Brenntag SE

The role of the administrative, management and supervisory bodies

Reference: page 95 (Group sustainability statement); pages 74-77, 79-80, 83-85, 88-90, 92 (Corporate governance statement).

Brenntag SE runs a two-tier system, the Board of Management and the Supervisory Board, under Article 9(1)(c)(ii) of the SE Regulation and the German Stock Corporation Act, with management and supervision "clearly separated" (page 95).

Diversity and independence datapoints (paragraphs 21(d)-(e)): the Supervisory Board regards "all current members...as independent," putting independence at 100% (page 88-90). Under Section 111(5) AktG the Supervisory Board set a 33.3% female-representation target for itself and reports 37.5% (three of eight seats: Chandrasekaran, Berlinger, Wiegand). The Board of Management's 20% target was met only while Dr. Kristin Neumann served; after departures during 2025 it was reorganized to two members, Jens Birgersson and Thomas Reisten, and is now 100% male (pages 88-90).

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: page 95 (Group sustainability statement); pages 75, 79 (Corporate governance statement).

Brenntag states that detail on the sustainability and business conduct matters addressed by the Board of Management and Supervisory Board "is provided in the Corporate governance statement" (page 95); GOV-2 is largely incorporated by reference there rather than repeated in the Group sustainability statement.

Within the statement itself, sustainability governance is tied to the remuneration cycle covered under GOV-3: the Supervisory Board sets and reviews the ESG targets for each Board of Management remuneration tranche (GHG emissions, the Total Recordable Injury Rate, female representation in management), tracked quarterly via the ESG scorecard that also reaches Board of Management meetings.

Integration of sustainability-related performance in incentive schemes

Reference: pages 95-96.

Following 2023 AGM approval, ESG targets sit in the Board of Management's long-term variable remuneration, paid as virtual shares over a four-year performance period. The Supervisory Board sets up to three ESG targets per tranche, each producing a multiplier of 0.8 to 1.2; the three targets for the 2023-2026, 2024-2027 and 2025-2028 tranches are Scope 1&2 GHG reduction, the Total Recordable Injury Rate (TRIR), and the percentage of women in management.

Assuming a 100% payout factor, "the percentage influence of the ESG targets is between -11.3% and +11.3%" for the CEO; the GHG element is a third of that. Because 2025's awarded remuneration draws on the pre-ESG 2022 tranche, "the impact of the emissions reduction target on the total remuneration awarded or due to the Board of Management in 2025 is 0%." The same three targets were extended to the Global Leadership Team.

Statement on due diligence

Reference: pages 95, 158 (Appendix: Statement on due diligence).

Brenntag maps the five core due diligence elements to pages of the Group sustainability statement and Corporate governance statement:

Risk management and internal controls over sustainability reporting

Reference: page 96 (Group sustainability statement); pages 56, 58-61, 63-64, 66-67 (Report on expected developments, opportunities and risks).

Sustainability-related risks identified as material through the 2024/2025 double materiality assessment "are also covered in the Group-wide risk management system": business-conduct risks sit under the compliance risk category, while pollution risks sit under environmental protection, health and safety (page 96).

Detailed information on the internal control system is cross-referenced to the Report on expected developments, opportunities and risks rather than repeated in full in the sustainability statement itself.

Strategy, business model and value chain

Reference: pages 97-100, 139 (Group sustainability statement); pages 34-35 (Group overview).

Brenntag is the global market leader in chemical and ingredients distribution, connecting "several 10,000 chemical and ingredients manufacturers" with customers, purchasing a product range of around 20,000 different chemicals and ingredients. In FY2025 it generated sales of EUR 15,171.5 million through a network of around 600 sites in over 70 countries with approximately 17,000 employees (page 99).

The sustainability vision "Future Sustainable Brenntag" breaks into six focus areas: portfolio and investment steering; climate change mitigation; resource efficiency and circular economy; fair and safe employer; responsible partner for suppliers and communities; management structures for business ethics (page 97). Medium-term 2025-2030 targets per area are set out in table 2.22, e.g. 100% of the product portfolio steered toward sustainability (achieved) and 93.9% renewable electricity (vs. a 100% 2025 goal).

Interests and views of stakeholders

Reference: page 100 (Group sustainability statement); pages 144-145, 151-152.

Key stakeholder groups are own employees/works councils, (potential) employees, management (L1), customers, suppliers and business partners, investors, and industry/research/NGO bodies, categorized per ESRS into affected stakeholders, users of the statement, or both (table 2.23). Significant issues are discussed at the Supervisory Board's Transformation and ESG Committee.

