Daimler Truck

The Corporate Sustainability Board (CSB), made up of the Board of Management members of Daimler Truck Holding AG and Daimler Truck AG, is the central management and decision-making body for sustainability, meeting at least twice a year under the Chairwoman. As of December 31, 2024 the eight-member Board of Management comprised six men and two women, so 25% women. The Supervisory Board monitors and advises the Board of Management on sustainability topics. Its 20 members are elected half by shareholders and half by employees, with three women on each side, giving 30% women overall. Eight of ten shareholder representatives (80%) were classified as independent. Required sustainability expertise is defined in requirements profiles consistent with the double materiality analysis. Both boards have experience in North America, Europe and Asia. The Group Sustainability Management department coordinates working groups covering climate, circular economy, workforce, human rights, traffic safety and compliance.

The Board of Management reports to the Supervisory Board, usually once per quarter, on the strategic direction of the Group and its segments, taking into account long-term economic, ecological and social goals. The Supervisory Board monitors and advises on sustainability aspects of corporate strategy, corporate planning, Board of Management remuneration and sustainability reporting. In 2024 the Board of Management addressed the material impacts, risks and opportunities identified in the double materiality analysis and discussed the selection and validation of strategically relevant ESG control indicators, prioritized by materiality, strategic ambition and benchmarking. The working groups drew up an initial set of ESG targets, with more planned for 2025. At least twice a year the working groups inform the CSB and other committees, including the Audit Committee, the Disclosure Committee and specialist committees, about material impacts, risks and opportunities, with a focus on implementing due diligence and assessing the effectiveness of policies, actions, key figures and targets.

The Board of Management remuneration system consists of non-performance-related fixed and performance-related variable components. Fixed base salary contributes around 25 to 35%, the annual bonus around 20 to 34%, and long-term variable remuneration around 35 to 50% of target total compensation. Non-financial performance criteria linked to sustainability are anchored in the variable remuneration, with criteria set by the Supervisory Board and derived from corporate strategy. Financial criteria based on EBIT and free cash flow are weighted 75% of the annual bonus, while non-financial criteria are weighted 25%. In 2024 the short-term criteria covered unit sales of locally CO2e-free vehicles (20%) and general employee wellbeing (5%). The 2024 VSEP tranche uses relative share price development against the MSCI World Industrials Index (75%) plus CO2e emission reduction from production and the proportion of female managers at levels 1 to 4. The share of variable target remuneration linked to sustainability is 25%; climate-linked remuneration was 12%.

Daimler Truck presents its statement on due diligence in the Declaration of Due Diligence, table B.87, in the Notes to the chapter Sustainability at Daimler Truck. The table maps the core elements of the due diligence process to where they are disclosed across the sustainability statement. Integration of due diligence into governance, strategy and business model is covered under ESRS 2 GOV-2, GOV-3 and SBM-3. Involvement of affected stakeholders in all important steps is covered under GOV-2, SBM-2, IRO-1 and MDR-P. Identification and measurement of negative impacts is covered under IRO-1 and topic-specific sections for S1, S2 and S4. Measures to counteract negative impacts are covered under MDR-A across E1, E2, E5, S1, S2 and S4. Tracking the effectiveness of efforts and communication is covered under MDR-M and MDR-T. Details on fulfilling the Group's due diligence are also referenced from the sustainability governance section.

The Group-wide risk and opportunity management system is integrated into planning, control and reporting processes, and sustainability aspects are integrated into it. Material risks and opportunities from the double materiality analysis were compared with this system. The Group Risk Management Committee (GRMC) is responsible for developing and assessing the appropriateness and effectiveness of the system. The internal control system (ICS) aims to ensure appropriate and effective accounting-related reporting. Risk assessment for the Group Sustainability Statement identified the overarching risk of reporting incorrect, incomplete, inaccurate or incomprehensible non-financial data, so no comprehensive risk mapping was carried out; the risk is mitigated by the existing reporting process and experience in integrated reporting. In 2024 a concept for a non-financial ICS consistent with the financial ICS was developed, introducing new central management controls covering key quantitative data points and control indicators. From the 2025 reporting year the results of the non-financial ICS will be reported regularly to governance committees, including the Board of Management and Supervisory Board.

As one of the world's leading manufacturers of commercial vehicles, Daimler Truck aims to develop sustainable transport solutions for goods and people. It focuses on environmental, social and governance topics, guided by the UN 17 Sustainable Development Goals. A long-term corporate goal is to lead the technology transformation to enable CO2e-free transport on the roads by 2050, offering battery-electric and hydrogen-powered trucks and buses that are CO2e-free in operation. From 2039 the company plans to offer only vehicles that are CO2e-free during operation in Europe, Japan and the USA. The value chain covers all processes from raw material extraction to the end consumer. The upstream value chain includes procurement of raw materials and components from a global supplier network plus transport and logistics; main materials include iron, steel and aluminum. Own activities focus on vehicle development, production, direct sales and complementary services such as maintenance, repair and financial services. Downstream activities include sales, product use and end-of-life recycling.

