Frequentis

Austria|Aerospace & Defence|Reporting year:FY2025 FY2024|Auditor: BDO|View original report →

Material Topics

ESRS 2 – General Disclosures E1 – Climate Change E5 – Resource Use and Circular Economy S1 – Own Workforce S2 – Workers in the Value Chain S4 – Consumers and End-Users G1 – Business Conduct

57 DRs reported25 not material

Sustainability statement, in full

The complete text of Frequentis’s FY2025 sustainability statement is held here – 116 pages, 309k characters, captured from the published report. Every disclosure below also links to its own passage.

Value chain diagram – from the 2024 report (click to enlarge)

Frequentis value chain showing Upstream suppliers/subcontractors, Frequentis core activities, and Downstream implementation partners and customersSource: Frequentis 2024 annual report, p.50. View original →

ESRS 2 – General Disclosures

GOV-1The role of the administrative, management and supervisory bodies

Reported

The role of the administrative, management and supervisory bodies

Reference: pages 21-24.

In 2025 the Executive Board comprised the Chairman, the CFO Peter Skerlan, COO Monika Haselbacher and Karl Wannenmacher, whose responsibilities are set out individually (e.g. Haselbacher covers Project Management & PMO, Customer Services, HSE Management and Quality Management). The Supervisory Board comprised eight members, including Chairman Johannes Bardach and Deputy Chairman Karl Michael Millauer, with initial appointment dates listed back to 2007. The report discloses that the Supervisory Board does not fulfil C rule no. 53: only three of six shareholder representatives are considered independent (Bardach, Reinhold Daxecker and Sylvia Bardach), a departure explained by their "extensive expertise" and "very precise knowledge of the Frequentis Group." An Audit Committee, established under Section 92(4a) of the Austrian Companies Act, performs preliminary examination of the non-financial statement.

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reported

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

Reference: page 45.

Since early 2022 Frequentis has pooled ESG expertise in a Group-wide ESG organisation. CFO Peter Skerlan bears executive-level responsibility for ESG, a mandate defined by the Supervisory Board on 30 March 2022 in the Executive Board's rules of procedure. An interdisciplinary ESG team is coordinated by an ESG Steering Group working closely with the Executive Board; specific projects are analysed and prioritised at a monthly jour fixe, and an annual ESG management review led by the CFO discusses the year's ESG activities and indicators and defines further action. The Executive Board and Supervisory Board "support all measures," and ESG is "a recurrent item on the agenda for Supervisory Board meetings." Modification of the sustainability & ESG organisation is planned for 2026 to strengthen its strategic focus.

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes

Reported

Integration of sustainability-related performance in incentive schemes

Reference: page 46.

Executive Board variable remuneration includes non-financial, largely ESG, targets alongside financial ones. Depending on achievement of the ESG targets, the variable remuneration from other targets can be adjusted by a factor of between 0.8 and 1.2, with targets set by the Committee for Executive Board Issues. For 2024 and 2025, two-year ESG targets covered energy, circular economy, compliance and cybersecurity. Climate-related considerations enter indirectly via the energy target, but the target for an absolute reduction in energy consumption "could not be achieved due to strong growth and new customer projects," so "the percentage of recognised remuneration for 2025 linked to climate-related considerations is therefore 0%." New non-financial targets for 2025-2026 (succession policy) and 2026-2028 (EcoVadis rating) were also set.

GOV-3(was GOV-4)Statement on due diligence

Reported

Statement on due diligence

Reference: page 47.

Frequentis maps its due diligence process to five key elements via a signposting table. Embedding due diligence in governance, strategy and the business model is addressed under ESG organisation; engaging affected stakeholders in all key steps is addressed under Stakeholder dialogue; identifying and assessing adverse impacts is addressed under Materiality assessment; and both taking action on adverse impacts and tracking the effectiveness of these efforts point to the Actions sections of E1, E5, S1, S2, S4, G1 and the entity-specific Safety & Security topic. The table itself constitutes the disclosure required by BP-1/GOV-4, cross-referencing rather than repeating the underlying content, consistent with the company's general basis of preparation.

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting

Reported

Risk management and internal controls over sustainability reporting

Reference: pages 47, 134-135, 140.

ESG organisation cross-references Opportunity and risk management and the Internal control system (ICS) for the accounting process for this disclosure. Frequentis states it "has implemented an active risk management system throughout the Group," compiling an internal evaluation of risks and opportunities into a Group-wide risk report. As part of the 2025 financial statement audit, in March 2026 BDO Assurance GmbH "confirmed the functioning and appropriateness of Frequentis' risk management system in accordance with C rule no. 83 of the Austrian Code of Corporate Governance." ESG-related risks are assessed as part of the materiality assessment, with their financial impact integrated into the Group-wide risk management process alongside other opportunity and risk categories.

SBM-1Strategy, business model and value chain

Reported

Strategy, business model and value chain

Reference: pages 47-52.

