ElringKlinger AG

Reference: pages 161-163.

The Supervisory Board had twelve members in 2025 (six shareholder representatives, six employee representatives); the Management Board had four members: Thomas Jessulat (CEO), Isabelle Damen (CFO), Reiner Drews (COO), Dirk Willers (CSO). "Overall responsibility for sustainability lies with CEO Thomas Jessulat." Chairman of the Supervisory Board Helmut P. Merch "is responsible for monitoring the impacts, risks, and opportunities."

Gender distribution (Dec 31, 2025): Management Board 1 woman/4 (25%); Supervisory Board 4 women/12 (33.3%). Independent Supervisory Board members: 4 of 12 (33.3%).

Committees: the Audit Committee "monitors statutory reporting obligations and regulatory requirements in the area of sustainability"; the Nomination Committee factors in sustainability when selecting Management Board members; the Personnel Committee factors it into Management Board remuneration. The Sustainability Council, chaired by the CEO and comprising Management Board members and area Vice Presidents, gives an annual progress update; Sustainability Steering Groups handle operational implementation.

The corporate unit Corporate Sustainability coordinates Group sustainability activity and reports to the CEO. No skills/expertise disclosure beyond noting Board members' "in-depth knowledge acquired through professional experience" in sustainability.

Reference: pages 163, 169.

"The Chairman of the Management Board (CEO) also discusses sustainability-related issues with his colleagues at Management Board meetings", and the Sustainability Council "informs the decision-makers annually about progress in the respective Steering Groups."

"The company has yet to examine how material impacts, risks, and opportunities are explicitly incorporated into the monitoring of corporate strategy." In 2025 the DMA results were incorporated into the risk survey of the general risk-management process, and "the Management Board dealt with all material impacts, risks, and opportunities in the reporting year." No known compromises were identified in connection with material IROs.

Both the Management Board and Supervisory Board "are furnished with information on the key matters of sustainability reporting in accordance with ESRS at regular meetings as required." The 2025 update to the double materiality assessment identified a need to adjust the sustainability strategy and management systems for certain IROs; initial measures in 2025 included integrating climate risks into existing management systems, elaborating Scope 3 decarbonization actions, and integrating sustainability further into supplier management.

Reference: page 163.

Sustainability performance is built into Management Board short-term (STI) and long-term (LTI) variable compensation via three modifiers redefined annually by the Supervisory Board, of which two are non-financial:

• Occupational safety modifier - based on the year-on-year change in the Group-wide occupational accident rate; the 2025 target was a 10% reduction.
• Energy-efficiency modifier - based on the trend in energy consumption relative to Group revenue (Scope 1, Scope 2 market-based and business-trip emissions); the 2025 target was also a 10% reduction. "There is no link between this remuneration modifier and the greenhouse gas emission reduction targets disclosed under ESRS E1-4, as the underlying Scopes differ," though ElringKlinger "is examining the extent to which a stronger link can be established in future."

Each modifier ranges 0.8-1.2 (1.0 = full attainment); the overall modifier is applied to adjusted EBIT and operating free cash flow to determine the STI/LTI payout. The Supervisory Board sets the modifiers and adjusts the incentive system; Say on Pay is put to the AGM at least every four years.

Reference: pages 163-165 (due diligence mapping table).

ElringKlinger maps the ESRS core elements of due diligence to sections of the sustainability statement:

• (a) Embedding in governance, strategy and business model - GOV-1, GOV-2, GOV-3, SBM-3
• (b) Engaging with affected stakeholders - GOV-2, SBM-2, IRO-1, plus topical policies (E1-2, E2-1, E4-2, E5-1, S1-1 to S1-3, S2-1 to S2-4, G1-3)
• (c) Identifying and assessing adverse impacts - IRO-1, SBM-3, and each topical standard's Impacts/risks/opportunities (SBM-3) subsection
• (d) Taking action on adverse impacts - the "Actions and resources" DR of each material topic (E1-3, E2-2, E4-3, E5-2, S1-3/S1-4, S2-3/S2-4)
• (e) Tracking effectiveness and communicating - the same set of topical actions/effectiveness sections

No narrative overview beyond the table; the mapping itself constitutes the GOV-4 statement.

Reference: pages 165-166.

The Risk Management System (RMS) "consolidates the risks of the entire Group" and complements strategic planning and the Group-wide corporate planning system. Time horizons: short-term (<1y, quantitative, Monte-Carlo aggregation), medium/long-term (1-5y and >5y, qualitative, likelihood categorized "unlikely" to "very likely", severity "low/medium/high"). A consolidated Group risk report goes to the Management Board and Supervisory Board every six months.

Process-integrated controls include completeness checks on recorded risks, plausibility checks, adherence to reporting dates, risk-manager training, and induction of new risk managers. A two-person rule applies to checking reported sustainability information. The RMS sits alongside the Compliance Management System (CMS) and Internal Control System (ICS) under Corporate Governance.

"The main risks identified include human error and completeness of data" is not stated here for GOV-5 (that language belongs to a different company); ElringKlinger's own risk-management narrative instead cites systemic weaknesses being escalated to the Management Board and quarterly reporting by the Global Risk Manager to the Management Board and Audit Committee.

Reference: pages 166-167, 197 (transition plan status).

ElringKlinger is "an automotive supplier" specializing in drive-system components (gaskets, shielding, lightweighting) and electromobility (battery and fuel cell components), plus a global aftermarket business and non-automotive high-performance plastics products. Headcount at Dec 31, 2025: 8,946 (ESRS definition, incl. trainees/interns/temps), across ~40 locations. Upstream: alloyed stainless steel, carbon steel, aluminum, polyamide pellets, elastomers, PTFE, sourced internationally. Downstream: product use phase and end-of-life/return and recycling management.

SHAPE 30 (launched 2024) is the corporate strategy, with sustainability as one of five success factors. The Group targets carbon neutrality in Scope 1 and Scope 2 by 2030, offsetting unavoidable residual emissions from 2030 onward, and a Scope 3 target on categories 3.1 and 3.4 (~74% of Scope 3), -32.5% by 2033 (2023 base).

