities, particularly with regard to ESG sustainability matters" (page 87-88). The Supervisory Board "monitors and advises the Executive Board, including with regard to the impact, risks and opportunities in the area of ESG sustainability matters" through four committees (page 89).

Composition and diversity (page 89): the Supervisory Board is 33 percent female (four of twelve members), 83 percent independent (ten of twelve), and 75 percent German nationals. The Executive Board met its stated gender target (0 percent for a two-member board).

Information and sustainability matters

Reference: pages 89-90.

The Executive Board, Supervisory Board and Audit Committee "are informed by Group Investor Relations about material impacts, risks and opportunities, the implementation of due diligence in the area of sustainability and the results and effectiveness of the policies, measures, metrics and targets adopted" (page 89).

"All IROs identified for Bilfinger were available to the Executive Board when dealing with the materiality analysis carried out in the reporting year. These formed the basis for the final assessment of materiality" (page 90); the Audit Committee and Supervisory Board then discussed the results.

During the reporting year the Supervisory Board dealt in particular with "Strategy, functional organization, sustainability reporting and CO2 reduction," and the Group Executive Management was informed about current HR/HSEQ topics at every meeting and "dealt in detail with the development of the target for reducing greenhouse gas emissions" (page 90).

Remuneration and ESG targets

Reference: pages 90, 110.

"The remuneration system for the Executive Board, which has been in place since 2024, takes ESG targets into account in both the short-term and long-term incentives" (page 90); detail is incorporated by reference to the remuneration report.

The climate-specific extension (ESRS E1 paragraph 13) is disclosed under Targets related to climate change: the long-term incentive tranche for the 2024-2026 performance period "takes into account the three-year development of CO2e in Scopes 1 and 2 (cumulative), measured based on the intensity of kgCO2e/T € revenue. The intensity in the base year 2023 is 10.49 kgCO2e/T €. The goal is a 20 percent improvement compared to 2023" (page 110).

Supervisory Board remuneration "does not include any sustainability components" (page 90).

Statement on due diligence

Reference: page 90.

"Bilfinger's administrative, management and supervisory bodies exercise due diligence with regard to potential and actual negative impacts throughout the value chain within the scope of corporate governance. The requirements are based on national legislation and the German Corporate Governance Code" (page 90).

The five core elements of due diligence disclosed are: (a) integration into governance, strategy and business model; (b) involvement of relevant stakeholders; (c) identification and assessment of negative impacts; (d) measures to prevent and mitigate negative impacts; and (e) tracking the effectiveness and communication of progress (page 90). Each element is mapped in a table to the corresponding ESRS 2 GOV, SBM, IRO and MDR disclosure requirements and to the topic-related ESRS (page 90-91).

Risk management and internal controls

Reference: page 92.

This disclosure requirement is incorporated by qualified reference to the Chapter Risk management of the combined management report (Section 36.b) (page 92). The referenced chapter "includes a description of how sustainability risks have been prioritized compared to other types of risks, the decision-making process and the associated internal control procedures, a description of the extent to which and how the process for identifying, assessing and managing impacts and risks is integrated into the overall risk management process" (page 93, footnote 52).

Strategy, business model and value chain

Reference: pages 83-84.

"Bilfinger is an internationally oriented industrial services company, which offers engineering and other industrial services to customers in the process industry" (page 17558 context), active "primarily...in Europe, North America and the Middle East, working for customers in the process-industry in the core markets of chemicals and petrochemicals, energy, oil & gas, pharma & biopharma as well as adjacent markets" (page 83). With over 30,000 employees, Bilfinger offers "consulting & engineering, prefabrication & installation, access & insulation as well as asset performance" (page 83).

As a service provider, Bilfinger is part of its customers' upstream value chain; downstream influence is limited "to environmental matters to enhance the efficiency and sustainability of customers," with "no further influence on end products for consumers" (page 83).

Bilfinger states it "does not generate revenue from exploration, extraction, production, manufacturing, processing, storage, refining or distribution of fossil fuels," is "not active in chemicals production," and has no activity "in the field of controversial weapons or in the cultivation and production of tobacco" (page 84).

