Daimler Truck

Reference: pages 77-78.

The Corporate Sustainability Board (CSB), comprising the Board of Management members of Daimler Truck Holding AG and Daimler Truck AG, meets at least twice a year and holds overall responsibility for sustainability, supported by working groups on climate and environmental protection, the circular economy, workforce issues, human rights, traffic safety and compliance. As of December 31, 2025, the Board of Management comprised seven members - five men and two women, a 28.6% female share (2024: 25%).

The Supervisory Board has 20 members elected in equal numbers by shareholders and by employees of the Group's German companies, with three women on each side (30% female representation, unchanged). All shareholder representatives are classified independent except Renata Jungo Brüngger and Harald Wilhelm; all employee representatives are independent except Barbara Resch, giving 85% overall independence. Required sustainability expertise is defined in requirements profiles consistent with the double materiality assessment, and the Board of Management reports to the Supervisory Board, usually quarterly, on strategic direction including environmental and social goals.

Reference: page 78.

The Board of Management reports to the Supervisory Board, usually once per quarter, on strategic direction, with environmental and social goals agreed jointly alongside long-term economic goals; sustainability topics discussed include corporate strategy, corporate planning, Board of Management remuneration and sustainability reporting. In developing the Company's five strategic pillars, the Board of Management and Supervisory Board considered sustainability impacts, risks and opportunities, including decarbonization of the product portfolio, development of locally CO2e-free solutions, efficiency and standardization, and responsible partnerships.

Key investment and cooperation decisions - for example on technology platforms, joint ventures and autonomous driving - considered climate and environmental impacts as well as social and governance aspects alongside market maturity and economic viability. Reporting to the Supervisory Board also covers the implementation of due diligence and the results and effectiveness of adopted guidelines, actions, metrics and targets, detailed in the Declaration of Due Diligence (page 156).

Reference: pages 78-79.

Board of Management remuneration consists of a fixed base salary (around 30-33% of target compensation), an annual bonus (around 29-30%) and long-term variable remuneration via the Virtual Share-based Equity Plan (VSEP, around 37-41%). For the annual bonus, financial criteria (Group EBIT and free cash flow of the industrial business, or segment EBIT where relevant) are weighted 75% and non-financial sustainability criteria 25%. The 2025 non-financial targets were "unit sales of locally CO2e-free vehicles" (20% weighting) and workplace accidents measured by the Lost Time Injury Rate (5% weighting).

For the 2025 VSEP tranche, the non-financial performance criterion is reduction of CO2e emissions, and from 2025 this covers both Scope 1 and Scope 2 (previously Scope 2 only). The percentage of variable target remuneration dependent on sustainability targets remains 25%; the percentage linked specifically to climate-related factors rose to 16% in 2025 (2024: 12%).

Reference: page 156 (Declaration of Due Diligence, table B.101).

The Declaration of Due Diligence maps the five core elements of due diligence to specific disclosures within the Group Sustainability Statement: (a) integration into governance, strategy and business model is covered under GOV-2 (page 78), GOV-3 (pages 78-79) and SBM-3 (page 87 for E1, 115 for S1, 132 for S2, 138 for S4); (b) involvement of affected stakeholders under GOV-2, SBM-2 (page 76), IRO-1 (page 82) and the MDR-P policy disclosures across each topical chapter; (c) identifying and assessing adverse impacts under IRO-1 (page 82, covering E1, E2, E5 and G1) and the equivalent process descriptions in the S1, S2 and S4 chapters; (d) taking action under the MDR-A action disclosures in each topical chapter; and (e) tracking effectiveness and communication under the MDR-M and MDR-T disclosures across the same chapters.

Reference: pages 79-80.

The risk assessment for the Group Sustainability Statement identified an overarching risk that incorrect, incomplete, inaccurate or incomprehensible non-financial data could be reported; given this, no separate comprehensive risk mapping was carried out for non-financial reporting, and the identified risk is instead mitigated through the existing reporting process and the Company's experience in integrated reporting. In 2024 a concept for a non-financial internal control system (ICS), consistent with the financial ICS, was developed to integrate CSRD requirements into the control framework.

Building on the double materiality assessment, central management controls were implemented in the reporting year covering material quantitative data points and control indicators. Human Resources, Environmental Management, Development and Procurement are responsible for implementing controls for the identified material impacts, risks and opportunities in their areas, and in 2025 the results of non-financial ICS management controls were reported to the Board of Management and the Supervisory Board.

Reference: pages 74-75.

Daimler Truck operates more than 40 production sites with over 100,000 employees, developing transport solutions for freight and passenger transport. The value chain runs from raw material extraction (iron, steel, aluminum, secured through long-term supplier relationships and audits) through own development, production, direct sales and financial services, to downstream sales, vehicle use and end-of-life recycling. Sustainability strategy is organized under "Planet", "People" and "Performance", aligned to the 17 UN Sustainable Development Goals.

The business strategy rests on five pillars: unlocking growth and efficiency (including expanding locally CO2e-free vehicles, India, construction/defense business, autonomous trucks and the ARCHION Japan joint venture); a customer solutions powerhouse; a modular technology approach balancing conventional and locally CO2e-free powertrains; a lean and effective organization (including the "Cost Down Europe" efficiency program); and a performance-oriented corporate culture built on "Simpler. Faster. Stronger." The Company targets locally CO2e-free new trucks and buses in Europe, the USA and Japan by 2039, worldwide by 2050, and net-zero CO2e at global production sites by 2039.

Reference: page 76.

Regular stakeholder dialogue informs the double materiality assessment, IRO management, strategy development and due diligence processes. The most relevant stakeholders are customers, suppliers, employees and investors; within the workforce, the works council and trade unions play a central role. The topics most frequently raised by stakeholders in the materiality process were the challenges of climate protection, fair working conditions, and the protection and respect of human rights.

