Evonik Industries AG

Reference: page 122

Evonik Industries AG operates a two-tier governance system with separate executive board and supervisory board levels. The supervisory board has 20 members, ten representing shareholders and ten representing the workforce, including six women and 14 men, which meets the statutory 30 percent minimum quota for women. The board considers all current members independent. Its diversity concept covers independence, age, maximum term of office, and skills such as international experience and business and scientific knowledge. The skill set was expanded to include ecological and social sustainability, and ten members now have expertise in this area. The supervisory board has set up an executive committee, an audit committee, an investment and sustainability committee, an innovation and research committee, a nomination committee, and a mediation committee. The investment and sustainability committee addresses all sustainability-related topics relevant to the supervisory board. The four-member executive board bears overall responsibility for sustainability and all climate-related aspects, with direct responsibility assigned to the chief human resources officer. One executive board member is female.

Reference: page 123

The executive board provides regular, timely, and extensive information to the supervisory board on all matters of relevance to the company, with major sustainability aspects included in context. On this basis, Evonik's sustainability activities were discussed at several supervisory board meetings in 2024. Responsibility for sustainability topics is delegated through a sustainability council, which steers sustainability management and decisions, meets at least twice a year, is chaired by the chair of the executive board, and includes the heads of the divisions. Its decisions are prepared by a sustainability circle made up of representatives of relevant functions and units, chaired by the chief human resources officer and also meeting at least twice a year. During the reporting year the supervisory board, its investment and sustainability committee and audit committee, and the executive board addressed environmental, social, and governance topics including portfolio transformation, climate change mitigation, green energy, circular economy, product stewardship, occupational health and safety, cybersecurity, and the materiality assessment. Sustainability is also a criterion in the risk assessment of capital expenditure on property, plant and equipment.

Reference: page 124

The supervisory board sets the total remuneration of each executive board member, comprising basic salary, variable short- and long-term components, pension benefits, and other elements. Remuneration for executive board members and all executives is based on personal performance and the overall performance of the Evonik Group. The short-term incentive includes a sustainability component covering the development of plant safety and accidents in the past year. Non-financial targets in the 2024 executive board performance factor included successful implementation of the first ESRS-compliant reporting, establishment of the Evonik Carbon Footprint and portfolio sustainability assessment, development of the first building blocks of a climate transition plan, and Next Generation Culture change management. Since 2023 the long-term incentive plan for the executive board and roughly 160 senior executives has included a sustainability component: 80 percent of the award is based on Evonik share performance and 20 percent on sustainability targets. The 2024 LTI targets are CO2 emissions reduction (40 percent), increasing the Next Generation Solutions share of the portfolio (40 percent), and a social index covering learning, health, and diversity (20 percent). Target achievement ranges from 0 to 200 percent.

Reference: page 125

Sustainability is a core element of Evonik's overall strategy, and all identified material sustainability topics are incorporated into the company's strategic alignment. The strategy is complemented by specific policies on topics such as climate change, water, biodiversity, product stewardship, and circular economy. The due diligence and risk management requirements, which are consistent with the sustainable corporate strategy, are firmly embedded in business processes through policies including the policy statement on human rights, the Evonik Code of Conduct, and the Evonik Code of Conduct for Suppliers. The report provides an overview of the existing management systems used to meet due diligence obligations for each material topic, and shows how Evonik assesses identified impacts, risks, and opportunities and what actions it takes to counteract negative ones and emphasize positive ones, including the outcomes. A statement on due diligence maps the core elements of due diligence to pages in the report: embedding due diligence in governance, strategy, and business model; engaging with affected stakeholders; identifying and assessing adverse impacts; taking actions to address them; and tracking the effectiveness of these efforts and communicating.

Reference: page 97

The process of sustainability reporting, like financial reporting, is part of the processes and organization risk category of the Evonik Group risk management system, with risks arising primarily from process deficiencies. The basis for safeguarding against process-related risks is the ESRS Group Reporting Manual, which sets out the principles for sustainability reporting on the basis of ESRS requirements, supported by procedural instructions governing data collection in the various spheres of responsibility. Preparation of the sustainability report is integrated into the process of preparing the financial report, using existing mechanisms for allocating responsibilities, applying the dual control principle, and monitoring schedules. Specific controls were implemented to ensure the accuracy and completeness of ESRS reporting and are reviewed and optimized regularly. Alongside data validation in the annual reporting process, environmental data are subject to in-house performance analyses, benchmarks, internal and external audits, and oversight by various authorities. All information is subject to a limited assurance engagement by KPMG AG Wirtschaftspruefungsgesellschaft, with the independent practitioner's report reproduced under supplementary information.

Reference: page 98

Evonik is a global specialty chemicals company whose purpose is leading beyond chemistry to improve life, today and tomorrow. Its sustainable corporate strategy, Next Generation Evonik, integrates sustainability into core processes and is built on three building blocks: Next Generation Solutions (market perspective), Next Generation Technologies (asset perspective), and Next Generation Culture (human resources perspective). The core process is the sustainability analysis of the business. Strategic targets include increasing the share of sales from Next Generation Solutions to over 50 percent by 2030 (45 percent in 2024) and keeping the share of products classified as challenged below 5 percent. In line with its Science Based Targets initiative commitments, Evonik aims to cut Scope 1 and 2 emissions by 25 percent and Scope 3 emissions by around 11 percent between 2021 and 2030. It plans to invest more than 3 billion euros in Next Generation Solutions and 700 million euros in Next Generation Technologies between 2022 and 2030. In 2024 the group generated sales of 15.1 billion euros, operated 104 production sites, and employed 31,930 people. The Technology and Infrastructure division also sells natural gas, electricity, and steam, accounting for 552 million euros of sales.

Reference: page 106

Evonik engages continuously with its stakeholders, both in the operating business and at group level, to better understand different perspectives, review its own positions, and identify potential opportunities and risks at an early stage. It defines and prioritizes stakeholder groups using criteria such as type of influence (direct or indirect), impact cluster, and characterization. Stakeholders with direct influence include customers, employees, suppliers, shareholders, lenders, legislators, authorities, and local residents, while those with indirect influence include contractors' employees, analysts and rating agencies, politicians, the scientific community, associations and trade unions, NGOs, competitors, media, and future generations. Nature is indirectly included as a silent stakeholder via data from NGOs and the scientific community. Communication channels include personal or remote discussions, town hall and staff meetings, open days and site visits, the whistleblower system, surveys, sustainability reporting, and the Evonik website and social media. The executive board plays an active role by attending events such as the annual shareholders' meeting, investor meetings, site visits, and town hall meetings. Insights gained feed into relevant processes such as the sustainability analysis of the business and the materiality assessment, and Evonik also regularly holds a stakeholder conference.