Interests and views of stakeholders

Reference: page 84.

Bilfinger identifies four key stakeholder groups with target-group-specific engagement (page 84): customers (daily presence at customer facilities, annual satisfaction surveys including Net Promoter Score), workers (works councils and the European Works Council, annual appraisals, quarterly Pulse Checks on strategy/sustainability/employer attractiveness), suppliers (Supplier Code of Conduct, regular audits on working conditions, equal treatment and data protection) and capital market participants (quarterly reports, capital market days, conferences, the Annual General Meeting, lender briefings).

"The results of these dialogs are systematically incorporated into the strategy and business model" (page 84).

Material impacts, risks and opportunities

Reference: pages 85-87.

"The materiality analysis was updated in 2025; the sustainability topics classified as material in the previous year remained largely unchanged" (page 85). The material topics reported on are climate change, own workforce, workers in the value chain, business conduct, and the company-specific topic of industrial services to enhance efficiency and sustainability (pages 86-87).

For each material topic, Bilfinger sets out how it shares in the impacts through its own activities and business relationships, e.g. "Climate change: Bilfinger has set the goal of actively contributing to climate change mitigation through its business relationships to increase the efficiency of customer plants" (page 87).

"From today's perspective, there are no material risks and opportunities that pose a significant risk of a material adjustment to the carrying amounts of the assets and liabilities reported in the associated financial statements in the next reporting period" (page 87). The corporate strategy formulated in 2023 was "subjected to a comprehensive analysis in the reporting year," with results "publicly communicated in December 2025 together with new medium-term targets for the next five years until 2030" (page 87).

Process to identify and assess material IROs

Reference: pages 92-93.

Bilfinger "identifies and evaluates significant impacts, risks and opportunities (IROs) throughout the entire value chain on the basis of double materiality," covering own operations and the upstream and downstream value chain (page 92-93). The methodology comprises identification (potential and actual IROs recorded for all ESRS 2 topics, subtopics and sub-subtopics, from internal analyses, industry comparisons and stakeholder dialog), assessment (materiality scored 1 to 5, with scope, scale, likelihood and, for negative impacts, irremediable character considered), time horizons (short/medium/long-term), scenario analysis for climate-related IROs, and a distinction between actual/potential and positive/negative impacts (page 93).

"Impacts, risks and opportunities with ratings in the upper fifth of the rating scale are classified as material" (page 93). The process is unchanged from the prior year and is embedded in the Group-wide risk and opportunity management system (page 92).

Disclosure requirements covered

Reference: pages 91, 93-98.

"Bilfinger's sustainability statement covers all of the company's material disclosure requirements under the reporting standards. The determination was made on the basis of a double materiality assessment...Sustainability topics that fulfill at least one of the materiality criteria are reported in the respective topic-related chapter or as company-specific disclosures" (page 94). Topics reported on: industrial services to enhance efficiency and sustainability (company-specific), climate change, own workforce, workers in the value chain, and business conduct (page 94).

Bilfinger states it "makes use of the option of an abridged reporting on the topic of workers in the value chain, which has been assessed as material. Condensed reporting is carried out in accordance with the disclosure requirements defined in ESRS 2.17," and "also makes use of the phase-in of disclosure requirements" (page 91) — applied to S1-7, S1-11 and E1-9, each marked "Omitted (phase-in)" in the index (pages 94-95).

Biodiversity/ecosystems (E4), resource use/circular economy (E5), pollution (E2), affected communities (S3), water/marine resources (E3) and consumers/end-users (S4) are explicitly stated as not material (page 96). The index is followed by an Appendix B list of ESRS datapoints derived from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law) (pages 96-101).

Transition plan for climate change mitigation

Reference: pages 106-107.

"Bilfinger is aware of the importance of a formal transition plan for decarbonization. The company has worked on developing this plan in the past and will continue working on it in the coming financial year before finalizing it with regional managers" (page 107) — i.e. no finalized formal transition plan document is yet in place.

