CTS Eventim AG & Co. KGaA

Reference: pages 81-83.

CTS KGaA has a dual management system: the Executive Board of the general partner, EVENTIM Management AG (CEO Klaus-Peter Schulenberg, CFO Holger Hohrein, COO Alexander Ruoff, CTO Karel Dörner), and a four-member, non-executive Supervisory Board of CTS KGaA. "In the reporting year, all members of the Supervisory Board (100%) were independent", and the gender ratio was 1:3 on the Supervisory Board and 0:4 (all male) on the Executive Board.

The Supervisory Board's Audit Committee (Dr Cornelius Baur, chair, and Dr Bernd Kundrun) is "responsible for monitoring sustainability-related impacts, risks and opportunities (IROs)", reviewing sustainability reporting and monitoring the process for identifying material IROs. Both Audit Committee members' relevant expertise (strategic consultancy/ESG committee membership; digital business models and impact investing) is described.

Reference: pages 83-84.

The head of Compliance & Sustainability is responsible for sustainability reporting and reports to the CFO. A dedicated ESG Committee was established in 2025, chaired by the CFO, meeting quarterly and covering Compliance & Sustainability, HR, Central Finance, E-Commerce, Corporate Development and Live Entertainment; its tasks include defining the sustainability strategy and targets and assisting the Double Materiality Assessment.

The head of Compliance & Sustainability reports to the CFO weekly and to the Audit Committee at least semi-annually. "During the reporting year all IROs identified as material were submitted to the Executive Board, the Supervisory Board and the ESG Committee to ensure appropriate consideration." Since 2025, material sustainability matters have also been integrated into the Group-wide risk management system.

Reference: page 84.

"The remuneration and incentive schemes for the members of the Executive Board are primarily based on financial and operational performance metrics. Sustainability matters are not yet defined as a stand-alone variable remuneration component." The Annual Shareholders' Meeting approved, in May 2025, a remuneration scheme that allows ESG criteria to be integrated into the Executive Board's variable remuneration in future, but "to date, no ESG-related components have been included." The Supervisory Board of EVENTIM Management AG is responsible for defining the specific ESG targets within that scheme.

Reference: page 84.

CTS EVENTIM discloses the mandated due-diligence mapping table, cross-referencing each of the four core elements of due diligence to the sections of the statement that address it: embedding due diligence in governance/strategy (ESRS 2 GOV-2, SBM-3); engaging with affected stakeholders (ESRS 2 GOV-2, SBM-2, IRO-1, and MDR-P in the S1, S2, S4, G1 chapters); identifying and assessing adverse impacts (ESRS 2 IRO-1, SBM-3 and the IRO tables in the topical chapters); addressing adverse impacts (MDR-A in E1, E5, S1, S2, S4, G1); and tracking effectiveness (MDR-M and MDR-T in E1, S1, G1).

Reference: pages 84-85.

In the reporting year CTS EVENTIM built an internal control system (ICS) for sustainability reporting "based on the principles of the COSO-ICSR framework", covering material ESG topics and the related data-collection, validation and approval processes. Compliance & Sustainability reports identified risks monthly to the CFO, quarterly to the ESG Committee and ad hoc to the Audit Committee; three reports went to the Audit Committee in FY2025.

The company names the "first full application of the ESRS and the associated audit" and data aggregation across systems (partly estimated/extrapolated) as the principal reporting challenges, and describes a Group-wide data tool with version history and a plausibility-check process run by Compliance & Sustainability.

Reference: pages 86-90.

CTS EVENTIM operates two segments, Ticketing and Live Entertainment (5,329 employees in FY2025: 2,971 Ticketing, 2,358 Live Entertainment), running platforms such as eventim.de and venues including the Waldbühne Berlin, Eventim Apollo London, K.B. Hallen Copenhagen and LANXESS arena Cologne, plus the ARENA MILANO under construction. The value chain for each segment is described step by step (platform development, B2B/B2C sales, ticket sale and dispatch for Ticketing; design, procurement, financing, marketing and execution for Live Entertainment), with upstream partners named as promoters, artists, venues and software developers.

