Deutsche Börse

The role of the administrative, management and supervisory bodies

Reference: pages 80-84.

Sustainability is anchored at both board levels. The Executive Board is jointly responsible for the strategic orientation of sustainability matters; within the CEO's area, Group ESG Strategy develops, implements and monitors the sustainability and climate strategy, while the Sustainability Reporting department (reporting to the CFO) prepares the sustainability statement. Since 2024 the Group Sustainability Committee (GSC), chaired by the Chief Sustainability Officer, is "the central management body for sustainability matters," advising the Executive Board on material impacts, risks and opportunities and meeting quarterly (page 80).

At Supervisory Board level, the Strategy and Sustainability Committee "deals in particular with sustainable corporate governance and business activities in the areas of environment, social and good corporate governance" (page 80); the Audit, Risk and Nomination Committees also address sustainability in their areas.

Composition (page 81-82): Executive Board - 7 members, 2 women (29%), average age 55. Supervisory Board - 16 members, 7 women (44%), average age 57; all 8 shareholder representatives were classified as independent in 2025 (page 83). Eight of the 16 Supervisory Board members report in-depth sustainability expertise across environment, social and governance topics (page 83).

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

Reference: pages 80-81.

In financial year 2025, "the updated double materiality assessment, including the identified impacts, risks, and opportunities, was presented to the GSC" (page 80), which meets quarterly and can convene ad hoc specialist working groups. An annual activity report informs the Executive Board of the progress and further development of sustainability activities.

The Supervisory Board "took its regular look at the personnel situation and dealt with the results of the annual employee survey and the personnel strategy" in 2025; the Audit Committee addressed sustainability reporting and its integration into the internal control system, including the double materiality assessment, and the Nomination Committee took sustainability criteria into account when reviewing Executive Board remuneration and the diversity concept (page 80). In 2025 a governance workshop on Board rights/obligations and a compliance workshop on antitrust and regulatory trends were held for the Executive and Supervisory Boards (page 80-81).

Integration of sustainability-related performance in incentive schemes

Reference: pages 83-84.

Sustainability targets are anchored in both short- and long-term variable Executive Board remuneration. In the short-term component, individual targets contributing to the company's long-term and sustainable development carry a weighting of one third, and sustainability targets sit within the catalog of possible individual targets "taking into account the materiality analysis of the Deutsche Börse Group" (page 84).

In the long-term component, "two equally weighted sustainability targets with a total weighting of 25 percent" apply: employee engagement and equal opportunities, each measured using an index derived from the double materiality assessment, "motivation, satisfaction, and retention of employees" being the stated rationale (page 84). Climate-related targets are explicitly not part of the long-term variable remuneration. The Supervisory Board may adjust the number, type and weighting of sustainability targets (maximum four) before each new performance-share tranche (page 84).

Statement on due diligence

Reference: page 84.

Deutsche Börse Group states that, "as a global stock exchange organization," it is exposed to environmental, social and governance risks from its own activities and from customer and supplier relationships, and "pursues a continuous due diligence approach based on a double materiality assessment along the entire value chain," covering both actual and potential negative impacts including reputational risk (page 84).

The statement maps the core elements of due diligence to specific sections of the sustainability statement in a dedicated table: governance embedding to General Information/E1; stakeholder engagement to SBM-2, E1 and G1; impact identification/assessment to General Information, E1 and G1; actions on adverse impacts to E1 and G1; and tracking effectiveness/communication to E1 and G1 (page 84).

Risk management and internal controls over sustainability reporting

Reference: page 77.

"Risk management and the design of the internal control system for the sustainability statement are integrated into the Group-wide risk management approach (see section 'Risk Management Approach' in the Risk Report) and the internal control system (see section 'Structure of the Internal Control System (ICS)' in the Risk Report) and are an integral part of the sustainability statement in order to comply with ESRS 2 GOV-5 and GOV-1.22c" (page 77) - the company cites the disclosure requirement by name.

Preparation responsibility sits with Financial Accounting and Controlling (FA&C), Human Relations, Group Compliance, Group Risk Management and Group ESG Strategy. Energy and GHG data are "collected and calculated using a software to ensure uniform data collection, transparency, and traceability," with emission factors standardized in line with the GHG Protocol (page 77).