Daimler Truck maintains constant dialogue with stakeholders to understand their viewpoints, concerns and expectations, feeding insights into sustainability initiatives, projects and processes and into due diligence. The most relevant stakeholders include customers, business partners, employees and investors. Within the workforce, the works council plays a central role in sustainability management, representing and promoting workforce interests. Exchange with politics, media and society also plays an important role, including direct dialogue with political decision-makers and involvement in associations, committees and initiatives such as the UN Global Compact, econsense, Hydrogen Europe, the VDA, ACEA, the Diversity Charter and the European Women's Management Development Network. The viewpoints of key stakeholders on strategy and business model were analyzed as part of the double materiality analysis. The most frequently mentioned topics include the challenges of climate protection, fair working conditions, and the protection and respect of human rights. Input received at formats such as the International Motor Show (IAA) is incorporated into the continuous revision of strategy.

The double materiality analysis confirmed the focus topics of the sustainability strategy and identified seven areas of action as material. Climate change, circular economy, the team, human rights and traffic safety are assessed as material from both the impact and the risks and opportunities perspectives, while pollution and compliance are also identified as material. Environmental impacts and risks in ESRS E1, E2 and E5 are closely linked to strategic efforts to decarbonize transport, driven through a product portfolio of CO2e-free vehicles. A possible risk is that slow expansion of CO2e-free vehicle infrastructure could hinder unit sales, requiring a new skilled workforce strategy affecting the workforce and society, reflected in S1, S2 and S4. In the reporting year the identified material risks and opportunities had no current financial effect on financial position, performance and cash flow, and no material adjustment risk to 2025 carrying amounts was identified. The Board of Management, acting as CSB, examines these factors and assesses business model resilience; a formal resilience analysis was not carried out in 2024.

The double materiality analysis considers the ESRS principles and was conducted in five phases. Phase 1 identified relevant sustainability topics using internal and external documents such as the Annual Report, international ESG standards, regulations, ESG ratings, media reports and competitor information. Phase 2 mapped the value chain, involving internal experts and integrating external stakeholders; nine internal and external stakeholder groups were identified, including customers, employees, suppliers, investors, networks and initiatives, science, associations, the Supervisory Board and the works council. Phase 3 involved stakeholders through interviews and qualitative surveys to prioritize impacts, risks and opportunities. Phase 4 assessed and classified impacts, risks and opportunities using qualitative scales from 1 to 5; severity of impacts considered extent, scope, irreversibility and likelihood, while risks and opportunities considered potential financial extent and probability. Severity or extent multiplied by probability gave a score, with results of 15 or higher defined as material. For potential negative human rights impacts, severity takes precedence over likelihood. Phase 5 validated results with relevant department managers.

The Notes list all disclosure requirements of ESRS 2 and the seven thematic ESRS standards that are material for Daimler Truck and were used to prepare the Group Sustainability Statement, with tables showing where information is located, including information included by reference. The material thematic standards are E1 climate change, E2 pollution, E5 resource use and circular economy, S1 own workforce, S2 workers in the value chain, S4 consumers and end-users, and G1 business conduct, alongside ESRS 2 general requirements. Not all disclosure requirements of the thematic standards E3, E4 and S3 were taken into account, as these are below the materiality threshold. Where no information is yet available for a disclosure requirement, no reference is provided. Several individual data points are marked as not material or phase-in. The index provides page references for each disclosure requirement, and a separate table lists data points arising from other EU legislation.

Daimler Truck describes a climate protection and climate change adaptation strategy built around a dual-track approach of battery-electric and hydrogen-based drive technologies, aiming for locally CO2e-free freight and passenger transport by 2050. It reports a green production 2030 initiative covering Scope 1 and 2 reductions. The company states it is currently working on a Climate Transition Plan (CTP) that takes into account short and long-term climate risks and opportunities and, in addition to Scope 1 and 2, includes strategic decarbonization targets for Scope 3 emissions, aligned with the climate-related disclosure requirements of EFRAG ESRS E1. It plans to adopt the CTP in 2027. Daimler Truck acknowledges its current climate transition strategy does not yet fully meet ESRS requirements. Scope 3 reduction targets are to be defined as part of the future CTP. In the reporting year the company made CapEx investments of 725 million euros and R&D operating expenditure of 1,277 million euros for related measures.

Daimler Truck reports several policies addressing climate protection and climate change adaptation. The central instrument is the Corporate Environmental Protection Policy, which covers climate protection, climate change adaptation, resource preservation, energy efficiency, prevention of pollution, water, waste, energy and hazardous substances management. It sets out six environmental guidelines and states that pursuit of greenhouse gas emission neutrality is an integral part of corporate strategy. The policy applies to all employees and managing body members of Daimler Truck Holding AG and all controlled Group companies. Compliance at production sites is monitored through environmental and energy management systems including ISO 14001, ISO 50001 and EMAS, with German sites required to be EMAS certified. Other relevant policies include the Daimler Truck Code of Conduct, the Business Partner Standards and the Daimler Truck Special Terms. The company states it is developing a comprehensive climate policy to be integrated into the existing Corporate Environmental Protection Policy, connected with the planned CTP.