Dialog formats include employee surveys, town halls, the Sustainability Community and Safety Week (employees); key-account dialog, self-assessment questionnaires and the Brenntag Sustainability Survey (customers); and direct interaction, audits, EcoVadis assessments and a grievance mechanism (suppliers). Findings from the Brenntag Sustainability Survey fed specifically into the materiality assessment for climate change, pollution, water, and circular economy/resource use.

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 101-102, 104, 108-109, 115, 120, 123, 138-139, 151, 154.

The materiality matrix (2.24) plots outside-in financial materiality against inside-out impact materiality, with thresholds of 2.50 (inside-out) and 2.00 (outside-in). Topics clearing both thresholds are climate change, own workforce, workers in the value chain, resource use and circular economy, water, business conduct and pollution; biodiversity and ecosystems, affected communities, and consumers and end-users fall below threshold and are not material.

"No current or anticipated financial effects of Brenntag's material risks and opportunities on its financial position, financial performance or cash flows were identified for the 2025 reporting period either" (page 102). A 2025 qualitative resilience workshop concluded the Group "still has the resilience to address the material impacts and risks and take advantage of the opportunities."

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 101-103, 104, 109, 115, 120, 123, 138-139, 151, 154.

The double materiality assessment was performed in 2024 and "validated in the reporting period" (2025), with reassignment of specific IROs and an updated risk-assessment scale; "the overall assessment was confirmed as still valid." Six steps: (1) stakeholder identification, building on a 2022 survey; (2) a long-list of topics/sub-topics informed by peer analysis; (3) classification as impact/risk/opportunity by internal experts; (4) impact assessment on severity (scale, scope, irremediability), with likelihood excluded for potential human-rights impacts so severity takes precedence; (5) risk/opportunity assessment against financial position, performance and cash flows, supported by scenario analyses and carbon-price data; (6) validation with internal stakeholders, the Board of Management and the Audit and Compliance Committee.

Biodiversity: "the topic of biodiversity and ecosystems continued to be assessed as being not material," though Brenntag still considered vehicle-fleet and product-portfolio dependencies per the ESRS-mandated upstream process; no site-specific assessment was performed and systemic, transition or physical risks were not included (pages 102-103).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: page 101; pages 158-165 (Appendix: disclosure requirements and EU-legislation datapoints tables).

Brenntag publishes a full ESRS content index (table 2.65, pages 158-160) mapping each disclosure requirement it covers to a section and page range, plus a second table (2.66, pages 161-165) cross-referencing datapoints that derive from SFDR, Pillar 3, the Benchmark Regulation and the EU Climate Law, flagging several as "Non-material" or "Phase-in."

Topics assessed and found not material: biodiversity and ecosystems (E4), and "social matters," covering affected communities and consumers/end-users (S3, S4) — "Social matters were identified as being not material to Brenntag within the meaning of the law and were therefore not included in the Group sustainability statement applying a global policy" (page 94). "No information corresponding to intellectual property, know-how or the results of innovation is omitted" (page 94).

Transition plan for climate change mitigation

Reference: pages 104-105.

Brenntag joined the Science Based Targets initiative (SBTi) in 2022, aligning Scope 1&2 targets to 1.5°C and Scope 3 to well below 2°C (WB2C); the targets "were validated by the SBTi in January 2025." Two flagship programs anchor delivery: the carbon management program (an internal EUR 30/tCO2e price funding site projects) and the CERO (Carbon Emission Reduction in Operations) project, which assigns regional Scope 1&2 reduction targets. The Synapse project, launched in 2025, targets Scope 3 by steering the portfolio toward lower-carbon products, addressing "approximately 92% of our Scope 3 emissions."

The plan is the CEO's direct responsibility, approved in full by the Board of Management; "due to Brenntag's business model, no significant locked-in CO2e emissions were identified." Brenntag "is not excluded from the EU Paris-aligned Benchmarks" and held a CDP rating of A- in 2025, "among the top 7% of all rated companies."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 resilience-analysis subsection, where this content is disclosed in the FY2025 report (pages 102-103, 108-109). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk: a 2022 pilot, reviewed again in 2025, assessed long-term physical risk at Brenntag sites worldwide under three global warming scenarios for 2050 — RCP2.6, RCP4.5 and RCP8.5 — scoring exposure from 0 (very low) to 1 (very high); "the results show that physical damage due to climate change may be a material risk over the long-term" (pages 108-109).