Daimler Truck participates in associations and initiatives including econsense, the UN Global Compact and Hydrogen Europe to exchange views with civil society, business and political representatives, and advocate for technologies such as hydrogen propulsion. It is also a member of industry associations (Verband der Automobilindustrie, the Association des Constructeurs Européens d'Automobiles) and diversity initiatives (the Diversity Charter, the European Women's Management Development Network), participating actively in relevant working groups of these bodies.

Reference: page 83; summary table page 85.

The double materiality assessment confirmed seven areas of action as material: climate change, circular economy, our people, human rights and traffic safety are material from both the impact and the risk/opportunity perspective, while pollution and compliance are also identified as material. Relevant ESRS standards and topics were mapped to the material impacts, risks and opportunities, determining which ESRS data points are reported, with some entity-specific information added.

The Board of Management, in its role as the Corporate Sustainability Board, addresses these material impacts, risks and opportunities and assesses business-model resilience. "A formal resilience analysis was not conducted in the 2025 reporting year"; instead, strategy analyses supporting the five strategic pillars assessed resilience along the value chain, including scenario analyses of the ZEV strategy, after-sales business and the "Cost Down Europe" efficiency program. The identified material risks and opportunities had no effect on FY2025 financial position, performance or cash flow, and no material risk of adjustment to FY2026 carrying amounts was identified. The climate resilience conclusion is also presented under E1-3 (2025 ESRS numbering).

Reference: pages 82, 84.

The double materiality assessment ran in five phases: initial situation (internal/external documents, ratings, media, competitor information); mapping the value chain (nine internal and external stakeholder groups: customers, employees, suppliers, investors, networks and initiatives, scientific communities, associations, the Supervisory Board and the works council); stakeholder involvement (interviews and surveys); assessment and prioritization on a 1-5 qualitative scale for severity, scope, irreversibility and probability, with severity multiplied by probability against a materiality threshold of 15 out of a maximum 25; and validation with department heads.

A dedicated climate risk analysis (page 84) used time horizons of 2030, 2040 and 2050. Physical risk scenarios covered IPCC SSP1-2.6 (low), SSP2-4.5/SSP3-7.0 (middle) and SSP5-8.5 (high), drawing on IPCC, World Bank and WRI Aqueduct 2023 data; transition risk used NGFS pathways: Net Zero 2050 (1.4°C), Delayed Transition (1.7°C) and Current Measures (3°C). A conservative in-depth analysis of the high-warming physical scenario identified heat waves, water stress, forest fires, storms and floods in the medium term; the low-warming transition scenario identified low-carbon technology shifts and energy-price volatility. Water/marine, biodiversity and ecosystem screening found no significant IROs, so no further disclosure was required.

Reference: pages 150-155 (Notes to the chapter, tables B.91-B.100).

The Notes provide concordance tables listing all disclosure requirements of ESRS 2 and the seven thematic standards material for Daimler Truck, with page references, stating: "We have not taken into account all disclosure requirements of the thematic standards E3, E4 and S3, as these are below our materiality threshold." Where the Company does not yet have information on a disclosure requirement, no reference is provided in the tables.

Several data points are marked "Phase-in", including E1-9 (anticipated financial effects of climate risk), E2-6 (anticipated financial effects of pollution), E5-6 (anticipated financial effects of resource use), and S1-11, S1-12, S1-13 and S1-15 (social protection, persons with disabilities, training metrics and work-life balance metrics). Others are marked "Not material", including E2-4, E2-5, the E3 and E4 datapoints, S3, and G1-5 and G1-6. A separate table (B.99-B.100) cross-references individual EU-legislation-derived data points within each ESRS disclosure requirement to specific pages.

Reference: pages 91, 96.

Daimler Truck states it "is currently developing a Climate Transition Plan (CTP) ... and expect[s] to adopt it in 2027"; no CTP has yet been adopted. In the reporting year the Company made investments (CapEx) of EUR 507 million (2024: EUR 725 million) and research and development operating expenditure (OpEx) of EUR 1,348 million (2024: EUR 1,277 million) on projects across supply chain, production and product actions that reduce greenhouse gas emissions directly and indirectly, partly reflected in EU Taxonomy CapEx/OpEx metrics.

Existing targets underpinning the eventual plan include a 42% reduction in Scope 1 and 2 production-site emissions by 2030 versus a 2021 baseline (878 to 509 kt CO2e); carbon neutrality on the balance sheet at all production sites worldwide by 2039 (India, Japan and USA sites from 2025); and locally CO2e-free new trucks and buses in Europe, the USA and Japan by 2039, extending worldwide by 2050. The production targets were set without full consideration of specific scientific frameworks and were not validated against a science-based pathway.

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (page 84, climate risk analysis subsection). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

During the reporting year Daimler Truck "initiated a more in-depth climate risk analysis", systematically identifying and qualitatively evaluating physical and transition risks across own sites, key suppliers and central downstream locations, over 2030, 2040 and 2050 horizons. Physical risks were assessed using three IPCC-based pathways - SSP1-2.6 (low), SSP2-4.5/SSP3-7.0 (middle) and SSP5-8.5 (high) - drawing on IPCC, World Bank and WRI Aqueduct 2023 data. Transition risks used NGFS pathways: Net Zero 2050 (1.4°C), Delayed Transition (1.7°C) and Current Measures (3°C).

As "a conservative approach", the Company conducted an in-depth analysis of the high-warming physical scenario, identifying heat waves, water stress, forest fires, storms and floods as medium-term hazards, and of the low-warming transition scenario, identifying low-carbon technology shifts and energy-price volatility. Results feed into subsequent IRO materiality assessment and action development. The scenarios are stated to be compatible with the assumptions underlying Note 1 of the financial statements.

