CEWE Stiftung & Co. KGaA

The role of the administrative, management and supervisory bodies

Reference: pages 102-103.

The CEWE Group is governed by an Executive Board (5 members in most of 2025, fluctuating with one departure/arrival) and a 12-member Supervisory Board, all non-executive. Women make up 50% of the Supervisory Board (previous year: 50%) and 20% of the Executive Board (previous year: 17%); both boards are "100.0% independent" by the Company's own count.

Sustainability management is "an integrated part of corporate governance," assigned to the CEO and the Sustainability department. Within the Executive Board, CEO Thomas Mehls is responsible for sustainability and Sirka Hintze for Finance and Controlling; the Finance department coordinates CSRD reporting while individual business units monitor their own impacts, risks and opportunities. "Dedicated capacity was created within the Finance team for the second year of reporting in accordance with ESRS (partial application)."

Employee representation runs through Works Councils at the four German Photofinishing sites (37 members) plus a Group Works Council; only WhiteWall (Frechen) and DeinDesign (Bad Kreuznach) lack employee representation.

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

Reference: page 104.

The Group's governing bodies "received regular progress updates on CSRD implementation during financial year 2025," via fixed Supervisory Board, Board of Trustees and Audit Committee meetings, with minimum notification requirements assured under Section 90 AktG. The double materiality assessment (DMA), first completed in FY2024 and updated in FY2025, was communicated directly to the Executive Board; other CSRD findings went to the Executive Board and the Supervisory Board's Audit Committee.

A candid governance gap is disclosed: "The Company has yet to fully complete the integration of the risks derived from the CSRD materiality assessment into the Group-wide risk management system," so individual business units, not the central risk process, still own these risks.

The Company also states plainly: "the administrative, management and supervisory bodies and their relevant committees did not address individual, specific material impacts, risks and opportunities" and no related trade-offs were considered in FY2025, so "a corresponding list in accordance with GOV-2-26 c is therefore not required."

Integration of sustainability-related performance in incentive schemes

Reference: page 110.

The disclosure is a single, direct statement: "The Company has not established any performance-related remuneration schemes in relation to sustainability for Executive Board members or management staff." No sustainability-linked pay exists for either governing body or management in FY2025.

Statement on due diligence

Reference: pages 110-111.

Due diligence is "integrated into the Company's governance, strategy and business model development," cross-referenced to SBM-1 (p.112), SBM-2 (p.116) and the topic-specific stakeholder-engagement sections for S1, S2 and S4. An "IRO-PAT mapping" assigns existing policies (P), actions (A) and targets (T) to each identified impact, risk and opportunity.

The Company is candid about the limits of this process: "As of this writing, no specific disclosures exist for tracking the effectiveness of these efforts and for communicating their results," though "ongoing reviews are made as part of the processes as described." Departments prepared policies, actions and targets as "standardised fact sheets" during internal workshops to meet ESRS data-point content requirements.

Risk management and internal controls over sustainability reporting

Reference: pages 111-112.

Risk identification follows the German Stock Corporation Act (AktG); risks (including sustainability risks) are scored by impact and likelihood to produce an expected risk value, reviewed by the Executive Board and Supervisory Board at least quarterly, with an internal control system using a "dual-control principle" (risk manager and risk owner both approve each step).

A specific gap is disclosed: "the Company has already recorded two sustainability risks in its internal risk management software," but "as of this writing, no link has been made between the risks identified during the double materiality assessment and the general risk management system (RMS)." Material risks and actions are reported in the Group risk report from page 72.

Strategy, business model and value chain

Reference: pages 112-114.

CEWE operates three strategic business units: Photofinishing (digital photo products, led by the CEWE PHOTOBOOK, plus photo calendars, wall art, greeting cards; brands include CEWE, Cheerz, DeinDesign, Pixum, WhiteWall), Retail (photo hardware and photofinishing products via bricks-and-mortar and online channels in Czechia, Norway, Poland, Slovakia and Sweden), and Commercial Online Printing (SAXOPRINT, viaprinto). The Group runs 13 photo labs/production facilities shipping to 21 European countries; FY2025 Group revenue was EUR 864.5 million (2024: EUR 832.8 million).

Upstream materials are primarily FSC(R)-certified paper, plus paperboard, ink, adhesives, film, plastics, pigments, solvents, metal and glass, sourced from long-standing partners and moved by road, rail and marine freight. Downstream, products reach customers via apps, websites, software and Photostations, directly or through retail outlets. The Company states it "does not earn revenue from fossil fuels, the production of chemicals or tobacco, or controversial weapons."

Interests and views of stakeholders

Reference: pages 116-118, with topic-specific detail at S1 SBM-2 (p.158), S2 SBM-2 (p.172) and S4 SBM-2 (p.178).

Key stakeholder groups are employees, consumers/end-users, investors and credit institutions, business partners (suppliers/distributors), NGOs, affected communities, and Nature as "a silent stakeholder." Each group's relevance to the DMA and the actions taken are described in turn: employee welfare is addressed under S1 (p.158); community benefit runs through donations, sponsoring and grants -- "In 2025, the CEWE Group supported more than 200 organisations and clubs, including several sites run by SOS Children's Villages worldwide."

Engagement is carried out mainly through proxy stakeholders rather than direct surveys: "Key stakeholders are also taken into account in the course of the double materiality assessment (DMA). The topic-specific SBM-2 disclosures are made in the respective topical standards."

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

Reference: the central IRO table, pages 105-111 ("Material impacts, risks and opportunities and their interaction with strategy and business model (ESRS 2 SBM-3)"); topic detail at E1 SBM-3 (p.128), E4 SBM-3 (p.144-145), E5 SBM-3 (p.147), S1 SBM-3 (p.158), S2 SBM-3 (p.173) and S4 SBM-3 (p.178). The general index itself notes content is "Reported in the topical standards."

