EnBW Energie Baden-Württemberg AG

Role of the Board of Management and Supervisory Board

Reference: pages 138-139.

Responsibilities and governance processes comply with statutory requirements. The integrated opportunity and risk management system, under the responsibility of the CFO, takes "a holistic and integrated approach to effectively and efficiently identify, evaluate and manage opportunities and risks."

Composition: the Supervisory Board of EnBW AG has 20 members, half shareholder representatives and half employee representatives under the German Co-determination Act (MitbestG). 95.0% of Supervisory Board members are independent. Diversity: Supervisory Board 35.0% women / 65.0% men (unchanged from 2024); Board of Management 20.0% women / 80.0% men (unchanged).

Training on sustainability matters is provided to both bodies regularly, and both can draw on the sustainability department, accounting department and relevant functional units. The Supervisory Board "took full account of the objectives for its composition during the reporting period with respect to both its overall composition and appropriate coverage of its competency profile."

Consultation by the Supervisory Board and Board of Management on sustainability matters

Reference: pages 139-140.

The Board of Management and Supervisory Board "are informed about relevant sustainability matters on a regular basis and then decide on how to address them." In 2025 the Board was informed about progress on the Sustainability Agenda and reporting under the Supply Chain Due Diligence Act (LkSG).

Sustainability matters and questions generally go through the Sustainability Committee, comprising the heads of the business and functional units, meeting at least twice a year, headed by the Chairman and Deputy Chairman of the Board of Management. A central sustainability department reports directly to the Chairman of the Board of Management. The finance, investment and sustainability committee of the Supervisory Board prepares investment decisions where "economic, strategic and sustainability-related factors must be considered," meeting when necessary.

Integration of sustainability-related performance in incentive schemes

Reference: pages 139-140.

Sustainability matters are incorporated into both the Short Term Incentive (STI) and Long Term Incentive (LTI) for the Board of Management. The preliminary STI (based on financial indicators) is adjusted qualitatively by a factor of 0.7 to 1.3.

Variable remuneration under the LTI is also subject to sustainability criteria: "the calculation is performed using two to a maximum of four sustainability performance indicators," covering ESG components including climate-related considerations, such as renewable energy expansion targets and the LTIF safety indicator. Since the 2022-2024 LTI period, between 50% and 70% of variable remuneration is attributed to the EBT financial indicator and correspondingly between 50% and 30% to sustainability performance indicators. At present, "no climate-related considerations are included in the remuneration of the Supervisory Board."

Statement on due diligence

Reference: page 140.

EnBW maps the core elements of due diligence to sections of the combined management report and sustainability statement:

The statement is presented as this reference table rather than narrative text.

Risk management and internal controls over sustainability reporting

Reference: page 140.

EnBW's risk management and internal control systems for sustainability reporting are presented in the Report on opportunities and risks, in the sections "Principles of the integrated opportunity and risk management system," "Structure and processes of the integrated opportunity and risk management system" and "Structure and processes of the accounting and sustainability-related internal control system." The disclosure is a cross-reference to those sections of the general management report rather than a standalone narrative within the sustainability statement itself.

Strategy, business model and value chain

Reference: page 141.

EnBW is "one of the largest integrated energy companies in Germany and Europe," supplying electricity, gas, water and heat plus energy and infrastructure products and services. 2025 revenue was EUR 34,390.0 million (2024: EUR 34,524.4 million), split across electricity (EUR 16,964.1m), gas (EUR 14,470.7m), energy/environmental services (EUR 2,182.7m) and other (EUR 772.5m). EnBW is also active in the "gas" fossil fuel sector.

Upstream value chain: exploration, development, production, import, conversion, transport and storage of energy sources. Downstream: provision and sale of energy to private, commercial and industrial customers, plus smart infrastructure (fast-charging, telecommunications, household solutions).

31,541 employees (2024: 30,391). The Sustainability Agenda is "an integral component of our corporate strategy."

Interests and views of stakeholders

Reference: pages 141-142.

Key stakeholders include the capital market, customers, local authorities, policy-makers, the public and media, civil society, industrial partners and employees. The HR strategy "People as the main focus" takes employee needs into account; the central works council discusses sustainability matters.

A Stakeholder Committee (internal experts from relevant departments) has met once a year since the 2024 financial year; the accounting and sustainability departments coordinate and document meetings and evaluate feedback, guided by a Stakeholder Engagement Policy. "We did not identify any additional material matters in 2025 by engaging with our stakeholders."

The Supervisory Board is kept informed of stakeholder views, supported by sustainability and other experts, with the Chairman of the Supervisory Board available to talk with investors as recommended by the DCGK.

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

Reference: pages 142-150.

"The actual and potential impacts identified influence the focus areas of our Sustainability Agenda within the framework of our strategy." EnBW presents its material IROs in three tables by ESRS 2 area (Environment, Social, Governance), each row tagged with a type symbol (+ actual positive, (+) potential positive, - actual negative, (-) potential negative, ! risk) and a page reference into the topical chapter, and mapped to the three business segments (Sustainable Generation Infrastructure, System Critical Infrastructure, Smart Infrastructure for Customers).

Changes versus the prior year (page 146): E1 impacts were combined into one; the wastewater-treatment impact was dropped as no longer material; one E5 impact was moved from E1; one S1 impact was split in two; the SENEC-related S4 impact/risk was removed and the telecommunications impact dropped as no longer material.

Description of the materiality assessment

Reference: pages 146-150.

EnBW uses ESRS 1 Appendix A AR 16 as the basis, applying "a top-down approach with a subsequent bottom-up validation" across the three segments Sustainable Generation Infrastructure, System Critical Infrastructure and Smart Infrastructure. A four-point rating scale is used for severity/likelihood; an impact "reached or exceeded a threshold value of 3" is classified material. A four-step decision process: department-level identification, central evaluation, Group-company survey/validation, then determination of relevant disclosure requirements.