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (page 83). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Daimler Truck states plainly that "a formal resilience analysis was not conducted in the 2025 reporting year." In its place, the Board of Management, acting as the Corporate Sustainability Board, carried out comprehensive strategy analyses during the development of the Company's five strategic pillars to assess and strengthen resilience to external and internal challenges, including identifying and evaluating material risks and opportunities along the value chain from material costs to sales and after-sales service.

Scenario analyses were used to identify the impacts of potential crises at an early stage - for example in the ZEV (zero-emission vehicle) strategy, the after-sales business, or the effects of the "Cost Down Europe" efficiency program - and to develop contingency plans. The report states that the identified material risks and opportunities had no effect on financial position, performance or cash flow in the reporting year, and no material risk of adjustment to FY2026 asset or liability carrying amounts was identified.

Reference: page 88 (Master Policy Environmental Protection, table B.36).

The Master Policy Environmental Protection covers climate protection, climate change adaptation, resource preservation, energy efficiency, pollution prevention, water, waste, energy and hazardous-substance management, and biodiversity, applying to all employees and locations. A subordinate "expert policy on climate protection" sets out decarbonization targets and planned key levers, together with how Daimler Truck responds to physical and transition climate risks to strengthen resilience.

The policy's general objectives frame environmental protection and the pursuit of greenhouse-gas-emission neutrality as integral to the corporate strategy for long-term value creation, aimed at enabling locally CO2e-free transport. Compliance is monitored through the Company's environmental and energy management systems, including ISO 14001, ISO 50001 and EMAS certification with regular audits, and the policy is available to all employees via the central policy platform and the Group's public website.

Reference: pages 91-98.

Actions are organized across supply chain, production and product. In the supply chain, the CDP climate questionnaire covered 63.6% of planned 2025 production-material purchasing volume, and a site assessment covering around 2,000 suppliers of production material supports resilience against acute physical risks. In production, notable 2025 actions include wet-on-wet painting at the Neu-Ulm plant (saving about 700 MWh of power and 2,200 MWh of gas annually), an electric chassis painting system at the Santiago Tianguistenco plant in Mexico (saving about 4,000 MWh of gas and around 700 t of CO2e), commissioning of a 22 MWp photovoltaic system at the Halberstadt Global Parts Center, and site selection for the WärmeWerk Wörth geothermal joint venture. Installed photovoltaic capacity reached 64.6 MWp (2024: 40.6 MWp), generating 57.7 GWh (2024: 35.7 GWh).

In products, Daimler Truck had eleven locally CO2e-free truck and bus models in series production during the year, completed customer trials of five Mercedes-Benz GenH2 fuel-cell trucks covering over 225,000 km, and continued expanding the TruckCharge e-infrastructure offering.

Reference: pages 93-96.

Under "Green Production 2030", Daimler Truck targets an annual reduction of 592 GWh in production energy consumption by 2030 versus the 2013/2014 mean baseline (3,861 GWh), and an increase in renewable energy's share of production from 18% (2021) to over 55% by 2030, supported by a complementary 100% green-electricity-supply target by 2030 (78.1% in 2025) and self-generation of over 5% of electricity needs by 2030 (3.4% in 2025).

The headline CO2e target is a 42% reduction in Scope 1 and 2 production-site emissions by 2030 versus 2021 (878 to 509 kt CO2e), currently covering 88.3% of Group-wide Scope 1 and 2 emissions. By 2039, all production sites worldwide are targeted to be CO2e-neutral on a balance-sheet basis, with India, Japan and selected USA sites targeted from 2025. The report states that "specific scientific frameworks were not fully considered in setting the target," so the targets are not validated against a science-based pathway, though the Company references ESRS E1 AR28 for the comparable -42% reference value.

Reference: pages 94-95 (table B.43).

Total Group energy consumption was 3,295,790 MWh in 2025, down from 3,342,579 MWh in 2024. The renewable share of total energy consumption rose to 33.8% (2025) from 29.4% (2024), while the fossil share fell to 63.0% from 68.5%; nuclear-sourced energy accounted for 3.2% (2025). Renewable energy consumption, including purchased renewable electricity/heat/steam/cooling and self-generated non-fuel renewable energy, totaled 1,114,313 MWh Group-wide in 2025 versus 982,195 MWh in 2024.

Energy intensity in climate-intensive sectors (NACE codes C - manufacturing and G - trade, maintenance and repair of motor vehicles) was 72 MWh per million euros of net sales in 2025, up from 66 MWh per million euros in 2024. Currently, 78% of global electricity consumption and 40% of district heating consumption at production sites is sourced from renewable energy (2024: 70% and 12% respectively).

Reference: page 89 (table B.37).

Combined Scope 1 and 2 emissions at production sites fell to 497 kt CO2e in 2025 from a 2021 base year of 878 kt CO2e, a 43.4% reduction, already ahead of the 2030 target of 509 kt CO2e; Group-wide (entire Group, including extrapolated non-production sites) Scope 1 and 2 emissions were 563 kt CO2e in 2025 versus 630 kt CO2e in 2024.

Scope 3 gross significant indirect emissions fell to 323,402 kt CO2e in 2025 from 388,247 kt CO2e in 2024, driven mainly by category 3.11 (use of sold products), which fell to 305,957 kt CO2e from 368,818 kt CO2e amid significantly lower unit sales in 2025; category 3.1 (purchased goods and services) was 17,445 kt CO2e (2024: 19,429 kt CO2e). Total Group GHG emissions were 324,301 kt CO2e location-based and 323,965 kt CO2e market-based in 2025 (2024: 389,172 kt and 388,877 kt respectively). Market-based CO2e intensity was 6,560 t CO2e per million euros (2024: 7,191).

Reference: pages 96-97 (table B.46).

Daimler Truck does not disclose GHG removals; instead, it uses purchased carbon credits to offset residual Scope 1 and 2 emissions at selected production sites as "a transitional action towards CO2e-free production" on the path to its 2039 balance-sheet carbon-neutrality target. In 2025, 277,000 t CO2e of certificates were cancelled (2024: 246,000 t), 100% from reduction projects (none from extraction/removal projects) and 100% certified to the Gold Standard, with 0% located within the EU and 0% counted as a corresponding adjustment under Article 6 of the Paris Agreement.