The table lists 51 individually typed IRO rows across E1, E2, E4, E5, S1, S2, S4 and G1 (see iro.json for the full breakdown by type). Climate change dominates E1 with both physical risks (raw-material supply disruption, higher cooling costs) and transition risks (carbon pricing, regulatory tightening), offset by market and funding opportunities. Own-workforce impacts split into a "Working conditions and labour rights" cluster and an "Integrative and safe working environment" cluster, the latter carrying most of the Company's positive-impact rows (freedom of association, work-life balance, disability inclusion, equal treatment).

General disclosure of resilience: "As part of the materiality assessment, the Company has assessed the resilience of the strategy and business model... The Company did not conduct a separate resilience analysis. The lack of this scenario analysis limited the overall volume of quantitative data that could be provided" (pages 118-119).

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

Reference: pages 119-127 (general methodology), with topic-specific IRO-1 sub-sections for E2 (p.125), E3 (p.125), E4 (p.126), E5 (p.127) and G1 (p.125).

The DMA runs a four-step process: preparation (scope and stakeholder identification, appointing internal subject-matter-expert proxy stakeholders); identification of IROs; assessment of impact materiality (severity x likelihood for potential impacts) and financial materiality (magnitude x likelihood); and verification by management, Works Councils, the Supervisory Board and its Audit Committee. "An auditing firm provided support for the double materiality assessment process in the form of external consultants."

Impact severity combines scale, scope and (for negative impacts) irremediable character; for potential impacts, severity is weighted by probability rather than strictly multiplied. Topic-specific sub-processes cover water/marine resources (an annual WRI Water Risk Atlas review via CDP, concluding the topic is immaterial, pages 125-126), biodiversity (site checks for protected-area proximity; dependencies on ecosystem services "were not considered," page 126), and resource use/circular economy (proxy stakeholders from Purchasing, plus local waste-management consultations, page 127).

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

Reference: page 127 (narrative), with the full content index ("ESRS Index") at pages 190-195, including a separate "Disclosure requirements under other EU legislation" table.

"A sustainability aspect is considered material if it fulfils one or both of the criteria for impact materiality and financial materiality... If a sustainability aspect is classified as material, the corresponding information must be disclosed in the topical ESRS." The index marks each of the 84 numbered disclosure requirements as either a page reference, "Not a material topic," or "Material topic, phase-in."

The report is explicit that it applies ESRS only partially, ahead of Germany transposing the CSRD: "since 2024, the report has been prepared by partially applying the ESRS... the CEWE Group reserves the right to deviate from these standards in some cases," with deviations listed in the Index and in the topical standards themselves. It also states: "The report does not include disclosures that, according to ESRS 1, are subject to phasing-in. The CEWE Group does not report on optional or phase-in data" -- language this review relies on to classify the "Material topic, phase-in" rows as omitted rather than reported.

Transition plan for climate change mitigation

Reference: pages 128-131.

CEWE's 2030 target is a 40% absolute reduction in Scope 1 and 2 GHG emissions versus a 2024 base year (-2,653 t CO2e), aligned with SBTi methodology, plus a 10% reduction in Scope 3 emissions by 2030 versus 2024 -- a target the report admits "is not aligned with the 1.5 degree pathway" (the 1.5C-aligned reference value would be -42%, i.e. 63,323 t CO2eq). The Company targets climate neutrality by 2045.

Decarbonisation levers are organised in four IRO clusters: raw-material availability, rising operating costs from physical hazards, Scope 3 emissions (supply logistics, inbound deliveries, commuting, business travel), and Scope 1/2 emissions (electricity, renewable energy, building efficiency, heating, vehicle electrification by 2030). Concrete 2025/2026 actions include a new Freiburg production/logistics site with photovoltaics and heat pumps (completed 2025) and an Oldenburg building renovation with PV and geothermal (planned 2026, EUR 6,212 thousand of budgeted CapEx).

No scenario analysis informed the decarbonisation levers: "When determining decarbonisation levers, no scenarios were referenced, although these were accounted for in the resilience and climate risk assessment" (p.134).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3/IRO-1, where this content is disclosed in the FY2025 report (pages 118-120, 128-129). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against -- CEWE's own content index uses 2023-numbering headings (E1-2 "Policies," E1-3 "Actions," E1-4 "Targets") with no native E1-2/E1-3 scenario-analysis section.

CEWE distinguishes physical risks (heat stress, sea-level rise, drought, flooding) from transition risks (carbon pricing, tightening regulation) and states plainly: "The CEWE Group has audited the resilience of its strategy and its business model. In 2021, the Company commenced implementation of a scenario analysis in line with the recommendations made by the Task Force on Climate-related Financial Disclosures (TCFD)" (p.128).

Scenarios used (p.128-129): the World Energy Scenario (Greenpeace Energy [R]evolution, 5th edition, 2015, modelling a doubling of energy prices over 20 years), RCP 2.6 ("best-case") and RCP 8.5 ("worst-case"), drawn from IPCC/CMIP models. The analysis nominally covers short-, medium- and long-term horizons per ESRS 1, but "the ability of the CEWE Group to adapt to climate change has not been assigned to any short-, medium- or long-term time horizons." No temperature projection per scenario, nor a refresh date beyond "commenced... in 2021," is given.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 118-119, 128-129). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

At the general, cross-topic level: "As part of the materiality assessment, the Company has assessed the resilience of the strategy and business model of the CEWE Group... using qualitative approaches... The Company did not conduct a separate resilience analysis. The lack of this scenario analysis limited the overall volume of quantitative data that could be provided" (pages 118-119).