Transition risk: assessed qualitatively against carbon pricing (using the High-Level Commission's recommended 2030 price range), the pace of low-emission technology development, and shifts in consumer behavior (page 108). No named 1.5°C-aligned transition scenario (e.g. IEA NZE) is disclosed — transition exposure is described narratively rather than modeled against a labeled scenario, which is a gap worth flagging. Scope, assumptions and timing: Group-wide, incorporating the double materiality assessment; reviewed again in 2025 rather than re-run from scratch.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and IRO-1, where this content is disclosed in the FY2025 report (pages 101-102, 108-109). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Brenntag believes that it is resilient to the challenges of climate change identified due to its strong market position and its strategic alignment with the 1.5°C target" (page 108). The analysis, conducted in the prior year and "validated and reviewed" rather than redone in 2025, incorporates the double materiality assessment and the physical-risk scenario work.

Uncertainties and capacity to adjust: Scope 1&2 decarbonization depends on low-emission-technology development and regional fuel availability, so the truck fleet shifts to biofuels short/medium-term before a longer-term switch to electric and hydrogen vehicles; Scope 3 reduction depends on supplier cooperation, and lower-PCF products "still face commercial challenges, as demand and willingness to pay remain limited" (page 108).

Policies related to climate change mitigation and adaptation

Reference: page 106.

"In 2025, Brenntag developed an integrated, company-wide climate protection policy" covering all sites, facilities and the upstream/downstream value chain across mitigation, adaptation, energy efficiency and renewable energy. It sits alongside the Code of Business Conduct and Ethics and the QSHE guidelines; all were adopted by the Board of Management and are available on the intranet, with the Code also published externally.

Brenntag also participated in 2025 in the SBTi pilot test for the Corporate Net-Zero Standard V2 and the UN Global Compact Climate Ambition Accelerator project.

Actions and resources in relation to climate change policies

Reference: pages 106-108.

Scope 1&2: renewable electricity reached 93.9% (2024: 87.4%), avoiding 52,581 tonnes of Scope 2 emissions; the 2025 RE100 milestone of 100% renewable electricity was met everywhere except Singapore. The carbon management program (budget ~EUR 6.2 million) funded projects including the Traun, Austria net-zero site (groundwater heat pumps, 220 kWp PV, ~120 tCO2e/yr saved) and CERO decarbonization roadmaps for North America and EMEA to 2028. Biofuels reached 5.4% of fleet fuel (2024: 0.7%), saving 7,391 tCO2e; 41,181 tCO2e were offset via a Brazilian VCS-certified forest project (22.6% of Scope 1&2, vs. 67.7% in 2024).

Scope 3: the CO2Xplorer tool provides product carbon footprints for 2,100+ chemical products; a lower-carbon sodium hydroxide (-65% vs. conventional) and renewable ammonia (-87%) were introduced, and the Synapse project targets ~7.7 million tonnes of Scope 3 savings by 2028 through portfolio steering and phase-out of carbon-intensive lines.

Targets related to climate change mitigation and adaptation

Reference: pages 109-111, 113.

SBTi-validated, Board-approved gross targets from a 2023 base year: -58.8% absolute Scope 1&2 GHG by 2034; -35% absolute Scope 3 by 2034; net-zero across the value chain by 2050, via -90% Scope 1&2 by 2045 and -90% Scope 3 by 2050. Methodology follows the SBTi Corporate Near-Term Criteria (v5.2) and Net-Zero Standard (v1.2), using the cross-sectoral absolute-contraction pathway and the market-based method.

2025 progress: Scope 1&2 down 6.1% (2024: 6.4%); Scope 3 down 19.4% (2024: 4.8%). Residual Scope 1&2 emissions are to be offset via carbon credits from 2045; Scope 3 relies on supplier action. Named decarbonization levers by 2030-contribution: truck-fleet decarbonization (21% of Scope 1), procurement sustainability criteria (~9% of Scope 3), low-carbon portfolio expansion (~7% of Scope 3), renewable electricity (5% of Scope 2), among others.

Energy consumption and mix

Reference: pages 112, 114.

Natural gas consumption rose from 147,946 to 181,564 MWh while crude oil/petroleum products fell from 632,205 to 525,001 MWh. No coal, nuclear or other fossil sources are consumed. "All of Brenntag's business activities are in high climate-impact sectors" (page 114).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 113-114.

Scope 3 is split across 15 GHG Protocol categories (table 2.31); the largest are purchased goods and services (20,319,526 t), end-of-life treatment of sold products (1,621,311 t) and use of sold products (1,094,918 t). Carbon intensity (market-based): 1,598 tCO2e/mEUR (2024: 1,850, -13.6%). Scope 2 is calculated both location- and market-based per the GHG Protocol, with 2025 emission factors from UK DBEIS.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 107.