"No transition plan in accordance with ESRS E1-1 was presented in the reporting year" - full compliance is not yet possible because dovetailing the existing climate strategy with quantified ESRS-standard transformation pathways, sectoral benchmarks, financial impacts and transition risks, and integrating SBTi-aligned targets with financial/investment/control processes, remain under development.

Reference: pages 168-169.

Stakeholders of strategic relevance: employees, works council, customers, banks, shareholders, business partners and suppliers, plus government/regulatory bodies, the public and media, NGOs, associations and the scientific community. Engagement channels are tabulated by group (e.g. employees: intranet, meetings, staff surveys; suppliers: discussions, negotiations, self-assessments, audits; investors: AGM, roadshows, capital-market events).

The 2025 DMA update built on a stakeholder survey first conducted in 2022. "ElringKlinger has identified the need for adjustments to its sustainability strategy and management systems" for certain IROs; 2025 initial measures included folding climate risk into existing management systems, elaborating Scope 3 decarbonization actions, and deepening sustainability integration in supplier management, reflecting that "ElringKlinger's business model is closely linked to global supply chains that pose various challenges in respect of working conditions and human rights."

Human-rights-specific engagement runs through employee surveys, Works Council dialogue and confidential whistleblower channels for compliance and human-rights violations.

Reference: pages 170-171 (overview and scope), 171-176 (material IRO table).

"Owing to the first-time application of the ESRS framework...there were no changes to the material impacts, risks, and opportunities compared to the previous reporting period." Three entity-specific metrics are reported: energy efficiency (GOV-3), the R&D ratio linked to innovation/product transformation (E1-3), and the accident rate in occupational health and safety (S1-14).

"ESRS E3 Water and marine resources, ESRS S3 Affected communities, and ESRS S4 Consumers and end-users were not classified as material in the double materiality assessment and have therefore not been included in the combined sustainability report" (p.170-171).

The materiality-assessment table (pp.171-176) lists 40 individually typed impacts, risks and opportunities across E1, E2, E4, E5, S1, S2 and G1, each tagged with upstream/own-business/downstream attribution and a time horizon. No material adjustments to asset/liability carrying amounts are anticipated for the coming reporting year, and there were no events in 2025 with a significant financial impact tied to material sustainability risks/opportunities.

Reference: pages 177-180 (general methodology), 179-180 and 193-194 (climate-specific detail; cross-referenced under E1-2/E1-3).

Five-step process: (1) determine relevant sustainability topics/sub-topics per ESRS 1 AR16; (2) integrate stakeholder interests via workshops with internal experts, covering upstream/downstream processes; (3) assess impacts/risks/opportunities - actual impacts scored on scale x scope x irremediable character, potential ones also weighted by likelihood, using a "gross approach" that disregards mitigation; (4) set the materiality threshold at "half of the maximum number of points...for actual and potential impacts and slightly below half for financial risks and opportunities"; (5) validation by Corporate Sustainability and approval by the CEO, with Central Risk Management involved so results feed the general risk-management process.

Climate scenarios: IPCC SSP1-2.6, SSP2-4.5, SSP3-7.0 and SSP5-8.5, assessed over a current period (2011-2030) and future period (2031-2050). The cross-location assessment used SSP5-8.5 ("highest level of potential physical climate risks...extreme but scientifically plausible") supplemented by SSP2-4.5 as the moderate reference scenario, "allowing for a bandwidth perspective."

The DMA "will be conducted annually" going forward (previously updated ad hoc).

Reference: page 182 (text), 248-253 (ESRS index and legislation-datapoint appendix).

"In the context of sustainability reporting in accordance with CSRD, ElringKlinger drew up a structured overview of the relevant disclosure requirements. It is based on the results of the entity-specific materiality assessment in accordance with ESRS 1 Chapter 3." The overview covers all sector-agnostic and entity-specific requirements, cross-referenced by paragraph number.

Two appendices carry the substance: the ESRS index (pp.248-249), an overview of all disclosure requirements the materiality assessment covered, and a second table (pp.250-253) mapping datapoints required by other EU legislation (SFDR, Pillar 3, the Benchmark Regulation, the EU Climate Law) to their location in the report or to a "Not material" designation.

Reference: pages 166-167 (SBM-1 status statement), 193, 197.

"At the time of writing, ElringKlinger already has a climate strategy. This strategy is currently being adapted to the goals of the Science Based Targets initiative (SBTi). A comprehensive transition plan in accordance with ESRS requirements has not yet been established. However, the development of such a plan is envisaged."

Under SBM-1: "No transition plan in accordance with ESRS E1-1 was presented in the reporting year" - full compliance isn't yet possible because dovetailing the existing climate strategy with ESRS-standard quantified transformation pathways (sectoral benchmarks, financial impacts, transition risks) is not sufficiently mature, and integrating SBTi-aligned emission targets with the associated financial, investment and control processes is still under development. ElringKlinger expects the internal data, planning and control structures needed to fully map an ESRS E1-1 transition plan "in the coming reporting years." No CapEx/OpEx allocation to the plan is disclosed for this reason.

ElringKlinger is "not excluded from the EU Paris-aligned benchmarks" is not stated in this report; no equivalent statement on benchmark exclusion appears.

Reference: pages 195-196.

ElringKlinger has no single climate-dedicated policy; climate action is embedded in management systems certified to ISO 9001, IATF 16949, ISO 14001, ISO 45001, ISO 27001 and ISO 50001 (the last "attests to ElringKlinger's energy policy"). The Central Policy on Climate Change Mitigation and Carbon Neutrality is "a strategic management tool and a binding framework for all units," currently under review and being adapted to the Management-Board-adopted climate targets; Corporate Sustainability owns it.

The ElringKlinger Code of Conduct and Supplier Code of Conduct set binding standards on efficient resource use, eco-friendly product/process design and reducing environmental impact, including GHG-reduction and harmful-impact-avoidance actions; the Supplier Code of Conduct rolled out Group-wide in 2023, with supplier acceptance "growing steadily." The Management Board is responsible for the codes; monitoring sits with Compliance, backed by systematic risk reviews, internal controls and a Group-wide whistleblower system.