Strategy, business model and value chain

Reference: pages 78-80.

Deutsche Börse Group's purpose is "to build trust in the markets by providing transparent, reliable, and stable infrastructures" (page 78). The Group is organized into four segments - Investment Management Solutions, Trading & Clearing, Fund Services, Securities Services - plus cross-functional administration and IT functions that are "considered a further part of the value chain" (page 78).

The sustainability strategy's key matters are: climate (Paris Agreement alignment, net-zero target, transition plan), employees (talent, skills, inclusion), entrepreneurial action (ethical conduct), stakeholder engagement, and sustainability-related business/products (page 78).

Value chain capitals described include intellectual capital (software, licenses, M&A knowledge), financial capital, human capital (around 16,000 employees), physical resources (offices, data centers, IT hardware via defined procurement criteria) and natural resources (water, energy; used resources recycled via waste/water suppliers) (pages 79-80). Upstream value creation is shaped by supplier relationships; downstream by customers, products/services and capital-market development (page 79).

Interests and views of stakeholders

Reference: pages 84-85.

Key stakeholder groups are "customers, employees, investors, suppliers, regulators and legislators, non-governmental organizations and networks, and rating agencies" (page 85). The statement describes, group by group, how each is engaged: employees through works councils, employee surveys and meetings; investors at investor days, the AGM and quarterly/half-yearly meetings; suppliers through Code of Business Conduct commitments and risk-based reviews; regulators through consultations and discussion formats; NGOs/networks through memberships and workshops; rating agencies through ESG ratings, questionnaires and direct exchange; and customers through personal exchange and digital channels (page 85).

The Executive Board and Supervisory Board "are informed regularly about the interests and views of stakeholders" via the sustainability governance process (page 85).

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

Reference: pages 87-90.

Following the double materiality assessment, "Deutsche Börse Group has defined ESRS E1 (Climate Change), ESRS S1 (Own Workforce) and ESRS G1 (Business Conduct) as material," with the S1 sub-topics of safe employment/working hours and inclusion/equal opportunities identified as material; ESRS E2-E5 were assessed as non-material (page 87).

The IRO overview table (pages 88-89) lists, among others: climate physical and transition risk plus a GHG-emissions negative impact (E1); secure employment, training and inclusion positive impacts plus a skills-shortage transition risk (S1); principles of corporate governance, whistleblower system and political influence positive impacts (G1); and Deutsche Börse Group-specific topics - ESG-ratings participation and products/services transparency (positive impacts), transparent/stable/secure markets (opportunity), ICT risk (risk), and products/services financing non-sustainable activities (negative impact) (page 89). The company states identified risks and opportunities "currently do not result in any financial effects on the financial position" (page 87); ICT risk is reported as material for the first time this year, while corruption/bribery prevention and supplier/payment-practices management are no longer reported topics (page 87).

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

Reference: pages 85-87.

Identification: relevant value-chain actors/factors are identified from the business model and validated with specialist departments; "a detailed analysis of individual business relationships or geographical aspects is not carried out, as our business model does not indicate an increased risk of adverse impacts" (page 86). An initial topic list built from ESRS, company-specific input and benchmarking is validated, structured into sub-topics, and sub-topics without value-chain linkage are excluded (page 86).

Assessment: impacts and opportunities are assessed in expert workshops; ESG risks use standardized risk-assessment templates within the Group-wide risk management framework, "not treated as a separate risk type, but rather as drivers of existing risks" (page 87). Impact materiality uses magnitude/scope/irreversibility (plus probability for potential impacts) against a 50% scored threshold, with severity taking precedence over probability for human-rights impacts (page 86). Financial materiality for opportunities uses probability/financial-impact thresholds that scale inversely (higher impact needs lower probability); ESG risks are material if Group-wide probability/impact thresholds are exceeded (pages 86-87). Thresholds are applied proportionally to subsidiary size (page 87).

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

Reference: page 124 (table), pages 125-127 (ESRS 2 Appendix B datapoints).