Reference: page 111

Evonik's double materiality assessment identified 13 material sustainability topics, each underpinned by specific impacts, risks, and opportunities (IROs) that are allocated to the ESRS structure and shown with their impact type, positive or negative and actual or potential character, time horizon, and value chain focus. The material topics are portfolio transformation, mitigating climate change, green energy, water management, biodiversity, circular economy, product stewardship, attractiveness as an employer and employee satisfaction, diversity and equal opportunity, occupational health and safety, responsible corporate governance and human rights, responsibility within the supply chain, and cybersecurity. These topics correspond to the material standards ESRS 2, E1, E2, E3, E4, E5, S1, S2, and G1, while S3 affected communities and S4 consumers and end-users were assessed as not material. Portfolio transformation and cybersecurity are entity-specific topics. The IROs were assessed initially without countermeasures and negative consequences may not be offset by positive ones. Evonik describes each IRO together with its relevance to the strategy and business model in the management approaches in the respective chapters, then sets out targets, actions, and progress in 2024 for the aggregated IROs. The material topics define the structure of the sustainability report.

Reference: page 108

Evonik's double materiality assessment evaluates both the actual and potential positive and negative impacts of its business (inside-out perspective) and the impact of external factors on its business activities (outside-in perspective). The process comprises five steps: analysis and description of Evonik's environment; identification of IROs from internal and external sources such as the sustainability analysis of the business, risk management, and compliance, environment, and safety systems, also drawing on rankings and frameworks such as MSCI, EcoVadis, GRI, SASB, and TCFD; assessment of the significance of IROs through an evaluation sheet completed by internal experts, with impact materiality using the ESRS severity criteria of scale, scope, and remediability plus likelihood, and financial materiality using EFRAG's five-level scale; cut-off, clustering, and prioritization against materiality thresholds; and validation of the material topics. Corporate functions including ESHQ, Compliance, Human Resources, Innovation, Strategy, Investor Relations, and Procurement served as proxies for stakeholders. Final material topics were approved by the responsible executive board member, with external validation by representatives of industrial unions, industry associations, NGOs, sustainability consultancies, and the financial sector. The assessment is reviewed annually, and the value chain and opportunity and risk management feed into the process.

Reference: page 112

As part of the materiality assessment, Evonik assigned its IROs to the ESRS ESG logic and to the individual topical standards, then to the ESRS structure down to the level of the sub-sub-topics of ESRS 1 AR 16, reflecting relevance and value to decision-making. A gap analysis carried out in 2023 ensured that the IROs covered all sustainability matters specified in the ESRS, including underlying sub- and sub-sub-topics. After assessing the materiality of the topical standards, Evonik completed the review and definition of the materiality of the underlying data points on the basis of ESRS 1 Appendix E, using available data and expert opinions from specialist colleagues. The IROs aggregated into material topics define the structure of the sustainability report and were allocated to the General information, Environmental information, Social information, and Governance information chapters stipulated in the ESRS. Evonik prepared two indices containing the findings: an ESRS Index of disclosure requirements covered and an ESRS Index of disclosure requirements under other EU legislation, found in the annex to the sustainability report. The guidance table maps each ESRS topical standard to the report chapters with key focus and further disclosures.

Reference: page 129

Evonik has a climate transition plan (which it notes is not a full transition plan within the meaning of the ESRS) that initially provides for reducing CO2 emissions in line with its SBTi-validated targets by 2030, with the remaining greenhouse gas emissions to be reduced in the period from 2030 to 2050. The plan rests on three pillars for Scope 1 and 2: exiting coal-fired power generation, Next Generation Technologies, and renewable energies. Evonik aspires to be climate-neutral by 2050. The SBTi targets and roadmap up to 2030 were approved by the executive board. Actions include decommissioning the Marl (Germany) coal-fired power plant at the end of March 2024, cutting CO2 emissions by up to 1 million metric tons per year. In the period to 2030, Evonik plans to invest about 700 million euros in Next Generation Technologies. In 2024, projects to reduce CO2eq emissions by roughly 440,000 metric tons annually involved an investment volume of around 99 million euros.

Reference: page 129

Evonik adopted a climate policy in 2023 and published it on its website. Climate change mitigation is embedded in the company's strategy (Next Generation Evonik), under which new targets were set in 2022. Reducing CO2 emissions (Scope 1 and 2) is embedded in the remuneration of the executive board and other executives. Carbon pricing is used as an additional planning criterion, particularly because investment decisions may result in higher costs if there is no carbon pricing. Along the value chain, Evonik works on innovative solutions to reduce emissions, often in collaboration with suppliers and customers.

Reference: page 130

Actions to implement the climate transition plan address Scope 1 and 2 emissions to 2030, Scope 3 emissions to 2030, and emissions from 2030 to 2050. For Scope 1 and 2, measures include exiting coal-fired power generation (the Marl coal-fired plant was decommissioned at the end of March 2024, cutting up to 1 million metric tons of CO2 per year), Next Generation Technologies, and an incremental switch to renewable energy. The EAGER project (Evonik Assessment of Greenhouse Gas Emission Reduction), launched in 2022, identified potential to reduce Scope 1 and 2 emissions at the top 20 sites (80 percent of GHG emissions) by around 1 million metric tons of CO2eq. Evonik plans to invest about 700 million euros in Next Generation Technologies to 2030, and around 99 million euros was invested in 2024 in projects reducing roughly 440,000 metric tons CO2eq annually. Scope 3 actions rest on three levers: reducing emissions of purchased raw materials, using alternative raw material sources, and reducing logistics and packaging emissions.

Reference: page 129

Evonik's emission reduction targets were validated by the SBTi in 2023, confirming the Scope 1 and 2 target is suited to limiting global warming to well below 2 degrees C. The base year is 2021. The group-wide targets are: reduce absolute Scope 1 and Scope 2 emissions by 25 percent between 2021 and 2030, and reduce absolute Scope 3 emissions by 11 percent (exact target 11.07 percent) between 2021 and 2030 (covering all upstream categories and the downstream category transportation and distribution). Evonik aspires to be climate-neutral by 2050. The science-based targets cover 100 percent of Scope 1 and 2 emissions and more than two-thirds of Scope 3. On target achievement, Scope 1 and 2 emissions fell from 6.30 million metric tons CO2eq in the 2021 base year to 5.06 million in 2024 (target 4.73 million by 2030), a 20 percent decrease versus the base year. The SBTi-defined Scope 3 emissions fell from 15.8 to 14.5 million metric tons (target 14.1 by 2030), a 9 percent decrease.