Climate risk methodology (pages 147-148): site-specific analysis on the CMIP6-based climate risk platform using RCP 2.6, 4.5 and 8.5; time horizons short (reporting year), medium (to 2040), long (to 2050). In 2025 a full climate risk analysis was carried out for all open-field PV plants for the first time, finding "high resilience to climate-related risks." Transition risks use RCP 2.6 (1.5°C, limited overshoot) in energy price modeling. Net zero targeted for own operations by 2040 and the value chain by 2050.

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Disclosures covered by the sustainability statement

Reference: page 150.

"Based on the results of the materiality assessment, we determined the material matters in accordance with ESRS 1 Appendix A AR 16. When an impact, risk or opportunity reached or exceeded the threshold value of 3, we classified this impact, risk or opportunity and the associated sustainability matter as material and included it in the reported standards, disclosure requirements and datapoints."

EnBW presents a full content index, "Reported disclosure requirements pursuant to ESRS 2 IRO-2" (pages 226-228), listing each covered standard and disclosure requirement with its page reference, plus a separate table "Datapoints deriving from other legislation pursuant to ESRS 2 IRO-2" (pages 228-230) marking individual Appendix B datapoints Material/Immaterial and flagging any use of the phased transitional provision.

Transition plan for climate change mitigation

Reference: pages 151-154.

EnBW "regularly publishes an update to our Climate Transition Plan - most recently in November 2025," approved by the Board of Management. Reduction paths follow current SBTi standards for a 1.5-degree-aligned path across all three Scopes; intermediate targets to 2035 are SBTi-validated, and the long-term 2040/2050 targets were assessed by Moody's as 1.5-degree-aligned, based on IEA scenarios.

Decarbonization levers: restructuring the generation portfolio (renewables, coal phaseout by 2028 "provided the relevant framework conditions are met"), green electricity certificates for grid-loss Scope 2, and Scope 3 levers such as substitute gas products and heat-pump alternatives to natural gas.

Locked-in emissions: to 2030, mainly from coal-fired thermal plants still operating; from 2040, mainly two thermal waste-treatment plants, where CCS is "currently being examined."

"As climate change mitigation is being taken into account in the currently ongoing restructuring of our company, we do not have any special financial planning for the climate change mitigation actions defined in the transition plan" (page 154).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 147-148). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk is assessed via a validated climate risk platform based on the IPCC's CMIP6 climate models, using RCP 2.6, 4.5 and 8.5, with "an average plausible scenario and a high-risk scenario as the 'worst case.'" Time horizons: short term (reporting year), medium term (to 2040), long term (to 2050). In 2025 EnBW carried out a full climate risk analysis for all open-field PV plants for the first time, applying the same methodology to a representative sample of other generation types and locations "in accordance with the EU taxonomy," finding "a high resilience to climate-related risks."

Transition risk uses RCP 2.6 (1.5°C, limited overshoot) within energy price modeling that feeds "Assessment of the robustness of our business model against the background of climate change." Related: EnBW targets net zero for own operations by 2040 and the full value chain by 2050 (page 148).

Resilience in relation to climate change

Back-filled from ESRS 2 IRO-1 and E1-3 Actions and resources (pages 148, 156). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

EnBW states its actions are derived "among other sources, from our resilience analysis conducted as part of the Assessment of the robustness of our business model against the background of climate change." Following the 2025 climate risk analysis of open-field PV plants and a representative sample of other generation and grid locations, the report concludes there is "a high resilience to climate-related risks," attributed to systematic consideration or exclusion of risks during planning and the decentralized distribution of generation plants, which "reduces the relative individual risk considerably."

The transition plan builds resilience actions into its scope, including preventive and adaptation measures; in 2026 the analysis is planned to expand to all EU-taxonomy-relevant generation locations, then the grid portfolio.

Policies related to climate change mitigation and adaptation

Reference: page 155.

The Environmental & Climate Action Policy describes underlying targets and principles for climate change mitigation and adaptation, including "aligning our activities with the latest scientific findings and the goals of the Paris Agreement" and complying with the mitigation hierarchy. The policy applies Group-wide; implementation responsibility sits with each Group company, with a management officer for environmental protection reporting to the responsible Board of Management member.

Group companies with environmentally relevant activities operate environmental management systems under EMAS or ISO 14001; 76.8% of employees work in Group companies validated/certified this way (2024: 75.8%). The Climate Transition Plan adds specific targets, strategy, governance and how transitory and physical climate risks are handled.

Actions and resources in relation to climate change policies

Reference: pages 156-158.

A table of material actions/technologies with implementation status: conversion to renewables, RE uptake, hydrogen uptake and electrification are all "In progress"; CCU/CCS is "Under examination"; SF6 replacement and process optimization are "Under examination / pilot projects."

Key action: expansion of renewables and dispatchable/battery capacity, including the He Dreiht offshore wind farm and a planned 400 MW / 800 MWh battery storage system at Philippsburg Energy Park. Coal phaseout targeted by 2028; the Lippendorf lignite stake was sold in December 2025. First hydrogen-ready gas plant (Stuttgart-Münster, 124 MWel) commissioned April 2025. SF6 reduction pilots at TransnetBW and Netze BW; methane-leak reduction at ONTRAS (mandatory EU Methane Regulation measurements since 2024) and terranets bw (own mobile compressor, ~80% reduction).

Targets related to climate change mitigation and adaptation

Reference: pages 158-163.

Base year 2018. Net zero targets announced in 2025: Scope 1 and 2 net zero by 2040 (at least 95% reduction, residual offset by removals); Scope 3 net zero by 2050 at the latest (at least 90% reduction). Interim: Scope 1/2 generation emission intensity -87.4% by 2035, -97.7% by 2040; remaining Scope 1/2 (mainly grid operation) -71.4% by 2035, at least -90% by 2040; Scope 3 sold-electricity intensity -87.4% by 2035, -98.1% by 2040; Scope 3 use-of-sold-products/upstream -71.4% by 2035 (raised from 42.5%), net zero by 2050 at the latest.

2025 progress: operations (Scope 1+2) down to 2.2 million t CO2eq (2024: 2.1 million t, base 2018: 2.3 million t) — an 11.6% reduction since 2018. Targets were "formally adopted by the Board of Management and acknowledged by... the Supervisory Board," with subsidiary-level targets (TransnetBW, SWD) supplementing the Group target.