As a foundation, "Bilfinger successfully had its climate targets validated by the internationally recognized Science Based Targets initiative (SBTi) in the 2025 financial year," committing "to achieving net-zero emissions throughout the entire value chain by 2050" (page 107). The targets and alternatives "were discussed in Group Executive Management" and decided "by a formal Executive Board resolution," with the Supervisory Board informed (page 107). Specific Scope 1/2 measures by region were developed in 2025; Scope 3 measure development "is planned for the coming financial year" (page 107).

Back-filled from ESRS 2 IRO-1 and the E1 climate-DMA section (pages 107-108). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Climate scenario analysis

Reference: pages 107-108.

Physical risk: "the company's own operations and the downstream value chain were considered. Bilfinger's upstream value chain was not identified as relevant." "Using the IPCC SSP5-8.5 scenario, climate hazards, exposure and vulnerability were assessed for the periods 2015-2034 and 2031-2050" (page 107) — a high-emission scenario, consistent with the standard's requirement.

Transition risk and opportunity: analyzed "on the basis of the International Energy Agency (IEA) 'Net Zero Emissions by 2050' and NGFS scenarios," grouped into market, technology, policy/regulation and reputation per TCFD (page 108) — a 1.5°C-aligned scenario is used, though global-average-temperature projections are not stated.

Key assumptions, exact scope of operations and the date of the exercise beyond "financial year 2025" are not detailed. "The aggregated results of the climate scenario analysis were transferred to the materiality analysis, but were not assessed as material" (page 108).

Back-filled from ESRS 2 SBM-3 (pages 108-109). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Resilience in relation to climate change

Reference: pages 108-109.

"The resilience of the business model was assessed using climate scenario analyses and taking into account the most important influencing factors" (page 108). The analysis assumes the energy mix "will increasingly shift toward nuclear and renewable energies," expecting short/medium-term revenue growth "from energy infrastructure and efficiency improvements" and a longer-term shift of revenue "to non-fossil markets" (page 108).

"Short-term market reactions with strong shifts in demand are identified as uncertainties," mitigated by "the cross-sector orientation of our business model and the decentralized structure," and by "diversification of our business activities and long-term contracts" (page 108-109). No quantified capacity-to-adapt figures are given. Overall, "it was determined that there are no significant risks or opportunities for Bilfinger's business model" across the 2025, 2030 and 2050 horizons considered (page 108).

Climate policies

Reference: page 109.

"Bilfinger SE has Group-wide concepts in place to meet the challenges of climate change," covering both own operations and the upstream/downstream value chain, built around two core areas: "climate change adaptation and climate protection" (GHG reduction in Scopes 1 and 2 under the GHG Protocol, measured via a Group-wide SOP) and "energy consumption and energy mix" (promotion of renewables and efficiency) (page 109).

Integration into strategy runs through "promotion of climate-friendly energies," "digitalization and monitoring," "stakeholder integration" and "optimization of the value chain...with the involvement of suppliers" (page 109). The Executive Board is responsible for implementation; the Supervisory Board monitors material aspects. Progress is assessed against GHG intensity per net revenue (page 109).

Climate actions and resources

Reference: pages 111-112.

Bilfinger "used an emissions tracking tool...to model and evaluate decarbonization measures," recording affected sources, reduction potential and cost per tonne of CO2e (page 111). Scope 1 levers: fleet electrification ("Vehicles in Europe from 2026" policy, expected -66% Scope 1 emissions by 2034 vs. 2024), fuel transition to HVO100 (-26%), and building efficiency/portfolio measures (-8%) (page 111-112). Scope 2 levers: green electricity procurement and Energy Attribute Certificates, which "reduced CO2e emissions by 8,485 tonnes in financial year 2025," targeting ~-70% by 2034 (page 112). Scope 3: "decarbonizing the electricity mix" and "sustainable procurement," not yet quantified (page 112).

"The financial resources budgeted for investments (CapEx) and operating costs (OpEx) are not classified as material" (page 112); "nature-based solutions...were not implemented in the financial year" (page 112).