Reference: pages 196-198.

Actions apply "across all locations" and are "implemented consistently worldwide." Six decarbonization levers are named: (1) increasing energy efficiency - building maintenance, heat recovery, compressed-air leak prevention, smart-meter software, ~1% of annual PP&E investment; (2) expansion of renewable energy - on-site wind/solar, no new installations added in 2025; (3) global conversion to green electricity - "Since 2025, all plants within the European Union have been operating entirely on green electricity"; a China plant conversion saved 7,928 tCO2; (4) electromobility in the vehicle fleet - ~20% of fleet fully electric; (5) decarbonization of the supply chain - focused on Scope 3.1; (6) offsetting unavoidable emissions in Europe.

R&D ratio (entity-specific metric): 5.5% of Group revenue in 2025, ~120 new patent applications filed; FY2026 target range 3-5%. "The emission and energy savings that can be achieved through these actions cannot be quantified due to the large number of individual measures." No CapEx/OpEx is disclosed by lever, as "no specific resources have yet been allocated to individual actions."

Reference: pages 198-200.

Near-term SBTi-aligned targets (base year 2023, target year 2033): Scope 1+2 combined -54.5% by 2033 (18,810 tCO2 base -> reported 2025 gross Scope 1 of 20,374 tCO2, location-based Scope 2 54,723 tCO2, market-based Scope 2 17,986 tCO2). Scope 3 categories 3.1 (purchased goods, direct materials) and 3.4 (upstream transport/distribution) - -32.5% by 2033 against a 615,142 tCO2 base (~74% of total Scope 3). "The reference climate and energy policy scenarios used by the SBTi were incorporated," with a Scope 1/2 pathway compatible with 1.5°C and a Scope 3 pathway compatible with 2.0°C.

"By the end of 2025, ElringKlinger had succeeded in decarbonizing its Scope 1 and Scope 2 emissions faster than originally planned...its strategic climate targets in these scopes were met in full. In Scope 3, the broken-down annual targets were also achieved." The climate targets "have not yet been externally reviewed or validated" - SBTi validation is not yet obtained.

Reference: page 200 (table), 199 (NACE classification).

ElringKlinger falls under NACE 29.3 ("Manufacture of parts and accessories for motor vehicles"), a high-climate-impact sector.

2025 energy consumption (MWh): fossil total 131,348 (crude oil/petroleum 13,135; natural gas 80,512; purchased fossil electricity/heat/steam/cooling 37,701) = 52.6% of the mix. Nuclear consumption 3,702 MWh (1.5%). Renewable total 114,654 (purchased renewable electricity/heat/steam/cooling 110,350; self-generated non-fuel renewable 4,304 from on-site PV and a wind turbine at Redcar/UK, Suzhou/China and Changchun/China) = 45.9%. No coal or fuel from renewable sources (incl. biomass) reported. Total energy consumption: 249,704 MWh; energy intensity 0.15 MWh/EUR k. No prior-year comparatives, as this is the first ESRS reporting year.

Reference: pages 200-203 (tables and methodology).

2025 GHG emissions (tCO2e): gross Scope 1 20,374; Scope 2 location-based 54,723, market-based 17,986; gross Scope 3 794,259 (nine categories reported: 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 3.9, 3.12; six others excluded as immaterial). Total location-based 869,356; total market-based 832,619. GHG intensity: 0.53 tCO2/EUR k location-based, 0.51 market-based. Scope 3.1 (purchased goods, direct materials) 486,966 tCO2e; largest single category.

Consolidation uses financial control; Scope 1/2 use primary data (German Federal Environment Agency factors for Scope 1, local grid-operator factors for Scope 2 market-based); Scope 3 mostly spend-based per the GHG Protocol Scope 3 Standard, with ~18% of Scope 3 based on primary data. IPCC AR6 GWP100a factors are used. Parent company ElringKlinger AG's 2025 total was 353,509 t CO2e market-based (9,791 t direct + 385 t fleet + 343,333 t Scope 3).

Reference: pages 204-205.

"In the year under review, the ElringKlinger Group did not use natural sinks or technical solutions to remove greenhouse gases from the atmosphere...At present there are no policies or actions in place for this type of mitigation activity." No GHG removals relating to own or value-chain activities were made in 2025.

ElringKlinger anticipated using offsets of 14,500 tCO2 outside its value chain for 2025's unavoidable emissions; the credits will be purchased and retired in Q1 2026, allocated retroactively to 2025. Credits used support a solar project in India and comply with the Gold Standard, "used exclusively to avoid CO2 emissions" (no biogenic/technological-sink removal credits are purchased). Purchases are voluntary, do not count toward the Group's reduction targets, relate solely to unavoidable emissions at European sites, and are made without long-term multi-year contracts.

Reference: page 205.

"ElringKlinger does not currently operate a Group-wide internal carbon pricing system. Looking ahead, however, there are plans to introduce such a scheme in the long term as a management tool." No further detail (scope, price level, or timeline) is given.

Back-filled from ESRS 2 IRO-1's climate methodology (pp.179-180) and the E1 chapter's SBM-3/resilience subsection (pp.193-194). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification: the report states "ElringKlinger has identified only climate-related transition risks as material" (p.193), yet separately runs a physical-risk scenario analysis (p.193-194) - the two statements sit in tension and are recorded as written, not reconciled.

Scenarios: IPCC SSP1-2.6, SSP2-4.5, SSP3-7.0 and SSP5-8.5 (p.179-180). The cross-location run centers on SSP5-8.5 ("extreme but scientifically plausible," a conservative high-emission case) plus SSP2-4.5 as "the reference scenario for likely developments." No named 1.5°C-aligned transition scenario appears (e.g. no IEA NZE); no global average temperature projection is stated.

Time horizons: current period 2011-2030, future period 2031-2050 (20-year IPCC windows), aligned to SHAPE 30's 2030 horizon and EU climate targets.