Energy consumption and mix

Reference: page 164.

"Total energy consumption increased to 40,098 GWh (2024: 32,015 GWh)," driven mainly by higher primary-energy use in coal power plants; the renewable share of total energy consumption fell from 11.5% to 9.4%. "All of EnBW's economic activities are in high climate impact sectors," NACE categories D (Energy supply) and E (Water supply; sewerage; waste management).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 165-168.

Scope 1 rose because thermal generation plants were deployed more due to market prices/availability. Scope 3 is dominated by category 3.11 (use of sold gas/coal, 24,300 thou. t) and 3.1/3.2 (purchased goods/upstream gas and coal, 4,227 thou. t). Material Scope 3 categories: six of 15, above a 100,000 t CO2eq threshold; categories 3.10 and 3.14 excluded as immaterial. CO2 emissions avoided: 9,704 thou. t CO2eq (2024: 10,815), mainly hydropower and offshore wind.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 169-170.

"At the EnBW Group and within its downstream and upstream value chain, there are currently no GHG removals from the atmosphere with subsequent permanent storage." Carbon credits are used at a "relatively low level" to offset end-user emissions and to achieve climate neutrality at certain Group companies (Netze BW, certified per ISO 14068-1 for 2024; Netze-Gesellschaft Südwest) or business areas (TransnetBW, targeting Scope 1/2 neutrality by 2035, Scope 3 by 2045).

2025: 794,268 t CO2eq of carbon credits outside the value chain cancelled (2024: 346,951 t); a further 517,655 t planned for cancellation. Credits must be Verified Carbon Standard (Verra) or Gold Standard certified, scalable, diverse in action type and no older than five years; from 2040 EnBW will switch to removals and long-term storage for residual Scope 1/2 emissions instead of credits.

Internal carbon pricing

Reference: page 170.

EnBW does not operate a formal internal carbon pricing scheme. Instead, "as part of its investment planning, EnBW analyzes the impacts that new projects will have on the reduction targets and greenhouse gas budget (Scopes 1-3)," to ensure compliance with the greenhouse gas budget across the generation portfolio. Within the Group strategy, the impacts of different investment options on EnBW's climate targets — reduction paths and greenhouse gas budget — are analyzed. "This approach ensures compliance with our climate change mitigation targets as an alternative to a carbon pricing scheme."

Policies related to pollution

Reference: pages 171-172.

Materiality is scoped to two E2 sub-topics: "we therefore identified the topics of air pollution and substances of very high concern as material sustainability matters" (radioactive waste is instead disclosed under E5).

The EnBW Pollutants Management Policy, anchored in Sustainability Agenda measure 8, lays down principles for reducing air pollutant emissions; the central lever is the fuel switch from coal to natural gas and later hydrogen at Altbach/Deizisau, Heilbronn and Stuttgart-Münster, alongside best-available-technique flue gas cleaning until then. For substances of very high concern, EnBW Kernkraft has a holistic policy for hazard/emergency management during nuclear dismantling. On water/soil: "contamination of water or soil is not material for EnBW compared to air pollution," as impacts are not continuous or significant and PRTR reporting thresholds are not exceeded.

Actions and resources related to pollution

Reference: pages 172-173.

Air pollution mitigation at coal and waste incineration plants: dust separation (electric and fabric filters), flue gas desulfurization and denitrification, and mercury precipitation dosing; new combined cycle gas turbine plants add SCR catalytic converters for NOx. "Substantial resources" and "generous project budgets" are allocated for these and for new/modernized wastewater cleaning systems. Certified experts carry out regular inspections under section 29a BImSchG and section 53 AwSV, alongside authority inspections and internal audits.

For substances of very high concern, EnBW Kernkraft uses cleaning and filtration processes with continuous emissions monitoring to comply with license limits, plus radiological exhaust-air cleaning and mechanical/chemical wastewater treatment.

Targets related to pollution

Reference: pages 173-174.

Voluntary targets tied to the Group strategy for the gradual fossil-fuel phaseout, for the period through 2030:

EnBW "exceeded" its 2025 SO2 and NOX targets. SO2 and NOX intensity fell 62% and 39% respectively versus the 2018 base year (295 and 337 mg/kWh). "Apart from air pollutants... there are currently no defined targets for use-specific reductions of substances of concern, with the exception of the substitution requirement for hazardous substances."

Pollution of air

Reference: pages 174-175.

Pollutant Release and Transfer Register (PRTR) emissions to air, 2025 vs 2024:

Particulate matter was "< TV" (below the PRTR threshold value) in both years; it is reported voluntarily "despite the fact that our emissions are currently below the threshold value." Emissions from "large combustion plants and waste incineration plants" are expected to decline as fossil generation is reduced; the E2-4 Appendix B datapoint is separately flagged as using the phased transitional provision even though the DR itself is reported (page 229).

Substances of concern and substances of very high concern

Reference: pages 175-176.

"Material substances of concern are produced at EnBW in the form of emissions during the operation of coal power plants" — nitrogen oxides, arsenic, mercury and particulate matter, plus other PRTR substances under E2-4. Substances of very high concern are reported separately, under radioactive waste in E5.

The figure "includes the PRTR substances that can be assigned to the main hazard classes according to CLP." The 2024 comparative has been restated.

Policies related to water and marine resources

Reference: pages 176-177.

Material sub-topic: "we therefore identified the topic of water discharge in connection with our own operations as a material sustainability matter," specifically discharge of heated cooling water at thermal power plant sites.

The EnBW Water Management Policy, derived from Sustainability Agenda measure 8, covers analysis of water-stress areas, water management, water-saving technologies, monitoring/audits, wastewater management, water risk management, employee training and supply-chain water management. Key lever: the fuel switch from coal to gas and later hydrogen at Altbach/Deizisau, Heilbronn and Stuttgart-Münster power plants. Water management authorization sits with public authorities; EnBW operates within authorized water management plans under a monitored approval/measurement/verification system. Marine resources relevance is limited to offshore wind siting.