Frequentis is "an international provider of solutions for safety-critical control centres," organised into the Air Traffic Management segment and the Public Safety & Transport segment (police, fire, emergency, rail, coastguard, port authorities). "More than 90% of customers are state-run authorities" or public administrative bodies. The company has a network in "more than 50 countries," with locations including Vienna (headquarters), Australia, Brazil, Canada, the Czech Republic, France, Germany, Italy, Norway, Romania, Singapore, Slovakia, Switzerland, the UK and the USA. Strategy is aligned to three megatrends: mobility, safety & security, and technological change. The value chain concentrates on direct relationships: upstream suppliers, subcontractors and service partners; Frequentis' own product development, production and sales; and downstream implementation partners, customers and end-users such as air traffic controllers and dispatchers.

SBM-2Interests and views of stakeholders

Reported

Interests and views of stakeholders

Reference: pages 52-54.

In the late-2023/early-2024 materiality assessment, ten stakeholder groups were asked to assess 37 ESRS sub-topics plus four company-specific safety & security sub-topics: employees, Supervisory Board, managers, Executive Board and Managing Directors, shareholders/capital market representatives, banks, suppliers and subcontractors, customers, NGOs/advocacy groups, and project partners. A table maps each group to its communication formats (e.g. Supervisory and Executive Board meetings, intranet and career fairs for employees, roadshows for investors, supplier visits and audits for subcontractors) and the topics addressed. Frequentis also operates a whistleblower service, available via frequentis.com/whistleblowing, "for simple and anonymous reporting of concerns about possible non-compliant behaviour," open to internal and external stakeholders.

SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model

Reported

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

Reference: pages 54-58.

The double materiality assessment identified six material ESRS topics — E1, E5, S1, S2, S4 and G1 — plus one company-specific topic, safety & security, presented in a three-dimensional materiality matrix (impact materiality, financial materiality, stakeholder significance). "The update of the materiality assessment in autumn 2025 did not result in any change in the material ESRS sustainability topics," though within G1 "a new risk was identified with regard to a possible loss of orders or reputational damage due to failure to fulfil ESG reporting enquiries." Per-topic tables list each impact, risk and opportunity with its time horizon. A climate risk and vulnerability analysis has been performed, but "an additional specific resilience analysis was not performed with regard to sustainability risks." Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities

Reported

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

Reference: pages 57-60.

The ESG Steering Group began examining CSRD requirements in early 2023, supplementing the standard ESRS topic list with a company-specific "Safety & Security" section. Impact materiality used an anonymous online questionnaire reaching "about 3,250 people," complemented by two internal-expert workshops covering impact and financial materiality respectively. Impacts were scored 1-4 across scale, scope, irremediable nature and likelihood, with a >=2.5 arithmetic-mean threshold for materiality; risks and opportunities were scored 1-4 against EBIT-impact thresholds across five risk categories, with a >2 threshold. Results went to the Executive Board and Supervisory Board. "In autumn 2025, the materiality assessment was updated in collaboration with internal experts," with the outcome approved by the Executive Board. Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reported

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

Reference: pages 61-64.

Frequentis presents a concordance table mapping every disclosure requirement it covers to its location in the statement, built on "the list of ESRS datapoints (EFRAG implementation guide 3 'List of ESRS Datapoints')," after which "some metrics were classified as not relevant and are therefore not reported." Topical standards listed are ESRS E1, E5, S1, S2, S4 and G1, consistent with the six material ESRS topics; E2, E3, E4 and S3 do not appear because they were assessed as not material. Two datapoints are flagged rather than cross-referenced to a chapter: E1-9 is marked "Disclosures pursuant to ESRS 1 Appendix C, qualitative only," and E5-6 is marked "No financial risks and opportunities identified." A second table lists Appendix B datapoints deriving from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law).

E1 – Climate Change

E1-1Transition plan for climate change mitigation

Reported

Transition plan for climate change mitigation

Reference: page 80.

"In 2025, Frequentis gave a commitment that it would define science-based climate targets in conformance with the Science-Based Targets initiative (SBTi) by the end of 2026 and develop a transition plan for climate change mitigation by the end of 2027." The report is explicit that the formal transition plan itself has not yet been produced: the disclosure records the commitment and its timetable rather than a completed plan with quantified decarbonisation levers or a defined implementation budget. The identified material E1 impacts, risks and opportunities feeding into this future plan are set out in the E1.SBM-3 table (page 79), and the underlying climate scenario work is described under ESRS 2 IRO-1 (pages 58-59), cross-referenced here as E1-2 in the 2025 ESRS numbering.

E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysis

Reported

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 58-59). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A climate risk and vulnerability analysis of Frequentis' own locations and assets was performed in 2023 and extended in the 2025 materiality assessment to the upstream and downstream value chain. Physical risk was evaluated using three IPCC scenarios — SSP1-2.6, SSP2-4.5 and SSP5-8.5 — "reflecting different temperature developments," with time horizons extending to 2085; the value-chain extension used "a high-emission climate scenario," implicitly SSP5-8.5. Transition risk was assessed across five TCFD-based risk categories using "one climate scenario that is in keeping with the Paris Climate Agreement," though the report does not name that scenario or state its temperature projection. "No assets or business activities were identified that are incompatible with the transition to a climate-neutral economy."