In 2025 Brenntag canceled 41,181 tCO2e of certificates from a new project (2024: 131,126 t), 100% from reduction projects and 0% from removal projects, 100% Verified Carbon Standard, 0% located within the EU, and 0% qualifying as corresponding adjustments (table 2.26). The selected project supports preservation of the Brazilian rainforest, located where Brenntag itself operates sites. 10,000 tCO2e of further certificates are planned to be canceled from 2026.

This offsetting covered 22.6% of Scope 1&2 emissions in 2025 (2024: 67.7%); the residual, non-offset reduction is the primary lever tracked under E1-4.

Internal carbon pricing

Reference: page 105.

Under the carbon management program, each Brenntag entity is held accountable for 100% of the Scope 1&2 emissions it causes through a set internal price of EUR 30 per tonne of CO2e. The price is calculated from achieved emissions reductions, carbon taxes, emissions-certificate costs, renewable-energy costs and voluntary offsetting, referencing international carbon-pricing overviews, market analyses, fuel-price trends and EU emissions-trading frameworks.

The resulting amount is paid into an internal climate protection fund that sites and companies can apply to for emissions-saving projects; the Sustainability Council sets the price and selects funded projects.

Policies related to pollution

Reference: pages 115, 117.

The Global QSHE Policy (Quality, Safety, Health, Environment) sets the Group's pollution-prevention strategy, approved by the Board of Management and applied worldwide; actions follow a three-step prevention, retention, elimination approach to spillages, backed by a global Process Safety Management (PSM) system built on the CCPS framework (page 115).

For products, the Global Safe Product Policy (introduced 2023) commits Brenntag to the most stringent applicable rules worldwide, gradually reducing sale of substances of very high concern (SVHCs) above 0.1% concentration — both on the EU-REACH Annex XIV authorization list and the candidate list — even outside the EU where local law permits continued sale (page 117).

Actions and resources related to pollution

Reference: pages 115-118.

The PSM program expanded its focus sites from 363 to 375 in 2025; a strengthened audit team completed 35 centrally organized Tier 1 assessments plus regional Tier 2/3 work. Brenntag recorded eight PSE-1 (higher-category) process safety events in 2025 — four product releases fully contained by retention systems (nothing entered the environment) and four smaller releases that caused lost-time injuries. A global release-prevention initiative launched in September 2024 moved in 2025 to a second phase on "Operational discipline."

On substances, a dedicated Power BI tool consolidating ERP data supports SVHC visibility and substitution decisions, and a 2025 master-thesis project with Brenntag Essentials explored regulatory and internal decision frameworks for substitution.

Targets related to pollution

Reference: pages 117-118.

Brenntag targets a 25% reduction in the process spill rate by 2030 versus a 2023 base of 1.88 cases per million tonnes of outgoing warehouse product. The 2025 rate was 2.62 (2024: 2.76) — an improvement on 2024 but still above the interim target of 1.81, after a weak first quarter (3.58). "No significant releases of pollutants into soil or water were reported in 2025."

For substances of (very high) concern, the Global Safe Product Policy drives a continuous-monitoring approach rather than a numerical target: "Beyond that, there are currently no further targets in accordance with the requirements of ESRS" (page 117).

Pollution of air, water and soil

Reference: page 117.

Brenntag reports a nil return for 2025: "No significant releases of pollutants into soil or water were reported in 2025." Historical exposure exists — the company incurred EUR 3.1 million of operating expenses in connection with a 2023 warehouse fire in Canada, with further environmental-monitoring costs expected through 2027 in consultation with authorities — but this is reported as a one-off legacy item rather than an ongoing air/water/soil pollutant release.

Relevant releases are defined and reported with reference to Annex II of the E-PRTR Regulation (EC) No 166/2006 (page 117).

Substances of concern and substances of very high concern

Reference: pages 118-119.

By hazard class, the largest 2025 categories are specific target organ toxicity — repeated exposure (441,626 t), hazard to the aquatic environment long-term (314,934 t) and reproductive toxicity (230,719 t, of which 44,131 t SVHC). Prior-year figures were corrected for three reasons — SVHCs previously double-counted as substances of concern, products now counted once regardless of hazard-class, and a regional data gap closed retroactively — reducing the 2024 substances-of-concern total by 373,279 t while raising the SVHC total by 8,365 t (page 119). Only substances at a concentration over 0.1% are counted; volumes come from ERP sales data.

Anticipated financial effects from pollution-related impacts, risks and opportunities

Reference: page 117.

Brenntag's own content index lists this disclosure requirement under the narrower heading "Operating and capital expenditures incurred in the reporting period in conjunction with major incidents and deposits" (table 2.65, page 159), pointing to page 117: the EUR 3.1 million of operating expenses tied to a 2023 warehouse fire in Canada, with further costs anticipated through 2027 for environmental-monitoring measures agreed with the authorities.