Actions and resources related to water and marine resources

Reference: page 177.

Actions within the environmental management system: appointed water protection officers, regular authority monitoring plus third-party sampling/analysis, and water withdrawal logbooks for verification and documentation.

To counter heated cooling water discharge, EnBW uses modern cooling systems (air coolers, newer/efficient plants, combined heat and power) to reduce thermal burden versus older direct-flow cooling, and has developed a water/heat/oxygen management system with authorities for high-temperature, low-water-level summer periods. Roughly 60% of water-material generation locations sit in areas of high water stress per the WWF Water Risk Filter (October 2025), but account for only ~15% of total withdrawal; ~97% of cooling water withdrawn is returned to the river. No location-specific water-stress protection policy has therefore been established.

Targets related to water and marine resources

Reference: pages 177-178.

Two voluntary, Group-wide targets:

The 2025 wastewater target was met (25 l/kWh, within the 22-25 range); intensity was 19% below the 2018 base year (31 l/kWh) despite the year-on-year rise, which reflects higher fossil-source generation and lower renewables generation in 2025. Effectiveness is "monitored annually within the framework of the environmental management systems and through reviews conducted by senior management."

Consideration of biodiversity in strategy and business model

Reference: page 179.

EnBW interacts with nature "through the use of land and water and through soil sealing," material chiefly in conventional/renewable generation and critical infrastructure operation. New construction can cause habitat loss; compensation measures follow applicable statutory requirements. Biodiversity is anchored in Sustainability Agenda measure 7, "Biodiversity," under the strategic theme "Energy of change," Board of Management responsibility.

The EnBW Biodiversity Management Policy covers transition-plan integration and compensatory measures, and targets reduced biodiversity loss "in line with the Kunming-Montreal Global Biodiversity Framework (GBF)." The material EnBW locations for biodiversity comprise ten power plants and three gas cavern storage facilities; operations there stay within legally permissible limits (Habitats Directive, Birds Directive, Federal Nature Conservation Act) under the mitigation hierarchy.

Policies related to biodiversity and ecosystems

Reference: page 180.

The EnBW Biodiversity Management Policy commits to "avoid, mitigate or compensate for biodiversity loss and deforestation" to the greatest extent possible, avoids activities in areas of high biodiversity loss, and integrates biodiversity into corporate strategy and stakeholder collaboration. Applies Group-wide; implementation responsibility sits with each Group company, with a management officer for environmental protection reporting to the responsible Board of Management member.

A binding governance structure defines roles, minimum standards and feedback processes; a cross-functional team (nature/species protection, environmental protection, sustainability) coordinates centrally. A Group-wide Biodiversity Network held its first meeting in October 2025. Subsidiary examples: TransnetBW's soil protection guidelines for HVDC lines; naturenergie's conservation plans for High Rhine power plant sites and concession routes.

Actions and resources related to biodiversity and ecosystems

Reference: pages 180-182.

Every new construction project applies environmental impact assessments where mandatory, and the mitigation hierarchy under the Federal Nature Conservation Act and Habitats/Birds Directives otherwise. Since 2011, the "Stimuli for Diversity" amphibian/reptile program has funded 159 projects (11 realized in 2025, ~EUR 43,000/year, open-ended). EnBW has built fish-ascent installations and retrofitted fish ladders at numerous hydropower plants; at Hirschhorn a pilot "fish-friendly turbine" was monitored.

EnBW voluntarily avoids new wind farms in NATURA 2000 areas; wind farms in forests are largely sited on spruce monoculture or storm-damaged "calamity areas," and almost all solar parks sit on agricultural land. TransnetBW manages ~75% of power-line sections in forested/green areas under its ecological route management concept (ÖTM); other subsidiaries take compensatory action (flower meadows, replacement planting) and resettle/monitor amphibians, bats and birds.

Targets related to biodiversity and ecosystems

Reference: page 182.

Voluntary, Group-company-level targets rather than a single quantified Group target. naturenergie targets improved upstream/downstream fish ladders at its hydropower plants, surveyed every ten years; a variant study for the Laufenburg fish ladder redesign was completed in 2025. TransnetBW targets operating at least 95% of power-line sections in forested/green areas under its ecological route management concept (ÖTM) by 2030, developed with its "Plant Operations" department; around 75% is currently managed this way, with a detailed status survey carried out in 2025.

Impact metrics related to biodiversity and ecosystems change

Reference: page 182.

"Group-wide metrics related to our material impacts will be developed in the next few years"; land-use-change parameters are being developed separately per Group company from 2025 onward as part of the biodiversity policy.

As of 31 December 2025, 13 of EnBW's material sites, covering 238 hectares of land, are either located in or near (within a 2 km radius of) biodiversity-sensitive areas, where they "could have minor impacts on biodiversity." These locations must comply with the Federal Nature Conservation Act's regulations on protecting biodiversity-sensitive areas.

Policies related to resource use and circular economy

Reference: pages 183-184.

"EnBW recognizes the importance of avoiding the use of virgin resources and of increasing the relative share of secondary (recycled) resources," anchored in Sustainability Agenda measure 6, Executive Board responsibility. The EnBW Waste Management Policy covers waste reduction/minimization, circular-economy implementation and supply-chain waste management, applied Group-wide with a management officer for environmental protection reporting to the responsible Board of Management member.

Waste is managed under section 6 of the German Circular Economy Act (KrWG): avoidance and reuse/recycling are preferred before disposal. Conventional power plants generate the largest waste streams (sludge mixtures, fly ash, bottom ash, slag, filter dust). Supplier sustainability is assessed via EcoVadis ratings within procurement; sustainability criteria will be added to future tender evaluation matrices.

Actions and resources related to resource use and circular economy

Reference: pages 184-185.

A 2024 feasibility study identified circular-economy potential; two photovoltaics projects followed, including metrics for measuring circular-economy performance (concluded early 2025) and a follow-up action-identification project due to conclude Q1 2026, for rollout in 2026.