E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate change

Reported

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (page 57). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Frequentis states plainly that no formal ESRS resilience analysis has been carried out: "A climate risk and vulnerability analysis has been performed on climate-related risks... An additional specific resilience analysis was not performed with regard to sustainability risks." The company instead relies on its existing 2023 climate risk and vulnerability analysis (extended to the value chain in 2025, see E1-2) and states that "the risks are recorded and actively managed as part of the Group-wide risk management." No discussion of implications for the business model, capacity to redeploy or adapt assets over short/medium/long term, or specific areas of uncertainty in a resilience sense is provided beyond this general risk-management framing.

E1-4(was E1-2)Policies related to climate change mitigation and adaptation

Reported

Policies related to climate change mitigation and adaptation

Reference: page 80.

The Environmental & Energy Policy sets Frequentis' strategic focus on climate mitigation and energy, covering "reducing greenhouse gas emissions, efficient use of energy, improving energy performance in design activities, and including energy-efficient products and services in the procurement process." It is binding for companies within the ISO 14000-certified management system, with the Global Corporate Policy requiring others to define a local equivalent. In the value chain, "the biggest emission drivers are purchased goods and services, the energy consumption of products sold to customers, and business travel"; a Group-wide travel policy restricts business trips to necessity and weighs cost-efficiency and sustainability, directly addressing the pollution impact and transition-cost risk identified in the E1.SBM-3 table. The Executive Board and local Managing Directors are responsible for applying the policies.

E1-5(was E1-3)Actions and resources in relation to climate change policies

Reported

Actions and resources in relation to climate change policies

Reference: pages 81-82.

Frequentis AG obtained initial ISO 50001 Energy Management certification in H1 2025, supported by a cross-departmental energy and environment team meeting three to four times a year. LED lighting conversion, due to complete in 2027, is expected to cut lighting energy by "about 65%," having already reduced location-based Scope 2 emissions by 15 tCO2e in 2025. Electric vehicles reached 45% of the Group fleet (2024: 34%), cutting Scope 1 emissions by 83 tCO2e year on year, with a full AG fleet switch targeted "by 2030." A mandatory environmental training module launched in 2025. Frequentis also cites its own products' role in reducing customers' emissions, including 20 years of involvement in the SESAR "green aviation" programme.

E1-6(was E1-4)Targets related to climate change mitigation and adaptation

Reported

Targets related to climate change mitigation and adaptation

Reference: page 82.

Frequentis "does not currently have any measurable, outcome-oriented targets that meet the ESRS minimum disclosure requirements as set out in MDR-T." In line with its SBTi commitment, it will define science-based targets by the end of 2026 and then develop a transition plan for climate change mitigation, "tak[ing] into account achieving climate neutrality by 2040." In the interim, effectiveness of policies and actions is tracked at meetings of the energy and environment team. The company also aims to obtain EMAS certification for Frequentis AG in Vienna in H1 2026, a "voluntary environmental management and auditing system" whose public environmental statement is intended to "increase transparency."

E1-7(was E1-5)Energy consumption and mix

Reported

Energy consumption and mix

Reference: pages 82-83.

Renewable energy accounted for 55% of Group total energy consumption in 2025 (up from a lower 2024 base), driven largely by Frequentis AG in Vienna, where the entire electricity supply — hydroelectric, wind and other ecological sources — brought AG's renewable share to 96%. In-house photovoltaic installations at Vienna and Frequentis Australasia in Brisbane supply about 1% of Group energy. The Group energy table reports total energy consumption of 15,953 MWh in 2025 (2024: 14,984 MWh), of which 8,460 MWh fossil (54%), 8,648 MWh renewable (54%... reported as 54%/58% across metrics) and a non-assignable portion estimated, for 11% of consumption, "on the basis of the size of the building" for companies without direct data.

E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions

Reported

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 84-86.

Group gross Scope 1 emissions were 585 tCO2e in 2025 (2024: 593), gross location-based Scope 2 was 2,669 tCO2e and market-based Scope 2 was 691 tCO2e. Significant Scope 3 categories — Category 1 purchased goods and services (81,763 tCO2e), Category 2 capital goods, Category 6 business travel, Category 11 use of sold products (44,736 tCO2e) and Category 15 investments — were selected using a 2%-of-total-emissions threshold. Total market-based Group emissions reached 44,082 tCO2e in 2025. Calculations use the GHG Protocol via emission factors from Climatiq (UBA, BEIS, ADEME, CEDA, IEA databases); Scope 3 Category 1 relied on spend-based, country-specific factors, and primary data accounted for only "0.1%" of Scope 3 calculations, concentrated in Category 6 business travel.

E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits

Not Material

E1-10(was E1-8)Internal carbon pricing

Not Material

E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Omitted

E5 – Resource Use and Circular Economy

E5-1Policies related to resource use and circular economy

Reported

Policies related to resource use and circular economy

Reference: page 89.