Beyond this item, no broader quantification of anticipated financial effects from pollution IROs is given; the general statement that "no current or anticipated financial effects of Brenntag's material risks and opportunities...were identified for the 2025 reporting period" (page 102) applies across topics.

Policies related to water and marine resources

Reference: pages 120-122.

Water management sits under the Global QSHE Policy and its environmental management guideline, requiring every site to run an efficient water/wastewater system under local law, Board-approved and tracked globally. A WRI-based water-risk analysis found 87 sites in water-risk areas, of which 63 face extremely high water stress; of those 63, only 30 have material mixing-and-blending water consumption (>120 m³/year) and form Brenntag's water-stewardship priority group.

A concrete example is underway at Bari, Italy, where a submitted rainwater-collection system design is expected to capture/reuse ~1,248 m³/year, about 15% of the site's mixing-and-blending water consumption.

Actions and resources related to water and marine resources

Reference: pages 120-122.

Beyond site-level management (QSHE guideline, WRI risk screening, the Bari rainwater project), Brenntag's water treatment product portfolio advances customers' water resilience: recycling/reuse support, heavy-metal removal for safe wastewater discharge, activated-carbon remediation of PFAS-contaminated groundwater and soil, micropollutant (e.g. pharmaceutical residue) removal, and membrane technology to cut energy use in reverse osmosis. "Beyond these approaches, no specific policy to improve the water quality of polluted bodies of water...has been developed and approved in accordance with ESRS" (page 121).

These downstream actions are distinguished in the materiality matrix as a positive impact (page 120), separate from the negative own-operations water-scarcity impact.

Targets related to water and marine resources

Reference: pages 121-122.

"Although there are currently no targets in accordance with ESRS requirements," Brenntag has built a global water-data collection policy to standardize monitoring, with a 2025 analysis of global data-capture processes; identifying the 30 priority high-water-stress sites is described as the first step of its water-stewardship strategy (page 121).

Brenntag also "voluntarily participated in the CDP Water environmental disclosure initiative" in 2025 to advance transparency, and states it has no ESRS-compliant target for its water-treatment product offering beyond continued regional-regulation-driven development (page 122).

Water consumption

Reference: page 121.

Consumption relates specifically to mixing-and-blending (M&B) processes; data come from site water bills, product-database extracts or estimated percentages of water added during M&B, with Q4 extrapolated on a 75%/25% quarterly split. Consumption in water-risk areas fell year on year even as total consumption rose.

Policies related to resource use and circular economy

Reference: pages 123-124, 126-127.

"Resource efficiency and the circular economy are elements of the sustainability vision Future Sustainable Brenntag, even though a specific circular economy policy has not yet been adopted in accordance with ESRS requirements" (page 123). The model operates through circular procurement (extending the portfolio with circular-origin/circular-enabling products) and circular services (industrial symbiosis, closed-loop treatment of customer secondary flows/waste).

Packaging is managed regionally — an EMEA guideline on refurbished intermediate bulk containers (IBCs) and a North America Poly/Stainless-Steel IBC use protocol — pending a planned global standardization policy. Waste sits under the same Board-approved Global QSHE Policy and environmental management guideline as pollution and water (page 126).

Actions and resources related to resource use and circular economy

Reference: pages 123-124, 126-127.

Brenntag established ten circular business models across both divisions in 2025 (table 2.40: bio-based raw materials, upcycled ingredients, solvent/activated-carbon/glycol recycling, circular pipeline rental services, direct reuse, etc.), collectively exceeding EUR 10 million in annual sales. A TÜV Rheinland-certified PCF methodology, applied at the Antwerp Distillation Company and Lohn-Ammensegg sites, quantifies CO2e savings for recycled products such as upcycled diethylene and triethylene glycol.

On waste, regional initiatives such as "Slow Moving Avoidance" and "Product Disposal Reduction" in Brazil, and slow-mover repurposing partnerships in EMEA, shift the approach "from reactive to preventive." A 2025 global review standardized waste data capture and reporting across all regions for the first time at site level (page 126).

Targets related to resource use and circular economy

Reference: pages 125-127.

The target of ten circular business models, each generating over EUR 1 million a year by 2025, was met collectively (not individually) at over EUR 10 million combined sales (table 2.40). "The target is therefore regarded as having been met," tracked quarterly via the ESG scorecard; it is voluntary and not tied to external scientific criteria.

No ESRS-compliant targets yet exist for packaging or waste specifically: "no targets in relation to packaging have yet been set in accordance with ESRS requirements" (page 126) and "although no targets have yet been set for waste in accordance with ESRS requirements, Brenntag intends to monitor certain waste streams" (page 127), pending further data-system build-out.