The Sustainability Strategy sets four areas of action: protecting the climate (the 2025 Scope 1+2 target, see E1-4), conserving resources, enabling access, and demonstrating responsibility.

Reference: pages 90-91.

CTS EVENTIM lists its key stakeholder groups — ticket buyers/event visitors, promoters, employees, shareholders, and the Executive/Supervisory Boards — against their most relevant dialogue formats (customer surveys, topic-specific webinars, the annual online survey, employee engagement formats, the AGM, and Board/committee meetings). Insights from these dialogues feed into the Compliance & Sustainability department and the ESG Committee, and "the stakeholder perspective... has been factored into the materiality assessment process." Employee perspectives specifically feed the business strategy through regular surveys (see S1-2).

Reference: page 91.

The 2025 update to the Double Materiality Assessment found "no new topics compared to the previous year... identified as material", with material topics confirmed as Climate Change (E1), Resource Use and Circular Economy (E5), Own Workforce (S1), Workers in the Value Chain (S2), Consumers and End-users (S4) and Business Conduct (G1). Within S1, the update changed the mandatory disclosure set: "ESRS S1-10 Adequate Wages", reported the previous year, "is no longer subject to mandatory reporting", while "ESRS-S1-9 Diversity Metrics" was newly included.

"There were also no significant financial effects from the material risks and opportunities" in the reporting year.

Reference: pages 91-94.

The 2025 Double Materiality Assessment updated the process first run in 2024 ("the analysis was conducted for the second time in the reporting year, a full reassessment was not carried out") across impact and financial materiality, involving 13 named departments, a workshop and an online survey. For the three environmental topics, the company ran a site-level geodata analysis: "the three environmental topics E2, E3 and E4 were subjected to a separate site-level analysis... before being identified as not material" — none of its permanent sites fall within IUCN protected areas (E2/E4), and while 53 sites showed elevated water-stress risk, "the low water intensity of business activities meant there were no material impacts" (E3). A 2025 climate risk assessment (TCFD/UBA-based) was also integrated into the assessment (see E1 IRO-1).

Reference: pages 95-100.

CTS EVENTIM's content index, the "ESRS Index", maps each chapter (11.2 ESRS 2 through 11.9 G1) to its disclosure requirements, explicitly stating "For all material IROs, the mandatory disclosures were systematically identified at the level of the topics, sub-topics and sub-sub-topics... and fully reported." A second table, "Overview of the data points derived from other EU legislation" (ESRS 2 Appendix B), lists each Appendix B datapoint against Benchmark/SFDR/Pillar 3/EU Climate Law references and the statement section where it is addressed, or marks it "Not material" or "Not relevant" where the underlying topic (E3, most E2/E4/S3 datapoints) was assessed as immaterial. This is the index used throughout this extraction to determine which of the 84 keys are reported.

Reference: pages 107-108.

"CTS EVENTIM does not yet have a complete Group-wide transition plan for climate change mitigation." The company built its carbon-footprint base data in 2024, refined it in 2025 alongside a detailed climate risk assessment, and states the transition plan itself "is still being developed" and "due to be completed and presented to the Executive Board for approval in 2026", with supporting policies to follow "by the end of 2027." The 2025 statement therefore reports the GHG footprint (E1-6), the first quantified target (E1-4) and individually-implemented actions (E1-3) as the building blocks of that future plan, not a finished plan.

Back-filled from E1 IRO-1 (Section 11.3.1, pages 101-104), the report's topic-specific climate-risk-identification section. This disclosure requirement did not exist as a standalone code under the 2023 ESRS the report was prepared against.

Physical and transition risks were assessed using IPCC scenarios: "an optimistic climate change mitigation scenario (SSP1-RCP2.6), which corresponds to the 1.5 degree C target, and a pessimistic scenario (SSP5-RCP8.5), which describes a heavily fossil-dependent, growth-driven world", over short- (<1yr), medium- (1-5yr) and long-term (5-35yr) horizons, using TCFD categories (policy/legal, technology, market, reputation) for transition risk and UBA/EU Taxonomy-aligned site screening for physical risk. Data sources named include the DWD German Climate Atlas, the World Bank's Climate Change Knowledge Portal, the Aqueduct Water Risk Atlas and IPCC/IIASA scenario explorers. Climate scenarios "have not yet been formally integrated into financial planning."