A Circular Economy Policy, developed across 2024 and 2025 with multiple departments, has begun implementation of its first prioritised measures. The existing Environmental & Energy Policy also "contributes to improving the use of materials and resources and reducing waste"; the Procurement Policy and the Corporate Social Responsibility (CSR) Code for Suppliers require environmental impacts related to the circular economy to be taken into account in procurement, even though they "do not directly address the identified material impacts, risks, and opportunities." A dedicated Waste Management Policy for Frequentis AG in Vienna, based on the Vienna waste management law (AWG), addresses hazardous and electronic waste specifically. The Executive Board and local Managing Directors are responsible for applying these policies.

E5-2Actions and resources related to resource use and circular economy

Reported

Actions and resources related to resource use and circular economy

Reference: pages 89-91.

Building on the Circular Economy Policy, Frequentis structured 2025 actions around "six Frequentis-specific topics along the value chain" identified in 2024: procurement/design/logistics (favouring modular, repairable systems and short, mostly European, supplier routes); development/production (reusable software components, recycled waste, waste heat reuse in Vienna); installation/testing (careful reuse of cables and tools); shipping/transport (reusable packaging, aligned with the EU Packaging and Waste Regulation from August 2026); operation/service (long-life products supported by service and maintenance programmes, and hardware repurchase from customers); and waste disposal (systematic sorting; hazardous waste "less than 2% of total waste" at Frequentis AG in 2025). A core circular-economy team continues this work into 2026.

E5-3Targets related to resource use and circular economy

Reported

Targets related to resource use and circular economy

Reference: page 92.

"Frequentis does not currently have any measurable, outcome-oriented targets that meet the ESRS minimum disclosure requirements as set on in MDR-T," but tracks effectiveness of the actions in its 2025 Circular Economy Policy. A cross-departmental priority is developing a sustainable procurement policy selecting materials and services on ecological, social and governance criteria. Priority compliance work targets the EU Packaging and Waste Regulation and the WEEE Directive, to be extended in 2026, alongside broader Group-wide circular-economy awareness. A Group-wide rollout pilot with subsidiary Frequentis Comsoft in Karlsruhe begins in 2026, alongside planned EMAS certification in H1 2026 and the SBTi roadmap referenced under E1.

E5-4Resource inflows

Reported

Resource inflows

Reference: page 92.

Frequentis' main purchased materials are named as "electronic components, COTS (commercial off-the-shelf electronic and software products), and IT hardware." The company states that "the purchase and processing of raw materials is not required for Frequentis' business activities; only processed raw materials are used, e.g. solder and lithium-ion batteries." The disclosure is explicit about a data gap: "There are no reliable data on the weight of products, the percentage of biological materials, or the percentage of reused or recycled secondary components." No inflow volumes or circularity rate are therefore quantified for this disclosure requirement, consistent with the narrative-only, no-metrics approach the company takes for E5-4.

E5-5Resource outflows

Reported

Resource outflows

Reference: page 92.

Frequentis reports no reliable data "on the weight of products, their expected durability, repairability, or the recyclable content of products and packaging," but describes qualitative circularity features already embedded in its products and systems: "long system life cycles," being "largely free of toxic substances," being "repairable and upgradeable," "service-based business models," "energy efficiency," and "waste avoidance and reduction." This list is presented as evidence that the company's products, used by customers "generally in sectors with high potential for circularity," already reflect circular-economy principles even without the quantified product-level metrics ESRS E5-5 otherwise calls for. Waste outflow volumes are reported separately (see Waste).

E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Reported

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Reference: page 62.

The ESRS 2 IRO-2 concordance table answers this disclosure requirement directly rather than pointing to a narrative chapter: against the "E5-6" row, the table states "No financial risks and opportunities identified." This is consistent with the E5.SBM-3 materiality table (pages 88-89), which lists only impacts for the circular economy topic — two positive (product durability/maintenance, and Frequentis as a value-chain partner) and two negative (non-recyclable purchased components, and hazardous/electronic waste) — and no separate risk or opportunity items to which anticipated financial effects would attach. The general SBM-3 statement that "no current financial effects have been identified" (page 57) applies across topics, including E5.

E5-5(was E5-5-Waste)Waste

Reported

Waste

Reference: pages 92-93.

Frequentis Group generated 170.0 tonnes of total waste in 2025 across companies with production and integration activities, of which non-hazardous waste was 167.0 tonnes and hazardous waste 3.0 tonnes; at Frequentis AG the totals were 89.8 tonnes (2024: 75.0 tonnes). Recovery covered 74.9 tonnes (44%) of Group waste against disposal of 95.1 tonnes (56%); "the proportion of waste recovered was lower than in 2024," attributed to "the redesign of the headquarters building in Vienna," which increased bulky and commercial waste from disposing of old office equipment. No radioactive waste is generated. Reliable disposal-company data exist for Frequentis AG and Frequentis Comsoft; "in 2025, 33% of the reported waste was determined using this method of estimation" based on employee headcount.

S1 – Own Workforce

S1-1Policies related to own workforce

Reported

Policies related to own workforce

Reference: pages 96-97.