Resource inflows

Reference: pages 125-126.

"As a chemical distributor, Brenntag's products leave the sites in the chemical state in which they were delivered," so material inflow essentially equals outflow; total weight is derived from sales data, and 0% of biological products are currently sustainably certified (page 126).

Resource outflows

Reference: pages 125-128.

Packaging (table 2.42): total purchased packaging (IBCs, drums, wooden pallets) of 60,475 t (2024: 60,943 t); 39.7% reused or recycled parts (2024: 39.0%); 99.9% recyclable content.

Waste (tables 2.43-2.44): total waste generated 45,392 t (2024: 56,647 t), of which 28,435 t non-hazardous and 16,957 t hazardous; 73.8% non-recycled (2024: 82.1%). Disposal splits into recycling (11,876 t), incineration (6,120 t), landfill (8,151 t) and other disposal (13,172 t, newly reported in 2025).

Waste

Reference: page 127 (table 2.43, 2.44); policies page 126.

Disposal breakdown: recycling 11,876 t (5,674 t non-hazardous + 6,202 t hazardous); incineration 6,120 t; landfill 8,151 t; other disposal operations 13,172 t (first reported in 2025). All sites in Latin America are required to systematically separate waste "beyond local statutory requirements" (page 127).

Policies related to own workforce

Reference: pages 139-140, 142-146, 148-150.

Workforce policies run through the Global QSHE Policy (occupational health and safety, encompassing "100% of the workforce"), the Global Living Wage Policy (2022), the 70-20-10 Global Development Framework plus an October-2025 Group-wide Learning and Development Policy, and the Code of Business Conduct and Ethics / diversity policies for the Board, Supervisory Board and workforce generally. All are Board-approved and available on the intranet.

External workers — primarily temporary staff and freelancers integrated into Brenntag's organization — are "explicitly included in occupational health and safety actions so as to ensure uniform standards" (page 139). "No activities were identified at significant risk of forced labor or child labor" in Brenntag's own operations (page 139).

Processes for engaging with own workforce and workers' representatives about impacts

Reference: page 100; pages 144-145.

Engagement runs through elected codetermination bodies where local law provides for them, works councils, a representative body for severely disabled persons in Germany, global management town halls, annual individual employee appraisals, the internal platform ShareON@Brenntag, and ideas-management systems. Brenntag "follows a decentralized approach" rather than a single global framework agreement with employee representatives (page 144).

Employee-sentiment engagement was expanded in 2025: alongside the annual eNPS survey, quarterly "2 questions - 2 seconds" sentiment checks continued, and an expanded eNPS & Engagement survey ran in November 2025 covering satisfaction, motivation, engagement and business success.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: page 150; pages 152-153, 156.

Brenntag operates a whistleblowing system open to employees and external stakeholders, alongside reporting through a line manager, HR or the compliance function; reports cover violations of the Code of Business Conduct and Ethics, human rights issues, and discrimination/harassment. Electronic whistleblowing reports are "captured and documented centrally" and forwarded to the compliance function (page 150).

The recorded scope of discrimination cases was expanded in 2025 to include harassment reports, with prior-year figures restated for comparability (a reclassification adding 49 discrimination/harassment cases and removing 55 from the "other complaints" count). Outcomes, remedial and preventive actions are published in aggregated form annually.

Taking action on material impacts on own workforce

Reference: pages 140-150.

Across the material IRO rows identified in the workforce materiality table (2.50), Brenntag links named actions to each: occupational health and safety (the four-pillar QSHE strategy, RC/RD industry-initiative participation, PSM); secure employment and adequate wages (the Global Living Wage Policy and annual gap analysis); social dialog (town halls, appraisals, codetermination); working time/work-life balance (the "New Work - Towards Greater Flex" framework); training and skills development (the 70-20-10 framework, the new Learning and Development Policy, the Brenntag Academy launched October 2025); and diversity (Employee Resource Groups, unconscious-bias training, Board/Supervisory Board diversity policies).

"The potential negative impacts listed are confined to individual incidents, such as accidents" rather than systemic failures (page 139).

Targets related to own workforce

Reference: pages 139, 142-143, 145, 147, 149.

Workforce targets include: TRIR below 2.0 by 2030 (from a 2021 base of 3.1; 2025 actual 2.1); 100% of employees receiving a living wage (met since end-2023, with 37 gap cases identified and 22 closed in 2025); an annual eNPS engagement survey (met again in 2025); unconscious-bias training for all leaders/HR/recruiters by 2025 (only partially achieved — 35.4% participation — deadline extended to 2027); and at least 30% women across management below the Board of Management by 2030 (2025: 37.8% at L1-L5+ combined, 39.3% at L1, 33.3% at L2).