Climate targets

Reference: pages 109-111.

Validated by the SBTi in 2025. Net-zero across the value chain by 2050. Near-term (by 2034, 2024 base year): Scope 1+2 absolute reduction of 58.8 percent; Scope 3 absolute reduction of 35 percent (page 110). Long-term (by 2050): Scope 1+2 and Scope 3 each reduced 90 percent, with "the remaining 10 percent of greenhouse gas emissions...neutralized in accordance with the SBTi criteria" (page 110).

2024 is the base year, "the company completed its first comprehensive GHG inventory covering Scopes 1, 2, and 3" that year (page 110-111). Targets exclude carbon credits and avoided emissions; the market-based method is used for the combined Scope 1+2 target. Linked incentive: the 2024-2026 LTI tranche targets a 20 percent improvement in Scope 1+2 CO2e intensity versus the 2023 baseline of 10.49 kgCO2e/T€ (page 110, ESRS E1 paragraph 13).

Energy consumption and mix

Reference: page 113.

Total energy consumption: 238,569 MWh in 2025 (2024: 226,119 MWh), up 6 percent. Fossil share fell to 81.69 percent (2024: 89.71 percent) despite the higher total; renewable share rose to 17.93 percent (2024: 9.92 percent), driven by EACs, renewable electricity procurement and HVO100 fuel use. Nuclear-source consumption: 0.38 percent (page 113).

"The framework agreement for electricity continues to guarantee the entire supply of 100 percent green electricity to buildings under Bilfinger's operational control," with EACs purchased additionally for Norway and Germany sites outside the agreement (page 113). Bilfinger generated 2,414 MWh from on-site solar (2024: 1,812 MWh), 75 percent self-consumed. "Bilfinger does not generate or sell energy from fossil or nuclear sources" (page 113).

GHG emissions

Reference: pages 113-116.

2025 gross emissions: Scope 1 = 36,242 t CO2e (2024: 35,828; +1%); Scope 2 location-based = 14,846 t CO2e (+14%), market-based = 10,815 t CO2e (-30%); combined Scope 1+2 market-based = 47,057 t CO2e, down 8 percent from the 51,244 t CO2e 2024 base year, "on a validated science-based decarbonisation pathway" (page 115). Scope 3 (four significant categories: purchased goods & services, capital goods, employee commuting, use of sold products) = 1,569,506 t CO2e (-4%), 93 percent-plus of the footprint. Total market-based GHG emissions: 1,616,563 t CO2e (-4%). GHG intensity (market-based) per net revenue: 298.06 t CO2e/€ million, down 11 percent (page 115).

Significance review of Scope 3 categories occurs every three years (next: 2027); categories 3.9, 3.10 and 3.14 are "not relevant to Bilfinger's business model" (page 116).

GHG removals

Reference: page 117.

"Bilfinger has set science-based net-zero targets by 2050. In accordance with the guidelines of the SBTi, a maximum of 10 percent of the remaining GHG emissions may be offset by carbon removals" (page 117). No removals or carbon credits have been used to date: the 2025 targets and emissions figures are stated as gross, without reliance on removals. "The removals used must be permanent, credible and transparent in their methodology," restricted to "nature-based and/or technological processes that are approved for use by the SBTi" (page 117).

Own workforce policies

Reference: pages 119-120.

Bilfinger "has established a risk management system to ensure compliance with due diligence obligations in accordance with the German Act on Corporate Due Diligence Obligations," plus a Group-wide Statement of Principles on Human Rights that "regulates the implementation of human rights due diligence obligations" for employees and suppliers (page 119-120). Core principles include the right to dignity/fairness/respect, zero tolerance for discrimination/harassment/forced or child labor, and commitment to "the United Nations Guiding Principles on Business and Human Rights" (page 120).

Occupational safety standards are "integrated into Group-wide policies and standard operating procedures" covering both own employees and external workers in Bilfinger's area of responsibility (page 120). Bilfinger "is committed to the principles of the Universal Declaration of Human Rights...and the UN Global Compact initiative," extending to principles 3-6 on freedom of association, forced/child labor and discrimination (page 119).