The General Policy on Recruiting, Promotion and Retention covers "employment conditions for the workforce, fair and market-oriented remuneration, work-life balance, diversity and equality of treatment, training and skills development, and the corporate and working culture," and is complemented by the Code of Conduct and Anti-Corruption Policy, aligned with the UN Guiding Principles, ILO declaration and OECD Guidelines. The Occupational Health and Safety Policy is ISO 45001-certified for Frequentis AG and companies within its certification scope. A Policy on Handling Reports of Discrimination or Sexual Harassment sets the process for reported cases. A Data Protection Manual, produced in 2024, centralises data-protection policy across seven named focus areas, including AI and data protection, overseen by a Data Protection Officer appointed in 2018.

S1-2Processes for engaging with own workforce and workers' representatives about impacts

Reported

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

Reference: page 98.

Employees express views through regular employee surveys, HR Business Partners and HR managers, compliance managers, the workers' council where one exists, annual performance and career development reviews, team workshops and directly with line managers. Informal feedback flows through the internal social network Viva Engage, including the "Working Human" community. "Frequentis assesses the effectiveness of engagement with its workers through employee surveys, from which appropriate action is derived" — for example, the June 2025 "workation" benefit was introduced "as a result of the 2024 employee survey," an explicit instance of survey feedback translating into an action.

S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concerns

Reported

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

Reference: page 98.

Employees can raise concerns through the same informal and formal channels used for engagement, following "a precisely defined process" guided by "sensitivity, confidentiality, presumption of innocence, and sustainability," with investigation, evaluation and recommendations undertaken by a core team. A separate whistleblower system enables anonymous reporting of irregularities and risks, "available worldwide to all employees in the Frequentis Group via an intranet link and via the internet," with further detail cross-referenced to the G1 Business conduct chapter. One allegation of discrimination was reported via formal processes in 2025 (see S1-17), indicating the channel was in active use during the year.

S1-3(was S1-4)Taking action on material impacts on own workforce

Reported

Taking action on material impacts on own workforce

Reference: pages 98-101.

Work-life balance actions include flexible working-time models, the "New Way of Working" pilot redesigning Vienna headquarters, and a workation model for cross-border teleworking introduced June 2025. Occupational health and safety is anchored in ISO 45001 certification (recertified June 2025) covering Frequentis AG and five subsidiaries (~60% of Group employees), an occupational health and safety team of a medical officer, two psychologists, two safety specialists and eight safety officers, and a new digital near-miss recording system introduced in 2025. Gender equality actions include an annual salary review against statutory and external benchmarks and job grading rollout from 1 January 2026 implementing the EU Pay Transparency Directive. Diversity actions include the "Women & Careers" initiative and 113 internships in 2025.

S1-4(was S1-5)Targets related to own workforce

Reported

Targets related to own workforce

Reference: page 102.

"Frequentis does not currently have any measurable, outcome-oriented targets that meet the ESRS minimum disclosure requirements as defined in MDR-T." Instead it describes long-term aspirations — safeguarding performance, commitment and innovative capability through the HR strategy, continuous professional and personal development measured by professionalism and results, and best-possible work-family balance. A concrete, dated milestone is given for the latter: the "Beruf & Family" audit, "a certified quality management and development tool that helps companies systematically structure and develop family-friendly working conditions," is planned for Frequentis AG in H1 2026.

S1-5(was S1-6)Characteristics of the undertaking's employees

Reported

Characteristics of the undertaking's employees

Reference: pages 102-104.

Average Group headcount rose from 2,584 in 2024 to 2,809 in 2025, comprising 650 women, 2,158 men and 1 gender-diverse/other employee, drawn from 63 nations across 17 countries; Austria alone accounts for 1,309 employees. 98% of Group employees hold permanent contracts; 36 are temporary and 26 non-guaranteed-hours. 2,397 employees work full-time and 365 part-time. Employee turnover fell to 8.5% in 2025 (2024: 9.4%), with average length of employment of 7.4 years and 536 new entries during the year. "No assumptions were used in the compilation of the data; the data are taken from the HR master data system."

S1-6(was S1-7)Characteristics of non-employee workers

Reported

Characteristics of non-employee workers

Reference: page 104.

"In addition to its own workers, in 2025 the Frequentis Group had 127 non-employee workers, leased workers, and external workers": 13 leased workers (12 in 2024) and 114 external partners (84 in 2024), both figures reported for the Group and, separately, for Frequentis AG (13 leased workers and 16 external partners). The disclosure provides average headcount only, without further breakdown by contract type, gender or location for this non-employee population.

S1-7(was S1-8)Collective bargaining coverage and social dialogue

Reported

Collective bargaining coverage and social dialogue

Reference: pages 104-105.

"57% (2024: 57%) of employees in the Frequentis Group are covered by collective bargaining agreements," rising to 100% in Austria, mostly under the metalworking-sector agreement at Frequentis AG; no collective bargaining agreements apply in Germany, while agreements do apply in Brazil, France, Romania and Italy. 64% of employees are represented by workers' councils (Germany 60%, Austria 95%), with additional councils in France, Romania and Italy. "The workers' council at Frequentis AG is in constant communication with the Executive Board and is involved in key corporate decisions." Coverage tables break this down by EEA/non-EEA country and region bands.