Second-life batteries recovered from electric vehicles were placed into operation as battery storage systems at the Rot an der Rot and Aach solar parks in 2025, at four locations overall. Power plant by-products (fly ash, slag, gypsum) are reused in construction; ferrous/non-ferrous metals are recovered and recycled from incineration slag. EnBW Kernkraft remediates pollutants from dismantled nuclear structures to increase the proportion recoverable or reusable, including scrap steel. Grid operators recycle transformer oil and larger grid equipment and use prefabricated/standardized components.

Targets related to resource use and circular economy

Reference: pages 185-186.

Two voluntary, Group-wide targets:

The waste-reduction target excludes waste from redispatch/reserve power plant deployment. The 2025 increase reflects higher fossil-source generation. Effectiveness is "assessed as part of the environmental management system and in management reviews completed every year." Cascading-use policies for materials "are not yet considered standard" between procurement and usage; interrelationships will be identified in a Group project during 2026. TransnetBW separately targets ≥80% reuse of excavated soil from grid expansion and QNG (German Sustainable Building) certification by 2030.

Resource inflows

Reference: page 186.

Supply-chain quality and supplier risk are automatically evaluated based on sector and company risk; higher-risk suppliers are asked for additional sustainability-performance information to allow more detailed evaluation of resource inflows. Material resources named: "wind power plants, solar panels, gas turbines and conventional power plant technology," plus, for the grid business, "pipes, cables and associated technical services." No quantified resource-inflow volumes (e.g. by material type) are given in this section; the disclosure is descriptive rather than metric-based.

Resource outflows

Reference: pages 186-187.

Resource outflows are mainly by-products and waste from thermal power plants (fly ash, gypsum, slag — retained in the construction-industry circular economy) and, at EnBW Kernkraft, residual nuclear materials.

Radioactive residues from nuclear dismantling are decontaminated at GNR treatment centers (Neckarwestheim, Philippsburg) and fed back into the material cycle where legal thresholds allow, "reducing the amount of radioactive waste to just a single-digit percentage of the total amount of waste generated during the dismantling process."

Waste

Reference: pages 186-187 ("Waste and resource outflows" table); accounting narrative page 187.

Waste is classified under the European Waste Catalogue as transcribed into the German Waste Catalogue Ordinance (AVV), first by origin, then by material properties, with a hazard assessment determining registration/documentation obligations. EnBW Kernkraft's radioactive waste, from dismantling nuclear power plants, is packaged and transferred under the German Act on Reorganization of Responsibility for Nuclear Disposal to BGZ; main streams are "activated and contaminated metals, ion exchange resins, evaporator concentrates, mixed waste, activated and contaminated demolished concrete, activated concrete structures and incineration residues."

Policies related to own workforce

Reference: pages 196-198.

Sustainable HR strategy sits under Sustainability Agenda measure 9 ("Diversity and education"), part of the "Culture of sustainability" theme. Named policies address material impacts: work-life balance (Chief Human Resources Officer responsible, applies to permanent and integrated non-employee workers); health, via the occupational medicine department (AMD) and corporate health management (BGM), both reporting to the CHRO; occupational safety, governed by the "Occupational safety and health protection policy," Board of Management overall responsibility, with 30% of the workforce covered by ISO 45001 or an equivalent nationally recognized system; diversity, equity and inclusion (DE&I), covering eight dimensions, anchored in the EnBW Code of Conduct; and training and skills development, via a digital learning platform and company agreements on qualification, development dialog and idea management.

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

Reference: pages 198-199.

Engagement runs through direct and indirect (workers'-representative) channels: the annual EnMAB employee survey (occupational safety, equal opportunities, change readiness, plus free-text comments), and a separate psychological-stress risk assessment (GB Psych) run every three years, most recently 2024; up to four dialog events a year between the Board of Management, works council and employees; annual or more frequent employee appraisals; the WIN company suggestion scheme; cross-functional working groups (e.g. the Health Working Group, Inclusion Teams); and works council structures, including a Group works council, whose topic-oriented divisions are set out in the collective bargaining agreement. Company agreements with works councils cover working-time models, mobile working, appraisal rights and remuneration benefits.

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

Reference: page 199.

"EnBW has processes to reduce negative impacts for its own workers and has established channels that workers can use to raise their concerns and have them addressed." The EnBW whistleblower system lets employees and external persons report grievances and potential violations through multiple channels, anonymously if desired, in more than 50 languages, via a 24/7 hotline, an online form, direct contact with the compliance department, or an external ombudsperson.

Employees and external persons are encouraged to use the internal grievance mechanism for potential violations of human rights, environmental law or other misconduct; findings feed into "the continuous development and optimization of existing due diligence obligations" and "minimizing risks and the rapid implementation of corresponding remedial action."

Taking action on material impacts on own workforce

Reference: pages 199-204.

Work-life balance: flexible hours/locations, parental leave, workation, childcare and caregiver support, part-time management roles; a 2025 "Shared leadership" company agreement enables shared leadership roles.

Health: occupational healthcare, company-doctor consultations, operational integration management, vaccinations, physiotherapy and psychological services; health centers at seven locations; over 100 health courses offered in 2025.

Occupational safety: the SafE program (started 2024) standardizes safety-officer roles and rolls out Quentic software; Netze BW's sixth annual "Occupational Safety Awareness Day"; evacuation exercises at fuel-switch construction sites; a new Group drone-pilot standard; the "100 days without accidents" goal was achieved 19 times across locations in 2025.

DE&I: diversity training, employee networks (women's networks, Pride Network, People-of-Color Network), the "Career Compass" female-leadership program and a Group Inclusion Agreement.

Targets related to own workforce

Reference: pages 204-205.

Occupational safety: target LTIF overall ≤3.3 by 2030 (no fatal work-related accidents is the overriding aim).

Diversity: target of at least 20% women at the top two management levels below the Board of Management by 31 December 2025 — not yet achieved in top management (18.2%, 2024: 17.4%) but achieved in upper management (24.2%, 2024: 25.5%); middle management stood at 25.2%, all levels combined at 24.5%. A new target of 30% women across all management levels, including middle management, by 31 December 2030 has been set.