Engaging with own workforce

Reference: pages 118-119.

Employee representation runs through the Group Works Council (German companies) and the European Works Council (EU/EEA/Switzerland/UK), with the Group CEO responsible for HR and social affairs as Labor Director (page 118). "A voluntary employee Pulse Check is carried out on a quarterly basis to assess employee satisfaction and their understanding of the Group strategy," with consolidated results "reported to the Executive Board on a quarterly basis" (page 119).

The BilfingerIn app, introduced in 2023, gives employees direct access to information "at local, regional and global level" in 17 languages; "by 2025, around 18,800 employees had already registered...corresponding to around 60 percent of the global workforce" (page 119).

Remediation channels

Reference: page 120.

"The Bilfinger reporting channel that aligns with the German Whistleblower Protection Act — the Confidential Reporting Line — enables employees and third parties to anonymously report violations of applicable law, the Bilfinger Code of Conduct or internal Group guidelines" (page 120). Employees may also complain to superiors, HR or compliance managers. "The whistleblower system and the complaints procedure ensure that the identity of whistleblowers is protected," who "are protected against reprisals" (page 120).

"The efficiency of the process is reviewed at least once a year and whenever necessary." In 2025, Bilfinger "received no complaints via the OECD's national contact points" and "has not paid any fines, sanctions or compensation for labor-related incidents or human rights complaints" (page 120-121).

Taking action

Reference: page 117.

"Measures: Bilfinger relies on prevention training, continuous improvement of working conditions and open communication channels for employee concerns. Effectiveness: Bilfinger is not aware of any significant negative impacts" materializing from the identified own-workforce IROs (page 117).

This sits alongside the topic-specific actions disclosed under the individual S1 metrics chapters: occupational-safety programs ("Safety Works!", safety walks, Safety Awards, page 122), the BilfingerIn app and Pulse Check for engagement (page 119), and apprenticeship/training investment (at least 0.5 percent of annual revenue, page 121).

Targets related to own workforce

Reference: page 90 (MDR cross-reference).

No single quantified own-workforce-wide target is stated; the index records this disclosure requirement as reported under the minimum disclosure requirements: "Policies, actions, targets and metrics are reported in accordance with the disclosure requirements for the minimum requirements." Effectiveness is instead tracked topic by topic: occupational safety pursues "the principle of zero incidents" with tracked LTIF/TRIF (page 122), training investment is benchmarked at "at least 0.5 percent of annual revenue" (page 121), and the Pulse Check and performance-appraisal participation rate (100 percent of employees with system access in 2025) serve as engagement-effectiveness indicators (page 122).

Employee characteristics

Reference: page 123.

Total employees: 31,449 at 31 December 2025 (2024: 32,443) — male 27,944, female 3,493, other 3, not reported 9 (page 123). "60 percent of employees are industrial workers (previous year: 63 percent), while 40 percent are non-industrial workers" (page 123). Female share is stable at "11 percent (previous year: 11 percent)," attributed to "the nature of the business" as "an international industrial services provider for the process industry" working in production facilities and on customer construction sites (page 123).

By contract type (headcount): 28,390 permanent, 3,059 temporary, 29 non-guaranteed hours, 29,601 full-time, 1,848 part-time (page 124). Largest countries by headcount: Germany 5,987, Poland 3,979, Netherlands 3,285, United Kingdom 3,799 (page 124).

Collective bargaining and social dialogue

Reference: pages 118-119.

"A total of 67 percent of the workforce is covered by collective bargaining agreements" (page 118). Coverage is broken down by the countries representing more than 10 percent of total employees: Germany and the Netherlands fall in the 80-100 percent band, Poland 60-79 percent, the United Kingdom 40-59 percent and the Middle East 0-19 percent (page 118-119). Workplace representation (EEA countries only) is also reported for Germany, the Netherlands and Poland.

"Since 2010, Bilfinger has had an agreement with its employees on representation by a European Works Council" (page 119).

Adequate wages

Reference: page 124.