Scope: all material business activities; SSP5-8.5 found 23 sites worldwide exposed to heightened risk, with heat stress, air-temperature change and water stress the most severe across locations (p.193).

Assumptions: rising renewable share, energy-efficiency gains, faster/cheaper decarbonization technology (p.194).

Timing: developed 2023-2025 (site analyses 2023-2025, DMA 2024/2025); updated "at regular intervals."

Back-filled from the E1 chapter's SBM-3/"Resilience analysis" subsection (pp.193-194). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

(a) Results: "the overall result of the resilience analysis shows that ElringKlinger has a fundamentally high level of resilience despite increasing climate-related risks." Physical risks are mitigated site-by-site (insulation, AC, flood protection, emergency plans, business continuity, insurance); transition risk through prioritizing sustainable mobility, renewable-energy expansion, energy efficiency and product-portfolio transformation. SHAPE 30 is said to strengthen adaptive capacity; for high-risk locations ElringKlinger "would develop targeted measures to stabilize the business model."

(b) Uncertainty: identified uncertainties on at-risk assets, locations and activities "will be taken into account in the further development of the corporate strategy, in investment decisions, and in the design of...climate mitigation and adaptation measures," against assumptions of long-term shifts in macroeconomic conditions, the energy system and technology.

(c) Capacity to adjust: draws on the IRO-1 methodology (2023-2025 site analyses, downscaled IPCC/ERA5 data) plus a supply-chain resilience analysis "based on a representative supplier base covering around 70% of purchasing volume." No quantified financial-flexibility figures are given; updated "at regular intervals" rather than annually.

Reference: pages 207-208.

Group-wide policy foundation: Code of Conduct, Quality and Environmental Policy, Supplier Manual, Supplier Code of Conduct. The Quality and Environmental Policy addresses "low-emission and low-waste production processes," managing air/water quality and responsible chemicals handling, owned by the VP Quality (reports to the COO). The Code of Conduct and Supplier Code of Conduct set requirements on air/soil pollution and handling substances of (very high) concern.

The Supplier Manual (accepted by "a majority of the Group's direct suppliers of materials") calls on direct material suppliers to adopt ISO 14001-based environmental management to avoid/reduce emissions, waste, wastewater and SoC/SVHC impacts; Supplier Quality Management (VP reports to the COO) reviews compliance. Group recognizes its influence "is limited, particularly in the upstream stages of raw material extraction and processing." Responsibility for the pollution topic sits across Quality, Real Estate & Facility Management, Production and Tooling, Purchasing & Supplier Quality Management, and Supply Chain Management.

Reference: pages 208-209.

Emissions at production sites: technical optimizations, modern exhaust-air systems and environmental analyses target NOx, mainly from thermal processes (actions detailed with time horizons under E1-2). Wastewater handling focuses on avoiding surface-water discharges and reducing pollutant loads.

Substances of concern: systematic internal-database recording, safety-data-sheet updates, hazardous-substance risk assessments and operating instructions under the German Hazardous Substances Ordinance.

Substances of very high concern (SVHC): a structured process covering assessment of environmental aspects, a register of applicable legislation (REACH, Hazardous Substances Ordinance), defined roles/responsibilities, defined implementation processes, compliant procurement specifications, and monitoring/internal audits; unavoidable SVHC use follows EU Directive 98/24/EC and TRGS 600.

"In the reporting year 2025, no additional measures beyond the established processes were implemented" - existing environmental analyses, the annual LkSG risk assessment, SVHC reviews and audits continued as planned. "At present, ElringKlinger does not have in place a Group-wide action plan" for pollution; actions remain decentralized by location.

Reference: page 209.

ElringKlinger has voluntarily set Scope 1/2/3 emission targets (cross-referenced to E1), but "has not defined measurable, outcome-oriented, and time-bound targets for other emissions into the air and water," citing the current absence of precise measuring technology; effectiveness of its emission-reduction measures "has not yet been systematically recorded or evaluated using defined indicators."

"ElringKlinger has not set a measurable, outcome-oriented, time-bound target for substances of concern and substances of very high concern." For SVHC the focus is "a risk-based assessment of individual cases and the continuous review of possible substitutes"; for substances of concern, "specific targets can only be determined in a subsequent step on the basis of the data collected for the first time." DNSH (EU Taxonomy) assessments of substance substitutability were carried out in 2025, particularly for battery/fuel-cell technology, on an annual basis.

Reference: page 210.

"In accordance with regulatory requirements, only emissions from facilities that exceed the thresholds of the European Pollutant Release and Transfer Register (E-PRTR) are relevant for reporting purposes. In the reporting year 2025, no machinery within the ElringKlinger Group exceeded these thresholds." For transparency, cumulative air-pollutant emissions from production plants are nonetheless reported: NOx 27,472 kg, SO2 492 kg, CH4 349 kg, N2O 37 kg (2025), calculated by multiplying fuel-specific primary-energy use by fuel-specific emission factors (individual-installation measurement "not yet possible").

No measurable, time-bound targets for specific air/water emissions have been set; the company instead "monitors the trajectory of its environmentally relevant emission parameters over time on the basis of calculated emissions." Appendix 3 (legislation datapoint table) accordingly marks the E-PRTR datapoint (paragraph 28) "Not material" (p.251) - a nil return consistent with the narrative, not an omission.

Reference: pages 210-212.

Substances of very high concern (SVHC), by main hazard class under REACH Art.57, kg/year: carcinogenicity 0.01, germ cell mutagenicity 0.01, reproductive toxicity 10.03, PBT 0.01, vPvB 0.18. All figures based on supplier disclosures under REACH Art.33(1) at or above the 0.1% weight-by-weight concentration threshold; SVHC use also occurs at three of four plants not connected to the central ERP system, estimated by standardized extrapolation.