Training: the People Engagement Index (PEI) target for 2025 and 2030 is 77 to 83 points; career-development-opportunity satisfaction in the employee survey stood at 74% (2024: 72%). "At the present time, there are no other time-bound, measurable, quantitative targets."

Characteristics of the undertaking's employees

Reference: page 206.

By segment: Sustainable Generation Infrastructure 25.0% (7,890), System Critical Infrastructure 41.0% (12,931), Smart Infrastructure for Customers 18.8% (5,939), Other 15.2% (4,781).

Characteristics of non-employee workers

Reference: page 206.

Non-employees comprise people with contracts to supply labor ("self-employed people") and people provided by undertakings engaged in "employment activities"; both categories are not included in the employee headcount figures reported under S1-6.

Diversity metrics

Reference: pages 204, 207.

Gender, highest management level below the Board of Management (page 204): 347 in total (2024: 380) — 283 men (81.6%), 64 women (18.4%), 0 gender-diverse (2024: 311 men/81.8%, 69 women/18.2%, 0 gender-diverse).

Age structure, all employees (page 207): under 30: 5,383 (2024: 5,154); 30-50: 16,115 (2024: 15,117); over 50: 10,043 (2024: 10,120).

Management-level gender splits are also disclosed by tier under S1-5: top management 18.2% women, upper management 24.2%, middle management 25.2%, all levels 24.5%.

Training and skills development metrics

Reference: pages 202-204.

Average training hours per employee, 2025: 44.0. By gender: women 47.7 hours (2024: 47.2), men 42.4 hours (2024: 43.7), gender-diverse employees 17.0 hours (2024: 60.3).

Performance and career development reviews: 74.6% of employees participated in 2025 — 77.4% of women, 73.5% of men, 50.0% of gender-diverse employees. "No figures for previous year, data collected for the first time in 2025."

Supporting programs: the "EnBW Guides" competency model, a development dashboard, 360° feedback, the Mentoring@EnBW program, the LernWerk digital learning platform (including "LernGPT@LernWerk" for AI training) and the Leadership Development Journey, with a new Leadership Future Journey pilot launched in 2025 for upper/top management.

Health and safety metrics

Reference: page 207.

In 2025 there was a fatal accident involving an external company's employee carrying out renovation work for TransnetBW; an accident-analysis-team investigation was ongoing at the time of reporting, following an established procedure of sequence-of-events analysis, risk assessment and prevention-strategy development.

Compensation metrics (pay gap and total compensation)

Reference: page 207.

"The unadjusted gender pay gap between female and male employees, expressed as a percentage of the average pay level of male employees, was 15.4% in the 2025 financial year (2024 restated: 15.6%)." The calculation methodology was amended in 2025 to take full-time/part-time status into account; under the prior methodology, the unadjusted gender pay gap would have been 20.5%.

The Appendix B "Datapoints deriving from other legislation" table separately marks the "Excessive CEO pay ratio" datapoint (paragraph 97(b)) as "Immaterial" (page 230), while the unadjusted gender pay gap datapoint (97(a)) is marked "Material," consistent with the pay-gap figure being the substance of what is reported here.

Incidents, complaints and severe human rights impacts

Reference: page 207.

The Appendix B table marks the datapoint "Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines" (paragraph 104(a)) as "Immaterial" (page 230), while incidents of discrimination (103(a)) are marked "Material," consistent with the discrimination and complaints figures being the substance reported here.

Policies related to value chain workers

Reference: pages 208-211.

The EnBW Declaration of Human Rights is the overarching policy, aligned with the UN Global Compact (member since 2010), the UN Guiding Principles on Business and Human Rights and OECD Guidelines. It covers own workforce, value chain workers, affected communities and consumers/end-users; it does not directly bind TransnetBW, terranets bw or ONTRAS Gastransport, which are "requested to apply it in an analogous manner." No non-respect of the UNGPs, ILO Declaration or OECD Guidelines involving value chain workers was reported via the whistleblower systems in 2025.

The Supplier Code of Conduct (SCoC) is an obligatory part of business-partner contracts, covering occupational health and safety, child/forced labor prevention, equal opportunities, remuneration, working hours, freedom of association and collective bargaining, grievance mechanisms and indigenous-peoples protection. The Policy Statement under the German Supply Chain Due Diligence Act (LkSG) is overseen by a Human Rights Committee and Human Rights Steering Committee.

Processes for engaging with value chain workers about impacts

Reference: pages 211-212.

Engagement is mainly indirect, through industry initiatives (econsense, RECOSI, SolarPower Europe) where EnBW serves on management boards and heads working groups, focused on fair working conditions, occupational health and safety, and human rights. Direct engagement occurs via on-site visits and audits: for high-risk, strategically relevant business partners, on-site meetings are held every one to two years, including a 2025 visit by sustainability, trading and compliance staff to LNG facilities in the United States. Procurement professionals and category managers hold supplier dialogs "several times per year" on issues such as component origin and production-country working conditions. The Human Rights Steering Committee holds operational responsibility for event-driven consideration of value chain worker perspectives.

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 212.

Ongoing and event-driven LkSG risk analyses identify negative impacts on value chain workers early, triggered by grievance-mechanism findings, evidence of a supplier violation, or significant business changes affecting the LkSG risk situation. A partially automated business-partner assessment identifies human rights and environmental risks, feeding internal mitigation guidance.

Value chain workers can use EnBW's whistleblower systems, accessible to internal and external persons regardless of personal impact. Effectiveness and progress are reviewed annually and as needed; the Human Rights Committee reports to the Board of Management at least annually, the Economic Committee receives regular updates, and the audit department examines process compliance regularly.

Taking action on material impacts on value chain workers

Reference: pages 212-213.

Supplier selection/evaluation: all direct raw-material business partners undergo a business-partner human rights audit; an automated supplier-selection process requires a self-assessment on environmental management, occupational safety, human rights, anti-corruption, data protection and quality management. Netze BW's underground/grid construction prequalification requires supplier self-assessments and training on occupational safety, minimum wage and working-time provisions, with continuous review via audits and on-site inspections.