Daimler Truck reports climate actions focused on three areas: product development, supply chain and production. In product development it advances battery-electric and hydrogen vehicles, launched series production of the Mercedes-Benz eActros 600 (over 600 kWh battery, around 500 km range), operates Battery Technology and eDrive Technology Centers, and pursues LFP battery cells through the Amplify Cell Technologies joint venture. In the supply chain it uses the Sustainability Assessment Questionnaire and CDP questionnaire, and is electrifying inbound logistics, targeting fully electric delivery traffic to the Woerth plant by end of 2026. In production it relies on energy efficiency, renewable energy and technological actions. Completed reporting-year actions include a heat pump at the Kawasaki plant (around 3,700 MWh and 700 t CO2e saved per year), ventilation optimization at Woerth (around 2,700 MWh and 460 t CO2e), and HVAC upgrades at Aksaray (around 1,300 MWh and 230 t CO2e). Around 40.6 MWp of photovoltaic capacity is installed worldwide, generating 35.7 GWh in 2024. Reporting-year CapEx was 725 million euros and R&D OpEx 1,277 million euros.

Daimler Truck reports a Group-wide target to reduce Scope 1 and Scope 2 emissions of all production sites by 42% by 2030 compared with 2021, corresponding to a reduction from 878 ktCO2e to 509 ktCO2e. This combined target covers 90% of Group-wide Scope 1 and 2 emissions in the reporting year. The Board of Management adopted the targets in 2022, and they were not validated against a scientific pathway. Under green production 2030 the company aims to cut production-related energy consumption by around 590 GWh by 2030 (from a 2013/2014 average of 3,861 GWh), reduce energy consumption per vehicle by 16% by 2030, and source at least 55% of energy used from renewables by 2030. Production sites in India and Japan are expected to reach CO2e balance-sheet neutrality from 2025, the USA is also targeted, and all production sites worldwide should be carbon-neutral on the balance sheet by 2039. Scope 3 reduction targets are to be defined within the future Climate Transition Plan.

Daimler Truck reports total energy consumption for the entire Group of 3,342,579 MWh in 2024 (3,084,539 MWh for measured production sites). Consumption from fossil sources was 2,284,233 MWh, or 68.3% of the total, including natural gas (1,477,469 MWh), purchased fossil electricity, heat, steam or cooling (444,096 MWh), crude oil and petroleum products including LPG (348,266 MWh) and coal products (13,219 MWh). Consumption from nuclear sources was 76,151 MWh, or 2.3%. Total energy consumption from renewable sources was 982,195 MWh, or 29.4%, comprising purchased renewable electricity, heat, steam and cooling (947,191 MWh) and self-generated non-fuel renewable energy (35,004 MWh). The company states it currently obtains 70% of its electricity and 12% of its district heating from renewable sources, and produced 35,747 MWh of renewable energy and 503,026 MWh of non-renewable energy during the year. Energy intensity in climate-intensive sectors (NACE codes C and G) was 66 MWh per million euros.

Daimler Truck discloses gross Scope 1, 2 and 3 emissions for 2024, applying a financial control approach supplemented by operational control per ESRS and the GHG Protocol. Figures are in 1,000 t CO2e. Total Scope 1 and 2 emissions were 630 for the entire Group (568 for production sites), down 35.3% from the 878 base year 2021. Scope 1 gross emissions were 389 for the Group (349 production sites), with 23.4% from regulated emission trading schemes. Scope 2 location-based was 536 and market-based 241 for the Group. Total significant Scope 3 emissions were 388,247, comprising purchased goods and services (3.1) at 19,429 and use of sold products (3.11) at 368,818. Total GHG emissions were 389,172 location-based and 388,877 market-based. This is the first year Daimler Truck reports Scope 3, using secondary data. Market-based CO2e intensity was 7,191 t CO2e per million euros (location-based 7,197). Biogenic Scope 3 emissions from use of products sold were 2,561,018 t CO2e.

Daimler Truck reports that it does not undertake GHG removals within its own operations or value chain, but offsets remaining Scope 1 and 2 emissions through carbon credits as a transitional action toward CO2e-free production. Since 2022 the company has produced in a CO2e-neutral manner at its European production plants and selected other locations, with compensation expanded to CO2e from reporting year 2023. In 2024 remaining Scope 1 and 2 emissions were offset at European production sites and some other locations through qualified climate protection projects. All offset projects meet the Gold Standard Foundation quality standards, with independent external due diligence for each project. Per table B.38, CO2 certificates cancelled in the reporting year totalled 246 thousand t CO2e, of which 100% were reduction projects (0% extraction projects), 100% Gold Standard, 0% within the EU, and 0% counting as a corresponding adjustment under Article 6 of the Paris Agreement. The deletion for fiscal year 2024 was executed in February 2025.

Daimler Truck reports that it currently has no internal CO2 pricing systems in place. However, the company states it is investigating the implementation of an internal carbon price (ICP). To evaluate the potential impact of an ICP on various emission sources along its value chain, it has retrospectively analysed the effectiveness of various price levels using selected pilot projects. In addition, the company is developing a methodology and a roadmap for the structural evaluation of abatement costs within its decision-making processes. Daimler Truck states this evaluation serves to achieve greater transparency around the selection of emission reduction measures and thereby strengthens its decarbonization strategy.

Daimler Truck bases its environmental policy on the environmental policies laid down in its Environmental Protection Directive and commits to an integrated improvement process. Through these policies the company strives for continuous improvement towards freedom from pollutants and emissions. Beyond the basic requirement of compliance with legal regulations, proactive and continuous development of products is a priority. 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 operational implementation by management representatives in the segments, plants, and central functions. The company has established the Truck Regulations Compendium, a reference work covering the most important global regulations on exhaust emissions, on-board diagnostics, connectivity, autonomous driving, electric drive, noise, safety, and diesel quality.