"Bilfinger's goal is to guarantee all employees appropriate remuneration that corresponds to the reference values and promotes recognition and motivation. We guarantee fair and adequate remuneration at all our locations by ensuring that our wages always meet at least the statutory minimum wage, applicable collective agreements or relevant industry standards" (page 124).

Coverage with adequate wages, as a percentage of active headcount: global workforce 100 percent (31,449 employees), workforce in EEA countries 100 percent (20,967), workforce outside EEA countries 100 percent (10,482) (page 124).

Training and skills development

Reference: pages 121-122.

"At least 0.5 percent of annual revenue is invested in apprenticeships and employee further education," focused on "technical skills, leadership skills, sales techniques and project management" (page 121). Average training hours per employee in 2025: female 13.4, male 15.8, total 15.5 (page 121-122).

In Germany, "Bilfinger employs around 270 apprentices at more than 30 locations and in 26 professions"; Bilfinger education GmbH holds "DIN EN ISO 9001:2015 and DIN ISO 21001:2021 certifications as well as AZAV approval" (page 122). "In 2025, 100 percent of employees with system access participated in the performance appraisal process," corresponding to 38 percent of the total workforce (33 percent of male and 74 percent of female employees) (page 122).

Health and safety metrics

Reference: pages 122-123.

2025 metrics (2024 in brackets): fatalities from work-related injuries 0 (0); lost-time accidents 14 (22); rate of lost-time accidents (LTIF) 0.18 (0.32); days lost to work-related injuries/fatalities 1,635 (1,225) (page 123). "At Bilfinger, all employees are covered by the health and safety management system" (page 122). TRIF (days lost per million hours worked) was 0.91 (2024: 1.12) (page 123).

Bilfinger "conducted internal audits at 16 Group companies" in 2025 (2024: 14) and holds ISO 9001 certification at 142 locations, ISO 14001 at 132, ISO 45001 at 139, and SCCP at 37 (page 123). The company pursues "the principle of zero incidents" through the "Safety Works!" program and annual Safety Awards (page 122).

Incidents and complaints

Reference: pages 120-121.

2025 (2024 in brackets): total incidents of discrimination, including harassment, 55 (42); indications of violation 22 (n.a. — the Local Case Reporting System was only introduced in 2024); total fines, penalties and compensation for damages €0 (€0) (page 121).

"Bilfinger is not aware of any serious incidents of human rights violations, in particular with regard to the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises. Accordingly, no fines, sanctions or compensation payments were made in this connection" (page 121).

Policies related to value chain workers

Reference: pages 100, 125.

Bilfinger reports this material topic under the ESRS 2.17 abridged/condensed reporting option rather than as a granular, separately-coded disclosure: "Bilfinger makes use of the option of an abridged reporting on the topic of workers in the value chain, which has been assessed as material. Condensed reporting is carried out in accordance with the disclosure requirements defined in ESRS 2.17" (page 91). This is why the DR does not appear by code in the primary content-index table; the Appendix B cross-reference table still cites specific paragraphs for some S2 datapoints. The Appendix B table cites "ESRS S2-1 Policies related to value chain workers paragraph 18," alongside "Human rights policy commitments paragraph 17," "Nonrespect of UNGPs on Business and Human Rights and OECD guidelines paragraph 18" and "Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 19" (page 100).

In the S2 chapter: "The principles of the Bilfinger Code of Conduct, the Code of Conduct for Suppliers and the Bilfinger Statement of Principles on Human Rights are an integral part of strategic management" for workers in the value chain, covering "ban on child and forced labor," "anti-discrimination and diversity," "health and safety" and "freedom of association and collective bargaining" (page 125).

Engaging with value chain workers

Reference: pages 84, 125.

Bilfinger reports this material topic under the ESRS 2.17 abridged/condensed reporting option rather than as a granular, separately-coded disclosure: "Bilfinger makes use of the option of an abridged reporting on the topic of workers in the value chain, which has been assessed as material. Condensed reporting is carried out in accordance with the disclosure requirements defined in ESRS 2.17" (page 91). This is why the DR does not appear by code in the primary content-index table; the Appendix B cross-reference table still cites specific paragraphs for some S2 datapoints.