Back-filled from E1 SBM-3 (Section 11.3.2, page 107), under the heading "Resilience of the business model in relation to climate change". This disclosure requirement did not exist as a standalone code under the 2023 ESRS the report was prepared against.

The resilience analysis used the same scope as the materiality assessment (own operations plus up/downstream value chain, no exclusions) and assessed each material climate risk on three dimensions: degree of impact, dependency, and existing/possible actions. "The outcome was that, overall, the strategy and business model are in a robust position with regard to the climate-related risks identified as material... No risks were identified that would fundamentally call into question the resilience of the business model or strategy." Remaining uncertainty is addressed by folding climate risks into Group-wide risk management.

Reference: page 108.

"There are currently no Group-wide policies specific to climate change in place since the focus in the reporting year was on calculating the carbon footprint... and developing climate targets." Policies are explicitly sequenced to follow the transition plan: "Policies related to the climate targets and transition plan will therefore be drawn up by 2027 as part of a subsequent process." This is a disclosed absence with a stated reason and timeline, not a silent gap.

Reference: pages 108-109.

Actions are "not yet part of an overarching strategy but have been initiated and implemented individually by individual entities" - consistent with the absence of a completed transition plan. Named examples: a transport-operator interface reducing visitor-travel emissions (21% of digital-ticket buyers chose the combined ticket); an electricity supervisor and about 43% certified green electricity at FKP Scorpio's Southside Festival; ISO 20121 sustainable-event-management certification for Rock am Ring/Rock im Park; LED retrofits at LANXESS arena (up to 43,000 kWh/year saved); a fully renewable-powered stage at Waldbühne Berlin; 2.2 MW of rooftop/car-park photovoltaic planned for ARENA MILANO; and ISO 14001:2015 certification at TicketOne. "As this report represents the base year, no quantitative emission reductions are reported yet."

Reference: pages 109-111.

"In 2025, CTS EVENTIM defined a binding target for reducing its GHG emissions for the first time": Scope 1 and Scope 2 emissions down 42% by 2030, against base year 2025. The target is "oriented to the minimum requirements" of SBTi for a 1.5 degree C-compatible pathway using an IPCC economy-wide pathway (no sector pathway exists for events), "will be pursued without using GHG removals, carbon credits or avoided emissions", and "did not undergo an external review by an auditor"; SBTi has "not yet conducted a formal validation process." The target "does not currently cover Scope 3 emissions." It was approved by the Executive Board and submitted to the Supervisory Board's Audit Committee.

Reference: page 111.

Total 2025 energy consumption was 31,865 MWh: fossil sources 29,117 MWh (91.4%), nuclear 120 MWh (0.4%), and renewables 2,628 MWh (8.2%, made up of 24 MWh renewable fuel, 2,491 MWh purchased renewable electricity/heat and 114 MWh self-generated). "CTS EVENTIM's business model does not include any activities in climate-intensive sectors" under Regulation (EU) 1893/2006. Consumption is based on about 75% primary data (utility-company information) and about 25% extrapolation from average per-employee consumption; the fossil/renewable/nuclear split uses supplier energy-mix data or, failing that, country grid-mix data, with DBEIS conversion factors.

Reference: pages 112-118.

Emissions are calculated under the GHG Protocol across Scope 1, location- and market-based Scope 2, and nine material Scope 3 categories (purchased goods and services; capital goods; fuel/energy-related activities; upstream transport; waste; business travel; employee commuting; downstream transportation - newly material this year; investments). Scope 3.8 and 3.10-3.14 are explicitly assessed and disclosed as not material, e.g. "CTS EVENTIM does not manufacture or sell any physical products that undergo high-emission or energy-intensive processing." An entity-specific visitor-mobility metric is also reported; a 2025 methodology change (primary event data replacing a literature-based modal split) restated the 2024 comparative "from 966,805 tCO2e to 505,483 tCO2e", and a calculation-logic error restated 2024 Scope 3.15 (Investments) "from 7,797 tCO2e to 21,668 tCO2e." Detailed per-scope figures sit in tables spanning pages 112-118.