Reference: page 142

Evonik's net electricity and steam consumption in 2024 decreased by 8 percent year on year to 12,822 GWh (2023: 13,997 GWh), mainly due to energy-saving actions and the sale of the superabsorbents business. Total gross energy consumption in 2024 was 19,597 GWh, of which fossil energy was 91 percent (17,891 GWh, including natural gas 9,901 GWh and coal and coal products 931 GWh), nuclear sources 0.1 percent (27 GWh), and renewable sources 8.6 percent. Total renewable energy consumption was 1,679 GWh, corresponding to a 13 percent share of total net electricity and steam consumption. As a specialty chemicals company, Evonik is allocated to the energy-intensive sector under NACE Code Division 20. The energy intensity ratio was 1.29 GWh per billion euros of sales. Energy targets are overall savings of 1,200 GWh from energy efficiency projects in 2021 to 2030, and switching externally purchased or acquired electricity to 100 percent green electricity by 2030 (47 percent in 2024).

Reference: page 135

In 2024, total gross Scope 1 GHG emissions and gross market-based Scope 2 GHG emissions decreased by 4.4 percent year on year to 5.06 million metric tons of CO2eq, mainly attributable to the closure of the coal-fired power plant in Marl at the end of March 2024. Per the Evonik Carbon Footprint table, total Scope 1 emissions were 3.39 million metric tons CO2eq in 2024 (2023: 3.89), of which about 79 percent were subject to carbon pricing systems. Total Scope 2 emissions (market-based) were 1.67 million metric tons (2023: 1.40), comprising purchased electricity 0.83 and purchased steam 0.84; site-based Scope 2 was 1.94 million metric tons. Scope 3 emissions (fast-close) rose to 21.6 million metric tons (2023: 18.9), split into 15.1 upstream and 6.6 downstream. Total GHG emissions (Scope 1, 2 and 3), market-based, were 26.7 million metric tons (2023: 24.2); site-based total was 26.96 million. GHG intensity (market-based) was 1.76 thousand metric tons CO2eq per billion euros of sales. The method is based on the GHG Protocol Standard.

Reference: page 129

Evonik does not use carbon offsets outside its own value chains in its carbon footprint accounting. As of 2024, Evonik's portfolio includes no GHG emissions that cannot be technically reduced by 2050, and the company states it is not currently possible to forecast the economic viability of all technically feasible actions. Biogenic CO2 removals are reported separately: in 2024, minus 1.3 million metric tons of CO2 was recorded for Scope 3 category 1, plus 0.8 million for categories 11 and 12 together, and around plus 0.1 million for direct Scope 1 process emissions. For the period after 2030, remaining Scope 1 and 2 emissions are to be reduced through further energy efficiency and heat integration, with anticipated breakthroughs in carbon capture and storage (CCS) and carbon capture and utilization (CCU). The remaining greenhouse gas emissions are planned to be reduced in the period from 2030 to 2050 in line with the climate neutrality target.

Reference: page 131

Evonik applies internal carbon pricing when planning major investment projects, with the aim of reliably and consistently reflecting carbon-intensive investments in all investment applications worldwide; the expected development of carbon prices is also factored into impairment tests. The current assumption is that a price of 131 euros per metric ton of CO2 will apply in the EU Emissions Trading System (EU ETS) by 2030. In all other regions relevant to Evonik, the forecast has been revised to an average of 37 euros per metric ton of CO2 by no later than 2030, reflecting the political framework in key emerging markets and developing countries. Carbon pricing covers all of Evonik's Scope 1 and 2 emissions (100 percent), and specific calculations are made solely for investment planning. A CO2 cost calculator using location- and fuel-specific emission factors and regional carbon price development scenarios enables harmonized evaluation of investments across the group.

Reference: page 159

Product stewardship is described as Evonik's license to operate, monitoring products across the value chain from raw materials to delivery. The cornerstones are set out in a product stewardship policy published on Evonik's website, aimed at future-proofing the portfolio by replacing hazardous substances. Beyond complying with statutory requirements such as REACH and the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), product stewardship includes voluntary commitments. Evonik is committed to the international Responsible Care initiative and the Responsible Care Global Charter of the ICCA, with implementation and control mechanisms set out in an internal product stewardship standard. Chemical safety, covering substances of concern (SoCs) and substances of very high concern (SVHCs), has always been a priority.

Reference: page 159

Evonik continuously replaces hazardous substances in its products and works on alternative solutions. Substances are evaluated using Evonik's own chemicals management system (CMS), harmonized with ICCA and REACH requirements, which lets substances be assessed at global level. As an extension, the Chemicals Management SystemPLUS (CMSPLUS) is used for products containing more than 0.1 percent of SVHCs, with the aim of reducing or replacing these wherever possible. During the reporting period Evonik continued to include and evaluate substances and products in CMS/CMSPLUS, assessing products with the highest content of SVHCs (and SoCs where possible). Actions also include implementing the REACH Regulation and improving dossier quality (over 500 dossiers reviewed since 2019; full review targeted by end 2026), monitoring REACH-type regulations in other regions, and engaging on the proposed EU PFAS restriction (an estimated 10,000 substances) and microplastics via Operation Clean Sweep.

Reference: page 159

Evonik aims to keep the proportion of sales generated with products classified as challenged below 5 percent long-term, achieved by continuously replacing hazardous substances and working on alternatives. A voluntary target is to include and evaluate substances and products from acquisitions (between 2021 and 2023) in CMS/CMSPLUS by the end of 2026. For products containing more than 0.1 percent of SVHCs, the aim under CMSPLUS is to reduce or replace these wherever possible. Evonik strives to continuously reduce or replace SVHCs wherever possible, mitigating associated risks for employees, customers, and the environment through advanced technologies and risk management actions.

Reference: page 184

The "Emissions into the air and water" table (T64) reports annual emissions of pollutants exceeding the thresholds in Annex II of the E-PRTR Regulation (91 pollutants/groups), covering both direct discharges and wastewater transferred to external facilities (indirect discharge). 2024 air emissions (metric tons, excluding greenhouse gases): nitrogen oxides (NOx/NO2) 1,424 (2023: 1,955); sulfur oxides (SOx/SO2) 800 (2023: 1,374); NMVOCs 220; ammonia 126; particulate matter (PM10) 124. NOx fell 27 percent and SOx 42 percent following decommissioning of the coal-fired block of power plant 1 in Marl at end-March 2024. 2024 water emissions (metric tons): chlorides 16,682; total organic carbon (TOC) 2,178; total nitrogen 226; total phosphorus 46.6; cyanides 3.27; plus trace metals. Soil emissions are negligible and all emissions were below E-PRTR thresholds. Microplastics: around 285,000 metric tons (mainly granules) left production sites as products in 2024.