For climate specifically: "The resilience analysis is an integral element of the CDP report and is regularly reviewed for accuracy and updated as needed as part of the annual reporting to CDP... The Company is still in the process of drafting specific action plans for strengthening its resilience to climate change impacts," though initial mitigation action (green electricity, PV, geothermal) is already under way. The Company commits to "providing further details in relation to its access to finance, its ability to redeploy, upgrade or decommission existing assets, and shifting its products and services portfolio" in future reporting (p.128).

Policies related to climate change mitigation and adaptation

Reference: pages 129-130.

IROs are grouped into four clusters with policies "documented in the Environmental Management Manual and standard operating procedure 612... as part of the integrated management system (ISO 14001 and ISO 50001)," plus disclosure via the CDP climate questionnaire. Climate-related risk is reviewed at least annually over short- (0-1y), medium- (1-5y) and long-term (5-20y) horizons, with financial/strategic impacts deemed "material" above 1% of revenue or profit.

Responses by cluster: raw-material availability is addressed by a multi-supplier strategy and substitute-material identification; rising operating costs by the same multi-supplier approach plus the ISO 50001 energy-management system; Scope 1/2 emissions by the energy-management system and 100% certified green energy in Germany; Scope 3 by participation in CDP and memberships such as the UN Global Compact. Responsibility sits with the Executive Board, with the climate strategy developed by Environmental Management alongside Purchasing, Energy, Logistics and Production Control.

Actions and resources in relation to climate change policies

Reference: page 131 ("Actions and resources in relation to climate change policies (E1-3)").

For clusters #1 and #2 (raw-material availability, rising operating costs) the Company states: "The CEWE Group has yet to implement actions specifically intended to counter impairments affecting raw material availability, rising operating costs and potential disruptions to business... CEWE has not yet developed appropriate actions because it currently does not have the financial and human resources to do so."

For clusters #3/#4 (Scope 3 and Scope 1/2), named actions include optimised supply-chain logistics and full-truck-load orders (planned 2026/2027); carbon-neutral shipping with DHL/UPS and elimination of a double stop in Germany (ongoing); a "Take your bike to work" initiative and job tickets; reduced business travel in favour of online meetings; low-power lighting and waste-heat recovery; the new Freiburg PV/heat-pump site (completed 2025); the Oldenburg building renovation (planned 2026); a Group-wide switch to green electricity; and electrification of the vehicle fleet by 2030. The Company adds: "The Company has yet to quantify the emission reductions achieved and targeted by the individual actions."

Targets related to climate change mitigation and adaptation

Reference: pages 132-133.

Scope 1+2: -40% absolute by 2030 vs. 2024 base year (-2,653 t CO2e, market-based), confirmed by the Executive Board and aligned with SBTi. Scope 3: -10% absolute by 2030 vs. 2024 (-96,709 t CO2eq), which the report states "is not aligned with the 1.5 degree pathway" (the 1.5C-aligned value would be -42%, 63,323 t CO2eq); a deeper Scope 3 reduction analysis is planned for 2026. Both targets replace earlier 2025 targets (2015 base year) that were set in 2017: "the targets for Scope 1 and 2 were achieved early... the Scope 3 figure failed to meet the original emissions target" due to calculation-basis changes, growth/acquisitions and over-optimistic supplier assumptions. CEWE targets climate neutrality by 2045.

No targets are set for raw-material availability or rising operating costs clusters: "CEWE has not yet developed appropriate targets because it currently does not have the financial and human resources to do so."

Energy consumption and mix

Reference: page 134.

Total energy consumption rose to 42,368 MWh (2024: 38,926 MWh). The renewable share reached 61% (2024: 60%), with renewable consumption of 25,846 MWh; fossil sources were 35% (2024: 36%), with the largest fossil component being purchased/acquired fossil electricity, heat, steam and cooling (15,010 MWh) followed by natural gas (7,719 MWh) and petroleum products (4,486 MWh). Nuclear-source consumption held at 4% (1,512 MWh).

Energy intensity was 0.049 MWh per thousand euros of net revenue (2024: 0.047). Photofinishing and Online Printing activities are classified under Sector C "Manufacturing" (NACE 18.1) and Retail under Sector G; "In general, all revenue is generated in 'high-emitting sectors'."

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 135-137.

FY2025: Scope 1 = 2,722 t CO2eq (2024: 2,605); Scope 2 market-based = 1,563 t CO2eq (2024: 1,509, +4%); Scope 2 location-based = 8,230 t CO2eq (2024: 8,840, -7%). Scope 3 = 118,879 t CO2eq (2024: 107,454, +11%), driven mainly by purchased goods and services (77,424 t, +5%), upstream transportation and distribution (8,125 t, +46%) and employee commuting (4,164 t, +95%). Total market-based emissions = 123,450 t CO2eq (+10%); total location-based = 129,831 t CO2eq (+9%).

Approximately 14% of value-chain emissions used primary data (2024: 3%). Categories 8 (upstream leased assets), 10, 11, 14 and 15 "have been reported as zero as these do not apply to CEWE." 76% of market-based Scope 2 relied on guarantee-of-origin/renewable-energy-certificate instruments. Germany accounted for 95,334 t CO2eq location-based of the Group total in 2025 -- by far the largest country share.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 138-139.

"The CEWE Group has not developed any projects within its own value chain that have the objective of achieving a targeted removal or storage of greenhouse gas emissions." Outside its value chain, the Company retired 14,563 t CO2eq of carbon credits in 2025 (2024: 36,600 t CO2eq), "used... only for external communications, which were conducted only to a limited extent in 2025" and not as part of carbon accounting or action planning. All credits (100%) originate from non-EU initiatives: VCS 8,971 (62%), CDM 4,714 (32%) and Gold Standard 878 (6%).