Daimler Truck focuses on reducing and ideally avoiding air pollution caused by its vehicles during the use phase, treating actions and innovations in product development as crucial. Product development plays a key role because a vehicle's environmental impact and pollutant emissions are largely decided in the early development stages. The company uses documentation that accompanies the development process, defining certain properties and target values for each vehicle model and engine variant, for example for fuel consumption or pollutant emissions. These target values are used to assess progress during product development and, if necessary, to initiate corrective measures. Legislators worldwide have adopted increasingly strict emissions standards for hazardous substances such as nitrogen oxides and particulate matter. Further actions on alternative drive technologies and increasing the efficiency of diesel trucks through digital products are reported in the climate protection chapter.

For the prevention of environmental pollution, Daimler Truck states that its focus is on compliance with legal requirements and the transformation to alternative drive technologies. The company reports that it has not set any further quantitative targets in this area. Product development is treated as central, with target values defined for fuel consumption and pollutant emissions for each vehicle model and engine variant used to track progress, but these are not framed as standalone quantitative pollution reduction targets. Actions relating to alternative drive technologies and to increasing the efficiency of diesel trucks through digital products are described in the climate protection and climate change adaptation chapter rather than as separate pollution targets.

The Corporate Environmental Protection Policy covers resource use and circular economy and sets environmental guidelines for reducing the use of primary raw materials and promoting recycled materials. The Group policy stipulates closed material cycles in production and the reduction of waste, addressing the positive material impact of increasing resource efficiency, waste prevention and reduction. Daimler Truck plans to introduce an Ecodesign Guideline built around three areas: extension of use, reducing resource consumption, and recyclability. Sustainability clauses in supplier contracts demand binding environmental standards, including reduced energy, water and waste, and require production-material suppliers to hold a certified environmental management system under ISO 14001, EMAS or comparable standards. Daimler Truck Special Terms require recycling service providers and partners to implement resource-saving recycling processes. The company follows the five-stage waste hierarchy of Section 6 of the German Recycling Management Act (KrWG).

Daimler Truck applies 7-R methods and uses life cycle assessments (LCAs) as the basis for its circular economy actions, with LCA data quality assured by TUV under ISO standards. Actions span redesign, remanufacture, repair, reuse, recycling, repurpose and recovery. The Genuine Remanufactured Parts brand reconditions used engines and transmissions. Used Mercedes-Benz trucks up to five years old with a maximum 500,000 kilometers can earn the Mercedes-Benz Trucks Certified label. Battery repurposing includes a stationary storage system exceeding 500 kWh at an eCitaro customer in Hanover. Recycling improvements include separate disposal of copper and cable sheath. Regional examples include Mitsubishi Fuso in Kawasaki, a green steel model truck in Europe, and a Neu-Ulm sorting pilot. At Gaggenau, UV paint overspray is collected and reused as recyclate, with almost 100% reusable. In 2024 the company introduced the Green Mover Award for environmental projects.

Daimler Truck has set a target to reduce the amount of waste at its production sites by around 40 kt and by around 12% per vehicle by 2030 compared with 2013/2014. The company notes this waste target contributes to its prevention strategy but does not yet fully meet ESRS requirements, and that specific scientific frameworks were not taken into account when setting it. It also targets a recovery rate of more than 95% at production sites by 2030; in 2024 the recovery rate was 86%. Progress is tracked using the green production database. Through the 7-R methods the company pursues a circular product design ensuring durability, repairability and recyclability to close material cycles and reduce its ecological footprint. Daimler Truck states it aims to define further targets to address the identified material impacts, risks and opportunities.

Daimler Truck reports that its main materials are steel, iron and aluminum, used in vehicle production and forming a fundamental component of its products. With the increasing production of battery-electric vehicles, the importance of rare earths and critical raw materials is expected to increase. The total weight of the products, plus the technical and biological materials used during the reporting period, is 5,911,980 t. Of this, 1,671,229 t are the absolute weight of secondary reused or recycled components, secondary intermediates and secondary materials, corresponding to 28.3% of the total weight. The total weight was calculated based on planned purchase volumes in the reporting year. Secondary material metrics are estimated using industry averages and data from the World Steel Association, the International Aluminium Institute and the Raw Material Information System. The main materials analyzed account for 84% of the total materials.

Daimler Truck's core products, trucks and buses, are designed for durability, reusability and repairability. The recyclability of the products considered at group level is 93% of the total weight, based on a theoretical calculation because the actual recycling rate varies significantly by region. Recyclability is calculated from the material data in the vehicle LCAs in their delivery state, critically reviewed by TUV, using ISO 22628 as the methodological approach, with segment values weighted by production figures and the ratio between diesel and alternative-drive vehicles. No reliable industry data exists for comparing product durability, but internal assessments assume durability is in line with the industry average. Spare parts determination begins in product development, where assemblies are divided into substructures and a repair depth is defined so damaged components can be replaced in a targeted way. Repairs increasingly extend to complex electrical components such as the high-voltage battery.