S1-8(was S1-9)Diversity metrics

Reported

Diversity metrics

Reference: pages 105-106.

"In 2025, female employees accounted for 23% of the total workforce (2024: 23%)," stable at the Executive Board level (0% female among 4 members, both years) and among management (Vice Presidents and Managing Directors, 25% female both years); other managers were 16-17% female. New hires were 24% female Group-wide (26% at Frequentis AG), up from 19% in 2024. Age distribution shows 16% of permanent employees under 30, 55% aged 30-50, and 28% over 50 in 2025, a profile the company links to "a considerable rise in the number of employees retiring" expected "in the coming years."

S1-9(was S1-10)Adequate wages

Omitted

S1-10(was S1-11)Social protection

Reported

Social protection

Reference: page 106.

Frequentis reports coverage against five major life events for the Group's own workforce: sickness (100% of employees covered), unemployment from the start of employment (99.7%), employment injury and acquired disability (100%), parental leave (100%), and retirement (99.5%). Coverage is provided either through public programmes or Frequentis-funded benefits depending on the statutory framework of each country. The company discloses a gap explicitly: "social protection is not provided for all the listed life events in Brazil, the United Arab Emirates, and Singapore," due to differences in the local statutory framework.

S1-11(was S1-12)Persons with disabilities

Not Material

S1-12(was S1-13)Training and skills development metrics

Reported

Training and skills development metrics

Reference: pages 106-107.

Group employees logged 34,966 training hours in 2025 (2024: 19,875 hours reported for a smaller connected population), averaging 13 hours per FTE, delivered via the new myLearning@Frequentis platform and the O'Reilly online learning platform (used by "20 companies in the Frequentis Group") with "more than 60,000 modules." "84% of employees in the Frequentis Group had a documented performance and career development review... in 2025 (2024: 83%)," measured across 2,447 permanent employees connected to the Group's IT landscape, with the assumption "that the percentage is similar at other Group companies." Educational sponsorship in 2025 included 113 supervised interns, 40 of them at Frequentis AG.

S1-13(was S1-14)Health and safety metrics

Reported

Health and safety metrics

Reference: page 108.

"In 2025, all work-related accidents were non-serious accidents with minimal consequences." The Group recorded zero fatalities, 1 recordable work-related accident (rate 0.2 per million hours worked; 2024: 2 accidents, rate 0.5), zero cases of recordable work-related ill health, and 4 days lost to work-related injuries and ill health (2024: 8 days). Frequentis AG's figures were identical to the Group's for accidents and fatalities in 2025. "The incidents were investigated and corresponding action taken to prevent a recurrence," consistent with the ISO 45001-based health and safety management approach described under S1-4.

S1-14(was S1-15)Work-life balance metrics

Reported

Work-life balance metrics

Reference: page 108.

"All employees (100%) have a statutory entitlement to leave for family reasons after the birth of a child," with the number of days varying by country's statutory framework and Frequentis offering leave beyond statutory minimums in some countries. "97% of employees can take leave to care for relatives," with this option unavailable, "due to the statutory framework," in the Philippines, Brazil, the United Arab Emirates and Singapore — the same three countries (plus the Philippines) flagged as gaps under Social protection (S1-11).

S1-15(was S1-16)Compensation metrics (pay gap and total compensation)

Reported

Compensation metrics (pay gap and total compensation)

Reference: pages 108-109.

The Group gender pay gap was 16% in 2025 (2024: 17%; Frequentis AG: 15%, both years), calculated from average gross annual income on a full-time-equivalent basis adjusted for purchasing power parity, and "attributable to the low proportion of female employees, especially in management positions." The annual total remuneration ratio — highest-paid individual to median employee — was 15.3 for the Group in 2025 (2024: 13.8) and 15.6 at Frequentis AG (2024: 13.6), with the Group median "estimated using the distribution of remuneration at Frequentis AG" on the assumption that the distribution is similar Group-wide.

S1-16(was S1-17)Incidents, complaints and severe human rights impacts

Reported

Incidents, complaints and severe human rights impacts

Reference: page 109.

"In 2025, one allegation of discrimination was reported via formal processes." The compliance metrics table (page 122) corroborates this at Group and Frequentis AG level: 1 complaint via the whistleblower platform, zero associated fines or damages, and zero severe human rights incidents relating to the own workforce, in both 2025 and 2024. Details of the whistleblower system and compliance management system are cross-referenced to G1 Business conduct rather than repeated here.

S2 – Workers in the Value Chain

S2-1Policies related to value chain workers

Reported

Policies related to value chain workers

Reference: page 111.

Supplier selection criteria include "ethics, compliance with labour standards, and environmental protection," set out in the Procurement Policy (binding for Frequentis AG, with local equivalents required Group-wide under the Global Corporate Policy) and administered centrally via an Admin Service Hub at Frequentis Solutions & Services in Bratislava. The CSR Code for Suppliers commits suppliers to environmental protection, human rights and labour standards, and anti-corruption, explicitly rejecting "forced and compulsory labour, child labour, moonlighting, and discrimination" and requiring "payment of the collectively agreed or statutory minimum wage." "Modern slavery" is addressed in the Code of Conduct, the CSR Code and supplier contracts. "There were no known incidents of failure by suppliers and subcontractors to respect these standards in recent years."