Reference: page 118.

"In 2025, no greenhouse gases were removed and stored as part of projects within the Company's own operations or in the upstream and downstream value chain. Moreover, no climate change mitigation projects for reducing or removing GHG emissions outside of the value chain were financed by purchasing carbon credits." A nil return, consistent with the E1-4 target being pursued "without using GHG removals, carbon credits or avoided emissions."

Reference: page 118.

"CTS EVENTIM does not currently apply any internal carbon pricing schemes." The disclosure is a single-sentence nil return with no further elaboration on methodology, shadow price or internal fee, consistent with the Company's first-year, base-year position on climate reporting generally: quantitative climate-management tools such as this are still to be developed alongside the transition plan (see E1-1).

Reference: page 121.

"CTS EVENTIM does not currently have any Group-wide policies on resource use or waste management. Due to the diversity of CTS EVENTIM's area of business, responsibility currently lies with the local entities." Group-wide guidelines are intended "by the end of 2026", to be embedded in ESG management and overseen by the 2025-formed ESG Committee, covering "efficient use of resources, recycling and the avoidance of waste" in areas under the Company's operational control. A disclosed policy gap with a stated timeline, not a silent one.

Reference: pages 121-123.

Rather than one Group programme, individual promoters run tailored waste actions. Named examples: FKP Scorpio's festival waste-separation system since 2015 ("Trasholution"), donation of returned waste bags/sorted recyclables (EUR 37,051 across four festivals) and 355 donated camping items at Hurricane; LANXESS arena eliminating "approximately 1.5 million single-use cups and more than 845,000 plastic items per year"; OpenAir St. Gallen's reusable-cup system, tent deposit and a 16.8% cut in combustible residual waste; FSC-certified ticket paper and a cooperation to feed ticket-envelope packaging into Germany's dual recycling system under the EU Packaging Regulation.

Reference: page 123.

"CTS EVENTIM currently does not have Group-wide targets regarding resource use or waste management, as no sufficiently reliable data basis is yet available." The Sustainability Strategy plans to build that data basis - "systematic recording and analysis of recycling rates and... waste streams from selected events" - as the basis for future "specific, measurable and outcome-oriented targets for reducing the relative volume of waste generated," limited to venues under the Company's operational control.

Reference: pages 123-124.

Covers "Products and Materials": tickets are the main physical product, made mainly from paper - Fan Tickets are fully paper-recyclable; heat-sensitive thermal tickets are only partly recyclable. "In 2025, 71.1% of the paper tickets distributed by CTS EVENTIM were recyclable," and dispatch envelopes are "100% recyclable." The recyclability metric is based on "complete recording of all types of paper purchased for tickets", assuming purchased volume equals sold volume; coated thermal tickets are classed as fully non-recyclable. Durability, reuse and repair are addressed qualitatively: single-use tickets are "not... repairable as they are designed as a consumable, single-use product."

Reference: pages 125-126 (waste tables and methodology).

Total 2025 waste was 13,751.64 tonnes (20.29 t hazardous), split 314.03 t offices, 11,024.99 t events, 2,412.62 t festivals. Non-hazardous waste directed from disposal totalled 11,842.06 t against 1,889.29 t directed to disposal; hazardous waste was 20.29 t total. "The total amount of non-recycled waste amounts to 10,403.42 tonnes, which corresponds to a share of 75.65%." Roughly 68% of the total volume is extrapolated (63% for offices, 82% for events, 28% for the 12 festivals sampled), from records covering venues under operational control; "for office buildings and event venues in which CTS EVENTIM acts as a tenant, no own disposal data are available."

Reference: pages 134-135.