The 2045 carbon-neutrality target "is set to a later date than Germany's net zero target... A scientific methodology and verification (e.g. by SBTi) has not yet been applied here. The Company has not yet adopted actions aimed at neutralising residual gross emissions."

Policies related to pollution

Reference: pages 140-142.

Policies sit in the Management Manual, consolidating the ISO 14001 (environmental) and ISO 50001 (energy) management standards, applied to production sites (Oldenburg, Mönchengladbach, Munich, Freiburg, Dresden, Montpellier, Warwick, Prague, Budapest, Kozle, Rennes, Bad Kreuznach, Frechen, Paris) but excluding Retail, OSF and sales offices; the Manual "refers only to the CEWE Group itself and not to the upstream or downstream value chain."

High-priority aspects: carbon emissions, energy/efficiency, wastewater, water balance, waste, packaging, environmentally friendly materials, scrap/material efficiency. Hazardous-substance handling follows the STOP principle (Substitution, Technical, Organisational, Personnel/PPE); the Company excludes SVHCs from the ECHA Candidate List and CMR 1A/1B substances "wherever possible," governed by the Hazardous Substances Ordinance, REACH and CLP, with new substances vetted before approval and entered in a hazardous-substances register.

Actions and resources related to pollution

Reference: pages 142-143.

Process-level actions: digital printing uses very small toner particles bound by imaging-oil liquid carriers "to prevent employees from being exposed to air pollution"; the remaining digital machines use water-based inks; other processes use solvent-free UV inkjet; offset printing is "mineral oil- and alcohol-free," using vegetable-fat or UV-cured inks and avoiding isopropanol in washing solution where possible. Safety data sheets are reviewed by qualified industrial chemists in central Chemistry before any chemical is procured, Group-wide.

Value-chain actions run through the sustainability questionnaire (environmental/energy/safety management systems, certificates, supplier audits) and the Supplier Code of Conduct, which "requires partners to observe all applicable environmental standards" with termination rights for repeated or major breaches.

Targets related to pollution

Reference: page 144.

"The CEWE Group has yet to adopt any Group-wide quantitative targets for pollution control. CEWE has not yet developed appropriate targets because it currently does not have the financial and human resources to do so." In their place, the Company tracks five qualitative indicators: no use of SVHC mixtures or mixtures containing SVHCs "wherever possible"; no use of CMR Category 1A/1B substances "wherever possible"; reduction in use of substances of concern (SoC); consistent application of the STOP principle; and "continuous pursuit of the goal of zero emissions." Site-level target audits run through the Environmental Management System.

Substances of concern and substances of very high concern

Reference: page 144.

"In accordance with the chemicals policy, substances of very high concern (SVHCs) are generally not used in the CEWE Group. The sole exception to this policy is a substance used for developing black-and-white film. Despite intensive collaboration with suppliers to substitute the affected SVHC, no alternative substance could be found... the SVHC classification only relates to the pure substance and not to the diluted chemical mixture we receive from our supplier. Furthermore, no financial effects from pollution-related risks and opportunities have been registered."

Quantified inputs (2025, tonnes): total substances of concern = 53.59 t, split by hazard class (skin sensitisation 39.52 t, hazardous to water bodies long-term 45.82 t, specific target organ toxicity repeated exposure 7.92 t, reproductive toxicity 4.96 t, and smaller amounts elsewhere). Substances of very high concern = 0.02 t (reproductive toxicity). Chemicals are checked above a 1 t/a materiality threshold from ERP records; "this data is not externally validated."

Transition plan on biodiversity and ecosystems

Reference: pages 144-145 ("Transition plan and consideration of biodiversity and ecosystems in strategy and business model (E4-1)").

"The upstream value chain of the CEWE Group incorporates a significant demand for wood as a raw material for paper production, which is sourced from managed forests. The use of wood can result in biodiversity losses, particularly as a result of logging and deforestation. The Company mostly uses FSC(R)-certified materials in order to counter these negative impacts... While FSC(R) certification guarantees sustainable management practices, it is not a substitute for the preservation of untouched ecosystems."

There is no dedicated biodiversity transition plan distinct from this FSC(R)-procurement response and the E1 climate transition plan; the SBM-3 narrative adds that the DMA "has not produced any physical, transition or systemic risks that could impair the resilience of the business model or the strategy" on biodiversity (page 145).

Policies related to biodiversity and ecosystems

Reference: pages 145-146.

Policies sit in the Management Manual and SOP 612, with the CEWE Group Executive Board responsible for implementation. They focus on procurement: "When purchasing paper, the CEWE Group insists on FSC(R) certification... FSC(R) certification had been obtained for all German companies by September 2010, with European companies following in 2011," covering prohibition of clear-cutting, restricted pesticide use, mixed-forest promotion, forest-floor preservation and rare-species/ecosystem protection (FSC(R) Principle 6).

The Company is explicit about scope limits: "the CEWE Group itself does not use its policies to explicitly address the social implications of impacts on biodiversity and ecosystems," though FSC(R) certification indirectly covers labour rights, indigenous-peoples' rights and local-population relations. "In its policies related to biodiversity and ecosystems, the Company does not address any material dependencies, nor any material physical risks and transition risks or opportunities."

Actions and resources related to biodiversity and ecosystems

Reference: page 146.

A direct negative statement: "The CEWE Group does not currently pursue company-internal actions related to biodiversity and ecosystems, and has not allocated any separate resources for this purpose. However, corresponding aspects are taken into account in existing, comprehensive policies and regulations." No mitigation-hierarchy actions (avoidance, minimisation, restoration/rehabilitation, offsets) have been defined, and the Company "does not make use of biodiversity offsets, nor does it incorporate local or indigenous knowledge or nature-based solutions into its biodiversity and ecosystems-related actions."