Supplier development: ongoing dialog with key suppliers on compliance, environmental and social issues; within RECOSI's Gas Working Group, EnBW co-developed "Responsible Sourcing Criteria" for gas-value-chain ESG assessment. EnBW co-initiated the German government's Energy Sector Dialog (2023) addressing fair working conditions for migrant construction workers. "In the reporting year, no severe problems or incidents related to the human rights of value chain workers were reported via the EnBW whistleblower systems."

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 213.

"There are currently no time-bound, measurable quantitative targets in place with regard to the identified impacts." Effectiveness of policies and actions on value chain workers is instead tracked through the annual LkSG process (S2-1), with the "overriding objective... placed on fulfilling our human rights due diligence and, in this context, the continuous review and evaluation of our impacts along the value chain and the implementation of preventative or, if necessary, remedial action." EnBW states it "will continue to actively engage in sector and corporate initiatives to promote positive impacts for workers."

Policies related to affected communities

Reference: pages 214-215.

Governed by the EnBW Declaration of Human Rights (own operations and value chain) and the LkSG Policy Statement, both administered via the Human Rights Committee and Human Rights Steering Committee, Board of Management overall responsibility. A 2025 Stakeholder Engagement Policy consolidates guidelines on affected communities, with the Chairman of the Board of Management responsible at Board level and the Communications & Brand department coordinating Group-wide, supported by a Stakeholder Mapping Tool and "lunch talk on citizen participation" dialog format.

EnBW "respect[s] the rights of the local population" near its sites, conducting social/environmental impact analyses ahead of planned projects and consulting locally, "as a matter of principle" seeking to avoid resettlement. The Supplier Code of Conduct extends these expectations, including respect for indigenous peoples' culture, traditions and religion. No non-respect of the UNGPs, ILO Declaration or OECD Guidelines involving affected communities was reported via the whistleblower systems in 2025.

Processes for engaging with affected communities about impacts

Reference: pages 215-216.

Social and environmental impact analyses precede planned projects "as occasion or the project demands," combining direct local-population consultation with internal expert input via a Stakeholder Mapping Tool developed in three workshops with involved departments. Citizen dialog runs through local in-person and virtual events, dialog platforms for renewable-energy and sustainability questions, and public hearings with project managers, authorities and the public during wind, PV and power-line application/construction phases, required to meet statutory environmental-assessment and safety obligations.

For indigenous peoples affected by EnBW's own operations, the company respects their right to free, prior and informed consent in fair negotiations, with on-site visits every one to two years to understand local customs and legal systems.

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 216.

Internal and external persons can use EnBW's whistleblower systems to report potential violations affecting affected communities, regardless of personal impact. If negative impacts are identified, the EnBW Human Rights Committee works with relevant departments and business units to develop targeted resolution action. LkSG risk analyses prioritize actual or potential negative impacts on affected communities "based on criteria such as the severity, likelihood of occurrence and extent of the contributions to the cause." Communities near EnBW locations can also use the grievance mechanism directly or raise issues during on-site audits.

Taking action on material impacts on affected communities

Reference: pages 216-217.

Environmental management systems certified to ISO 14001 apply at all material Group companies, and the Occupational Health & Safety Policy supports mitigation of health-related impacts at operating locations. Project-specific action includes public consultations, discussions with municipal councils and authorities, and appointed site managers as community contact points; citizens can benefit financially from renewable projects via participation models and the EnBW citizen participation platform.

For indigenous peoples, supplier audits assess environmental impacts on livelihoods (soil, air, water) affecting vulnerable groups; regular dialog is held via RECOSI and on-site visits. In the coal sector, RECOSI audits coal producers against the Bettercoal Code and obligates improvement measures. "In the reporting year, no severe problems or incidents related to the human rights of affected communities were reported via the EnBW whistleblower systems."

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 217.

"There are currently no time-bound, measurable quantitative targets in place with regard to the identified impacts." Effectiveness is tracked through the annual LkSG process. EnBW states it plans to "monitor the development of stakeholder communication concepts for new projects using targets based on key performance indicators and metrics," and in 2025 launched a pilot project with selected project developers "to refine the definitions and examine the availability of data within the Group."

Policies related to consumers and end-users

Reference: pages 218-219.

Material matters affect around 5.5 million customers purchasing electricity, gas, water and heat, split B2C (retail, small commercial, housing, agricultural) and B2B (large commercial, industrial, redistributors, municipal utilities, public institutions). Material impacts: potential negative effects on privacy/data protection; positive effects from diverse energy-access options and supply reliability.

Data protection: corporate guidelines based on GDPR/BDSG define the data protection management system (DPMS); Board of Management overall responsibility, centralized and decentralized organizational structures, decentralized data protection managers.

Access to energy/supply reliability: basic and reserve energy supplier obligations regardless of customer income/contract status; an Asset Management Policy governs grid asset management, with Netze BW's system certified to DIN ISO 55001 and TransnetBW conducting voluntary VDE-AR-N 4001 audits.

Processes for engaging with consumers and end-users about impacts

Reference: page 220.

Engagement on data protection runs via customer service hotlines and data protection officers, plus whistleblower-system access and direct online/email/phone contact. Twice-yearly studies and surveys include a customer satisfaction survey (~2,000 household interviews) generating the Customer Satisfaction Index, and the "Powerhelden" customer test panel (4,848 participants, including customers of other suppliers) providing product/service feedback. Additional feedback channels operate during direct customer contact (e.g. website contracting); app usability and product-acceptance studies run "several times per month on average." Where direct dialog is not possible, EnBW cooperates with consumer protection organizations or credible proxies. The Board of Management member for "System Critical Infrastructure and Sales" is responsible for taking customer issues into account.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: pages 220-221.

Data protection grievances are processed under GDPR/BDSG with regular reporting to the Board of Management and supervisory bodies; managers must report violations without delay via an established reporting system (email or phone to the data protection department).

A structured grievance management system covers other customer concerns via hotline, online form, email or post; every grievance is documented, routed to the responsible department for analysis, and resolved within a defined timeframe, escalating to external arbitration if unresolved. Weekly management reports track channel performance and outstanding grievances. Consumers can also use EnBW's whistleblower systems. Effectiveness is examined via internal audits and customer satisfaction surveys.