The statement carries a dedicated "Disclosure requirements under ESRS" table cross-referencing each covered ESRS code to its section of the management report (page 124, referenced from page 77: "An overview of the cross-references used to other parts of the combined management report can be found in the section 'Disclosure requirements under ESRS'"). The table lists BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, E1-1 to E1-8, a selected set of S1 codes (S1-1 to S1-6, S1-9, S1-13, S1-16, S1-17), and G1-1 and G1-5 - consistent with only E1, S1 and G1 being material. E1-9 and the other G1/S1 codes do not appear in this table.

A second table, "Data points that derive from other EU legislation (ESRS 2 Appendix B)" (pages 125-127), separately lists mandated cross-legislation datapoints (e.g., GOV-1 board diversity, SBM-1 fossil-fuel/weapons/tobacco involvement, several E1, E3, E4, E5, S1, S2, S3, S4 and G1-4 items) against EU Climate Law, Pillar 3, SFDR and Benchmark Regulation columns - these answer specific mandatory datapoints and are separate from the main disclosure-requirements index.

Transition plan for climate change mitigation

Reference: pages 92-93.

"Transition planning is an integral part of Deutsche Börse Group's group-wide sustainability and climate strategy." The current plan was "first approved by the GSC in financial year 2024" and presented to the Supervisory Board's Strategy and Sustainability Committee, and is reviewed annually (page 92). It supports the short-term 2030 targets, "consistent with limiting global warming to 1.5 degrees Celsius," using IEA pathway data provided via the SBTi, and is to be "gradually supplemented by further measures" toward the 2045 net-zero target (a 90% cut in Scope 1, 2 and 3) (page 92).

Scope 1/2 reduction relies mainly on "the gradual switch to renewable energies between 2025 and 2030 and the exclusive use of electric company cars from 2028 onwards" (page 93). Identified transition-plan investments/operating expenses are "not significant enough to fundamentally adjust" business activities or EU Taxonomy criteria; a qualitative CO2 lock-in assessment covered Scope 1/2 buildings (page 93). The company is not exempt from EU Paris-aligned benchmark reference values and is represented in EU Paris-aligned indices (page 93).

Identification of climate-related risks and scenario analysis

Back-filled from the "Climate scenario analysis and climate resilience" section, where this content is disclosed in the FY2025 report (pages 90-92). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Climate risks were assessed "as part of a double materiality assessment," using scientifically grounded NGFS scenarios built on IPCC data, "considered established market standards" and used by central banks and supervisory authorities (pages 90-91). Two scenarios were applied: Net Zero 2050 (RCP 2.6) - a transition scenario assuming "a 50 percent probability of meeting the objectives of the Paris Climate Agreement by 2050" - and Current Policies (RCP 8.5), used to assess exposure to physical climate risk assuming no significant policy tightening (page 91).

The analysis was conducted "qualitatively and quantitatively by the risk management functions and/or equivalent specialist departments," covering company-specific circumstances and short/medium/long time horizons, and drawing on external location-specific data for temperature change, extreme weather, heatwaves, droughts, fires, storms and floods (page 91). Two material risks were identified: physical risk (extreme weather/events affecting offices and data centers) and transition risk (decarbonization costs, regulatory change, and a related skills-shortage risk) (pages 91-92).

Resilience in relation to climate change

Back-filled from the "Climate scenario analysis and climate resilience" and "Transition plan" sections (pages 91-93). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Deutsche Börse Group states it "pursues a long-term sustainability strategy that ensures both operational and strategic resilience to identified climate risks while addressing the negative impacts of its own energy consumption," taking into account uncertainties in transition planning and in climate-scenario pathways, with "underlying assumptions and forecasts ... reviewed regularly" (page 92).

For physical risk, resilience rests on a Group-wide Business Continuity Management System (BCMS) aligned to ISO 22301:2019, covering employees, systems, workplaces and suppliers, with redundant critical IT design, regular simulation testing, tool-supported exposure monitoring and property-damage insurance for key locations (page 91). For transition risk, resilience is managed through the risk-management system, an annually reviewed risk policy, targeted training (a Group-wide Risk Culture & Awareness course in 2025) and a dedicated talent strategy (page 91). The company notes explicitly that "for Scope 3 emissions ... implementation is still pending. Consequently, no reliable statement can be made at this time about the potential reduction of negative impacts and risks" (page 92).