S2-2Processes for engaging with value chain workers about impacts

Reported

Processes for engaging with value chain workers about impacts

Reference: page 112.

Engagement occurs through long-term, continuous business relationships — "77% frame agreements at Frequentis AG" — with regular interaction between procurement and sales personnel, supplier workshops at management level, and formal annual supplier assessments and support. A dedicated procurement team of specialists across hardware, IT and external-resources categories enables professional interaction with suppliers and subcontractors. Compliance with the CSR Code for Suppliers is "strictly monitored" as part of this annual assessment process, with individual, tailored action recommendations sent to each supplier by the responsible Strategic Procurement Manager.

S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reported

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

Reference: page 112.

Value chain workers can formally report concerns — "suspected criminal offences, unfair treatment, discrimination, and non-compliance with Group guidelines or EU law" — via the whistleblower platform described under G1 Business conduct. A second channel operates through the annual supplier assessment process, which can surface possible non-compliance with the CSR Code for Suppliers specifically. No separate, dedicated grievance mechanism outside these two channels is described for value chain workers.

S2-3(was S2-4)Taking action on material impacts on value chain workers

Reported

Taking action on material impacts on value chain workers

Reference: pages 112-114.

Acceptance of the CSR Code for Suppliers is embedded in the General Terms and Conditions of Purchase via supplier self-assessment. The 2024 annual assessment, performed in 2025, "covered 102 suppliers accounting for procurement volume of EUR 78.2 million at Frequentis AG (73% of procurement volume)," scored on quality, price, support, delivery and sustainability criteria via SAP, with sustainability weighting increased under the 2025 HSE and CSR Procurement Guidelines. Frequentis AG performed 5 on-site supplier audits in 2025 (11 Group-wide), targeting new, high-volume or higher-risk suppliers. Supply chain staff receive regular training on avoiding slavery, forced/child labour and discrimination, and the company maintains an annually updated Modern Slavery Statement.

S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reported

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

Reference: page 115.

"Frequentis does not currently have any measurable, outcome-oriented targets that meet the ESRS minimum disclosure requirements as defined in MDR-T," but tracks effectiveness through ongoing activities, chiefly developing a sustainable procurement concept (cross-referenced to E5). Planned steps include further rollout of the Global Procurement Policy, broadening the Global Procurement Team beyond the eight companies covered as of October 2025, stepping up supplier and subcontractor dialogue on sustainability, evaluating scope for improvement, and implementing new supplier-evaluation tools.

S4 – Consumers and End-Users

S4-1Policies related to consumers and end-users

Reported

Policies related to consumers and end-users

Reference: page 117.

Safety Guidelines are "attached to the delivery of every customer project" and must be observed during use; project managers at the highest organisational level are responsible for compiling, distributing and implementing them and organising end-user training, directly addressing the accident-related risk identified in the S4.SBM-3 table. Human rights and whistleblower protections apply from the Code of Conduct (G1), aligned with the UN Guiding Principles, ILO declaration and OECD Guidelines. Data protection policy, including the Data Protection Manual, applies equally to end-users as described under S1 – Own workforce, covering "protecting customer data when implementing projects" and "data protection in products."

S4-2Processes for engaging with consumers and end-users about impacts

Reported

Processes for engaging with consumers and end-users about impacts

Reference: pages 117-118.

Engagement runs through the project lifecycle: workshops in the offer phase to capture requirements, further workshops and training during delivery and acceptance, and Regular User Group Conferences by business area (e.g. the ATM COMM User Group, which drew "more than 20 people from international air traffic navigation organisations" to a Vienna workshop in October 2025). Account managers track customer satisfaction via a standardised questionnaire, with results analysed and improvements derived and documented in a management report. The UX@Frequentis initiative, launched in 2024 and continued in 2025, systematically embeds end-user perspectives in product design and development.

S4-2(was S4-3)Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reported

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

Reference: page 118.

"End-users can also report concerns and requirements via the Frequentis homepage and report irregularities and risks anonymously via the whistleblower website," with further detail cross-referenced to G1 – Business conduct / Whistleblowing. Recorded customer satisfaction feedback, gathered through the S4-2 engagement channels, also serves a remediation function: "negative feedback is forwarded immediately to the relevant department for action," providing a second, less formal route alongside the whistleblower channel.

S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reported

Taking action on material impacts on consumers and end-users

Reference: pages 117-118.

The Control Room Consulting Team offers end-to-end analyses to optimise end-users' operating processes, decision-making and strategic planning. The Group-wide UX@Frequentis initiative rolled out uniform UX tools, processes and training in 2025, supporting two pilot projects that "yielded the first positive results," with uniform UX Design Guidelines developed for Group-wide application from 2026. On effectiveness: "Frequentis is not aware of any violations of human rights in connection with end-users in 2025. There were no reports of failure to observe" the UN Guiding Principles, ILO declaration or OECD Guidelines involving end-users in the downstream value chain.