Reference: page 163

Evonik reports data for SoCs and SVHCs broken down by hazard class in table T48, calculated with a new analytical tool covering purchase, sales, and product stewardship data. SoCs are defined per the Chemicals Strategy for Sustainability and include REACH SVHC Candidate List substances, substances with certain CLP Annex VI hazard classes, and substances hampering recycling/reuse under the ESPR; SVHCs are a subset of SoCs. 2024 ESRS disclosure totals (thousand metric tons, total in purchased raw materials and sold products, excluding double-counting): total SoCs 3,522, thereof SVHCs 184. In raw materials purchased for production: 2,733 SoCs (110 SVHCs); in sold products: 789 SoCs (74 SVHCs). Hazard classes are split into Class A (corresponding to SVHC properties, e.g., carcinogenicity cat. 1, germ cell mutagenicity cat. 1) and Class B (other hazard classes). Some estimates were required, especially for raw materials outside Europe not bound by REACH. Neither SoCs nor SVHCs are subject to authorization at Evonik.

Reference: page 143

Adequate water availability for cooling and production is key to Evonik's operations, with production stoppages due to water shortages, particularly in water stress areas, posing a potential risk. Evonik regularly analyzes short-, medium-, and long-term water risks at all production sites and aims to improve water use in its own operations and along the value chain. In 2023 Evonik adopted a water policy published on its website. Water management focuses especially on water scarcity as a material physical risk, assessed relative to the water catchment area and type of water use at each site. Evonik ensures wastewater discharge meets relevant legal requirements, harnesses advanced technologies for water treatment and reuse, and improves water quality through wastewater treatment plants, reducing reliance on freshwater supply. Products such as amino acids, hydrogen peroxide, and peracetic acid also help reduce water consumption and keep water clean.

Reference: page 144

Evonik uses the WWF Water Risk Filter to identify sites most affected by water risks. In the reporting period none of its 104 production sites rated very high or extreme; five locations were rated high risk and 76 medium risk. Future risks were assessed for the 2030 and 2050 horizons under pessimistic, current-trend, and optimistic scenarios. Assessment was fine-tuned by interviewing site experts (around half of sites assessed to date) and running workshops at sites with high water and operational risk. EAGER projects were identified to reduce specific freshwater withdrawal alongside cutting CO2 emissions. Examples: vapor recompression at Singapore (from 2025) and Delfzijl (Netherlands); connecting Antwerp to the Ecluse steam network (cutting CO2 by at least 100,000 metric tons/year and saving around 42,000 m3 water/year); Power-to-Heat heat pumps in Europe (saving over 3 million m3/year); and using treated municipal wastewater at Antwerp (saving around 2.5 million m3 of drinking water/year from 2026).

Reference: page 143

Evonik's target is to reduce specific freshwater withdrawal by 3 percent relative to production volume between 2021 and 2030. This voluntary corporate target, adopted by the executive board, reflects the special significance of freshwater compared with seawater, with no differentiation based on individual water risks, locations, or thresholds. It is to be achieved through a wide range of actions across all production sites, identified and budgeted under the EAGER project. Status of the target (table T42): specific freshwater withdrawal relative to production volume rose from a 2021 base year of 26.8 m3/metric ton to 32.3 in 2024, against a 2030 target of 26.0, a change of +21 percent versus base year. Between 2021 and 2024 production declined 23 percent due to portfolio measures, plant closures, and falling demand, while freshwater use fell only 8 percent, partly because closed plants used closed-circuit rather than through-flow cooling.

Reference: page 146

Water data (table T41, in million m3, 2024): total water withdrawal 431 (2023: 403), comprising total freshwater 236 (drinking water 17, groundwater 53, surface water including brackish 156, water from raw materials 1.7, other sources 8.8) and sea water 194. Total water discharge was 414, of which into sea/brackish water 270, into surface water 136, into external treatment facilities 7.4, and into products 0.9. Total water consumption (withdrawal minus discharge, mainly evaporation and drying losses) was 17 million m3, thereof 2.5 in areas at water risk including high water stress. Total water recycled and reused was 7.4 million m3 (around 80 percent from condensate recycling). Through-flow cooling water accounted for the largest discharge (356 million m3) and wastewater was 57.3 million m3. Sales were 15,157 million euros, the water intensity ratio was 1,119 m3/euro million, production was 7.31 million metric tons, and specific freshwater withdrawal was 32.3 m3/metric ton.

Reference: page 147

Evonik recognizes both opportunities and risks regarding biodiversity, including loss of biodiversity on land and in oceans and the risk of supply chain disruption from damaged ecosystems restricting biogenic raw materials. The starting points for examining biodiversity are conventional environmental topics such as air and water emissions and water and waste management. Evonik refers to ecosystem services and the direct drivers of biodiversity loss as defined by IPBES (land-/sea-use change, direct exploitation, climate change, pollution, invasive alien species). Since 2023 the direct drivers most relevant to Evonik (climate change, pollution, direct exploitation through water withdrawal, and upstream land use change) have been examined and quantified. Evonik has adopted a biodiversity policy published on its website. It plans to apply the TNFD LEAP approach to better reflect biodiversity in its business analysis, supports soil protection working groups at VCI and BDI, and contributes to deforestation-free palm oil supply chains.

Reference: page 147

Evonik has adopted a biodiversity policy published on its website. Aspects of biodiversity addressed in its business sustainability analysis include water, eutrophication, acidification, land use, use of renewable raw materials, emissions of critical and persistent chemicals, and microplastics. Evonik refers to the ecosystem services and direct drivers of biodiversity loss defined by IPBES. Through responsible procurement of palm oil, palm kernel oil, and their derivatives Evonik seeks deforestation-free supply chains, addressing this in its biodiversity policy. Since 2023 it has used the WWF Biodiversity Risk Filter and WWF Water Risk Filter to assess site risks based on recognized methods, and uses a geoinformation system (GISSus) linked to IBAT Alliance data to annually examine site impacts on areas of special significance for biodiversity within one kilometer of conservation or key biodiversity areas. A group-wide biodiversity dashboard is under development.

Reference: page 148

Evonik aims to achieve its biodiversity targets through its climate, water, and waste actions, with compensatory and restitution actions carried out in line with regulatory/legal requirements. It plans to introduce an IT application to understand the existence and diversity of Indigenous peoples at its locations. In the reporting period it began examining water and biodiversity risks in the supply chain, focusing on water-intensive and renewable raw materials and assessing land use and CO2 emissions from land use change. Since 2023 it has used the WWF Biodiversity Risk Filter and WWF Water Risk Filter, with a more extensive analysis initiated for Asia-Pacific sites (e.g., Shanghai MUSC and Rayong). Site initiatives include the Antwerp site committing to the Voka Charter for Sustainable Entrepreneurship (with renesting of protected barn swallows) and a 14-point plan to reduce NOx/NH3/SOx emissions. Evonik's products also help, e.g., EHC Reagent for groundwater remediation at Hanau and PhytoSquene as an alternative to shark liver oil.