Policies related to climate change mitigation and adaptation

Reference: page 90 ("Climate change statement" section).

The Group's Environmental Protection Statement "provides guidance for stakeholders regarding our understanding of the environment and the measures we are taking to improve our environmental performance," is "reviewed regularly, updated as needed, and published" on the website, with progress on the climate strategy "monitored by the GSC" (page 90). Climate awareness training, working groups and the Group Sustainability Day support employee engagement; energy-efficient building management and mobility concepts are implemented "wherever possible" at German and Luxembourg sites (page 90).

Climate targets "are based on the GHG Protocol and have been validated by the Science Based Target initiative (SBTi)" (page 90). Memberships supporting the policy include the Sustainable Stock Exchanges Initiative, Principles for Responsible Investment, econsense, UN Global Compact and CDP (page 90).

Actions and resources in relation to climate change policies

Reference: pages 93-95 ("Emission reduction measures").

The transition plan assumes a 5% annual growth rate and "dedicated measures to reduce emissions" (page 94). Named Scope 1/2 measures, to be completed "by 2030 at the latest": the Eschborn combined heat and power plant's gradual gas-to-renewable-electricity switch (expected ~3,300 t CO2 reduction by 2030); fleet electrification, complete by 2028 (~1,200 t CO2 by 2030); and site-wide renewable electricity conversion from 2025 (~1,500 t CO2 by 2030) (pages 94-95).

For Scope 3, the largest short-term reduction lever is business travel; sustainable aviation fuel was discussed by the GSC in June 2025 but "no new measures were taken in financial year 2025" due to availability and regulatory uncertainty (page 95). A supplier engagement programme integrates climate questions into supplier qualification and issued a climate-target questionnaire to existing suppliers from FY2024, with a 2025 monitoring system added to track progress (page 95). Category 1 (purchased goods and services) is the largest Scope 3 share, making supplier engagement "of central importance" to the 2045 net-zero target (page 95).

Targets related to climate change mitigation and adaptation

Reference: pages 92-94.

Short-term (2030, vs. 2022 base year): -42% absolute Scope 1 and 2 emissions; -42% absolute Scope 3 emissions from fuel/energy-related activities, business travel and employee commuting; and a supplier-engagement goal of 81% of relevant supplier spend (purchased goods, services and capital goods) having set SBTi-compliant targets by 2028 (page 93). Long-term: -90% absolute Scope 1, 2 and 3 emissions by 2045 (net-zero), using a cross-sector 1.5C-aligned emissions pathway (pages 93-94).

The Scope 1/2 base-year value is 11,800 t CO2 in 2022 (55% Scope 1, 45% Scope 2); the transition-plan base year of 130,180 t CO2 is "slightly below" total 2022 emissions of 132,108 t CO2 because some optional Scope 3 sub-categories (accommodation, home office) are excluded from the SBTi assessment though voluntarily reported (pages 94-95). Targets "were validated by SBTi in financial year 2024" and are reviewed "at least every five years" (page 94).

Energy consumption and mix

Reference: pages 96, 98.

FY2025 total energy consumption was 80,997 MWh (2024: 86,460 MWh), of which fossil sources were 24,397 MWh (30%, down from 38%), nuclear-sourced consumption 1,012 MWh (1%), and renewable-source consumption 55,588 MWh (69% of total, up from 60%) (page 98). The Eschborn combined heat and power plant generated 4,846 MWh in 2025 (2024: 11,403 MWh), of which 4,309 MWh was consumed internally (page 98).

Methodology follows the GHG Protocol using the operational control approach; Scope 1/2 emission factors come from ecoinvent (IPCC 2021/GWP100, UK DEFRA-aligned, updated annually), and the national energy mix uses IEA data, excluding renewables "as a precautionary measure if sufficient evidence is not available" (page 96). Market-based Scope 2 electricity was 53% renewable via certificates plus 16% via Guarantees of Origin/Energy Attribute Certificates in 2025 (2024: 49%/12%) (page 98).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 97-98.