Targets related to biodiversity and ecosystems

Reference: pages 146-147.

"The Company has not set any specific targets for controlling biodiversity. In 2025, the Executive Board approved the target to use only certified wood fibre-based materials by 2030 (100% FSC in Photofinishing)," including PEFC-certified materials, applying Group-wide with no interim milestones. The target is tracked "through regular discussions with the business units and by surveying the current certification status"; no ecological thresholds were applied, and there is no mapping to the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy for 2030, or the mitigation hierarchy.

Policies related to resource use and circular economy

Reference: pages 147-148.

Policies sit in the Management Manual and SOP 612, binding on all Group companies but not referencing the value chain directly (value-chain coverage instead runs through the Supplier Code of Conduct and supplier questionnaire). Five IRO clusters structure the policy: resource availability and substitution, resource efficiency, resource outflow reduction/substitution, supply-chain waste management, and own-operations waste management.

The Company flags a known limitation: "This already established procedure corresponds to the stated ISO standards [14001/50001] but is not entirely correspondent with the policy requirements as prescribed by the ESRS. Nor are the clusters resulting from the DMA entirely congruent with the environmental aspects as identified in the CEWE Group environmental policy... The CEWE Group has committed to successively rectifying these irregularities over the next few years."

Actions and resources related to resource use and circular economy

Reference: page 151.

"The CEWE Group has yet to define any actions at a strategic level whose results specifically accrue to clusters #1 to #5 and whose effectiveness can be audited... no financial or personnel resources have been allocated in order to prioritise other topics." Operational actions that exist are assigned only to cluster #1 (resource availability/substitution): FSC(R)-certified paper procurement since 2010, isolated packaging-plastic-reduction actions, and supplier-management requirements under the Supplier Code of Conduct and supplier questionnaire, reviewed via on-site audits when non-compliance is suspected.

Targets related to resource use and circular economy

Reference: page 151.

"The CEWE Group has not defined specific targets for the control of resource inflows and outflows." The FSC(R)-sourcing target is cross-referenced to E4-4 (page 146 f.); "Formal target planning neither includes circular economy-oriented product design nor the minimisation of the use of primary materials." Company strategy "also envisages reducing production scrap and reductions to the proportion of plastic in packaging," and aims to source all wood-fibre materials from FSC(R)-certified sources, but "this target has been set without formalised agreements or rules delivering measurable results... CEWE has not yet developed specific targets because it currently does not have the financial and human resources to do so."

Resource inflows

Reference: pages 151-152.

Material inflows: paper (photo/digital print paper, paperboard, end paper), packaging (paper, paperboard, plastic, photo pouches, wood), process materials (chemicals, printer ink, metals, foils, adhesive) and other materials (aluminium composite panels, acrylic glass, ceramics, textiles, canvas, rigid foam). Total weight of products/materials rose to 49,723.8 t in 2025 (2024: 47,466.5 t), "of which 100% technical" (no biological-material share reported). Secondary/reused/recycled materials totalled 5,607.53 t, 11.3% of total usage.

Risks attach to resource-intensive or environmentally critical inputs -- aluminium, chemicals, wood/paper, plastics, cotton, oil-based materials -- while opportunities lie in on-demand production, the renewability of paper/wood and FSC(R) certification. Rubber and bauxite are flagged as EU-critical raw materials; rare earths apply only to a negligible share of bought-in electronic components.

Resource outflows

Reference: pages 152-153.

Critical output products are photobooks, photo paper and printed products. Product recyclability: 67.8% of total output sold on the market is recyclable in 2025 (2024: 66.0%), comprising 51.1% of products and 16.7% of product packaging. "The CEWE Group has not identified any of its products as capable of being repaired, since these products do not include any replaceable components," so that datapoint is not reported.

Recyclable printed products are digital-printing-paper items without coating or foliation on both sides; textiles are reusable via the second-hand clothes cycle; photobooks, photo prints and wall art are cited as long-lived products. "Metrics are not subject to external validation." Product design "does not follow any specific design methodology according to circular principles," though recyclability, longevity and second use are considered when introducing new products.

Waste

Reference: pages 153-154.

Total operational waste rose to 13,398.3 t in 2025 (2024: 12,601.3 t). Hazardous waste was 677.7 t (2024: 833.4 t); non-recycled waste was 4,434.5 t, 33.1% of total (2024: 22.0%); no radioactive waste. Waste diverted from disposal (2025, non-hazardous/hazardous): recycling 8,733.0 t / 230.7 t; other recovery 3,885.6 t / 135.7 t; preparation for reuse 32.5 t / 0.1 t. Waste directed to disposal: incineration 12.5 t / 46.2 t; landfill 5.3 t / 2.3 t; other disposal 51.6 t / 262.8 t.

Waste is classified by European Waste Catalogue (EWC) code per production site, following the EU waste hierarchy (avoidance, reuse, recycling, other recovery, disposal; Directive 2008/98/EC, transposed via the German Kreislaufwirtschaftsgesetz). "Categorisation by process is partially based on assumptions... as some waste management companies did not provide details of the associated process." Metrics are not externally validated.

Policies related to own workforce

Reference: page 161.

Beyond statutory obligations, "there are currently no written and documented company-specific policy obligations in place on inclusion or targeted support measures for particularly vulnerable groups within the Company's own workforce," though initiatives exist in practice (the Equality Committee, Diversity Week). Cluster #1 (working conditions/labour rights) policies: the CEWE Code of Conduct, CEWE Human Rights Policy Statement, BME Code of Conduct, Ombudsman, CEWE Supplier Code of Conduct, and the general collective agreement for Photofinishing. Cluster #2 (integrative/safe working environment) applies the same document set minus the collective agreement, aiming to ensure all workers "are respected and appreciated regardless of their gender, age, ethnic origin, religion or sexual orientation," with the Executive Board holding implementation responsibility.