Reference: page 148

Based on the IPBES definition of direct drivers of biodiversity loss, Evonik contributes to preserving biodiversity by addressing issues such as climate change mitigation and direct exploitation of resources such as water. Its climate, water, and waste targets therefore contribute indirectly to preserving biodiversity. These targets are: reduce absolute Scope 1 and Scope 2 emissions by 25 percent between 2021 and 2030; reduce absolute Scope 3 emissions by 11 percent (exact 11.07 percent) between 2021 and 2030; reduce specific freshwater withdrawal by 3 percent relative to production volume between 2021 and 2030; and reduce specific production waste volume by 10 percent relative to production volume between 2021 and 2030. Evonik notes it does not yet have biodiversity-specific quantitative targets, instead relying on these climate, water, and waste targets as indirect contributors.

Reference: page 151

Table T43 lists sites exposed to potentially material risks based on the WWF Biodiversity Risk Filter (potentially high risk where overall assessment exceeds 3.40). Five sites are flagged: Jhagadia (India) high 3.4 physical; Nanning (China) high 3.4 physical; Jilin (China) high 3.44 reputational; Nanping-Laizhou (China) high 3.5 physical; and Zhenjiang (China) high 3.75 physical, with pollution a recurring very high indicator. Table T44 "Sites near to biodiversity-sensitive areas" shows the ten biggest production sites adjacent to conservation or key biodiversity areas. Overall, 36 percent of production sites lie within one kilometer of conservation or key biodiversity areas (Natura 2000 included). A total of 30 production sites are adjacent to conservation areas covering around 1,971 hectares (51 percent of total production site area); 13 sites covering 219 hectares are adjacent to key biodiversity areas (0.6 percent of area). The largest listed sites are Lafayette (USA, 700.4 ha) and Marl (Germany, 664.2 ha, Natura 2000 Lippeaue).

Reference: page 154

Evonik regards circular economy as a fundamental, system-oriented transformation of economic activity along the entire value chain, aiming for a climate-neutral, resource-efficient economy that preserves the value of products, materials, and resources for as long as possible. In the reporting period Evonik adopted a policy on the circular economy and use of resources, published on its website. As a specialty chemicals company at the heart of various value chains, refining products and changing raw material platforms is fundamental. Drivers include stringent regulatory requirements and customer commitments. Evonik's waste management follows a clear hierarchy: first avoid waste, otherwise recycle or recover energy, and only as a last resort dispose safely. It also pursues responsible palm oil sourcing, being an RSPO member since 2010, and addresses critical raw materials under the EU Critical Raw Materials Act by switching to circular sources.

Reference: page 155

Evonik's global circular economy program comprises short- to medium-term actions across three areas: raw materials procurement, waste and resource management in its own production, and solutions that make circularity possible. Actions include using circular raw materials (bio-based, recycled, CO2-based), developing mechanical and chemical recycling technologies, and structuring new value chains. Evonik opened a new rhamnolipids plant in Slovakia in 2024 producing biodegradable biosurfactants from renewable corn feedstocks, and cooperates with a leading recycling company using end-of-life mattress foams for circular polyurethane. Production actions include continuously optimizing processes, measuring and reporting waste, leveraging integrated production sites (e.g., Marl Chemical Park, where liquid organic residues substitute for heavy heating oil and waste sulfuric acid is recycled), and reducing/reusing/recycling packaging. Solutions include additives for chemical recycling, pyrolysis oils, alkoxide catalysts for PET recycling, and design for recycling (monomaterial packaging). Partnerships include the European Circular Plastics Alliance, Plastics Europe, Cefic, and a WWF/Beiersdorf palm oil project in Borneo.

Reference: page 155

Evonik has two executive-board-adopted targets: generate at least 1 billion euros in additional sales with circular products and technologies by 2030; and reduce specific production waste volume by 10 percent relative to production volume between 2021 and 2030. Through the global circular economy program, in cooperation with internal and external partners, Evonik intends to make circularity possible, with circular products paving the way for circular design, use of circular raw materials, extended useful lives, and improved recycling and recyclate quality. While plastics and related applications have been the biggest contributors to date, other business areas are emerging. The waste target is to be achieved by implementing a wide range of actions at production sites, identified for example through the EAGER project, with the voluntary targets aimed at the top of the waste hierarchy (waste prevention). Status (table T47): specific production waste rose from a 2021 base of 0.036 to 0.042 metric ton waste/metric ton production in 2024, against a 2030 target of 0.032, a change of +17 percent.

Reference: page 158

The total weight of raw materials used in 2024 was around 8.6 million metric tons. Bio-based materials accounted for 9 percent of this, while recycled materials made up 0.1 percent (7,300 metric tons). The calculation focused on direct procurement of raw materials, including supplies and toll manufacturing, based on a list of all purchased chemical raw materials from Evonik's central ERP system, supplemented where needed by other sources and a fast-close extrapolation from the first three quarters. Data were adjusted to reflect acquisitions and divestments, avoid double-counting of tolling products, and standardize weight units. Around 2 percent of direct procurement spending relates to units other than weight and is not considered, so the calculated weight data are increased by 2 percent to offset this. Evonik notes limited availability of circular raw materials (renewable/bio-based, recycled, CO2-based), of which it almost exclusively uses renewable raw materials such as palm oil (around 82,000 metric tons annual requirement) and sugars for fermentation.

Reference: page 158

The total waste volume in 2024 was 366,000 metric tons (2023: 348,000). Relevant waste streams include building and demolition rubble, waste from inorganic and organic chemical processes, and waste from waste and wastewater treatment plants, comprising materials such as chemical substances, plastics, paper, glass, wood, scrap metal, and electronic waste. The higher total was primarily due to a 6 percent rise in production waste to 305,000 metric tons (2023: 287,000), driven by product portfolio changes and plant expansions. Waste management (table T45): total waste recovered was 109 thousand metric tons non-hazardous and 105 hazardous (recycling plus other recovery); total waste sent for disposal was 62 non-hazardous and 90 hazardous (incineration, landfill, other). Evonik's circular economy also drives resource outflow solutions through recycling technologies, pyrolysis oils, and design for recycling. Evonik also reports its resource outflows in terms of recyclate and reuse to support circularity targets.

Reference: page 158

Total waste generated in 2024 was 366,000 metric tons (2023: 348,000). Of this, total non-hazardous and hazardous waste was 171 and 195 thousand metric tons respectively (table T45). Total amount of non-recycled waste was 217 thousand metric tons, a percentage of non-recycled waste of 59 percent. Production waste detail (table T46, thousand metric tons, 2024): non-hazardous production waste disposal 39 and recovery 74; hazardous production waste disposal 87 and recovery 105; total production waste generated 305. Specific production waste was 0.042 metric ton waste/metric ton production against production of 7.31 million metric tons. Within total waste management, recycling was 88 (non-hazardous) and 61 (hazardous), incineration 5 and 58, and landfill 34 and 13. The report notes Evonik's waste hierarchy prioritizing avoidance, then recycling or energy recovery, with safe disposal only as a last resort. These figures include only waste streams in the gate-to-gate process.