Taking action on material impacts on consumers and end-users

Reference: pages 221-222.

Data protection: risk assessments and, where needed, data protection impact assessments for new IT systems/processes; mandatory e-learning every two years for all employees, with additional courses in sensitive areas, refreshed and reviewed annually; third-party service providers must submit data-protection self-assessments before commissioning.

Access to energy/supply reliability: grid companies invest in expansion and digital solutions (smart grids) for stability; a new central control center in Karlsruhe (opened 2025) monitors over 8,000 fast-charging points, EnBW's largest charging network in Germany, with plans to expand to 20,000 charging points by 2030. "In the reporting year, no severe problems or incidents related to the human rights of consumers and end-users were reported via the EnBW whistleblower systems."

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 222.

Key performance indicators: SAIDI Electricity (average annual supply interruption duration per connected customer, unscheduled interruptions over three minutes) for supply reliability, and the Customer Satisfaction Index for EnBW and Yello, compiled from external retail-customer surveys. Overriding qualitative targets include establishing a Group-wide uniform level of data protection and integrating data protection requirements into all relevant processes. "Given these existing qualitative targets, no more specific plans regarding quantitative targets have been defined at this stage."

Business conduct policies and corporate culture

Reference: pages 46-53 (Corporate governance/Compliance sections, incorporated by reference for GOV-1/G1-1).

Since 2009 EnBW has had a Code of Conduct adopted by the Board of Management, binding for EnBW AG and controlled domestic/foreign majority shareholdings; it was "comprehensively revised" in 2025, adopted early 2026, adding corruption/bribery prevention, money laundering prevention, responsible AI, human rights, tax compliance and the whistleblower system.

The compliance management system (CMS), Board of Management overall responsibility, focuses on preventing, detecting and sanctioning corruption/bribery and other economic crime, competition/antitrust compliance, sanctions/export controls, capital-market compliance and anti-money-laundering. Indirectly integrated companies (Stadtwerke Düsseldorf, VNG, ZEAG, terranets bw, TransnetBW, naturenergie, Pražská energetika, Valeco Group) run their own CMS within the Group framework, coordinated via a central Compliance Forum, International Panel and Compliance Working Group.

Whistleblower protection: a 24/7 hotline and online form in 50+ languages, plus an external ombudsperson; confidentiality, fair proceedings, presumption of innocence and anti-retaliation protection apply throughout and after proceedings.

Prevention and detection of corruption and bribery

Reference: pages 49-52 (Compliance and data protection section, incorporated by reference).

Training: the mandatory e-learning course "Basic Compliance Knowledge" (launched 1 January 2025, annual for all employees) covers the Code of Conduct, anti-corruption, conflicts of interest and the whistleblower system. In 2025, 554 employees attended in-person/online compliance training (261 in sensitive areas, 255 new employees/managers, 38 managers); 541 attended the "Welcome Day on Compliance." Group-wide coverage: 83% on corruption/bribery avoidance content, 82% on the Code of Conduct.

Procedures: the Corporate Guideline on Gifts, Invitations and Hospitality and the Corporate Guideline on Sponsoring/Memberships/Donations set value limits requiring compliance-department approval above threshold. Annual compliance risk assessments (risk-based selection across CMS-integrated companies) and, new in 2025, a tool-assisted money-laundering risk analysis. The compliance department fielded 1,477 advisory requests in 2025 (mainly sponsoring, donations, gifts).

Independence: investigators must act independently and impartially; the Board of Management informs the Supervisory Board annually (and the audit committee quarterly) on material compliance breaches.

Targets related to business conduct

Back-filled from the compliance/business conduct sections, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

EnBW does not disclose a numerical business-conduct target. Consistent with MDR-T's alternative limb, effectiveness is tracked in the absence of a stated target: annual compliance risk assessments identify and prioritize corruption/bribery and related risks; training coverage is measured and reported (83% on corruption/bribery content, 82% on the Code of Conduct, 2025); a tool-assisted money-laundering risk analysis was introduced in 2025; the compliance department tracks 1,477 advisory requests handled in the year; and compliance breaches reported via the whistleblower system (131 in 2025, of which 33 confirmed at directly integrated companies, none involving bribery or corruption) are reported quarterly to the Board of Management and audit committee, and annually to the Supervisory Board.

Incidents of corruption or bribery

Reference: page 54.

"In the reporting year, a total of 131 potential compliance breaches were reported to the central compliance department of EnBW AG via the whistleblower system," including a report from Environmental Action Germany (DUH) about the US LNG supply chain under LkSG section 8, on which "no due diligence violations were identified."

From these reports, 33 compliance breaches were confirmed at directly integrated companies; none were associated with bribery or corruption. No corruption/bribery breaches occurred at indirectly integrated companies, independent transmission operators or foreign companies. "In the reporting period and even in the last three years, there have been no public legal cases regarding corruption and bribery brought against the company," no contract terminations for corruption/bribery breaches, and no convictions or fines for anti-corruption or anti-bribery law violations.

Political influence and lobbying activities

Reference: pages 49-50, 223-224 (lobby-register list); political dialog narrative page 50.

EnBW engages in political dialog via offices in Berlin, Brussels and Stuttgart, publishing position papers and contributing to consultations. The EnBW Code of Conduct (since 2009) "stipulates that no donations may be made to political parties, organizations affiliated to them, civil servants, elected representatives or candidates for public office."

Lobbying spend: the EnBW Group spent EUR 0.1 million on lobbying in 2025 (2024 restated: EUR 0.1 million); the prior methodology's figure of EUR 2.8 million included non-G1-5 items (memberships, sponsoring) now excluded for comparability.

EnBW AG and subsidiaries are listed in multiple lobby/transparency registers, including the EU Transparency Register (No. 13324391892-74) and the German Bundestag Lobby Register (No. R002297), plus state-level registers (Baden-Württemberg, Bavaria, Hesse, Saarland). "In the reporting period, there were no members appointed to the administrative, management or supervisory bodies who have held a comparable position in public administration... in the two years preceding 2025."