Anchored in the Group-wide Code of Conduct (updated in 2025) and a "Declaration of Principles on Respect for Human Rights" drawing on the UN Guiding Principles, ILO fundamental conventions and OECD Guidelines, and "therefore also includes the rejection of human trafficking." Two new Group-wide policies were signed off in 2025: an anti-discrimination policy and an occupational health and safety policy, both HR-owned and "currently being progressively rolled out." Implementation of human-rights due diligence sits with the Compliance Committee, which acts as LkSG Human Rights Officer. A global HR Policy sets talent management, remuneration and HR-reporting standards across entities.

Reference: page 135.

Set out in the global HR policy, with local implementation. In German Ticketing, dialogue runs through quarterly HR "Pulse Surveys", ongoing onboarding/exit surveys (evaluated semi-annually) and at-least-yearly talent-management reviews; results are published in the HR Hub and shared with the Executive Board. Vulnerable groups raised through these channels (e.g. women, migrants, pregnant employees, people with disabilities) "would be given special consideration where possible." A Group-wide employee suggestion scheme for sustainability ideas began its pilot phase at the end of 2025.

Reference: pages 135-136.

A Group-wide grievance mechanism plus the electronic Compliance Helpline whistleblowing system (anonymous reporting available, reviewed by an independent body) serve as the reporting and early-warning channels; "any retaliation or penalization of whistleblowers... will not be tolerated." Occupational health and safety incidents are additionally captured through local HR systems and, in larger entities, dedicated health and safety officers/committees, supported Group-wide by the new 2025 occupational health and safety policy.

Reference: pages 136-139.

Actions are mostly local and "not yet linked to specific policies or targets." Named examples: new feedback/performance-review mechanisms (rolled out to German Ticketing in 2025, other entities from 2026); communication of a management mission statement through onboarding and manager training; recruitment-process improvements tracked via "time to hire/recruit/fill" metrics and kununu feedback; diversity actions under the new anti-discrimination policy; health/wellbeing offerings including an external mental-health programme, office-ergonomics support and on-site vaccinations (Germany); and six-monthly-refreshed training and development programmes tied to individual performance reviews.

Reference: page 139.

"As 2025 represents CTS EVENTIM's first CSRD-compliant reporting year, the systems, processes and data bases required for target setting are still under development... CTS EVENTIM has not yet defined ESRS-compliant targets in financial year 2025." Effectiveness is tracked instead through Net Promoter Score and traditional HR metrics (sickness rates, turnover); HR sets yearly priorities and initiatives agreed with the CEO, reviewed every three to four months.

Reference: pages 139-141.

5,329 employees in FY2025 (2,971 Ticketing, 2,358 Live Entertainment; 2,618 in Germany). By gender: 2,559 male, 2,639 female, 4 other, 127 not specified. By employment type: 4,917 permanent, 412 temporary, 46 non-guaranteed-hours. Employee turnover was 20.42% (1,015 leavers), "extrapolated on the basis of 79% of the workforce." Country breakdown is a complete dataset; other metrics use ~79% primary data with the remainder extrapolated from the covered sample.

Reference: pages 141-142.

Top-management gender split (managing directors, VPs and department heads, 385 people): 279 male (72.4%), 86 female (22.4%), 20 not specified (5.3%). Age structure of the full 5,329-strong workforce: under 30 = 1,433 (26.9%); 30-50 = 2,995 (56.2%); over 50 = 901 (16.9%). Based on ~79% primary HR data with the remainder extrapolated from the covered sample; "S1-9 Diversity Metrics" became newly material for FY2025 (see ESRS 2 SBM-3), replacing S1-10 Adequate Wages.

Reference: pages 142-143.

"In the reporting year 2025, no fatal occupational accidents involving own or external employees were recorded." Recordable workplace accidents: 36, a rate of 4.66 per million working hours. "99.8% of the workforce is covered by a health and safety management system." Data is collected in full (not extrapolated) from entity reports for January-December 2025; the underlying working-hours denominator is estimated from country-specific average working days and a 40-hour full-time-equivalent week.

Reference: pages 143-144.