A total of 442.5 kt of waste was generated in the reporting year. Of this, 158.2 kt was not recycled, corresponding to 36% of total waste generated. The waste mainly contains aluminum, steel, sand, plastic, oil, cardboard, waste wood, paint, electronic waste, textiles and glass. Non-hazardous and hazardous waste is generated at all production sites. For the entire Group, total waste diverted from disposal was 380,665 t, including 5,318 t prepared for reuse, 284,345 t recycled and 91,002 t in other recovery operations. Waste directed to disposal totaled 61,841 t, comprising 2,400 t incineration, 58,380 t landfill and 1,061 t other disposal. Hazardous waste totaled 105,386 t and non-hazardous waste 337,119 t. The Group recovery rate was 86%, and 85% at production sites, against a target of more than 95% by 2030. Figures exclude construction waste and excavated soil. Daimler Truck North America and Mercedes-Benz do Brasil operate zero-waste-to-landfill concepts.

Daimler Truck describes several policies governing its own workforce. The Declaration of Principles on Social Responsibility and Human Rights, adopted by the Board of Management together with the general works council, global employee representation and IndustriALL Global Union in November 2022, sets out commitments to reject child and forced labor, promote equal opportunities, protect health and safety, and support education and training. It is based on the UN Guiding Principles on Business and Human Rights and is publicly available in more than ten languages. Further policies include the Policy on Occupational Health and Safety, the Violation and Investigation Policy governing the SpeakUp procedure, the HR Compliance Policy, the Global Compensation Policy, and Company agreements covering advancement of women, inclusion, fair treatment, health protection, remuneration and pensions. The Code of Conduct reinforces the commitment to respect human rights. Policies apply to Daimler Truck Holding AG and all controlled Group companies and are available to employees via the central policy platform.

Daimler Truck engages its workforce through elected employee representatives and trade unions, recognizing the right to form representatives, to collective bargaining and to strike. At international level the European works council and World Employees' Committee meet twice a year, once virtually and once in person, currently representing 16 countries with 28 representatives sent. In the European Economic Area, agreements provide for representation through a European works council or works councils of a Societas Europaea or Societas Cooperativa Europaea. The annual Group-wide employee survey is a key engagement tool; participation rose to 85% (2023: 82%) among over 100,000 employees, with general satisfaction averaging 4.06 on a five-point scale. Managers are encouraged to discuss results with their teams and derive actions, with the follow-up process scoring 3.91 (2023: 3.83). The Board member for HR is responsible for all forms of employee involvement mentioned.

Daimler Truck operates a global whistleblowing system called SpeakUp for anonymous and non-anonymous reporting and investigation of potential violations and misconduct. The Company regularly surveys the workforce on awareness of and trust in the system and carries out communication measures to support transparency. Where a violation is identified, remedial actions are determined and implemented taking into account proportionality and fairness. Depending on severity, remedial measures may lead to termination of employment and criminal charges, and those affected are offered social counseling. For units with an increased risk of discrimination, a diversity representative is appointed so that potential cases can be effectively addressed and, where necessary, remedied by a local contact person. Employees can also raise remuneration concerns, such as unequal treatment, with their manager and involve the HR department or the works council. The Violation and Investigation Policy maps the SpeakUp procedure and responsibilities.

Actions addressing material impacts, risks and opportunities relate to four areas: corporate culture and talent acquisition, qualification and development, diversity, equity and inclusion, and occupational safety and health protection. The employer campaign "You make us" was established globally in 2024. Employees have free access to LinkedIn Learning with over 24,000 web-based courses in 13 languages, and Udemy Business was added in October 2024. Qualification actions are organized in five clusters, and leadership programs include "DTR0CKs" and the Emerging Leaders Journey. The Impact Compass performance and development system was rolled out worldwide to clerk level. DEI actions include seven company-wide networks, the mandatory "Inclusion in Mind!" module, and the She@Truck women's advancement program; 47.5% of new hires in trainee programs were women. Occupational safety and health actions include the "WE CARE ABOUT US" initiative pursuing Vision Zero, risk assessments, a Health & Safety Wiki, and health checks.

At the end of the reporting year, the proportion of women in management positions (levels 1 to 4) was 20.5% (base year 2022: 18.6%). Daimler Truck aspires to increase the proportion of women in management positions to 25% by 2030, complying with local laws, regulations and restrictions that may apply. This aspiration was developed together with the responsible departments, with input from employee representatives, and agreed with the Board of Management and the Supervisory Board. Progress in the proportion of women, determined from HR reporting systems, is regularly evaluated and compared by the Board of Management. The Company also states that it aims to define further targets to address the identified material impacts, risks and opportunities. Certification-related aims include increasing ISO 45001 coverage, with the Ligny, France location scheduled for certification in 2026, intended to reduce accident rates.

As of December 31, 2024, Daimler Truck employed 111,415 people measured by headcount. By gender, there were 92,753 male, 18,617 female, zero other, and 45 not reported. By contract type, 104,919 were permanent employees and 6,496 were temporary employees, with no non-guaranteed-hours employees. By region, Europe had 52,891, North America 29,358, Asia 18,111, Latin America 9,046, Africa 1,742 and Australia 267. By country, Germany accounted for 38,277, the USA 18,106, Mexico 11,023 and Japan 10,632, with the remaining 33,377 elsewhere. By age, 20.5% were under 30, 53.8% between 30 and 50, and 25.6% over 50. During the reporting year 7,583 employees left the Company, giving a turnover rate of 7.4%. The employee definition covers active fixed-term or permanent contracts, including senior managers, part-time, trainees, interns and those on maternity or long-term sick leave. Business activities create jobs in 30 countries.