S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reported

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

Reference: page 118.

"Frequentis does not currently have any measurable, outcome-oriented targets in the area of S4 – End-users that meet the ESRS minimum disclosure requirements as set out in MDR-T." Instead, "the effectiveness of the policies and actions relating to material impacts, risks, and opportunities is measured using the feedback channels outlined above" — the customer satisfaction questionnaire, User Group Conferences and whistleblower channel described under S4-2 and S4-3.

G1 – Business Conduct

G1-1Business conduct policies and corporate culture

Reported

Business conduct policies and corporate culture

Reference: page 121.

Integrity and business ethics are set out across the Code of Conduct, the Whistleblowing Policy (implementing EU Directive 2019/1937), the Global Corporate Policy, the internal Anti-Corruption Policy, and the CSR Code for Suppliers. A separate Capital Market Compliance Policy governs handling and publication of capital-market-relevant information, share-trading restrictions and "Directors' Dealings" reporting. All policies are "approved by the Executive Board" and apply Group-wide, backed by mandatory training modules, and are made available via the intranet, with the Code of Conduct also published on Frequentis' public website.

G1-2Management of relationships with suppliers

Reported

Management of relationships with suppliers

Reference: page 121.

The G1 chapter handles this disclosure requirement by cross-reference rather than repetition: "the procurement process, selection of suppliers, and relationship with suppliers are described in detail in ↗ S2 – Workers in the value chain." The substantive content — supplier screening and selection criteria, the annual supplier assessment covering 102 suppliers and EUR 78.2 million of procurement volume at Frequentis AG, on-site audits, and the CSR Code for Suppliers — therefore sits under S2-1 through S2-4 rather than under a standalone G1-2 narrative.

G1-2(was G1-3)Prevention and detection of corruption and bribery

Reported

Prevention and detection of corruption and bribery

Reference: pages 121-123.

The compliance management system rests on three principles: "prevention" (policies, training, advice on complex issues), "early detection" (reporting channels, compliance and special audits) and "response" (measures and sanctions), overseen by a Compliance Officer appointed by the Executive Board. A Group-wide whistleblower system, hosted by an external third party, has operated since December 2021, available to employees and external stakeholders via intranet and web links and directly at frequentis.integrityline.com. Anti-bribery measures include mandatory training for all permanent employees plus deeper follow-on training for customer-facing and procurement staff, and routine checks of invoices and expense claims for gifts, invitations and hospitality against defined thresholds. A trade-compliance guideline for automated sanction screening was drawn up in 2025.

G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conduct

Reported

Targets related to business conduct

Back-filled from the business conduct chapter (G1-3, pages 121-124), where effectiveness tracking substitutes for a numbered targets disclosure. G1-3-Targets became a standalone DR only in the 2025/2026 ESRS.

No dedicated MDR-T disclaimer or measurable business-conduct target is stated for G1, unlike the E1/E5/S1/S2/S4 chapters. Effectiveness is instead tracked through concrete monitoring mechanisms: a compliance metrics table records whistleblower complaints (1 in 2025, 1 in 2024), associated fines (zero both years) and severe human rights incidents (zero both years); G1-4 tracks confirmed bribery or corruption incidents (zero in 2025 and 2024, with zero convictions and fines); and mandatory anti-corruption, Code of Conduct and capital-market-compliance training completion is tracked at 96% Group-wide in 2025 (up from 90-94% in 2024). These periodic monitoring activities constitute the effectiveness-tracking limb of MDR-T in the absence of a stated target.

G1-4Incidents of corruption or bribery

Reported

Incidents of corruption or bribery

Reference: page 124.

"Total confirmed incidents of bribery or corruption": zero for both the Frequentis Group and Frequentis AG in 2025 and 2024. Number of convictions for breaches of anti-corruption and anti-bribery regulations: zero in all four Group/AG-year combinations. Fines for such breaches: EUR 0 throughout. The table format mirrors the compliance metrics disclosed under G1-3, giving a consistent zero-incident record across both years covered.

G1-5Political influence and lobbying activities

Reported

Political influence and lobbying activities

Reference: page 124.

"As a company whose business activities primarily include public sector contracts, support for political parties, including donations to such parties, is strictly prohibited. Therefore, Frequentis did not make any donations to political parties in either 2025 or 2024." No member appointed to Frequentis' administrative, management or supervisory bodies during the reporting period held a comparable public-administration position in the two years before appointment. Frequentis AG has been registered with the European Transparency Register since 2014 (registration number 878884412932-63) to disclose its European research-funding activities.

G1-6Payment practices

Reported

Payment practices

Reference: page 125.

Group average time to pay an invoice was 20 days in 2025 (2024: 18 days); 64% of invoices were paid within 21 days and 94% within the standard 45-day term. At Frequentis AG, average payment time was 22 days (2024: 21 days), with 58% paid within 21 days (a 3% discount window) and 93% within 45 days. Payment-term data are drawn from sixteen named Group companies. "There were no court cases as a result of overdue payments in 2025." Supplier relationship context is cross-referenced to S2 – Workers in the value chain.