"In the reporting year, four complaints were submitted through channels that allow employees... to raise concerns. In addition, two incidents related to discrimination and harassment were reported" - all investigated with disciplinary and remedial action taken. "No further complaints related to human rights or working conditions were reported... through alternative external channels" (e.g. OECD National Contact Points), "no severe human rights incidents were identified", and no fines, judicial sanctions or compensation payments arose. Based on the Group whistleblowing system plus quarterly entity reports to Group Compliance.

Reference: pages 147-148.

Grounded in the Group Code of Conduct and the Declaration of Principles on Respect for Human Rights (UNGP/ILO/OECD-aligned), plus a new 2025 Supplier Code of Conduct setting "binding minimum standards relating to occupational health and safety, fair pay, working hours, freedom of association, non-discrimination and protection against child labour and forced labour", applicable to material direct suppliers. "During the reporting year, CTS EVENTIM did not become aware of any cases of non-compliance with these international standards in the upstream or downstream value chain." Monitoring (self-declarations, contractual provisions, random checks) sits with Compliance and Purchasing; the Compliance Committee acts as Human Rights Officer.

Reference: page 148.

CTS EVENTIM "conducted an analysis of the interests of potentially affected value chain workers" when designing the grievance mechanism, including checking access for marginalised or vulnerable groups (e.g. female workers, people with disabilities), which fed into the materiality assessment. "Beyond this, CTS EVENTIM has not yet established any other formalised process for engaging with value chain workers."

Reference: pages 148-150.

The same externally-operated Compliance Helpline whistleblowing system used for own-workforce grievances also serves value chain workers and their suppliers. Reports are reviewed by Group Compliance, investigated (internally or, if needed, externally) in confidence, and tracked through to remedial action or closure; the Supplier Code of Conduct requires suppliers to run their own channel or provide access to the Helpline. Effectiveness is reported to the Compliance Committee and Executive Board, with whistleblower protection governed by HinSchG and LkSG-aligned internal policy.

Reference: page 150.

A LkSG-based risk analysis covering the Group and its largest, most revenue-relevant suppliers identified country-, sector- and supplier-specific risk factors; findings fed into the new Supplier Code of Conduct, the Declaration of Principles on Respect for Human Rights, and internal health-and-safety/anti-discrimination principles. "Implementation measures are currently in preparation." The whistleblowing system is used to surface work-related incidents in the value chain; the Compliance Committee monitors effectiveness. "No severe human rights-related incidents were reported to CTS EVENTIM during the reporting year."

Reference: pages 150-151.

"The effectiveness of the existing concepts and actions is currently not subject to systematic tracking. Thus, CTS EVENTIM has not yet formulated any measurable, time-bound and outcome-oriented targets." A qualitative objective exists - continuing to review Group policies, expanding the Compliance Management System, training employees, and Group-wide rollout of the Supplier Code of Conduct - which the company intends to convert into measurable indicators "as the Sustainability Strategy is further developed."

Reference: pages 155-156.

The Declaration of Principles on Respect for Human Rights extends to consumers/end-users, backed by the Compliance Helpline as grievance channel; "in 2025, no cases linked to violations of the human rights of consumers and end-users were reported." Two named material policies: the Data Protection Group Policy (GDPR-based, Group-wide, annually reviewed) and event-specific visitor-safety policies, which in Germany must satisfy Model Assembly Venue Ordinance (MVStättVO) section 43 security-concept requirements before authorities issue an event permit.

Reference: pages 156-157.

Channels include pre-event mailings on postponements/cancellations/changes, call centres, email, social media, postal contact, self-service (help centre, FAQs, chatbot, "My EVENTIM" account) and an IVR phone system. In 2025 CTS EVENTIM introduced standardised Net Promoter Score and Customer Effort Score measurement in the German web shop after booking completion, plus structured customer interviews at early product-development stages. "These procedures are currently not yet designed as a systematic process for the targeted integration of the perspectives of particularly vulnerable customer groups", though such needs are addressed operationally (see S4-4).

Reference: pages 157-158.