Daimler Truck employees in the European Economic Area are covered by several collective agreements. The proportion of employees covered by collective agreements in the EEA is 96%. For Germany, which has more than 50 employees and represents more than 10% of the workforce, collective bargaining coverage falls in the 80 to 100% band at 97%, and social dialogue coverage is 99%. The collection of data for countries outside the EEA will only be carried out and taken into account from the reporting year 2025. The Company recognizes the right of employees to form employee representatives, to collective bargaining to regulate working conditions and to strike under applicable law, and works in a spirit of trust with elected employee representatives and trade unions. In companies bound by collective agreements, such as Daimler Truck AG, additional rights arise for employees, including the ability to object to notified pay groups and access to remuneration regulations and pay tables.

At the end of the reporting year, the proportion of women in management positions (levels 1 to 4) was 20.5%, up from 18.6% in the base year 2022. In top management (levels 1 and 2), there were 207 people in total: 175 male (84.5%) and 32 female (15.5%), with zero recorded as other or not reported. By age, 20.5% of employees were under 30 years, 53.8% between 30 and 50 years, and 25.6% over 50 years. Diversity is promoted across seven diversity dimensions: age, ethnic origin and nationality, gender and gender identity, physical and mental abilities, religion and ideology, sexual orientation and social background. In current Group-wide recruiting, 47.5% of new hires in trainee programs in the reporting year were women, and there is particular focus on training young people with disabilities. Gender figures are based on employees' own statements.

The key figure on fair wages was collected from subsidiaries that together represent 95% of the total headcount. Daimler Truck states that all employees receive fair remuneration in accordance with applicable reference values. The Center of Competence for Compensation introduced an app to ensure global transparency on minimum wage data and legal requirements. As part of the annual salary review, this department conducts a mandatory global survey via the app at all companies controlled by Daimler Truck, and the local HR department verifies the information and completes the questionnaire to confirm compliance with minimum wage laws. In the event of deviations, further investigations are initiated. Both the local HR department and the CoC for Compensation jointly review the feedback to ensure that no employees are paid below the minimum wage. Work is compensated across all Group companies worldwide according to the same principles set out in the Global Compensation Policy.

In the reporting year, 14 locations of majority-owned companies were certified according to ISO 45001, including the Daimler Buses sites in Neu-Ulm and Mannheim. The number of employees working at a site with ISO 45001 certification was 35,995, representing 32.3% of the total workforce, with the scope expanded to all employees and locations worldwide per ESRS specifications. There were zero fatalities from work-related injuries (employees, foreign workers and temporary employment agency workers) and zero fatalities due to work-related diseases. Recordable work-related accidents numbered 1,891, a rate of 9.4. Recordable work accidents according to the Lost Time Injury Rate numbered 1,354, a rate of 6.8, defined as accidents resulting in at least one day of absence per one million hours of attendance. Figures exclude commuting accidents, and an OSHA-based extrapolation is applied to smaller locations covering at most 10% of employees. Occupational health and safety relies on a holistic management system and the Vision Zero prevention approach.

The analysis of earnings differences covered 37 entities with a total of around 106,000 employees, including permanent, fixed-term, interns, students and trainees. For the gender pay gap and total compensation figures, an estimate was made based on data from over 94% of the global workforce. Using average gross hourly wages, the unadjusted gender pay gap is -15%, to the detriment of male employees. As a manufacturing company with a high proportion of production employees, whose jobs are generally classified lower than administrative or academic positions, the gap favors female employees mainly because men disproportionately work in production-related areas where remuneration tends to be lower. The total annual compensation of the highest-paid individual, the CEO of Daimler Truck, is 185 times the median total annual compensation of employees (excluding the highest-paid individual), determined using the CEO's total remuneration compared against the worldwide employee median.

In the reporting year 2024, three cases of discrimination were reported in the SpeakUp whistleblowing system: one in the category of sexual harassment, one racism and one reputational damage. The Company decides on appropriate measures based on proportionality and fairness; personnel measures in 2024 included extraordinary dismissals and warnings. In addition to these cases, 231 further complaints related to potential human rights violations within the own workforce were reported through SpeakUp. No significant fines, sanctions or damages were imposed for these cases and complaints. One severe human rights incident was identified within the own workforce, defined as a corporate-relevant case closed with merit relating to defined human rights categories. This does not constitute a case of non-respect of 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, and no fines, sanctions or damages were imposed.

Daimler Truck has established policies, standards, and processes for fulfilling its human rights due diligence obligations in the upstream value chain. The Declaration of Principles on Social Responsibility and Human Rights forms the basis for its commitment, particularly regarding value chain workers. Policies are based on international standards including the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, the ILO core labor standards, and the German Supply Chain Due Diligence Act (LkSG) in force since 2023. Additional relevant documents include the Supplier Compliance Due Diligence Policy, the Daimler Truck Business Partner Standards, the Mandatory Contractual Clauses on Social Responsibility and Environmental Protection, and the Violation and Investigation Policy. The Supplier Compliance Due Diligence Policy ensures a comprehensive annual risk assessment for all direct suppliers, prioritizing respect for human rights, environmental standards, and anti-corruption. It is published in the Policy Navigator, the uniform policy management system, and is reviewed as part of the annual effectiveness evaluation of the compliance management system.