FY2025 (base year 2022 in brackets): gross Scope 1 3,097 t CO2e (6,444); gross location-based Scope 2 26,995 t CO2e (27,599); gross market-based Scope 2 2,864 t CO2e (5,356); total gross Scope 3 112,556 t CO2e (120,308), led by Category 1 purchased goods/services at 70,123 t CO2e. Total GHG emissions (market-based) were 118,517 t CO2e in 2025 versus 132,108 t CO2e in 2022 (page 97).

Categories excluded as immaterial: upstream leased assets (Cat. 8, already in Scope 1/2), downstream transportation/processing/use/disposal of sold products (Cats. 9-11, the Group "does not manufacture or sell any physical products"), and downstream leased assets/franchises (Cats. 13-14, not a lessor or franchisor) (page 98). GHG intensity per net revenue was 0.0 t CO2e/EUR on both a location- and market-based basis (2024: 0.0) (page 99).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 98.

For FY2025, Deutsche Börse Group purchased CO2 certificates covering 45,369 t CO2 (2024: 19,166 t CO2), including an additional wind-power project outside the EU compared to the prior year, sourced from the "Gold Standard" provider category (page 98). The company states explicitly that "the purchase of CO2 certificates does not contribute to achieving the net-zero target by 2045 and is not counted as a reduction in emissions of the residual value after the 90 percent reduction" (page 98) - certificates are kept outside the transition plan's accounting.

Potential compensation measures are reviewed for SBTi-standard compatibility as the climate strategy develops; for the residual emissions remaining after the 2045 90% reduction, the company states it is "considering CO2 capture and storage methods from 2045 onwards" (page 98) rather than carbon credits.

Internal carbon pricing

Reference: page 96.

"Deutsche Börse Group did not apply any internal CO2 pricing systems in the financial year or in previous years" (page 96). This is a direct, complete answer rather than an omission: the company has assessed the question and reports a nil position for both the current and all prior reporting periods.

Policies related to own workforce

Reference: pages 102-103.

The People Strategy rests on "four strategic dimensions" - attracting talent, targeted development, enabling effective work, and personal/professional support - supplemented in 2025 by a new talent-management focus (page 102). The employee definition used Group-wide for headcount purposes includes active employees and those on long leave (illness, maternity) and partial retirement during the working phase, but excludes apprentices/interns, employees in early retirement or sabbatical, and the Executive Board (page 102-103).

The Human Rights Declaration, approved by the GSC, is based on the UN Guiding Principles on Business and Human Rights, ILO Declaration, UN Global Compact, OECD Guidelines and related instruments (page 103). The company states that "Deutsche Börse Group's business activities in 2025 did not include any activities associated with an increased or significant risk of forced, compulsory, or child labor" (page 103), and that compliance is "enshrined in particular in the Deutsche Börse Group Code of Business Conduct" (page 103).

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

Reference: pages 105-106.

Employees and their representatives are involved "on an ongoing basis and as required" through works councils, economic committees, representatives for disabled employees, personnel committees, trade unions and co-determined Supervisory Board seats, plus an annual anonymous People Survey (page 105). Feedback drives either Group-wide initiatives or targeted line-manager actions; 2025 employer attractiveness was rated 81% (2024: 85%) (page 105).

Depending on topic, representative involvement takes the form of "information, consultation, advice, or co-determination," with regular monthly meetings between the parent-company works council and the Chief Human Relations Officer (CHRO), who is responsible for ensuring results feed into the corporate concept (page 106). The company states it "is in dialogue with employees and employee representatives regarding the reduction of CO2 emissions and the transition to climate-neutral business processes" (page 106).

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

Reference: page 112.

Complaints that employees have failed to meet conduct standards "can be submitted to the Deutsche Börse Group whistleblower system, the direct line manager, Human Relations, workers' representatives (if available) or a control function such as Group Compliance" (page 112). For severe negative impacts on employees, fact-finding and remedial action - including disciplinary proceedings - are carried out jointly by Human Relations and Group Compliance, with further detail cross-referenced to the "Whistleblower system and protection of whistleblowers" section (page 112).