Offsetting in 2025 covered European production sites, several other sites (Portland, Saltillo, Tramagal), and, newly since 2025, Japan; sites in India and elsewhere in the USA were not offset. All offset projects underwent independent external due diligence, and the Company states it is assessing partially shifting from voluntary offsetting toward investment in absolute emission-reduction projects.

Reference: page 97.

Daimler Truck states plainly that "during the reporting period we did not have an internal CO2 pricing system in place." To evaluate the potential effects of an internal carbon price (ICP) on emission sources along the value chain, the Company analyzed the effectiveness of various price levels using select pilot projects, and has developed a methodology and roadmap for structurally evaluating abatement costs within its decision-making processes.

This development work is intended to increase transparency around the evaluation of abatement costs and the effectiveness of greenhouse-gas-reduction actions, in support of the decarbonization strategy, but no operative internal carbon price, applicable price level or coverage scope is yet in place or disclosed.

Reference: page 99.

Pollution-related policy is anchored in the Master Policy Environmental Protection (table B.36, page 88), which sets Group-wide environmental guidelines aimed at continuous improvement in reducing pollutants and emissions, alongside compliance with legal regulations and the proactive development of products. The ultimate responsibility for preventing environmental and air pollution lies with the Board of Management acting as the Corporate Sustainability Board, supported by Group-wide environmental and energy representatives and cross-departmental committees, with implementation carried out by management representatives in segments, plants and central functions.

The Company states it "utilize[s] internal databases and licensed external sources of regulatory information" to track jurisdiction-specific emissions, on-board diagnostics, connectivity, autonomous driving, electric drive, noise, safety and diesel-quality regulations, feeding into vehicle development documentation that sets target values for fuel consumption and pollutant emissions for each model and engine variant.

Reference: page 99.

The single material pollution impact identified is that "the air emissions caused by our vehicles can harm the environment and affect human health" through particulate matter, nitrogen oxides and volatile organic compounds during the vehicle use phase. Actions focus on product development: compliance with applicable emissions legislation and the transformation to alternative drive technologies, which are described in detail in the E1 climate chapter's "Our targets, actions and key metrics" section, including battery-electric and hydrogen-based vehicles and digital fuel-efficiency services for diesel trucks.

The Company states it "currently do[es] not collect any company-specific metrics" on air pollutant emissions and applies the simplification available under ESRS 1 Article 133. No further quantitative pollution-reduction actions beyond the drivetrain transformation and legal-compliance focus are described.

Reference: page 99.

Daimler Truck has not set a quantified numerical target for air pollutant reduction. The report states directly: "We have not set any further quantitative targets" beyond compliance with legal emissions requirements and the ongoing transformation to alternative drive technologies. The Company's approach instead relies on the target values embedded in vehicle development documentation for fuel consumption and pollutant emissions per model and engine variant, and on the CO2e and product-portfolio targets disclosed under E1, which the pollution chapter cross-references.

No separate pollution-specific metric or trajectory is tracked outside of these development-stage target values, and the Company applies the ESRS 1 Article 133 simplification for company-specific pollution metrics generally.

Reference: pages 100-101 (Ecodesign Guideline, table B.50).

Resource efficiency and circular economy is governed by the Master Policy Environmental Protection, the Ecodesign Guideline, the Mandatory Contractual Clauses on Social Responsibility and Environmental Protection, and the Daimler Truck Business Partner Standards. The Ecodesign Guideline establishes a structured, binding process embedding ecological considerations across all vehicle development phases, focusing on ease of disassembly, complexity reduction, component consolidation and weight optimization, applied in the Mercedes-Benz Trucks and Daimler Buses segments and overseen by the heads of product development in each.

Circular economy governance runs through a cross-functional working group (environment, R&D, strategy, purchasing) organized across three phases - Creation, Production, and Product Use & End-of-Product - and applies the "8R" methods. Life cycle assessments follow ISO 14040/14044 and an internal LCA guideline, first TÜV-certified in April 2025 and recertified annually; in 2025 LCAs were carried out for the eActros 400, updated eActros 600, eCitaro G fuel cell and Citaro hybrid.

Reference: pages 102-105.

In the supply chain, Daimler Truck held several Supplier (Sourcing) Days during the reporting year to collect ESG criteria such as recycling requirements from suppliers and integrate them into selection and qualification. In production, waste-reduction actions included converting certain packaging from single-use to reusable, replacing wooden with steel load carriers on the Detroit-Mannheim and Kawasaki shipping routes, and rolling out "zero-waste to landfill" concepts, newly including Daimler India Commercial Vehicles by year-end. At Detroit Diesel Corporation, a requalification procedure was developed to recover cylinder heads previously scrapped for casting and machining defects.

In products, Ecodesign training courses were prepared for rollout, and remanufacturing expanded with series production of "Genuine Reworked Batteries" in Germany for first-generation eActros 300/400 and eEconic customers, plus battery repurposing analysis at Daimler Buses and Trucks North America, with a first power-grid connection planned for 2026.

Reference: pages 102-103 (tables B.52-B.53).

Daimler Truck targets an annual production-waste reduction of 41 kt by 2030 against the base year, using a level-based logic with a zero baseline, and a recovery rate above 95% at production sites by 2030; the 2025 recovery rate was 84.8% (2024: 85.5%). Targets follow the five-step waste hierarchy under Section 6 of the German Circular Economy Act (KrWG), prioritizing prevention, then preparation for reuse, recycling and other recovery.

As with the energy and CO2e targets, "specific scientific frameworks were not taken into account in setting the [waste] target"; site-specific characteristics and variable influencing factors were incorporated alongside a fixed reduction figure, and progress is tracked through the Green Production database, which documents implemented and planned waste-reduction actions and reports progress to management.