Substances of concern (SoC), by hazard class, kg/year (aggregated, excl. SVHC): carcinogenicity 2,348; reproductive toxicity 71,249; skin sensitization 175,013; hazardous to the aquatic environment (chronic) 529,993; STOT RE 40,773; STOT SE 511. "ElringKlinger does not manufacture any substances of concern (SoC) or substances of very high concern (SVHC) itself; all purchased materials containing SoC or SVHC remain in the material cycle of the products and are delivered again with them." PFAS is used at one subsidiary for medical-sector applications only; "the types of PFAS used by ElringKlinger are neither substances of concern nor substances of very high concern." No microplastics were produced or used in 2025. Metrics are not externally validated beyond internal quality assurance.

Reference: pages 214-215.

"At present, the issue of material impacts, risks, and opportunities relating to biodiversity and ecosystems is not yet fully considered in existing corporate documents. ElringKlinger is therefore working on a transition plan to protect biodiversity and ecosystems, which is to be implemented in the short to medium term."

Biodiversity requirements are discussed only with direct suppliers, who must cascade them further upstream; "a systematic involvement of the upstream and downstream value chain therefore did not take place in the reporting year." No comprehensive biodiversity resilience analysis was conducted in 2025 ("planned for the medium term"), though site-level biodiversity risk was assessed via the WWF Biodiversity Risk Filter and proximity to Natura 2000/UNESCO/other protected areas alongside the climate risk analyses. "The results to date show that ElringKlinger's business model is fundamentally viable and robust," to be reinforced by targeted climate-adaptation investment and supply-chain transparency; the company will examine medium/long-term whether further adaptation measures are needed.

Reference: pages 214-215.

Conflict minerals: sourced from conflict-free regions "by maintaining a close dialogue with its suppliers and...transparent knowledge of the raw material sources," passed through the Supplier Manual, the Policy Statement on Human Rights, and associated environmental standards.

General environmental policies: the Quality and Environmental Policy and the Code of Conduct/Supplier Code of Conduct define "responsible land use, resource-conserving behavior, and compliance with environmental standards." ~72% of sites certified to ISO 14001; ~65% of European sites meet ISO 50001.

"In its materiality assessment, no relevant impacts were identified by ElringKlinger in respect of oceans and marine ecosystems or with regard to topics related to combating deforestation. Accordingly, no specific policies or intra-company approaches have yet been drawn up in these two areas" - the source for the "Not material" datapoint markers on E4-2 paragraphs 24(c) sustainable oceans/seas and 24(d) deforestation policies (p.251-252).

Reference: page 216.

Actions derive from the policies above and include environmentally compatible land use in construction (compliance with local building, noise and lighting regulations to minimize interference with sensitive habitats), a digital platform to monitor supply-chain sustainability/compliance risk, and recording of raw-material issues in the International Material Data System (IMDS). These rest on internal quality/environmental standards, the employee and supplier codes of conduct, the Supplier Manual, and ISO 14001/ISO 50001 certification, also used to raise upstream stakeholder awareness.

"Over the Group's course of business to date, there have been no situations requiring the implementation of a mitigation hierarchy. Similarly, ElringKlinger's current activities do not include any action on biodiversity offsetting, the protection of local and indigenous knowledge, or the use of nature-based solutions."

Reference: page 216.

"ElringKlinger has as yet not defined a measurable, outcome-oriented, and time-bound target in relation to biodiversity." Activity to date has focused on reducing the direct impact of the company's own operations; no targets have been set for the material upstream value-chain impact, attributed to "the existing database, which is still inadequate and does not currently provide the basis for a sound and reliable definition of targets." ElringKlinger "intends to further develop biodiversity-related matters on an ongoing basis and derive specific targets where necessary." "The effectiveness of the actions implemented is currently not systematically recorded or tracked by means of defined indicators."

Reference: page 216.

ElringKlinger owns, leases or manages ten sites covering around 44 hectares located in or near biodiversity-sensitive areas (Natura 2000, UNESCO World Heritage Sites, key biodiversity areas or other recognized hotspots) where its assessment identified negative impacts. Named sites/hotspots include Dettingen, Neuffen, Lenningen, Geretsried-Gelting, Runkel and Heidenheim (Germany, all in/near the Swabian Jura or adjacent hotspots), Piracicaba (Brazil, Atlantic Forest biome), Toluca (Mexico, Nevado de Toluca protection area), Karawang (Indonesia, Sundaland) and Qingdao (China, Qingdao-Rizhao coastal wetlands and islands).

The metric was determined by assessing site plans of all locations in or near key biodiversity areas; Real Estate & Facility Management prepares and validates it. "This metric is not subject to quality assurance by a competent external body." The biodiversity assessment additionally found "no direct cause-and-effect relationship" to land degradation/desertification or to impacts on threatened species from ElringKlinger's activities.

Reference: pages 219, 209 (Supplier Manual cross-reference).

Policies apply to ElringKlinger's own activities and to business partners/suppliers upstream. Suppliers must comply via the Supplier Code of Conduct and Supplier Manual, verified through the VDA 6.3 audit catalog and factored into procurement decisions. Own-business practice distinguishes conventional-drive products (selective resource-saving actions, "closed-loop approaches" returning materials to production via reuse/recycling) from new/alternative-drive products (battery, fuel cell), where circular principles are built into development from the outset; biological materials are used "only to a limited extent" due to customer material specifications.

"The aim of ElringKlinger's policies is to reduce the environmental impact over the entire life cycle of its products and to establish resource-saving and fully circular product solutions over the long term." Responsibilities follow GOV-1.

Reference: pages 219-220.

Three key areas of action, each at a different implementation stage: incorporating sustainability criteria into product development (medium-term), improving data transparency over materials used (short-term), and communicating resource-use/circular-economy requirements to the upstream supply chain (medium-term); central responsibility for waste management is also planned short-term. The circular-economy distinction is by business: components business (combustion-engine focus) emphasizes product recyclability; systems business (alternative drives) aims to "comprehensively integrate circular principles into its proprietary solutions."

In 2025 ElringKlinger "began to improve data transparency over resource inflows, especially raw materials." "As an integral or planned element of ongoing business activities, the actions described do not currently give rise to any significant current or future capital expenditure (Capex) or operating expenditure (Opex) for which separate disclosure would be required."

Reference: page 220.