Daimler Truck seeks dialogue with potentially affected stakeholders and exchanges ideas with workers, their interest groups, and civil society. Inclusion of upstream value chain workers' perspectives is managed by the Human Rights and Public Law department, coordinated with Sustainability Management and Purchasing. Suppliers were included as external interest groups through surveys during the double materiality analysis. In June 2024, an exchange took place between the Human Rights Officer and technical experts with employee representatives, trade unions, and non-governmental organizations, focused on actual and potential negative impacts in the upstream value chain. In November 2024, the company took part in a workshop with automotive industry stakeholders in Turkiye, launched by IndustriALL Global Union and IG Metall, to deepen dialogue on workers' and trade union rights. Truck drivers from transport logistics suppliers at the Holysov (Czech Republic) and Gaggenau (Germany) sites took part in an anonymous survey on working conditions and awareness of complaint mechanisms, conducted through the Responsible Trucking Initiative and to be rolled out gradually at all European production sites.

Through the SpeakUp whistleblowing system, internal and external whistleblowers as well as value chain workers can report potential rule violations and misconduct, including human rights and environmental violations, and demand remediation worldwide. When a report relating to value chain workers is received, the SpeakUp team forwards it to the responsible department within Legal and Compliance for review and investigation. Suitable measures include dialogues with suppliers to develop concepts for ending or minimizing violations, and external supplier audits, with business decisions taken to address confirmed negative impacts. Workers can also report to the World Employee Committee of Daimler Truck or the IndustriALL Global Union. During the reporting year, 14 cases were reported through SpeakUp involving value chain workers, twelve relating to the upstream and two to the downstream value chain. Seven related to withholding an adequate living wage, two to occupational health and safety, three to discrimination, one to trade union rights, and one to hazardous waste. None were classified as a severe human rights incident.

Management of material impacts on upstream value chain workers lies with specialist purchasing functions, including the annual risk analysis for direct suppliers and associated preventive and remedial measures. Supplier due diligence relies on binding requirements, screenings, audits, and qualification measures. A two-step risk analysis under the German LkSG first generates an abstract risk profile of direct suppliers using indicators such as location and use of critical raw materials, then subjects high-risk suppliers to an in-depth analysis using questionnaires. Ad-hoc analysis is carried out deeper in the value chain when there is actual evidence of violations by an indirect supplier. Particular focus is placed on suppliers of batteries containing critical raw materials such as lithium, cobalt, nickel, and graphite, with three-step supply chain assessments. The company conducted audits, requested certificates for mines and smelters, and offered training including the Expert Module Human Rights Compliance and Expert Module Compliance@Procurement. It participates in initiatives including the Responsible Minerals Initiative, Drive Sustainability, the Responsible Trucking Initiative, and RSCI audits, and held a Supplier Summit 2024 with 200 suppliers.

Daimler Truck states that it has not currently set any measurable targets regarding human rights in the upstream value chain. The activities and measures it applies to manage material impacts on value chain workers, including supplier due diligence, preventive and remedial measures, are regularly reviewed for suitability and effectiveness and adjusted where necessary. The annual effectiveness review of programs, processes, and measures that form part of the Human Rights Compliance Management System is carried out in the same way as for other compliance areas, supporting continuous improvement even in the absence of quantified targets.

For traffic safety, Daimler Truck understands consumers and end users to be drivers, passengers, road users in public traffic, transport companies and their employees, consignors and recipients of transported goods, companies and public institutions with transport activities, and rescue workers. Its commitment to respect human rights regarding consumers and end users is set out in the Declaration of Principles on Social Responsibility and Human Rights and in the Code of Conduct. The Product Compliance Management System (PCMS) is governed by a dedicated policy describing the core elements of the product-related compliance management system implemented by the Board of Management to ensure regulatory compliance of products, including product safety and liability, throughout the entire product life cycle from development through decommissioning. The PCMS policy references applicable market-specific laws, regulations, and automotive standards such as ISO standards, undergoes an annual monitoring process, applies to all Group companies except Daimler Truck Financial Services, and is available to all employees via the central policy platform.

Daimler Truck treats dialogue with customers as an opportunity to improve its systems and actions. Customers can visit Mercedes-Benz commercial vehicle centers across Germany or communicate concerns via email or the digital customer portal My TruckPoint for Mercedes-Benz Trucks. The company offers formats including product events for fleet drivers and dialogue platforms such as IAA Transportation 2024 in Hanover. It conducts market research studies with professional institutes across different customer structures, from drivers and purchasing decision-makers to individual and fleet customers, nationally and internationally, to obtain neutral, structured opinions on customer satisfaction, vehicle usage, and new product concepts. It regularly holds Truck Clinics where drivers test new products and provide direct feedback. As part of the double materiality analysis, transport operators were included as external stakeholders through surveys, which showed no consumers or end users are particularly affected in terms of severity of risk. Relevant information is provided to appropriate departments for consideration in projects and products.

All customers and potential customers affected by Daimler Truck's activities, such as transport companies or drivers, can file a complaint via the SpeakUp whistleblowing system. Through its Business Partner Standards, which every business partner must accept, the company explicitly points out the availability of SpeakUp and notes that business partners must also provide corresponding channels. Suppliers and sales partners are informed about the Compliance Awareness Module for SpeakUp. A group-wide policy regulates the procedure and responsibilities for the whistleblowing system, aiming to ensure a fair and transparent approach that balances proportionality for those affected with protection of the whistleblower. The company states that there is currently no systematic assessment of whether all consumers and end users are aware of and trust SpeakUp. Separately, the Product Compliance Management System operates a three-stage process in which cross-functional committees examine safety-related issues on vehicles in the field, and a high-ranking committee decides on field measures such as recalls, with affected customers and authorities informed and recalls published in the EU Safety Gate.