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

Reference: pages 162-163.

Structures include employee representatives on the Supervisory Board, site and Group Works Councils, regular employee meetings (four times yearly at the main Oldenburg site), the Group Works Council (quarterly in-person, biweekly online), and two annual events -- "Ship It Days" (nine teams proposed ideas in 2025) and "Innovation Days" (featuring a "Future Zone" for project showcases). The most recent major employee survey, "Great Place to Work," ran in 2022. Complaints can go to supervisors, the Works Council, HR, or an external ombudsman, also anonymously; "There was no global framework agreement in place in the reporting period," so complaint handling is case-by-case and "the effectiveness of this process is not assessed separately."

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

Reference: pages 163-164.

The remediation channel is the "ombudsman" complaint and reporting system, described in detail under G1-1 (page 185). "If a negative impact or rights infringement occurs despite the implementation of preventive actions, the CEWE Group will introduce appropriate countermeasures. Each case is handled and analysed individually by the corresponding business department," with review by the affected department and, where needed, involvement of the Works Council.

Taking action on material impacts on own workforce

Reference: pages 164-167.

Cluster #1 actions: the AuditorPlus occupational safety/health programme (used continually since 2012 at the German Photofinishing sites; "effectiveness... is not systematically tracked or assessed") and workplace health promotion (screenings, ergonomic advice, Hansefit, bicycle leasing) at the Oldenburg site. Cluster #2 actions: the Disabled Persons' Delegation (advocacy for roughly 1,500 colleagues across four sites; "effectiveness... is not systematically tracked or assessed"), the Equality Committee, mandatory e-learning on equal treatment and DEI since April 2024, and initiatives to raise women's share of leadership ("GROW" trainee programme: 12 participants, 58% women, 2025-2026 cohort; part-time leadership roles from 2025; mandatory diversity training for managers/HR from 2026).

"In the context of its partial application of ESRS, the CEWE Group reserves the right not to report on data point S1-4-40b."

Targets related to own workforce

Reference: page 167.

Only cluster #2 (integrative/safe working environment) has a measurable target: women's share to reach 50% on the Supervisory Board, 33% in the first management tier and 40% in the second, all by 2027, set by the Executive Board "taking legal requirements into account," with affected stakeholders consulted. "A specific base year has not been specified, as target achievement does not depend on a base value... No interim targets or milestones have been specified."

Cluster #1 (working conditions/labour rights) has no measurable target: "CEWE has not yet developed appropriate targets because it currently does not have the financial and human resources to do so. Notwithstanding this, the CEWE Group does track the effectiveness of its policies and actions... by means of regular reviews and assessments."

Characteristics of the undertaking's employees

Reference: pages 168-169.

Total employees at 31 December 2025: 5,658 (2024: 5,553); average headcount 4,900 (2024: 4,658). The temporary-contract ratio is 37.0% (2,097 of 5,658), reflecting seasonal hiring. By gender (average 2025): male 2,529, female 2,369, other 1. Germany is the only country with more than 50 employees representing at least 10% of the workforce: 3,878 employees at year end (2024: 3,886), average 3,394 (2024: 3,194). A footnote explains the figures differ slightly from the consolidated financial statements because "the CSRD used headcounts instead of full-time equivalents (FTE)."

Collective bargaining coverage and social dialogue

Reference: pages 169-170.

"Group-wide, 44% (previous year: 53%) of employees are covered by collective agreements." For Germany (the only country exceeding the 50-employee/10%-of-workforce threshold), collective-bargaining coverage is in the 60-79% band (64%) and workplace representation in the 80-100% band (89%). No coverage data is given for non-EEA regions. Methodology: the coverage rate divides employees under collective agreements by total headcount as of 31 December 2025, and social dialogue "is calculated as a percentage of all employees, with the number of employees in units with employee representatives considered in relation to the total number of employees."

Diversity metrics

Reference: page 171.

Gender distribution at top management (C1/C2 levels): 2025 -- male 139 (73%), female 51 (27%), total 190; 2024 -- male 135 (71%), female 55 (29%), total 190. "The diversity metrics refer to the gender distribution at the top management level (C1 and C2)." No age-band distribution of the Board of Directors or other diversity dimensions are quantified in this section.

Adequate wages

Reference: page 171.

"All (previous year: all) employees at the CEWE Group receive adequate wages for their job role, based on the applicable reference values." No below-benchmark headcount or country breakdown is given, consistent with a 100% compliant finding requiring no further quantification.

Persons with disabilities

Reference: page 159 ff. (the "Summary of positive impacts" / materiality-assessment narrative), flagged in CEWE's own index as "Material topic, phase-in."

The narrative on disability inclusion states: "Inclusion of persons with disabilities: The CEWE Group caters to the needs and requirements of people with disabilities... The CEWE Group also contributes to the inclusion of people with disabilities in the labour market, not only by employing people with disabilities but also by commissioning work from external workshops staffed by people with disabilities" (page 159). A Disabled Persons' Delegation covers roughly 1,500 colleagues across four sites (page 164).

No numeric percentage or headcount of employees with disabilities is disclosed; the index's "phase-in" flag indicates the Company is deferring this specific quantified datapoint under the ESRS 1 Appendix C reliefs it applies generally ("The report does not include disclosures that... are subject to phasing-in," page 98).

Training and skills development metrics

Reference: page 165 f., flagged in CEWE's own index as "Material topic, phase-in."

The disclosed content is action-level rather than a quantified metric: a mandatory e-learning programme on equal treatment and DEI since April 2024, and the internal "GROW" junior-management trainee programme (12 participants, 58% women, 2025-2026 cohort) aimed at building leadership skills through "knowledge transfer, job shadowing and mentoring" over a one-year course (pages 165-166).