"To date, no specific strategic targets have been set for resource use and the circular economy. The intention is to develop appropriate targets over the medium term." Until targets are set, effectiveness of actions is tracked "through existing data analyses," with planned actions adopted by internal resolution "to ensure continuous refinement of and preparations for future target-setting." No quantified metric or deadline accompanies this intention.

Reference: page 220.

Material resource inflows are the Scope 3 commodity groups Steel, Aluminum, Plastic Granules (Pellets), and Stamped & Deep Drawn Parts; Logistic Services & Equipment (incl. packaging) and Capital goods are "of minor importance." Total weight of technical and biological materials used in 2025: ~99,950 tonnes (direct materials/components; biological share negligible), derived from incoming-goods postings with revenue-based extrapolation. Recycled share: ~22,229 tonnes, ~22% of total weight, estimated by internal commodity-group experts. No reused products/materials were used in 2025 ("unnecessary to distinguish between reuse and recycling").

Critical raw materials (by weight, principal items): talc, magnesium, cobalt; rare earths - neodymium, cerium dioxide, lanthanum oxide (from the International Material Data System, IMDS). Water inflow was 216,663 m3 in 2025; "ElringKlinger does not operate any water-intensive processes and has therefore classified its own water inflow and outflow as not material overall."

Reference: pages 220-222.

Revenue by segment relevant to resource outflows: Original Equipment 68.1%, Aftermarket 23.1%, Engineered Plastics 8.8%. Product durability by business unit: Metal Sealing Systems & Drivetrain Components / Metal Forming & Assembly Technology gaskets/seals >15 years (aluminum/steel, easily recyclable, not repairable); Lightweighting/Elastomer Technology - elastomer-based materials "difficult to recycle" though metal bases of metal-elastomer gaskets are recyclable, thermoplastic covers designed for >15-year durability; E-Mobility cell-contacting systems 10-15 years, "generally not repairable"; Engineered Plastics 2-10 years, PTFE-containing products "severely limited" recyclability versus generally recyclable high-performance thermoplastics.

Packaging follows customer specification (disposable film/cardboard, largely recyclable; reusable wood/metal/plastic, customer-owned). Recyclable-content estimates reference the EU End-of-Life Vehicles Directive 2000/53/EC (85% material recoverability, 95% incl. energy recovery), though ElringKlinger's own material mix (steel, aluminum, plastics - "generally easily recyclable") differs from a whole vehicle's. See E5-5-Waste for waste-generation metrics.

Reference: page 222.

Waste generated in 2025 (tonnes): total 35,310; non-hazardous 33,905 (diverted from disposal: reuse 194, recycling 30,712, other recovery 227; disposal: incineration 1,636, landfill 880, other 257); hazardous 1,405 (diverted: reuse 36, recycling 499, other recovery 15; disposal: incineration 352, landfill 298, other 205).

Non-recycled waste: 4,099 tonnes (11.6% of total generated). "There is no radioactive waste." The three principal waste types are metal/aluminum residues from punching/stamping and forming technology, and paper/paperboard packaging. Waste data are captured from primary sources (invoices, weights, waste-facility records) where available, with reliable estimates used for a small unmeasured proportion. "At present, no effectiveness check is carried out for the metrics presented in this section...neither are the measurements and assessments available thus far validated by an external body independent of the internal quality."

Reference: pages 225-227.

ElringKlinger aligns policies with international standards (implicit reference to ILO/UNGP framework, detailed under S2-1) and publishes a Policy Statement on Human Rights and Related Environmental Standards addressing German Supply Chain Due Diligence Act (LkSG) requirements, covering "Equal treatment and equal opportunities for all" and "Working conditions" sub-topics and extending to own workforce, value-chain workers and affected communities/indigenous peoples; the VP Legal & Compliance owns and develops it.

Code of Conduct: prohibits discrimination "on account of personal characteristics such as ethnic origin, skin color, age, gender, sexual orientation, disability, religion, nationality, trade union membership, or political views," reportable via the "Share with us" whistleblower system.

"At present, ElringKlinger has no formalized policy commitment relating specifically to the promotion or inclusion of particularly vulnerable employee groups within its workforce"; the company states it is nonetheless "firmly in favor of equal treatment, non-discrimination, and workplaces free of harassment." A dedicated occupational safety policy, published on the Group website, underpins material health-and-safety IROs; the Quality unit manages it.

Reference: page 226.

Engagement channels: company and "town hall" meetings, regular works council/plant-manager dialogue, global staff surveys, anonymous feedback channels, and Management Board "fireside chats." Site-specific company agreements and continuous intranet/notice/social-media communication support transparency "especially regarding the ongoing transition in the automotive industry." Employees are also engaged on flexible working, part-time and parental-leave design via the 2023 global staff survey and annual appraisal feedback; Disabilities Officers and Equal Opportunities Officers, plus company doctors, channel feedback from vulnerable groups.

"Ultimate operational responsibility for these processes lies with the CEO and the Vice President Human Resources, who ensure that employees' views are assessed systematically and incorporated into strategic decision-making."

Reference: page 227.

"Although ElringKlinger's materiality assessment did not identify any material negative impacts on its own workforce," the Group maintains (occupational) safety management systems, health management, compliance/human-rights policies and grievance channels open to employees and externals for reporting human-rights violations. The "Share with us" digital whistleblower system (detailed under G1-1) allows confidential and anonymous reporting; every report receives a prompt initial assessment and case-specific investigation, monitored to full resolution, feeding regular compliance evaluations.

Structured procedures include six-monthly risk assessments, established management systems (cross-referenced to S1-3/E1-2), and recertification/communication cycles (cross-referenced to S1-2). Effectiveness is evaluated via employee feedback and internal/external reporting.

Reference: pages 227-230.

HR adjustment measures (STREAMLINE program): capacity downsizing at all Group sites under a "double voluntary action" principle, using severance and early-retirement models; employee representatives were involved in setting up the program, and affected staff receive one-to-one consultations with project specialists.