Reference: page 180

Evonik's workforce policies are anchored in its code of conduct and policy statement on human rights, which apply to all direct and indirect employees of the group and are based on the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the Ten Principles of the UN Global Compact, and the OECD Guidelines for Multinational Enterprises. Both the code of conduct and the policy statement forbid discrimination. The human rights policy covers the right to fair treatment, protection against discrimination, and the prohibition of forced labor, human trafficking, and child labor, with ultimate responsibility resting with the executive board. For occupational health and safety, the ESHQE management handbook sets out mandatory global rules on environment, safety, health, quality, and energy, and the group-wide Safety at Evonik management approach defines binding principles of action. Evonik was the first chemical company to sign an occupational inclusion policy. Mandatory training is provided on the code of conduct and on human rights (2024 training rate 84 percent worldwide).

Reference: page 173

Collaboration between employer and employee representatives based on trust is described as a key success factor. In Germany the fundamental rights of employees and their representatives are enshrined in statutory regulations such as the Works Constitution Act and the Executives' Committee Act, with works councils representing exempt and non-exempt employees and executive staff councils representing executives. Representatives are consulted in good time on all major changes within the company, and Evonik commonly involves them beyond the co-determination prescribed by German law in all matters relating to the group's future development. In reorganization or restructuring, works councils and executive staff councils seek socially responsible solutions such as job transfers or early retirement. Information and consultation rights on European cross-border issues are represented by the Evonik Europa Forum, composed of employer and employee representatives. Employee engagement is also gauged through 23 pulse checks in 2024 (13,572 participants), career-milestone surveys, and an advanced employee satisfaction survey tool integrated into the HR management system.

Reference: page 194

Evonik has set up various channels for reporting potential and actual compliance violations. An electronic whistleblower system, operated by an independent external provider with servers based exclusively in Germany, is accessible 24/7 worldwide via the intranet and Evonik's website in over 20 languages. It can be used by Evonik employees, agency staff working for Evonik, business partners, and other external stakeholders. The system is certified as conforming with European data protection legislation, and technical security measures ensure that neither Evonik nor the provider can identify a whistleblower who reports anonymously. Whistleblowers can set up their own mailbox to communicate confidentially and, if desired, anonymously with Evonik case managers. Employees and agency staff can also contact internal compliance officers personally or by phone, and reports may be submitted by email. Reports can cover all major compliance issues, including suspected human rights breaches, corruption, and blackmail. Evonik does not tolerate any disadvantage to persons who report violations in good faith.

Reference: page 170

Evonik's HR strategy takes a practice-oriented approach focused on employee recruitment, development, and retention, underpinned by selective HR planning and a recruitment policy for key positions. The company offers fair pay, flexible working models, and transparent development opportunities. To counter the skilled-worker shortage, Evonik stepped up employer branding, onboarding, and talent acquisition under the "Be Part of Something Special" employer identity, which was rolled out across business lines, functions, and regions in 2024. Talent management actions include the Evonik Explorer Program (around 200 participants in 2024), regular succession and development reviews at executive-board level, and the ONE Culture and Next Generation Culture initiatives to make the corporate culture more dynamic and performance-driven. In 2024 employee satisfaction and change-management efforts were intensified through 23 pulse checks (13,572 participants) and a new survey tool. On adequate wages, just 0.7 percent of employees are paid less than the adequate wage, all in Singapore; corrective action is being taken.

Reference: page 171

Evonik has set several quantitative targets for its own workforce. On learning, average self-directed digital learning using the LILY and LinkedIn Learning platforms should exceed three hours per employee per year by 2026 (baseline 2.05 hours in 2022, 1.7 hours achieved in 2024). On diversity, the proportion of women at executive, senior management, and other management levels is to reach 30, 25, and 33 percent respectively by 2026, and the intercultural mix at executive and senior management levels is to reach 25 and 35 percent respectively by 2026. On occupational and plant safety, the targets are a lost time injury rate (LTI-R) of 0.26 or below, a process safety incident rate (PSI-R) of 0.40 or below, and an occupational health performance index of 5.0 or above. Accident frequency is factored into the variable remuneration of executive board members. Progress is measured through standardized definitions, processes, dashboards, and the HR Dashboard.

Reference: page 175

As of December 31, 2024, Evonik employed 31,930 people (down from 33,409 in 2023), of whom 23,135 were men and 8,795 women. By contractual status, 29,522 held permanent contracts and 1,147 held temporary contracts, with 1,261 full-time apprentices/trainees. Around 96 percent of permanent employees worldwide have permanent contracts. By working time, 28,184 were full-time and 2,485 part-time. By region, EMEA accounted for 21,364, North America 4,746, Central and South America 748, and Asia-Pacific 5,072. By country, Germany had 18,305 employees, the USA 4,393, and other countries 9,232. Early turnover decreased to 1.7 percent (from 2.2 percent in 2023) and total turnover fell to 6.2 percent (from 6.6 percent); 2,059 employees left the company. Average length of service was 14.1 years. The data are headcount figures taken from the global SAP HR information system.

Reference: page 173

Based on its sites worldwide, Evonik has employee representatives for roughly 96 percent of its employees. Collective agreements on remuneration cover 100 percent of employees in Germany and around 67 percent of employees worldwide. The regular contractually defined working hours for more than 74 percent of employees are based on collective agreements. Performance- or profit-oriented incentive systems are in place at around 95 percent of sites and companies, covering some 99 percent of permanent employees. Evonik does not restrict employees' rights to freedom of association or to collective bargaining, and ensures these rights even in countries where freedom of association is not protected by the state. Table T53 presents collective bargaining coverage and social dialogue by region, showing 80 to 100 percent coverage for Germany within the EEA, with workers' representation bodies applicable in the EEA. At company level in Germany, employees' interests are protected by representatives on supervisory boards under co-determination.

Reference: page 121

Evonik's permanent workforce is made up of 28 percent women and 72 percent men. Of 147 executives, 32 (22 percent) are women and 115 (78 percent) are men. The proportion of women in management was 21.8 percent at executive level (32 of 147), 19.1 percent in senior management (92 positions), and 31.4 percent at other management levels (2,709 positions) in 2024; across all management levels the share was 30.7 percent (2,833 positions). In the reporting period, 28 percent of new hires were female and 72 percent male. On age structure, the average age was 43 years; 18 percent of the workforce (5,755 employees) was up to 30, 51.2 percent (16,351) was 31 to 50, and 30.8 percent (9,824) was over 50. Evonik employs people of 110 nationalities at 198 sites in 53 countries; around 46 percent of managerial employees do not hold German citizenship, and the share in senior management is around 26 percent.