No average training hours per employee, nor percentage of employees receiving regular performance/career reviews, is quantified. The index's "phase-in" flag indicates this specific datapoint is deferred under the ESRS 1 Appendix C reliefs CEWE applies generally.

Health and safety metrics

Reference: page 171.

"The percentage of individuals in the Company's own workforce covered as a result of applicable legal requirements is 100 (previous year: 100). There were also no deaths registered during the reporting period as a result of a work-related injury or work-related illness." Work-related accidents: 75 in 2025 (2024: 60), a rate of approximately 9.1% (2024: 7.4%), calculated as cases divided by projected total hours worked (from Workday target hours), multiplied by 1,000,000.

Work-life balance metrics

Reference: pages 159 and 166.

Qualitative rather than quantified: "Work-life balance: The CEWE Group uses programmes like the company-internal crèche and holiday camps to provide help with childcare, and also runs programmes targeting specific needs like the 'parent cafes'. This makes it easier for employees to achieve a good work-life balance" (page 159). From 2025, part-time leadership is being actively promoted: "all leadership positions will be advertised with the option to work part time on a near-full time basis (min. 80%)" (page 166). No percentage of employees entitled to or taking family-related leave is disclosed.

Compensation metrics (pay gap and total compensation)

Reference: page 171.

"The difference between the average income of female and male employees of the CEWE Group, expressed as a percentage of the average income of male employees (known as the gender pay gap), was 17.5% in the reporting period (previous year: 18.6%)," calculated on an unadjusted, Group-wide basis using average hourly wage per month. The annual total remuneration ratio (highest-paid individual to median employee, excluding the highest-paid individual) was 27:1 (previous year restated from 14.8:1 to 29:1 "due to a revision of the underlying data"). Seasonal workers, concentrated around the Christmas season, are included in the median calculation and materially influence the ratio.

Incidents, complaints and severe human rights impacts

Reference: pages 171-172 (the report carries an explicit "Incidents, complaints and severe human rights impacts (S1-17)" heading with quantified content).

"In the 2025 reporting period, there were three (previous year: three) complaints and four (previous year: two) cases of reported discrimination and harassment. None of these incidents was reported via the ombudsman. All incidents were investigated and assessed, and corresponding actions were introduced. The CEWE Group was not notified of any complaints submitted to the National Contact Point for OECD Multinational Enterprises... no fines, penalties or compensation for damages were imposed."

Note for review: CEWE's own printed ESRS Index (page 193) marks S1-17 "Not a material topic," which conflicts with this explicit, DR-coded disclosure in the body text. Per the site's guidance to trust the disclosure over a misleading table, this entry is recorded reported on the strength of the body text -- flag the index/body discrepancy for a human check.

Policies related to value chain workers

Reference: page 174.

Policies run through the Supplier Management System and four documents: the BME Code of Conduct, CEWE Code of Conduct, CEWE Human Rights Policy Statement, and CEWE Group Supplier Code of Conduct. Suppliers in amfori BSCI "critical" regions (e.g. Asia) receive particular attention and are preferred where BSCI-member; Chinese suppliers "are evaluated roughly every two years." The Human Rights Policy Statement applies "a standard assessment and correction procedure if there is a risk that own operations or suppliers' operations will have negative impacts on human rights"; the Supplier Code of Conduct explicitly rejects "all forms of forced and child labour" and permits contract termination after a repeat or single gross violation.

Processes for engaging with value chain workers about impacts

Reference: page 175, flagged in CEWE's own index as "Material topic, phase-in."

A direct negative statement: "The Company does not currently have a structured process for integrating opinions from workers in the value chain to be used as input and guidance during decision-making about policies. The interests of value chain workers are discussed only within the Company and are accounted for to the extent that the subject-matter experts at the CEWE Group are able to assess their needs." Potential negative impacts can be raised through the ombudsman reporting channel described under G1-1 (page 185). The index's "phase-in" flag indicates a specific related datapoint is deferred under the general ESRS 1 Appendix C reliefs CEWE applies.

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

Reference: pages 175-176.

The Ombudsman channel (see G1-1, page 185) is open to "customers, business partners and value chain workers." Where a negative impact is confirmed, "the Company initiates a procedure for assessment and correction, and activates the CEWE Group reporting chain" (report to ombudsman, then Compliance Officer). Effectiveness is checked via the Integrity Next sustainability platform, used annually to review control actions/remedies; "in 2025, the first suppliers contacted were those assigned to the high-risk category" based on headquarters location or sector, with implementation "ensured by means of annual questionnaires."

Taking action on material impacts on value chain workers

Reference: pages 176-177.

Four named actions across both IRO clusters ("Working conditions and occupational safety" and "Forced labour and child labour"): (1) cooperation with the Integrity Next sustainability platform, which replaced EcoVadis in the reporting year -- "a detailed evaluation of the 106 suppliers identified as especially high-risk... is still ongoing and was not completed in the reporting year"; (2) biennial supplier audits against the Supplier Code of Conduct, including new and Asia-region suppliers, verifying ILO fundamental-convention compliance and GOTS certification where relevant; (3) evaluation of new production-material suppliers ("the CEWE Group did not acquire any new relevant production material suppliers" in 2025); (4) the biennial sustainability questionnaire (most recently sent in 2024).

"No human rights violations in the value chain were registered during the reporting period." No actions specifically address negative impacts from CEWE's own operations on value-chain workers.

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

Reference: page 178.

Both clusters carry an explicit no-target, no-tracking statement: "The CEWE Group does not set targets for potential work-related accidents and/or illness as caused by the business activities of companies in the CEWE Group's value chain, nor does it currently plan to set a target because the CEWE Group currently has no way of collecting this data." For forced and child labour: "The CEWE Group has not defined any targets... nor does it have any plans to introduce such a target. Accordingly, the effectiveness of policies and actions in this connection is not tracked."