Customer Service is the central remediation channel, with a multi-level escalation process (automated resolution, trained agents, and a specialist team empowered to offer reimbursement or goodwill vouchers for complex/escalated cases); volumes and resolution times are reviewed at least monthly. The Compliance Helpline whistleblowing system is explicitly kept separate from customer-service complaints "in order to avoid impairing the system's functionality with regard to tracking potential legal violations", though it remains available to ticket buyers/visitors for reporting suspected legal violations, with HinSchG-aligned anti-retaliation protection.

Reference: pages 158-162.

Actions include: review/removal of unlawful event-marketing content via a dedicated reporting channel under the EU Digital Services Act; vulnerable-group safeguards such as stroboscopic-light warnings; the Group Data Protection Management System (training, defined roles, annual review); cross-sector event-security coordination (e.g. the German "Festival" working conference and promoter security coordination groups); 2025 web-shop accessibility upgrades under the German Accessibility Strengthening Act (BFSG) - contrast, scalable content, alt text, screen-reader structure - with non-compliant promoter tickets to be delisted from 2026; and the Unity Ticket pilot at Highfield Festival 2025, offering EUR 49/EUR 29 reduced-price passes to people receiving German social benefits (SGB II/VIII/XII, AsylbLG).

Reference: page 162.

"ESRS-compliant targets relating to customer satisfaction are currently still under development." The 2025 rollout of standardised NPS/CES measurement in the German web shop is described as "the foundation for a systematic measurement of the customer experience", to be extended to other countries "in the coming year", with specific targets to follow once that data basis exists.

Reference: pages 165-168.

Corporate culture rests on an updated 2025 Code of Conduct covering leadership, equal opportunity, human/employee rights, conflicts of interest, data protection, environmental protection and whistleblowing channels. Governance runs through the Compliance & Sustainability department (reports to CFO), the new 2025 ESG Committee, a Compliance Committee (also the LkSG Human Rights Officer) monitoring serious-breach investigations, and local compliance coordinators. Three named policies address corruption: the Code of Conduct, an anti-corruption policy, and a Supplier Code of Conduct. The multilingual Compliance Helpline whistleblowing system supports anonymous reporting with HinSchG/EU Whistleblowing Directive-aligned protections.

Reference: pages 168-170.

The Compliance Management System centres on the Compliance Helpline, an externally-operated, multilingual whistleblowing channel open to employees and third parties, with no attempt made to identify anonymous whistleblowers and a "presumed innocent until proven" standard. A new mandatory Group-wide training, "Compliance & the CTS EVENTIM Code of Conduct" (about 20 minutes, case studies plus a test), began rollout in 2025; "risk-exposed functions are... covered 100%", and "44.6% of employees completed the training" in the reporting year. Target: "by 2030, 90% of its employees then employed will have received training on both the content of the Code of Conduct and the anti-corruption policy" (see G1-3-Targets).

Reference: page 169 (within Section 11.9.5, G1-3).

CTS EVENTIM states a concrete, dated business-conduct target under the G1-3 training discussion: "CTS EVENTIM has set itself the objective that, by 2030, 90% of its employees then employed will have received training on both the content of the Code of Conduct and the anti-corruption policy, including the whistleblower channels." Current progress against that target is 44.6% of employees having completed the newly-introduced mandatory training course in 2025, with "risk-exposed functions... covered 100%" already. G1-3 became a standalone DR only in the 2025/2026 ESRS; under the 2023 ESRS this content sits under MDR-T.

Reference: pages 170-171.

"In the reporting year, no cases of corruption or bribery were reported within the Company's own operations or across the upstream and downstream value chain. A corresponding nil report is available... Consequently, no fines were imposed." Collected via quarterly inquiries to subsidiaries plus the whistleblowing system, consolidated and plausibility-checked by Group Compliance. Preventive measures listed include the compliance organisation's monitoring role, mandatory Code of Conduct rollout, structured investigation procedures for incoming reports, and the LMS-based mandatory training, which in 2025 "covered entities representing approximately 49% of Group employees."