Taking action on material impacts on own workforce

Reference: page 112.

2025 employee-satisfaction measures implemented across the People Strategy's strategic dimensions include: a flexible working model extending limited remote work abroad to France, Ireland, Luxembourg, the Czech Republic and Switzerland (further locations to be analyzed in 2026); a global Wellbeing Focus Week/Days programme with mental/physical-health content and a cross-location wellbeing working group; and continued inclusion and equal opportunities activity, including mandatory inclusive-leadership training for those not yet trained and a 2025 focus on "unconscious bias," with further 2026 measures in development (page 112).

Targets related to own workforce

Reference: pages 106-107.

Two Group-wide sustainability targets, revised in 2025 "to increase transparency and align itself with current market practice": the Employee Engagement Index (target >66%; actual 68% in 2025, 66% in 2024) measuring motivation and identification with the company via five People Survey questions, and the Equal Opportunities Index (target >88%; actual 86% in 2025, 88% in 2024) measuring perceived equality via four People Survey questions, which replaced the prior target on the proportion of women in leadership "to enable a more comprehensive and inclusive view" (pages 106-107). Target achievement is presented annually to the Executive Board and Supervisory Board by Human Relations (page 107).

Characteristics of the undertaking's employees

Reference: pages 107-108.

As of 31 December 2025, Deutsche Börse Group had 16,475 employees (2024: 15,495); headcount by gender was 9,817 male, 6,635 female, 3 other and 20 not disclosed (page 107). Germany (4,220), the Philippines (1,715) and the Czech Republic (1,692) were the largest country locations, with India, Luxembourg, the US, UK, Ireland and Denmark also listed (page 107). The turnover rate was 10% (2024: 11%), comprising 1,551 leavers (page 107).

By contract type: 16,134 permanent and 339 temporary (2024: 15,184/307); 15,433 full-time and 1,042 part-time (2024: 14,515/980); 4 non-guaranteed-hours employees (2024: 4) (page 108). A regional breakdown (EMEA, North America, Central/South America, Asia, Australia) is also provided (pages 108-109).

Diversity metrics

Reference: pages 104, 109.

At upper management level (the first three levels below the Executive Board), the 2025 gender split was 790 men (76%) and 251 women (24%) (2024: 762/76%, 244/24%) - unchanged year on year (page 109). The Group-wide age distribution in 2025 was: under 30 - 3,792 (23%); 30-50 - 10,065 (61%); 51-70 - 2,607 (16%); over 70 - 11 (page 109).

Inclusion and equal opportunities are governed by the Anti-Harassment and Inclusive Workplace guidelines, the publicly available Inclusion & Equal Opportunities Statement, and membership of the Diversity Charter and UN Women's Empowerment Principles; the Inclusive Workplace Council represents the global workforce and advises the Executive Board (pages 104-105). Mandatory ethics/anti-harassment training is scheduled annually or on joining, subject to local law (page 104).

Training and skills development metrics

Reference: pages 110-111.

Talent programmes include the 12-month high-potential Evolve! programme, the 12-month ada Fellowship Digitize! digital-transformation programme, an 18-month graduate trainee programme, and an 18-month senior-manager development curriculum, alongside e-learning, language/soft-skills/technology courses and the "Learn & Grow" month (page 110).

Average training hours per employee in 2025: male 23 (2024: 22), female 24 (2024: 23), other 8 (2024: 37), not disclosed 14 (2024: 5); overall 23 (2024: 22) (page 111). In 2025, 97% of employees recorded in the internal appraisal system received a performance appraisal (2024: 98%) - 40.1% female, 59.8% male, 0.1% unspecified; using the Group entity with the latest completion date (30 June 2025), 94% of appraisals were completed (2024: 85%) (page 110).

Compensation metrics (pay gap and total compensation)

Reference: page 111.

The unadjusted gender pay gap was 28.2% in 2025 (2024: 29.1%), calculated as the difference between average total annual remuneration of male and female employees divided by the male average, covering fixed salary, variable remuneration at grant value and benefits such as company car and pension (page 111). The company notes the figure does not control for "structural differences such as function, level, location, professional experience, recent promotion" (page 111).