Policies related to consumers and end-users

Reference: pages 180-182.

Five policy instruments: the CEWE Group IT security policy (BDSG compliance, secure IT processes); the CEWE Group Human Rights Policy Statement; the BME Code of Conduct; the Data Protection Policy (GDPR Article 13 disclosures covering the CEWE Community, webinars, CRM/newsletter registration and orders); and new Forum terms of service aligned with the Digital Service Act. A 2004 works agreement banned camera phones at German production sites to prevent data misuse; new employees receive a data-protection briefing in their Welcome Pack. "The Company has not established processes and mechanisms for monitoring compliance with these [human-rights] policies."

Processes for engaging with consumers and end-users about impacts

Reference: page 182.

Customers can reach the Company by phone, email, social media or an anonymous reporting procedure; products also reach consumers via business partners such as health/beauty chains and supermarkets. "To date, however, the Company has not established a structured process for contacting consumers and end-users or individuals representing these groups." Interests are instead accounted for through current decision-makers' and business departments' own insight into customer needs.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: pages 182-183.

The primary channel is the external Ombudsman, available anonymously for reports of corruption, fraud, breach of trust or other irregularities; customers can also contact the Company directly by email, phone or post. Forum posts can be reported and removed via the Customer Service process, though "this process does not envisage any compensation being made to individuals" affected by a reported post. "The Company does not currently use a structured policy to monitor the effectiveness and efficacy of reporting procedures, nor to assess the level of customer awareness of these reporting procedures and their confidence in them."

Taking action on material impacts on consumers and end-users

Reference: pages 183-184.

Core actions are preventive data-protection controls (see S4-1) and a dedicated, multi-stage process for "mix-ups" -- incidents where personal photos are disclosed to the wrong recipient -- documented in the Group-wide "Customer Service Processes." A large-scale employee training programme on data handling covers onboarding and ongoing refreshers, including the CARL internal communications app; costs are absorbed into the general training budget and not separately itemised. An "Emergency Group" investigates mix-up occurrences and drives process improvement. "The CEWE Group is not aware of any violations of human rights in relation to consumers or end-users in the reporting period. No fines were incurred."

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

Reference: page 184.

"The CEWE Group does not currently have any targets for improving data protection for end-consumers. In addition, the Company does not plan to introduce such a target at this time." This satisfies MDR-T's alternate limb: "The Company tracks the effectiveness of strategies for managing material impacts and risks, and audits these regularly" -- citing the Emergency Group's investigation of mix-up incidents and the associated internal review process as the tracking mechanism in place of a formal target.

Business conduct policies and corporate culture

Reference: pages 185-188.

Six instruments structure corporate culture: the CEWE Code of Conduct (ethical minimum standards, no tolerance for discrimination, harassment or bullying); the CEWE Group Human Rights Policy Statement (adopted 2022 under the German Supply Chain Due Diligence Act / LkSG, aligned to the UN Guiding Principles, ILO Declaration and OECD Guidelines, collaborating with EcoVadis on supply-chain review); the BME Code of Conduct (affiliated since 2010, annual self-assessment completed in 2025); the CEWE Group mission statement (five pillars: honest/fair conduct, economic viability, environmental protection, employee responsibility, community engagement); "The WE in CEWE" cultural-values framework; and a "Respektvolles Miteinander" (Mutual Respect) initiative launched October 2025, Group rollout from 2026.

The Ombudsman system, compliant with the German Whistleblower Protection Act (HinSchG) transposing EU Directive 2019/1937, lets employees, value-chain workers and customers report anonymously by email, phone or fax; "To date, the CEWE Group has not assessed whether individual workers in the upstream value chain are aware of the reporting channels and whether they are seen as trustworthy."

Management of relationships with suppliers

Reference: pages 188-190.

"Honest and fair conduct" governs supplier relationships: the Company "rejects any unlawful agreements or false bids" and seeks long-term partnerships, citing resilience "in times of global crisis with significant price volatility." Minimum standards sit in the Supplier Code of Conduct, enforced via audits (authorised third parties where appropriate), with Chinese suppliers evaluated roughly every two years; violations permit extraordinary termination. A separate Supplier Handbook formalises procurement procedures and supplier assessment, though "there is no obligation with regard to external standards," and "no stakeholders were involved in the preparation of this policy." On-site visits sometimes check production conditions at larger suppliers, though "no standardised checklist is currently used."

Targets related to business conduct

Reference: page 190 (immediately following the G1-3 immateriality discussion, under a "Metrics and targets" sub-heading).

A direct, explicit statement answers both limbs of MDR-T in the negative: "At present, the Company has not set any governance and compliance targets, and does not currently plan to introduce any such targets. The Company does not track the effectiveness of its policies and actions in relation to the material sustainability-related impact, risk and opportunity, and accordingly has not set any targets and qualitative or quantitative metrics to assess progress."

This is recorded reported rather than not_reported: the report is not silent on business-conduct targets -- it states plainly that neither a target nor an effectiveness-tracking process exists, which is itself the finding (the same logic the site applies to an explicit "no resilience analysis was performed" statement under E1-3).

Payment practices

Reference: page 190.

"The most frequently used payment term is 14 days net after receipt of invoice, with around 25% of payments being made under these standard payment terms." The calculation covers only material, active creditors on payment terms stored in the MM (Purchasing) module; "deviating agreements outside the MM module or inactive creditors are not included." No open legal proceedings with suppliers over late payment existed during the reporting period. "In the context of its partial application of ESRS, the CEWE Group reserves the right not to report on data point G1-6 33a."