Occupational health and safety: a plant-specific approach targeting accident prevention amid climate-related heat stress; all occupational accidents are logged centrally with root-cause analysis feeding continuous improvement.

Work-life balance: flexible working models, part-time options and parental leave, shaped by the 2023 staff survey and annual appraisal feedback.

Equality, diversity, pay equity and whistleblower protection: covered under SHAPE 30 and the Code of Conduct.

"Several measures were launched during the reporting year...No information can currently be provided on Capex or Opex expenditure; the measures will be implemented in the normal course of business activity." Effectiveness is assessed qualitatively via processes and feedback loops, with "no plans to measure it quantitatively as well" at present.

Reference: pages 230-231.

HR adjustment measures target: an annual saving of at least EUR 30 million in staff costs from FY2026 onward, tied to the STREAMLINE program; employee representatives were involved in setting the target, monitored via controlling/reporting processes tracking staff-cost trends.

Occupational health and safety target: reduce occupational accidents per million hours worked Group-wide by 10% year-on-year in 2025; the outturn was 8.5 accidents per million hours, a 14.0% improvement, "signals that the strategic target has been exceeded." Set in consultation with employee representatives, applies to all Group sites/regions.

"No specific targets were set in the reporting year for any of the other material impacts, risks, or opportunities; these are currently being managed via actions and processes, with plans in place to define targets in the medium term."

Reference: pages 231-233.

Headcount at Dec 31, 2025 (ESRS definition): 8,946 (male 6,087, female 2,859). By contract: permanent 7,955, temporary 991 (11.1% of total); by hours: full-time 8,060, part-time 595, non-guaranteed-hours employees 0. Employee turnover: 18.2% of average headcount (includes natural departures; excludes temporary agency workers). Significant-employee country: Germany, 4,325 employees (only country meeting the >=50 employees / >=10% threshold disclosed).

Metrics use headcount (not FTE) and the period average unless stated; both local Group-company HR systems and central HR Controlling feed the data, which is "analyzed in accordance with a uniform set of rules." "The metrics in the overall ESRS S1 section have not been validated by an external body other than that responsible for quality assurance."

Reference: page 233.

Gender distribution at the top-management level (the two management levels below the Management Board and Supervisory Board): male 321 (83.6%), female 63 (16.4%), other 0.

Age distribution (excluding temporary agency workers): under 30 - 1,362 (15.2%); 30-50 - 5,152 (57.6%); over 50 - 2,432 (27.2%). Methodology follows the S1-6 approach.

Reference: page 233.

Training hours (2025): male 51,133 hours (8.4 avg/employee); female 17,702 hours (6.2 avg/employee); Group total 68,835 hours, 7.7 average per employee (based on Dec 31, 2025 headcount). A digital learning/training-management system calculates the data.

Performance and career reviews: 4,943 employees reviewed out of the population covered, a 55.3% Group participation rate (male 3,623, female 1,320); the parent company ElringKlinger AG rate was 56.6%; actual reviews versus agreed reviews ran at 95.9%.

Reference: page 234.

"The health and safety metric from ESRS S1-14 included in the report is calculated based on a company-specific definition that differs from that used in ESRS"; scope is limited to salaried employees in this first reporting year, and "no information on work-related illnesses and days lost due to occupational injuries and deaths has been disclosed in the first reporting year," with plans to expand scope for FY2026.

"The percentage of ElringKlinger employees covered by an occupational health and safety management system in accordance with the standard ISO 45001 stands at 92.0%." Recordable occupational accidents: 131; accident rate 8.5 per million hours worked (-14.0% year on year); fatalities: 0. 70 occupational accidents related to ElringKlinger AG specifically. Data comes from a global EHS software package following a uniform incident structure. Datapoints for days lost (88e) are noted as "omitted in part" under the Appendix C transitional table (pp.247-248) because the days-lost reporting system "is currently still being developed."

Reference: page 234.

Unadjusted gender pay gap (2025): 24.3% - the raw salary difference between male and female employees before controlling for job role or experience, based on gross annual earnings (gross monthly pay incl. all allowances, divided by contracted hours) across all employees except temporary agency workers, apprentices, working students, interns, marginal part-time and partially-retired staff. "Since this was the first reporting year in which the metric was recorded, there are not yet any associated actions for this period."

CEO pay ratio: 51.4 - the ratio of the highest-paid individual's total annual remuneration to the median total annual remuneration of the same population used for the gender-pay-gap calculation (excluding the highest-paid individual).

Reference: pages 234-235.

"No human-rights-related complaints whatsoever were submitted in the 2025 reporting year via channels that the undertaking's employees can use to raise concerns. Neither were any cases of discrimination, including harassment, reported for the 2025 financial year." No fines, sanctions or compensation payments were imposed, and no reports were filed with OECD National Contact Points.

The parameter is a Group-wide analysis of reports via established whistleblower/grievance channels, limited to reflecting only reported incidents. Despite the nil return, ElringKlinger maintains preventive measures - ongoing grievance-channel development, human-rights/discrimination training, and defined breach-handling processes - "to ensure that an effective, standardized procedure can be called on should any reports be filed in the future."

Reference: pages 237-239.

ElringKlinger's human-rights framework (Code of Conduct for employees and suppliers, Policy Statement on Human Rights, LkSG-driven annual risk assessment, reporting channels) applies to value-chain workers. The Supplier Code of Conduct and Policy Statement on Human Rights are both publicly available, prohibit child and forced labor (defined to include slavery, bonded labor, trafficking and compulsory work), and align to ILO standards, the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises.

Regular audits of direct suppliers verify compliance; "the company did not become aware of any cases in which a supplier violated ElringKlinger's guiding principles or the international standards specified during the reporting year." No global blanket agreements or agreements with international trade union confederations on value-chain-worker human rights exist; the VP Strategic Communications and Corporate Sustainability, reporting to the CEO, owns strategy delivery.

Reference: pages 239-240.

ElringKlinger contracts directly with direct and indirect suppliers through a structured lifecycle: identification/qualification, selection, ongoing assessment, development, and (if needed) phase-out. Dialogue frequency scales with supplier risk profile, commodity group and status, more frequent for strategically important or high-risk suppliers; supplier sustainability views are sought and considered in contract-award decisions.