Supplier-facing engagement is described under stakeholder interests: "Close cooperation within the value chain, anchoring human rights and labor law standards in the Supplier Code of Conduct. Regular audits and communication on working conditions, equal treatment and data protection" (page 84), with the objective of "a trusting and reliable working relationship with our suppliers." The S2 chapter adds "an established dialog platform with customers and suppliers" as part of the measures taken on workers in the value chain (page 126).

Remediation channels for value chain workers

Reference: page 126.

Bilfinger reports this material topic under the ESRS 2.17 abridged/condensed reporting option rather than as a granular, separately-coded disclosure: "Bilfinger makes use of the option of an abridged reporting on the topic of workers in the value chain, which has been assessed as material. Condensed reporting is carried out in accordance with the disclosure requirements defined in ESRS 2.17" (page 91). This is why the DR does not appear by code in the primary content-index table; the Appendix B cross-reference table still cites specific paragraphs for some S2 datapoints.

"A Group-wide whistleblower system in which incoming complaints are systematically documented and tracked...is available to our own employees as well as employees in the upstream value chain and other third parties" (page 126) — the same Confidential Reporting Line disclosed under S1-3 and G1. "Complaints are treated confidentially and lead to specific remedial measures which — if a compliance violation is confirmed — ensure that the violation is properly ended, dealt with and prevented in the future" (page 126).

Taking action on value chain workers

Reference: pages 100, 126.

Bilfinger reports this material topic under the ESRS 2.17 abridged/condensed reporting option rather than as a granular, separately-coded disclosure: "Bilfinger makes use of the option of an abridged reporting on the topic of workers in the value chain, which has been assessed as material. Condensed reporting is carried out in accordance with the disclosure requirements defined in ESRS 2.17" (page 91). This is why the DR does not appear by code in the primary content-index table; the Appendix B cross-reference table still cites specific paragraphs for some S2 datapoints. The Appendix B table cites "ESRS S2-4 Human rights issues and incidents connected to its upstream and downstream value chain paragraph 36" (page 100).

Measures: "preventive and remedial measures implemented in line with the human rights strategy," "continuous and ad-hoc reviews of suppliers as part of ongoing risk analyses," and "regular compliance and HSEQ audits" (page 126). Results: "No negative impacts were classified as material in the 2025 materiality analysis. No material risks to the company were identified either," and risk assessments under the German Act on Corporate Due Diligence Obligations in Supply Chains "identified" no risks in 2025 "so material that they must be prioritized and mitigated by remedial measures" (page 126).

Targets for value chain workers

Reference: page 127.

Bilfinger reports this material topic under the ESRS 2.17 abridged/condensed reporting option rather than as a granular, separately-coded disclosure: "Bilfinger makes use of the option of an abridged reporting on the topic of workers in the value chain, which has been assessed as material. Condensed reporting is carried out in accordance with the disclosure requirements defined in ESRS 2.17" (page 91). This is why the DR does not appear by code in the primary content-index table; the Appendix B cross-reference table still cites specific paragraphs for some S2 datapoints. No separate numeric reduction target is set for value-chain-worker impacts; instead, effectiveness is tracked via audit and training metrics with stated annual goals.

"In 2025, 2,104 supplier audits were conducted in the upstream value chain (previous year: 1,599). The goal of increasing the number of these audits by at least 10 percent per year was thus achieved." A second target — "at least 80 percent of employees in purchasing complete training on sustainable procurement" for 2025 — "was achieved" (page 127).

Business conduct policies and corporate culture

Reference: pages 127-128.

Corporate values (2025 mission-statement revision): Accountability, Ambition, Dedication, Knowledge and Team spirit (page 127). "The Executive Board is responsible for the Group-wide dissemination and implementation of the Code of Conduct and aligns the corporate culture with the recommendations of the German Corporate Governance Code. All employees must confirm the Code of Conduct and are obligated to implement its provisions worldwide" (page 128). Violations "will not be tolerated and will result in disciplinary action up to and including dismissal and, if necessary, reporting to the relevant authorities" (page 128).