Reference: page 102.

Iron, steel, aluminum, plastic and natural rubber (tires) together make up around 95.4% of Daimler Truck's total materials used in vehicle production, calculated from planned purchase volumes for the reporting year. Total weight of products and materials used was 5,143,470 t in 2025 (2024: 5,911,980 t), of which 1,805,897 t (2024: 1,671,229 t) was secondary reused or recycled content - 35.1% of the total, up from 28.3% in 2024.

Secondary-material data is drawn from sources including the Sphera database, the World Steel Association, the International Aluminium Institute, the Joint Research Centre and information supplied directly by Tier 1 suppliers, with additional sources used for cross-checking and conservative estimation where needed. The Company notes that the growing production of battery-electric vehicles is expected to increase the future importance of rare earths and other critical raw materials.

Reference: pages 104-106.

Durability, repairability, upgradeability and recyclability are considered from the product-development stage. Group-level theoretical recyclability of the vehicles considered was 93.6% of total weight in 2025 (2024: 93.0%), calculated per ISO 22628 from LCA material data reviewed by TÜV and weighted across segments by production volume and drivetrain mix. No reliable industry benchmark exists for product durability; internal customer feedback on mileage, usage and repair frequency suggests durability broadly in line with industry norms, though this feedback is not collected comprehensively across all vehicles.

Spare-parts strategy begins in development, with interdisciplinary teams analyzing assemblies by design group to determine repair depth - for example, enabling separate replacement of a seat's armrests, backrests and covers rather than the whole assembly - informed by complaint analysis of vehicles already in use, so that repairs, including of complex electrical components such as high-voltage batteries, can be offered at the most resource-efficient level.

Reference: page 104 (table B.54).

Total waste generated in 2025 was 415.9 kt (2024: 442.2 kt), of which 155.7 kt was not recycled, representing 37.4% of the total (2024: 36.0%). Of the total, 356.2 kt was diverted from disposal Group-wide (2024: 380.6 kt) - comprising 4.7 kt prepared for reuse, 260.2 kt recycled and 91.2 kt in other recovery operations - while 59.8 kt was directed to disposal (2024: 61.5 kt), mainly 56.3 kt to landfill. Waste streams consist primarily of scrap metal, sand, sludge, waste oil, paper, plastics, textiles, packaging, batteries, tires, glass and waste electrical/electronic equipment.

Because suppliers are not legally obligated to report the final destination of non-hazardous waste, Daimler Truck applies a conservative approach, assigning waste of unknown treatment method to the next-lower recovery category pending greater data transparency, which the Company expects will improve reported recovery rates over time.

Reference: page 116 (Declaration of Principles, table B.61); also pages 122-123, 127, 130.

The Declaration of Principles on Social Responsibility and Human Rights, adopted with the general works council, the World Employees' Committee and industriAll Global Union in November 2022, commits Daimler Truck to human rights and good working conditions - rejecting child labor, forced labor and human trafficking, promoting equal opportunity and non-discrimination, and protecting health and safety at work - based on the UN Guiding Principles on Business and Human Rights and other international standards, with a Human Rights Compliance Management System and the SpeakUp whistleblowing system for redress.

Supporting policies covering the own workforce include the Rule Violation and Investigation Master Policy (page 122), the HR Compliance Master Policy (page 123), the Master Policy on Occupational Health and Safety (page 127) and the Global Compensation Master Policy (page 130), each applying Group-wide to Daimler Truck Holding AG, Daimler Truck AG and controlled Group companies and available to employees via the central policy platform.

Reference: pages 118-120.

Daimler Truck recognizes employees' rights to form representative bodies, to collective bargaining and to strike. At the international level, the European Works Council and World Employees' Committee, grouped under one roof, meet twice yearly (once virtually, once in person), currently representing 16 countries with 28 seconded representatives. During the reporting year, the "Cost Down Europe" efficiency program (targeting over EUR 1 billion in annual recurring cost reductions by 2030) was negotiated with the general works council, alongside a collective bargaining agreement with IG Metall including a redundancy ban until end-2034 and plant-preservation commitments.

The annual, Company-wide employee survey achieved 88% participation (2024: 85%), with overall satisfaction averaging 4.07 (2024: 4.06) and engagement 3.92 (2024: 3.86) on a five-point scale; results feed manager-led follow-up dialogue at team level.

Reference: pages 120-121 (table B.68).

The global SpeakUp whistleblowing system enables anonymous and non-anonymous reporting and investigation of potential rule violations and misconduct, including human rights concerns; Germany-based whistleblowers additionally have access to an external, neutral intermediary. In the reporting year 266 complaints were received (2024: 245), including seven discrimination cases (six sexual harassment, one racism): one was investigated with no violation found, five were confirmed after investigation, and one remained under investigation, with responses ranging up to extraordinary dismissal.

No cases of non-respect with the UN Guiding Principles on Business and Human Rights, the ILO Declaration or the OECD Guidelines were identified, based on internal review, and no significant fines, sanctions or damages were recorded (2025 and 2024: zero). Employees with remuneration objections may also raise them with managers, HR or the works council under state law and collective agreements.

Reference: pages 118-131.

Actions span the material impacts and opportunities identified for the own workforce (table B.60, page 115). Employer-branding and recruiting activities under the "You make us" campaign target digital and technology skills, alongside FEMTEC partnerships and a Company-wide agreement on recruiting severely disabled trainees (48.7% of 2025 trainees were women). Diversity, equity and inclusion actions include the DEI Advisory Board chaired by the President & CEO, eight Company-wide employee networks, the "She@Truck" women's advancement program, and the mandatory "Inclusion in Mind!" e-learning module for all managers.