Reference: page 172

Evonik pays its employees, including trainees and student interns, the statutory minimum wage in the respective country. In countries outside Europe that do not have a minimum wage, the living wage is used as the benchmark, defined as the minimum income required for a worker to cover their basic needs, with the relevant amount determined by reference to the Fair Wage Network's database. In European countries without a statutory minimum wage, Eurostat's average annual earnings for 2022 were used. Just 0.7 percent of employees are currently paid less than the adequate wage, and all of those concerned are in Singapore. HR tools worldwide ensure employees receive market- and performance-based remuneration aligned with their responsibilities, capabilities, and track records, irrespective of gender, age, or other personal characteristics, with discrimination forbidden under the code of conduct and policy statement on human rights.

Reference: page 174

Evonik's employees have social security cover protecting them against loss of income due to major events such as sickness, unemployment, workplace accidents, disability, motherhood, and retirement. Virtually 100 percent of the workforce are covered by statutory or company pension insurance and health insurance; there is no statutory pension insurance in the United Arab Emirates. In all regions, Evonik offers voluntary social benefits available to 99 percent of employees, including part-time workers, provided they meet the minimum working hours prescribed in some regions. In 2024, employees in Germany, the USA, Belgium, and Singapore could take part in an employee share program, with uptake of 35 percent. In many countries Evonik provides contribution-based pension schemes allowing employee contributions; in Germany employees can choose personal contributions of 0, 3, or 4 percent, while in the USA the standard contribution is 6 percent, with graduated employer contributions.

Reference: page 172

Around 88 percent of employees worldwide receive a regular performance appraisal; of those appraised, 70 percent are men and 30 percent women, and 70 percent are non-exempt and 30 percent exempt employees. Evonik operates a global learning strategy built on uniform digital solutions including the LILY platform and the LinkedIn Learning library of over 20,000 courses. In 2024, average self-directed digital learning using LILY and LinkedIn Learning amounted to 1.7 hours per employee (men 1.4 hours, women 2.4 hours), against a 2026 target of more than three hours. In 2024 Evonik trained 1,718 young people in Germany (1,229 at Evonik, 489 at external companies) across 38 recognized vocational training courses. Vocational training expenses amounted to 64.7 million euros and continuing professional development spending was 10.59 million euros, equating to 332 euros per employee. A total of 16,381 employees participated in 141 learning sessions.

Reference: page 180

In 2024, 100 percent of employees were covered by a health and safety management system. There were zero fatalities as a result of work-related injuries among both employees and non-employees, and no fatal accidents involving employees or contractors' employees at sites or when commuting, with no accidents resulting in more than six months' absence. Work-related accidents resulting in absences of at least one full shift numbered 45 for employees and 58 for non-employees (contractors). The rate of such accidents (LTI-R, per 200,000 working hours) was 0.14 for employees (down from 0.21 in 2023, well below the upper limit of 0.26) and 0.80 for contractors (up from 0.79 in 2023, due to fewer contractors being used). The total number of hours worked by Evonik's employees, including staffing agency personnel, was around 65 million. The LTI-R per 1,000,000 working hours was 0.7. For the first time, Evonik reported total recordable injuries (TRI) of 213, a rate of 3.28 per 1,000,000 working hours. Most injuries related to hands and fingers.

Reference: page 174

Evonik is committed to a family-friendly HR policy offered to 97 percent of employees worldwide, with cornerstones including flexible work hours, assistance with childcare and other caring responsibilities, and the hybrid #SmartWork model. Of 31,930 employees, 92 percent are in full-time and 8 percent in part-time employment; around 80 percent of the 8,795 female employees work full-time, compared with 97 percent of male employees. In Germany, all 18,305 employees, including 13,285 male employees, have a statutory right to parental leave. In 2024, 738 employees made use of this right, with male employees accounting for around 48 percent; men took an average of 1.7 months' parental leave while women took an average of 6.5 months. In 2024, 552 employees returned to work following parental leave, with men accounting for just under 62 percent. The option of extended periods of leave (more than three months) is now taken up by almost a quarter of employees.

Reference: page 173

In 2024 the global unadjusted gender pay gap, the difference between the average gross hourly earnings of women and men, was just under 9 percent, meaning women earn just under 9 percent less than men worldwide. In Germany, where around 60 percent of all Evonik employees work, the gender pay gap was 3.7 percent. The metric is influenced by factors such as the allocation of men and women to different job levels and job families. Comparison with the prior year is not possible because the calculation basis changed: in 2024 all remuneration components were included, whereas previously only basic remuneration was considered. The ratio of the total remuneration of the highest paid person to the median total remuneration of the entire workforce was around 57:1 in 2024; for the German workforce the ratio was 55:1. Both the gender pay gap and the ratio took into account base salary plus all other pay, excluding pension commitments; countries with more than 20 employees were included.

Reference: page 197

Evonik reports key metrics on serious breaches of human rights, discrimination, and corruption for the 2024 reporting period. For serious breaches of human rights relating to the company's own workforce, the number of cases was nil (table T67), including nil cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Core Labour Standards, or the OECD Guidelines for Multinational Enterprises; fines, sanctions, and compensation payments as a result were nil. On discrimination (table T68), there were 10 reported incidents of discrimination in 2024 (down from 12 in 2023), 2 complaints submitted via the company's complaints mechanisms for its own employees (down from 3 in 2023), and no complaints submitted to the OECD's national contact points. Fines, sanctions, and compensation payments as a result of the disclosed incidents and complaints were nil. On corruption (table T69), there were no rulings and no fines in respect of violations of anti-corruption law in 2024.

Reference: page 200

Evonik's policy framework for value chain workers centres on its code of conduct for suppliers, which is based on internationally recognized human rights and sets binding requirements for all suppliers. The code covers conduct in the business environment, human rights and fair working conditions (prohibition of forced labor, human trafficking and child labor; fair treatment and protection against discrimination; freedom of association and collective bargaining; fair remuneration and regular working hours; rights of local communities and Indigenous peoples), specifications for sourcing raw materials, and environment, safety, health, quality and energy. It also requires suppliers to implement standards with sub-suppliers and to set up their own complaints procedures so affected workers can report violations without disadvantage. The values are communicated to suppliers via general terms and conditions of purchase and regular Supplier Days. Affected workers can also use Evonik's externally operated whistleblower system. In 2024 no complaints were received from or about suppliers via the whistleblower system.

Reference: page 201

Evonik recognises that actively involving people who are potentially affected by human rights breaches in the supply chain is a key component of human rights due diligence. Its stated aspiration is to establish a structured dialogue process with potentially affected people, related groups and their representatives, so their interests are given adequate consideration in decision making and in defining and monitoring relevant targets and actions. Evonik planned to roll out this process in 2025 as part of its human rights and environmental risk analyses. Engagement with workers operates largely through the Together for Sustainability (TfS) initiative, which conducts on-site audits assessing working conditions, and through supplier validation and evaluation processes. Where actual breaches of human rights are identified, Evonik engages directly with the supplier, agrees binding corrective actions and, where necessary, makes redress to those affected.