All workforce targets are tracked quarterly via the ESG scorecard and were developed by functional specialists with Board of Management involvement.

Characteristics of the undertaking's employees

Reference: pages 139, 143, 145.

By contract type: 17,079 permanent vs. 157 temporary contracts in 2025. By region, headcount spans EMEA, North America, Latin America and Asia Pacific. A 439-employee variance versus 2024 arises from a change to an accounting-based definition of personnel metrics applied from FY2025, with 2024 figures recalculated for comparability (page 145).

Diversity metrics

Reference: pages 149-150.

ESRS-mandated L1/L2 reporting: women were 39.3% of L1 (11 of 28, using the ESRS all-countries basis) and 33.3% of L2 (58 of 174) in 2025. By age: under-30 = 8.8%, 30-50 = 58.1%, over-50 = 33.1% of the 17,236-strong workforce (table 2.59).

Adequate wages

Reference: page 143.

Brenntag has met its target that 100% of employees receive a living wage under the 2022 Global Living Wage Policy since the end of 2023, benchmarked against WageIndicator Foundation country data (which also confirms no country's standard week exceeds 48 hours, per ILO standards). The 2025 annual gap analysis found 37 employees in six countries requiring adjustment (2024: 114 in 15 countries); 22 were adjusted, 14 could not be adjusted in Singapore due to a contractual salary-adjustment restriction tied to a 2023 acquisition, and one case lapsed on termination of employment.

Interns, apprentices, freelancers and contractors are excluded from the gap analysis; variable pay and overtime are excluded from the wage comparison, which uses fixed remuneration and regular monetary allowances only.

Training and skills development metrics

Reference: pages 147-148.

The 70-20-10 Global Development Framework (70% on-the-job, 20% social/coaching, 10% formal training) underpins development, formalized further by the October 2025 Group-wide Learning and Development Policy and the new Brenntag Academy (launched October 2025, a central learning "one-stop shop"). Division-specific programs include the three-year Global Sales Enablement Program (1,365 Specialties employees in 2025), an EMEA Essentials sales-enablement program (~88 employees), and a new General Managers learning program (110 participants).

Hours are derived from standardized per-course minutes in the learning portal rather than self-reported time (page 148).

Health and safety metrics

Reference: pages 140, 142.

TRIR fell from 2.6 (2024) to 2.1 (2025), against a 2021 base of 3.1 and a 2030 target below 2.0; recordable incidents fell from 103 to 81, with 1,757 days lost. "For 2025, Brenntag has no work-related fatalities to report, either among its employees or among other individuals at its sites." Site certification: 352 of 355 relevant sites held an international quality standard (e.g. ISO 9001) at end-2025 (2024: 367 of 369).

TRIR is calculated per U.S. OSHA definitions of "work-related" and "medical treatment beyond first aid," covering own employees plus temporary/contract staff performing standard Brenntag activities; all fatal accidents to other persons at Brenntag sites are also reported (page 142).

Incidents, complaints and severe human rights impacts

Reference: page 150.

2024 figures were restated after the scope of tracked discrimination cases was expanded in 2025 to include harassment, adding 49 cases to this line and removing 55 from "other complaints" for comparability (page 150). No fines, penalties, compensation or severe human-rights incidents were recorded in either year.

Policies related to value chain workers

Reference: pages 151-152.

The Policy Statement on Human Rights and the Supplier Code of Conduct draw on the UN Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and core ILO conventions, covering freedom of association and collective bargaining, adequate working conditions, health and safety, and prohibition of human trafficking and child/forced labor. Both documents were developed on the basis of Brenntag's human-rights risk analysis under the German Supply Chain Due Diligence Act (LkSG) and adopted by the Board of Management; both are public.

A human-rights risk analysis identified environmental protection and health and safety as the main potential risks for chemical supply-chain workers, plus industry/country combinations with elevated child- and forced-labor risk (page 151).

Processes for engaging with value chain workers about impacts

Reference: page 100; page 152.

Brenntag has been a member of Together for Sustainability (TfS) since 2016, sharing supplier audit/assessment results across members to reduce duplicate effort, and works with EcoVadis (scoring suppliers 0-100 on environment, labor/human rights, ethics and sustainable procurement). On-site sustainability audits, conducted by responsible purchasers against a TfS requirements catalog, include direct interviews with supplier employees; Brenntag also accepts audits under SQAS, SMETA and PSCI standards.