Health and safety actions include the "WE CARE ABOUT US" initiative pursuing Vision Zero, newly published "Life Saving Rules", 172 ISO 45001-certified sites, and periodic due-diligence audits (seven sites evaluated in Mexico, South Africa and the USA in 2025). Remuneration actions include salary review rounds and a mandatory minimum-wage compliance survey across all controlled companies.

Reference: pages 125-126, 128.

Daimler Truck aspires to increase the proportion of women in management positions (levels 1-4), a goal developed with employee representative input and agreed by the Board of Management and Supervisory Board, tracked via table B.72/B.73 (women held 16.2% of top management levels 1-2 in 2025, versus 15.5% in 2024).

The Company's health and safety target is to reduce the Company-wide Lost Time Injury Rate (LTIR), pursued through prevention measures, training, safety-oriented leadership and digital safety solutions, also developed with employee representative input and agreed by the Board of Management and Supervisory Board. Progress on both targets is regularly evaluated against HR and accident-management reporting systems and compared by the Board of Management, though neither target carries a numerical percentage or target year in the disclosed text.

Reference: page 117 (tables B.62-B.64).

Total headcount was 108,476 at December 31, 2025 (2024: 111,415), of whom 90,125 were male, 18,308 female and 43 not reported. By country, Germany accounted for 37,763 employees, the USA 16,240, Japan 10,419, with the remainder spread across other countries; Mexico headcount was not reported separately for 2025 (2024: 11,023). By employment type, 105,325 employees were full-time and 3,151 part-time; the metrics are based on headcount of all persons with an active fixed-term or permanent contract, including senior managers, trainees, interns and employees on maternity or long-term sick leave.

External workers - primarily temporary and agency workers under NACE code N78 - are counted separately by headcount but not broken down in the same tables.

Reference: page 120 (table B.67).

Employees in the European Economic Area (EEA) are covered by several collective agreements, with the coverage rate at 94.7% in the reporting year (2024: 96.0%). For Germany specifically - the only country individually disclosed, at over 50 employees and more than 10% of the workforce - collective bargaining coverage was 96% and social dialog coverage was 98%.

Table B.67 presents both coverage rates using the ESRS-prescribed banded scale (0-19%, 20-39%, 40-59%, 60-79%, 80-100%) for the EEA overall and for qualifying countries individually. The 2025 collective bargaining agreement negotiated with IG Metall (page 119), including a redundancy ban until end-2034, illustrates the social-dialog channel in practice.

Reference: page 126 (tables B.73-B.74).

Gender distribution in top management (levels 1 and 2) was 83.8% male and 16.2% female in 2025 (198 total; 2024: 84.5% male, 15.5% female of 207 total). By age band, 19.9% of the 108,476-strong workforce was under 30, 53.9% between 30 and 50, and 26.2% over 50 in 2025 (2024: 20.5%, 53.8% and 25.6% respectively).

Diversity is managed under seven Diversity Charter dimensions - age, ethnic origin and nationality, gender and gender identity, physical and mental abilities, religion and ideology, sexual orientation and social background - overseen by the DEI Advisory Board, chaired by the President & CEO, meeting quarterly and supported by a global DEI network and regional councils.

Reference: page 131.

"All Daimler Truck employees receive fair remuneration in accordance with the applicable reference values." The Center of Competence for Compensation runs an app-based global survey during the annual income review, covering 100% of total headcount, under which local HR departments verify minimum-wage compliance and confirm findings via a questionnaire; deviations trigger further investigation, with both the local HR department and the Center of Competence jointly reviewing outcomes to ensure no employee is paid below the applicable minimum wage.

The Global Compensation Master Policy (table B.78, page 130) requires that remuneration be based on job requirements, knowledge, skills, responsibility and individual performance, rather than gender, origin or other personal characteristics, with market-positioning guidelines supporting sustainable and competitive salary development Group-wide.

Reference: page 129 (table B.77).

38.4% of the workforce (41,632 employees) worked at an ISO 45001-certified site in 2025, up from 32.3% (35,995 employees) in 2024. There was 1 fatality resulting from work-related injury among employees in 2025 (2024: 0), with no fatalities among external workers or Temporary Employment Agency workers in either year, and no fatalities due to work-related disease in either year.

The number of recordable work-related accidents was 1,831 in 2025 (2024: 1,891), with the Lost Time Injury Rate at 9.3 per million hours worked (2024: 9.4). Restricting the scope to work-related accidents specifically, 1,334 cases were recorded (2024: 1,354) at a rate of 6.8 (2024: 6.8). Extrapolation logic based on OSHA accident indicators is applied to smaller locations representing at most 10% of total employees, and the metric excludes commuting accidents.

Reference: page 131.

The unadjusted gender pay gap, based on average gross hourly wage, was -5% "to the detriment of male employees" in 2025 (2024: -15%), with the Company attributing both the direction and the year-on-year change primarily to a switch in methodology to actual gross salaries and recorded hours, and to the disproportionate representation of men in lower-paid, production-related roles. The metric was collected via a global survey covering over 95% of the workforce, using a December 1, 2025 cut-off date and local taxable gross salaries.

The annual total compensation ratio - the President & CEO's total compensation relative to the median employee (excluding the highest-paid individual) - was 74 times in 2025, down sharply from 185 times in 2024, reflecting both a change in CEO and the departure of the Company's previously highest-paid employee.

Reference: pages 120-121 (table B.68).

266 complaints were received via reporting channels in 2025 (2024: 245), plus seven cases of discrimination, sexual harassment or racism (2024: 3): six were sexual-harassment-related and one racism-related, with five confirmed after investigation, one investigated with no violation found, and one still under investigation at year-end. No significant fines, sanctions or damages were recorded, and zero severe human rights cases (such as forced labor, human trafficking or child labor) were identified in either 2025 or 2024.

Based on internal review, "there is no case that can be considered a non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises." Personnel measures taken in 2025 included extraordinary dismissals, one final warning and one separation agreement, with affected employees offered social counseling.