Reference: page 201

Employees at supplier companies and anyone potentially or actually affected can report violations of the supplier code of conduct standards through Evonik's externally operated whistleblower system without incurring any disadvantage. The system, run by an independent external provider with servers in Germany, is accessible 24/7 via the internet in over 20 languages and can be used anonymously. All cases are examined promptly so appropriate action can be taken. Where Evonik identifies actual breaches of human rights, for instance through audits, whistleblower reports or external sources, it immediately engages with the supplier, agrees binding actions to resolve the situation and, where necessary, makes redress to those affected. Possible actions include improvement plans, modification of procurement practices, collaboration with partners and temporary suspension of the business relationship while corrective measures are ongoing. Escalation levels are set out in internal process documents, with Procurement consulting the human rights officer where clarification is needed.

Reference: page 200

Evonik sourced from around 33,000 suppliers in 2024 (procurement volume of 10.5 billion euros) and deploys a dedicated sustainability, risk and compliance procurement team plus software such as EcoVadis. Through an annual group-wide human rights compliance risk analysis it identifies high-risk value chains (metallic and mineral raw materials, renewable raw materials, services, and logistics) and implements preventive and corrective actions, covering employees of direct suppliers and the deeper supply chain. As a founding member of the Together for Sustainability (TfS) initiative, Evonik uses self-assessments, audits and supplier validation. In 2024, 1,568 suppliers were assessed; Evonik initiated 22 audits and 92 assessments. Corrective action was initiated with 14 suppliers where major or critical audit issues arose. Fifty-two potential violations were identified at direct suppliers (27 resolved or halted) and 15 at indirect suppliers (all resolved or halted). Effectiveness is reviewed through recurring EcoVadis assessments and audits.

Reference: page 201

Evonik's principal target for value chain workers is to examine, by 2030, more than 90 percent of its significant raw material suppliers (those with an annual procurement volume above 100,000 euros) through TfS or equivalent assessments. As of the end of 2024, around 87 percent of major raw material suppliers had been validated against the applicable criteria. Evonik states that, because its goal is continuous improvement, it has not set detailed targets for preventing human rights breaches and environmental violations by direct and indirect suppliers, nor for creating positive impacts for people and the environment in its supply chains; this also applies to the risks and opportunities for Evonik itself arising from acting accordingly in respect of its supply chains. The structured dialogue process with potentially affected people was to be rolled out in 2025 as part of the human rights and environmental risk analyses.

Reference: page 189

The cornerstone of responsible corporate governance at Evonik is its code of conduct, together with the policy statement on human rights, the ESHQE policy and the code of conduct for suppliers. The code of conduct, available in 28 languages and adopted by the executive board, is an integral part of every employment contract and sets out principles on human rights, non-discrimination and fighting corruption, with zero tolerance for violations. Internal guidelines are implemented through comprehensive management systems, with the relevant compliance areas bundled in a House of Compliance overseen by the Compliance Committee, the chief compliance officer and Group Audit. The executive board sets minimum CMS standards and the supervisory board's audit committee oversees effectiveness. A group-wide, risk-based training concept covers antitrust law, anti-money laundering, fighting corruption, code of conduct and human rights, with a target training rate of at least 80 percent per compliance area. An external whistleblower system in over 20 languages allows employees and external stakeholders to report violations confidentially and anonymously, with protection from retaliation.

Reference: page 194

Evonik's organizational units perform business partner assessments through a permanent project group comprising Group Compliance (Antitrust, Compliance, Foreign Trade, Human Rights), Procurement, Marketing & Sales Excellence and Group Security. Together with an external provider they operate an IT-based process to validate the integrity of business partners, request integrity checks and initiate and monitor necessary action, supporting interdisciplinary collaboration and documentation. Evonik has issued a special code of conduct for suppliers setting out binding requirements. Intermediaries, especially sales intermediaries, undergo a compliance check before the relationship begins and at regular intervals, and must sign a compliance declaration; risk-based due diligence is also applied to acquisitions, joint ventures and major investment projects. Validation is the first step in every new supply relationship, based on the values in the supplier code of conduct, with details entered online and evaluated using a validation matrix. Existing relationships are evaluated annually, with detailed review of strategic suppliers. Procurement employees receive training on ESG assessments and audits.

Reference: page 189

Evonik prohibits all forms of corruption, including facilitation payments, and is committed to fair competition. Prevention tools bundled in the House of Compliance include risk analysis, training, awareness-raising and advice. Each unit performs regular risk analyses; regular analyses cover fighting corruption, antitrust law, anti-money laundering and human rights, and these analyses revealed no significant compliance risks after mitigating actions. National and international anti-corruption and anti-money laundering standards are aligned with the United Nations Convention against Corruption. A group-wide, risk-based training concept assigns employees to risk categories (none, low, high); mandatory anti-corruption training depends on contact with external third parties and organizational level. Detection relies on a requirement for all employees to report violations and on the whistleblower system. The chief compliance officer reports to the executive board every quarter and to the audit committee annually on compliance including fighting corruption; executive board training on rotating compliance areas (including fighting corruption) occurs every two years. In 2024 the worldwide fighting-corruption training rate was 95 percent.

Reference: page 197

Evonik reports key metrics on serious breaches of human rights, discrimination and corruption for the 2024 reporting period. For corruption, the number of rulings in respect of violations of anti-corruption law was nil and fines as a result of violations of anti-corruption law were nil (zero euros), for both 2023 and 2024. Despite no confirmed rulings or fines, Evonik reports that in 2024 the following actions were taken to sanction violations of anti-corruption standards and processes: dismissal of employees, warnings and reprimands, reassignment, training, awareness measures and criminal charges. Related disclosures show no serious breaches of human rights identified in relation to the company's own workforce and no associated fines, sanctions or compensation payments.

Reference: page 197

Evonik participates in opinion-forming processes at regional, national, European and international level, guided by a political mission statement, and provides transparent information about donations and the type and purpose of its participation in political processes. The Strategic Communication function handles political communication in Germany and Europe, with operational responsibility in the Governmental Affairs department; the head of Strategic Communication reports to the executive board chairman. Evonik maintains entries in the European Transparency Register (register number 5958991861-30) and Germany's national lobby register (Evonik Industries AG, R002081, and Evonik Operations GmbH, R002087). Evonik does not donate to political parties but sponsored a number of political events in 2024 with cash and in-kind donations totalling 135 thousand euros. Total annual lobbying spending, comprising personnel, infrastructure, representation, external advisory and other lobbying expenses, is disclosed via the register entries. In the two years before appointment, supervisory and executive board members held no comparable positions in a public authority or regulatory body.