The CEO pay ratio (highest-paid individual's total annual remuneration to median employee remuneration, excluding the highest-paid individual) was 97.0 in 2025 (2024: 94.7); the highest-paid individual as of 31 December 2025 was the CEO of Deutsche Börse AG (page 111).

Incidents, complaints and severe human rights impacts

Reference: pages 111-112.

In FY2025, 23 suspected cases (2024: 21) "related to discrimination, including harassment" were reported through Deutsche Börse Group's reporting channels, and one suspected human-rights-related case (2024: two) was reported to the Human Rights Officer; "this was not confirmed following an investigation" (page 111-112). The company states that "no fines, penalties or compensation payments were made in connection with the incidents and complaints described above (2024: no payments either)" and that "there were no severe human rights incidents in financial year 2025 (2024: no incidents either)" (page 112).

Business conduct policies and corporate culture

Reference: pages 113-116.

The Group's purpose - "We at Deutsche Börse create trust in the markets of today and tomorrow" - is backed by its five values of performance, reliability, integrity, openness and responsibility (page 114). All employees, Executive Board and Supervisory Board members must adhere to the Code of Business Conduct, owned by Group Compliance and approved by the Executive Board, covering legal/regulatory compliance, customer relationships, confidentiality, conflicts of interest, insider dealing/market-manipulation prevention, fair competition, anti-harassment, anti-bribery/corruption, human rights, environmental awareness and the whistleblower system (page 114). Guiding documents are approved by the Written Rules Committee (WRC), reviewed annually and re-approved on material update (page 114).

Compliance training is mandatory on joining and annually thereafter; the Group "deliberately refrains from differentiating between potentially risky functions in relation to bribery or corruption," applying uniform training to all employees (page 115). The whistleblower system accepts anonymous digital reports from employees and third parties, complies with the German Whistleblower Protection Act, and gets quarterly/annual availability reports from its external provider; "more than 90 percent (2024: 95 percent)" completed Code of Business Conduct/whistleblower training in 2025 (pages 115-116).

Targets related to business conduct

Back-filled from the business conduct chapter (pages 113-117), where effectiveness is tracked via training and system metrics rather than a stated outcome-oriented target. G1-3 became a standalone DR only in the 2025/2026 ESRS; no numbered G1-3 target section exists under the 2023 ESRS this report applies.

Deutsche Börse Group does not state a measurable outcome target for business conduct. Effectiveness is instead tracked through recurring compliance metrics: a Group-wide Risk Culture & Awareness Training programme "already completed by 99 percent of the target group" (page 117); "more than 90 percent (2024: 95 percent)" of employees completing Code of Business Conduct/whistleblower training, with roughly one hour per employee (page 115); annual WRC review and re-approval of all guiding documents (page 114); and quarterly plus annual availability reporting on the digital whistleblower system from its external provider (page 115). Corruption/bribery-prevention reporting itself was discontinued this year (page 87), so no corruption-specific target or tracking metric is presented.

Political influence and lobbying activities

Reference: pages 116-117.

In FY2025, Deutsche Börse Group "engaged in regular dialogue with national institutions (particularly in Germany, France, and Luxembourg) and international organizations (including the European Union and ... IOSCO)," including contributing to the EU Savings and Investment Union and Market Integration and Supervision Package discussions, and Germany's Location Promotion Act (StoFöG) at national level (page 116).

"In accordance with its publicly available Code of Business Conduct, Deutsche Börse Group does not support any political parties, their representatives or candidates, either financially or in kind. For this reason, as in the previous year, no such expenses were incurred in the 2025 financial year" (page 117). Deutsche Börse AG is registered in the EU transparency register (20884001341-42), the German Bundestag Lobby Register (No. R001339), and the Luxembourg and Hesse registers; lobbying is carried out by the Group Regulatory Strategy function in agreement with the Executive Board (page 117). No Executive or Supervisory Board member held a comparable public-administration/regulatory position in the two years before appointment (page 117).