Daimler Truck develops safety systems following the integral safety concept across four phases: safe driving, preparing for a possible accident, protecting during an accident, and post-accident assistance. Active safety and assistance systems include Active Brake Assist and Preventive Brake Assist that detect pedestrians and cyclists, Active Side Guard Assist and Active Side Guard Assist 2, Active Drive Assist 3, and Active Brake Assist 6. In the reporting year it introduced a revised Active Safety package meeting GSR Directive (EU) 2019/2144, including a rear-view camera and close-range monitoring, and the Connected Traffic Warnings system using V2X communication on the eActros 600. From 2020 to end of 2024, 97 Daimler Truck vehicles were tested worldwide, covering more than eight million kilometers before customer use. Passive safety includes airbags, seat belt tensioners, and high-rigidity cabins. Accident research has been conducted for over 50 years. The company is developing SAE Level 4 autonomous trucks aiming to enter the US market in 2027, and provides rescue guidelines, driver training, and awareness programs.

Daimler Truck references the European Union Vision Zero aim of no road fatalities by 2050 and the United Nations and WHO Decade of Action for Road Safety (2021 to 2030) goal of reducing traffic-related fatalities and injuries by 50% by 2030. As a truck and bus manufacturer, it underlines its ambition to increase traffic safety and contribute to Vision Zero through a comprehensive traffic safety concept and continuous development of new safety systems, focusing on optimizing advanced driver assistance and safety systems. However, the company states it has not set any further ESRS-compliant targets at this time. It continually reviews its actions to improve systems and achieve desired results through test runs, analyses, and accident research findings, and evaluates system effectiveness using theoretical and practical tests, endurance testing, test site runs, and simulation methods.

Daimler Truck's values and principles are anchored in the overarching Daimler Truck Code of Conduct, which provides guidance for daily actions, defines the rules applying to the entire workforce, and sets the principles by which the company works. Compliance with legal and ethical standards and a strong compliance culture are described as very important. The Compliance Management System (CMS) is a key component supporting a responsible corporate culture, helping meet legal requirements, prevent misconduct, and promote responsible governance, including concepts aligned with the United Nations Convention against Corruption (UNCAC). All employees and managing bodies are informed and trained on these regulations. The company conducts an annual employee survey addressing whether managers respond appropriately to behavior lacking integrity, whether employees openly address such behavior, and whether there is trust in the SpeakUp whistleblowing system. Through its Impact Culture, it promotes employee commitment and strategic participation. The SpeakUp whistleblowing system enables employees, business partners, and third parties worldwide to report potential misconduct anonymously via a secure website or free voicemail number in freely selected languages.

Daimler Truck bases collaboration with sales partners and suppliers on shared values and shared responsibility. Its Business Partner Standards define expectations of business partners including suppliers, covering respect and protection of human rights, good working conditions, environmental protection, and compliance with legal regulations, and referencing standards such as the Universal Declaration of Human Rights, the ILO core labor standards, the UN Guiding Principles on Business and Human Rights, and the ten UN Global Compact principles. Business partners are expected to recognize the standards, communicate them to employees and along their upstream value chain, and regularly check compliance. Further requirements are contained in purchasing contract conditions on social responsibility and environmental protection and in compliance contract clauses. A specially developed compliance awareness module supports partners. In production material purchasing, a sustainability rating based on the SAQ self-assessment is mandatory before new orders above a certain value, specifically contracts over 1 million euros where the supplier has annual turnover above 15 million euros. New and existing suppliers are checked for sustainability criteria, with audits for higher-risk suppliers and due diligence covering human rights.

Daimler Truck's compliance program aims to prevent, detect, and combat corruption across all business activities. It reviews business partners and transactions and deals with authorities and officials with particular sensitivity. A central element of the anti-corruption program is the Corruption Perceptions Index from Transparency International, used as a key parameter in risk evaluations. Increased corruption risks are identified in sales activities in high-risk countries and in relationships with authorized dealers, general agents, and suppliers worldwide. The standard compliance clause for contracts obliges all business partners to have appropriate anti-corruption procedures in place, and the SpeakUp whistleblowing system allows anonymous reporting of incidents. Clearly defined processes report all compliance issues to relevant committees, with the compliance organization playing an advisory and coordinating role supporting the Board of Management. Comprehensive training is provided, with 100% of high-risk functions covered by training programs. The Basic Training Module on the Code of Conduct, which includes corruption prevention content, is repeated every three years and had 42,922 participants, of whom 5,247 were managers.

In the reporting year, five cases of corruption were reported via the SpeakUp whistleblowing system. Four of these were closed as substantiated, and appropriate measures were taken by the company. In the 2024 reporting year, no convictions for violations of corruption and bribery regulations were documented. In the event of corruption, Daimler Truck has established clearly defined processes for reporting all compliance issues and the results of compliance measures to the relevant committees, anchored in the Group. The compliance organization plays an advisory and coordinating role, supporting the Board of Management of Daimler Truck Holding AG and Daimler Truck AG in complying with legal regulations and requirements.