Reference: page 134.

Policy for workers in the upstream value chain rests on the Declaration of Principles on Social Responsibility and Human Rights, supplemented by the Supplier Compliance Due Diligence Expert Policy (table B.81, page 134), the Daimler Truck Business Partner Standards, the Mandatory Contractual Clauses on Social Responsibility and Environmental Protection, and the Rule Violation and Investigation Master Policy. These draw on the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, ILO core labor standards, and the German Supply Chain Due Diligence Act (LkSG).

The Supplier Compliance Due Diligence policy governs an annual risk assessment of all direct suppliers, with substantiated-knowledge assessment extending to indirect suppliers, to identify and preventively address supply-chain risks; it is monitored and approved by purchasing functions, with sanctions screening handled under a separate compliance process.

Reference: pages 132-133.

The double materiality assessment included suppliers as external stakeholders through surveys, finding "no evidence that there are particularly vulnerable groups" among workers in the supply chain. During the reporting year Daimler Truck participated in two roundtables organized by the German Helpdesk for Business and Human Rights on metallic raw-material procurement and transport/logistics working conditions, and in a project with industriAll Global Union, IG Metall and social partners addressing employee and trade union rights in Türkiye.

Truck drivers from transport-logistics suppliers were surveyed anonymously on working conditions at the Mannheim, Neu-Ulm and Kassel German production sites, through membership in the Responsible Trucking Initiative; results indicated trust in reporting channels "can generally be further strengthened", and the survey is being rolled out to other European production sites.

Reference: pages 133-134 (table B.80).

Workers in the value chain can report potential rule violations, including human rights and environmental breaches, via the SpeakUp whistleblowing system, the World Employee Committee of Daimler Truck, or industriAll Global Union. In 2025, 17 cases affecting value chain workers were reported (2024: 15) - 13 upstream and 4 downstream. All 13 upstream cases were resolved: nine investigated with no violation found, one closed after preliminary review, and three confirmed (withholding of adequate wages, disregard of trade union rights, unequal treatment), addressed through measures such as wage settlement and supplier engagement in a multi-stakeholder trade-union initiative.

Of the four downstream cases, three closed (two with no violation found, one confirmed unequal-treatment case addressed with training and awareness programs). No cases of non-respect with the UN Guiding Principles, ILO Declaration or OECD Guidelines were identified.

Reference: pages 135-137.

Supplier due diligence under the German LkSG applies a two-step risk analysis: an abstract risk profile of direct suppliers based on location and use of critical raw materials, followed by in-depth assessment via supplier questionnaires for high-risk suppliers, with ad hoc analysis of indirect suppliers where evidence of violations emerges. Identified risk areas in 2025 included occupational safety and health, withholding of adequate wages, freedom of association, forced labor, security-force conduct and environmental impact, with an elevated forced-labor risk flagged for China, Indonesia, India, Türkiye and the United Arab Emirates.

For critical raw materials (notably lithium, cobalt, nickel and graphite), three-step supply chain assessments create transparency, identify risk hotspots and define mitigation measures. In 2025, 76.2% of planned production-material procurement volume came from suppliers holding a Sustainability Assessment Questionnaire (SAQ) rating, and the Company participates in the Responsible Minerals Initiative, Drive Sustainability and the Responsible Supply Chain Initiative (RSCI) audit program.

Reference: page 135.

Daimler Truck states directly: "We have not currently set any measurable targets regarding human rights in the upstream value chain." Instead, management relies on process-based mechanisms - binding supplier requirements, screenings and audits under the Human Rights Compliance Management System - to increase transparency about potential negative impacts and to work toward respect for human rights, including labor and social standards, and environmental protection standards along the upstream value chain.

Effectiveness in the absence of numerical targets is tracked through the annual effectiveness review of the Human Rights Compliance Management System's programs, processes and measures, conducted in the same manner as for other compliance areas, and through metrics such as the 76.2% SAQ-rated procurement coverage and the case-resolution statistics reported under S2-3 and S2-4.

Reference: page 140.

Beyond the Product Compliance Management System (PCMS) policy (table B.83, page 141), consumer- and end-user-related human-rights commitments are set out in the Declaration of Principles on Social Responsibility and Human Rights and the Daimler Truck Code of Conduct. The PCMS supports regulatory compliance, including product safety and product liability, throughout the product life cycle from creation through production, distribution, in-use operation and decommissioning, applying to all Group companies except Daimler Truck Financial Services, and is monitored annually for design, implementation and effectiveness.

Cross-functional committees examine potentially safety-relevant field issues through a three-stage process, with a senior-level committee determining whether recalls or other field actions are needed; recalls are published via the EU's "Safety Gate" and reported to affected customers and authorities in line with product liability and market surveillance obligations.

Reference: page 140.

The double materiality assessment included transport operators as external stakeholders through surveys, sharpening understanding of the risk of harm to drivers, passengers and other road users, and finding that no consumer or end-user group is particularly affected in terms of risk severity. Ongoing engagement channels include Mercedes-Benz commercial vehicle centers across Germany, the "My TruckPoint" digital customer portal, the annual Customer Focus Day, market research studies spanning drivers through fleet decision-makers, and "Truck Clinics" where drivers test new products and provide direct feedback that is routed to relevant development teams.

Consumer feedback and market research are conducted both nationally and internationally, across individual and fleet customer structures, to obtain neutral, structured input on customer satisfaction, vehicle usage and new product concepts.

Reference: page 140.

Customers and potential customers - including transport companies and drivers - can raise concerns directly via the Mercedes-Benz commercial vehicle centers, email, the "My TruckPoint" portal, or the Group-wide SpeakUp whistleblowing system, which is governed by a Group-wide policy balancing proportionality for those affected against protection for the whistleblower. Business partners are required, via the Business Partner Standards, to provide equivalent channels and are informed of SpeakUp through the compliance awareness module.