A dedicated IT solution classifies all Tier 1 suppliers into critical/high/medium/low risk categories using site, sector, sales and AI-supported 360-degree media screening, triggering proportionate preventive actions (training, assessment, audit).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: pages 152-153, 156.

A whistleblowing channel open to both employees and external third parties accepts anonymous reports; potential human-rights violations can also be emailed directly to the Human Rights Officer. Suppliers must protect good-faith reporters from retaliation under the Supplier Code of Conduct, a requirement passed down the supply chain.

Where violations (including child or forced labor) are identified, Brenntag applies a severity assessment, develops and tracks an action plan with the business partner on an "enablement before withdrawal" principle, and verifies remediation before closing the case; only after failed correction attempts does it reserve the right to terminate the relationship. In 2025, "Brenntag did not receive any reports of human rights violations within its upstream value chain that resulted in the need to specify and initiate remedial actions," though two supplier incidents remained under investigation at year-end.

Taking action on material impacts on value chain workers

Reference: pages 151-153.

Brenntag's supplier human-rights risk management (TfS/EcoVadis assessments, on-site audits, the Tier 1 risk-classification IT system) is the primary action against the material negative impact identified — potential human-rights violations where supply-chain risk is ignored or under-assessed, particularly child/forced labor, inadequate wages and working conditions (table 2.61). A comprehensive online human-rights training course was rolled out to all employees in 2025.

Brenntag also prepared in 2025 for the EU Deforestation Regulation (EUDR), forming a cross-functional team (Supply Chain, Quality, Legal, IT, Group Sustainability) and extending its risk-analysis IT system with product-supplier-level deforestation screening, supplier questionnaires and satellite geodata monitoring.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 153.

Two targets: (1) systematically capture all active ERP-managed suppliers and mitigate related risks from FY2024 onward — achieved again in 2025 and to continue; (2) all suppliers share Brenntag's vision on human rights and environmental protection by 2027, with 2025 interim steps including a procurement-integration roadmap, contacting ~30% of relevant suppliers on the Code of Conduct, and defining an approach to challenging raw materials (palm oil, conflict minerals, mica).

Targets were set by specialists including the Human Rights Officer with Board of Management involvement, and are tracked quarterly via the ESG scorecard, reported to the Board. "Brenntag plans to further optimize the content of the targets over the medium term."

Business conduct policies and corporate culture

Reference: pages 155-157.

Five core values — Care, Trust, Clarity, Excellence, Safety — guide conduct and business relationships (table 2.63). The Code of Business Conduct and Ethics sets principles of conduct for all employees, addressing bribery/corruption prevention, antitrust/competition law, conflicts of interest, data protection and information security; annual training is mandatory Group-wide, and internal audit reviews compliance regularly. A Supplier Code of Conduct extends equivalent standards to suppliers.

Both the Code and the Supplier Code are Board-approved, intranet-available, and published externally in multiple languages; meetings of more than three people are expected to open with a "Safety Moment" or "Culture Moment."

Prevention and detection of corruption and bribery

Reference: pages 156-157; page 83 (Corporate governance statement).

Brenntag's global compliance management system runs on mandatory annual training (Code of Conduct, anti-corruption, antitrust), a whistleblowing system and an Investigation & Remediation Council for significant reports; the compliance department head reports directly to the Board of Management, and the Supervisory Board's Audit and Compliance Committee receives regular updates.

2025 training completion: 93% Code of Conduct (2024: 95%), 97% anti-corruption (2024: 99%), 97% antitrust (2024: 98%) — the latter two targeted at at-risk functions (table 2.64). The SVP Compliance briefs the Board of Management and Supervisory Board quarterly.

Targets related to business conduct

Back-filled from the G1-3/G1-4 "Targets and metrics" subsection (pages 156-157), which addresses the MDR-T minimum disclosure requirement for targets.

"Even though no targets are set in accordance with ESRS requirements, Brenntag monitors the actions and requirements in this field" (page 157) — invoking MDR-T's second limb (tracking effectiveness in the absence of a stated target) rather than the first.

Effectiveness is tracked through: quarterly compliance reporting by the SVP Compliance to the Board of Management and Supervisory Board; regular Audit and Compliance Committee review of compliance and whistleblowing case trends; and annually-monitored mandatory training completion rates (93% Code of Conduct, 97% anti-corruption, 97% antitrust in 2025, table 2.64).

Incidents of corruption or bribery

Reference: page 157.

"In 2025, there were no convictions as a result of violations of anti-corruption and anti-bribery laws and therefore no fines." This nil return sits alongside the broader whistleblowing/compliance case-management infrastructure described under G1-1/G1-3, through which any substantiated incident would be investigated by the Investigation & Remediation Council and reported to the Board of Management.