Risk-based on-site audits use the VDA 6.3 questionnaire with an appended sustainability section; auditors received training on the sustainability section in 2025 "to raise awareness and establish a common understanding." Audits specifically probe the situation of vulnerable groups (young workers, women, people with disabilities). "ElringKlinger does not currently offer its suppliers any training with regard to engaging with stakeholder views."

Reference: pages 240-241.

The Group-wide grievance procedure (described under G1-1, the "Share with us" system) is "also open to all workers in the value chain." The Supplier Code of Conduct entitles ElringKlinger, commissioned third parties and customers to audit supplier compliance, restricted to Code-of-Conduct-relevant documents and conducted "in compliance with applicable data protection regulations" with prior notice.

The VP Purchasing and Supplier Quality Management (reports to the COO) owns operational implementation. Effectiveness assessment tools include quality metrics, auditors' reports, target agreements and target reviews, plus signals from grievance-channel reports. Risk-based on-site audits (VDA 6.3, sustainability appendix) are the Group's main channel for gaining insight into value-chain workers' views.

Reference: pages 240-241.

ElringKlinger addresses the identified S2 impacts (job creation, transparency, compliance) partly via the product-portfolio transformation toward climate-friendly technologies, which the report frames as securing employment for the Group and its suppliers. Preventive/remedial measures embed in the CMS and Group-wide risk-management process, with regular direct-supplier audits of workplace safety, fair remuneration, working hours and freedom from discrimination.

"In the 2025 reporting year, no severe human rights incidents or problems requiring remedy were identified within ElringKlinger's upstream and downstream value chain." "The Group has also not yet prepared an action plan concerning further implementation of due diligence obligations in the fields of human rights and the environment" - CapEx/OpEx data cannot currently be provided, though a plan is intended "in the medium term." As this is ElringKlinger's first CSRD-compliant report, "the Group is not yet referencing earlier reporting periods."

Reference: page 242.

"The ElringKlinger Group has no outcome-oriented and time-bound targets for the management of impacts, risks, and opportunities with regard to workers in the value chain at the time of writing, as the relevant reporting is still being established." Effectiveness is instead tracked through Supplier Quality Management processes: monthly monitoring of Supplier Code of Conduct acceptance, reported internally.

2025 metrics: Supplier Code of Conduct (drawn up 2023) accepted by 61.9% of direct suppliers and 17.0% of indirect suppliers; 165 supplier audits covering sustainability aspects were carried out. Whistleblower-system reports are also treated as an effectiveness indicator, since a report itself evidences employee awareness of the channel.

Reference: pages 244-246.

"Corporate Culture" is one of five SHAPE 30 success factors; values-setting workshops, town-hall meetings and management dialogues shape and review it. The Compliance Management System (CMS) rests on IDW Auditing Standard 980's seven elements (culture, objectives, organization, risks, program, communication, monitoring/improvement) and covers antitrust law, anti-money-laundering, conflicts of interest, privacy/data protection, human rights, and corruption/bribery. "In 2024, the CMS was reviewed in terms of its design and structural adequacy in the areas of anti-corruption and competition law. In 2025, an effectiveness review was carried out for the same areas, which confirmed the practical implementation and effectiveness of the management and control mechanisms for this system."

The Code of Conduct covers environmental protection, climate action, human rights, fair business practices, privacy, data protection, equal treatment and conflicts of interest. The "Share with us" digital whistleblower system, run by an independent third party, is open to the general public including suppliers and affected communities, guarantees confidentiality/anonymity, and is governed by the German Whistleblower Protection Act (transposing EU Directive 2019/1937). 95.5% of employees subject to mandatory training held a valid compliance-training certificate (3,794 employees) as of Dec 31, 2025.

Reference: pages 246-247.

The CMS's anti-corruption controls include separation of duties, the dual-control principle for material decisions, and reporting channels shared with the general compliance system. The compliance organization (organizationally independent, reporting to the CCO) documents all incoming reports, investigates promptly and objectively, and gives feedback within three months where contact details are known. The CCO notifies the CEO and the Audit Committee of the Supervisory Board of all reports and incidents, ad hoc and at scheduled meetings.

Prevention: early employee sensitization via onboarding and the compulsory training program (95.5% certification rate, see G1-1), reinforced by irregular advanced training for exposed teams such as Purchasing and Sales, covering case studies and industry-specific white-collar-crime risks.

Back-filled from G1-4 (Metrics and targets), where this content is disclosed in the FY2025 report (page 247). This disclosure requirement did not exist as a standalone item under the 2023 ESRS the report was prepared against; under 2023 numbering it fell within MDR-T (part of MDR-T/GDR-T disclosures).

"ElringKlinger has not set any targets in relation to the prevention of corruption or bribery. This is because no additional management measures have been identified so far due to a very low level of risk and an absence of incident."

The report substitutes the MDR-T "effectiveness tracked" limb for a target: "ElringKlinger is not aware of any breaches associated with corruption or bribery in the parent company or any subsidiaries in 2025. Neither were any fines imposed. Thus the ElringKlinger Group deems the procedures set out in the section on ESRS G1-3 regarding preventing, uncovering, and combating allegations or instances of corruption and bribery to be effective, meaning that no further action had to be taken."

Reference: page 247.

"ElringKlinger is not aware of any breaches associated with corruption or bribery in the parent company or any subsidiaries in 2025. Neither were any fines imposed." The Group treats the absence of incident as evidence that its G1-3 prevention/detection procedures "are...effective, meaning that no further action had to be taken."

No confirmed incidents, disciplinary actions, contract terminations or legal cases relating to corruption/bribery are disclosed (none occurred). The Appendix B legislation-datapoint table (p.253) carries the corresponding "24(a) Fines for violation of anti-corruption and anti-bribery laws" and "24(b) Standards of anti-corruption and anti-bribery" datapoints against this section, with no "Not material" marking (i.e. addressed, with a nil outcome).