The report acknowledges a gap: "there is currently no systematic assessment of whether all consumers and end users are aware of and trust the whistleblowing system SpeakUp to report misconduct, raise concerns and have them investigated," identifying an area for future improvement in channel-awareness monitoring.

Reference: pages 141-142.

Actions center on active and passive safety systems within the "integral safety" concept spanning four phases - safe driving, in case of danger, in the event of an accident, and post-accident assistance. In 2025, the updated Advanced Driver Assistance Systems package rolled out to the Cascadia platform in the USA and the newly introduced Actros ProCabin, meeting European General Safety Regulation requirements; the "Connected Traffic Warnings" V2X system extended to the Actros and Arocs series in Europe. A total of 97 vehicles were used worldwide from 2022-2025 for safety-system testing and validation, covering over seven million kilometers.

Autonomous-driving development continued with Torc Robotics and Innoviz on short-range LiDAR sensors for the Freightliner Cascadia, targeting SAE Level 4 long-haul applications, and the Coretura software-defined-vehicle joint venture with the Volvo Group was announced during the reporting year.

Reference: page 139.

Daimler Truck aligns its ambition with external frameworks - the EU's "Vision Zero" goal of no road fatalities by 2050, and the UN/WHO "Decade of Action for Road Safety" (2021-2030) target of a 50% reduction in traffic fatalities and injuries by 2030 - but states plainly: "We have not set any further ESRS-compliant targets at this time" beyond continuing to optimize advanced driver-assistance and safety systems.

In the absence of a numerical Company target, effectiveness is tracked through theoretical and practical testing of safety-system interventions (such as emergency braking and lane-keeping assistants), endurance and test-track runs, simulation-based verification, and over 50 years of accident research analyzing real-world heavy-commercial-vehicle accidents in Germany to inform system development priorities.

Reference: pages 79, 81, 144-147.

The Daimler Truck Code of Conduct (table B.31, page 81), revised in 2025, sets binding rules on respecting human rights, complying with laws, avoiding conflicts of interest, prohibiting corruption, protecting company assets and handling data, built around four "Purpose Principles": "We start with listening", "We build to solve", "We lead with the long view", "We progress together". It applies to all employees of Daimler Truck Holding AG, Daimler Truck AG and controlled companies, is available in twelve languages, and is reinforced through the Compliance Master Policy and Compliance Management System (CMS) headed by the Chief Legal and Compliance Officer, reporting to the President & CEO.

Corporate culture is fostered through the "Impact Culture" concept and employee survey feedback on whether unethical behavior is addressed openly and on trust in the SpeakUp whistleblowing system, which underpins transparency and open communication Group-wide (table B.86, page 145).

Reference: pages 147-149.

The Daimler Truck Business Partner Standards (table B.89, page 148) set expectations for suppliers and other business partners on human rights, good working conditions, environmental protection and compliance, publicly available and reinforced through Mandatory Contractual Clauses on Social Responsibility and Environmental Protection (table B.90, page 149). Suppliers are expected to communicate these standards to their own employees and value chain and to check compliance regularly.

For production-material purchasing, a sustainability rating based on the Sustainability Assessment Questionnaire (SAQ) is a mandatory criterion above a threshold order value (contract value over EUR 1 million and supplier annual turnover over EUR 15 million), applied to both new and existing suppliers, particularly when new locations or volumes are introduced. A two-stage risk-based due diligence process - initial IT-system risk assessment followed by in-depth questionnaires for high-risk suppliers - supports ongoing monitoring, supplemented by a supplier-facing compliance awareness module.

Reference: pages 146-147.

Daimler Truck's compliance program aims to "prevent, detect and combat corruption, bribery, and fraud as far as possible in all business activities," reviewing business partners and transactions with particular care in dealings with authorities and public officials. The Transparency International Corruption Perceptions Index is a key parameter in risk evaluation, with elevated corruption risk identified in sales activities in high-risk countries and in relationships with authorized dealers, general agents and suppliers worldwide; standard compliance contract clauses require business partners to maintain anti-corruption procedures.

Training is central to prevention: the Basic Training Module on the Code of Conduct, covering corruption prevention among other topics, reached 43,146 administrative employees in 2025 (2024: 42,922), with additional Expert Modules for Marketing & Sales (10,277 participants) and Procurement (1,951 participants), and an Executive Module for Corporate Governance (97 participants); high-risk functions had 100% training coverage in both 2025 and 2024.

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; the FY2025 statement was prepared under the 2023 ESRS.

Daimler Truck's own concordance table (page 156) cross-references MDR-T content for E1, E2, E5, S1 and S2 but does not list a G1-specific MDR-T reference, and no numerical business-conduct target (such as a corruption-incident reduction percentage) is stated in the G1 chapter (pages 144-149).

Effectiveness is instead tracked through monitoring metrics: "the proportion of high-risk functions covered by training programs is 100% (2024: 100%)" (page 147), and the Company reports that "no convictions (2024: 0) or fines (2024: 0) related to violations of anti-corruption or anti-bribery laws and regulations were recorded" during the reporting year (page 146). These compliance-training-coverage and zero-incident metrics function as the periodic monitoring measure in place of a stated numerical target.

Reference: pages 146-147.

"During the reporting year, no convictions (2024: 0) or fines (2024: 0) related to violations of anti-corruption or anti-bribery laws and regulations were recorded." This zero-incident outcome is supported by the Company's compliance training program (table B.88, page 147), which covers corruption prevention across the Basic Module - Daimler Truck Code of Conduct, the Expert Modules for Marketing & Sales and Procurement, and the Executive Module for Corporate Governance, each requiring repetition every three years or upon transfer into a higher-risk role.

The proportion of high-risk functions covered by anti-corruption training was 100% in both 2025 and 2024. Reporting and escalation processes for suspected corruption run through the SpeakUp whistleblowing system, with results made available to relevant governance committees.