"Bilfinger fosters an environment in which violations and concerns can be openly voiced," via "a Group-wide, confidential whistleblower system...available to employees and external persons" (page 128).

Management of relationships with suppliers

Reference: pages 87, 130-131.

"Compliance with fair payment terms toward our suppliers is an important condition for the economic success of both parties," with "actual positive impacts in the upstream value chain and for the company's own operations," aimed at "strengthening of stability and trust along the upstream value chain" (page 87).

Operationally: "supplier contracts are drawn up in accordance with the agreed standards. Compliance with these standards is regularly reviewed," and "Bilfinger conducts an ongoing risk analysis of the supplier pool in order to identify and address potential risks at an early stage" (page 130-131). "All suppliers must comply with the Bilfinger Supplier Code of Conduct and the Declaration of Principles on Respect for Human Rights" (page 131).

Prevention and detection of corruption and bribery

Reference: pages 129-130.

"Bilfinger pursues a zero-tolerance policy with regard to corruption and bribery. The compliance management system is established throughout the Group and certified in accordance with DIN ISO 37301:2021." The Chief Compliance Officer "reports to the Chief Executive Officer through the General Counsel and has an additional reporting line to the Supervisory Board and its Audit Committee" (page 129).

2025 compliance-training completion among target groups: Code of Conduct e-learning 94 percent (2024: 81 percent); refresher e-learning 92 percent (94 percent); on-site general compliance training 96 percent (91 percent) (page 129). "The share of high-risk functions covered by training programs is 98 percent" (page 129). Reports are investigated by the Independent Allegation Management Committee; "no convictions or fines for violations related to corruption and bribery regulations" occurred in 2025 (page 130).

Back-filled from the business conduct chapter; G1-3 became a standalone DR only in the 2025/2026 ESRS. Under the 2023 ESRS that Bilfinger reports against, business-conduct targets sat under MDR-T.

Targets related to business conduct

Reference: pages 129-130.

No single quantified business-conduct target is stated. Effectiveness is tracked instead: "the effectiveness of the compliance management system is regularly monitored by internal and external audits and by the Compliance Review Board" (page 130). Tracked indicators include the compliance-training completion rates against the relevant target groups (94/92/96 percent, page 129) and "the share of high-risk functions covered by training programs" at 98 percent (page 129). "The results of the investigations and the measures taken are reported to the Executive Board and the Audit Committee of the Supervisory Board at least quarterly" (page 130).

Incidents of corruption or bribery

Reference: page 130.

"In the 2025 reporting period, there were no convictions or fines for violations related to corruption and bribery regulations at Bilfinger. Accordingly, no measures were required to remedy such violations" (page 130).

"All reported suspected cases are documented in the whistleblower system and subjected to a preliminary review. If misconduct is confirmed, appropriate sanctions are imposed and process improvements are implemented to prevent similar violations in the future. The results of the investigations and the measures taken are reported to the Executive Board and the Audit Committee of the Supervisory Board at least quarterly" (page 130).

Payment practices

Reference: page 131.

"Bilfinger settles its supplier invoices in accordance with the agreed payment terms — regardless of the size of the supplier," so that "small and medium-sized suppliers (SMEs) cannot be systematically or deliberately discriminated against because of their size." In 2025, "it took Bilfinger an average of 39.9 days to pay an invoice from the date when the contractual or statutory term of payment started" (page 131).

Bilfinger "generally seeks to pay supplier invoices after 30 days with a 3 percent discount or after 45 days with a 2 percent discount or after 60 days net." These standard terms were used for 36.33 percent of payments (30-day), 65.12 percent (45-day) and 80.52 percent (60-day) of all payments in 2025. "No court proceedings for late payment were pending as of the reporting date" (page 131). Separate SME-specific reporting is "not material and is therefore omitted in accordance with ESRS 1, 3.2, 34.b" (page 131).