Frequentis

The role of the administrative, management and supervisory bodies

In 2024, the Executive Board of Frequentis AG comprised the following members:

Norbert Haslacher has been a member of the Executive Board of Frequentis AG since April 2015, originally with responsibility for Sales & Marketing. He was appointed CEO in April 2018.

Responsibilities: Strategy, Global Sales, Strategic Business Units, Corporate Communications & Marketing, Investor Relations, New Business Development & Invest4Tech, New Market Solutions, Partnerships and M&A.

Monika Haselbacher has been a member of the Executive Board of Frequentis AG and Chief Operating Officer (COO) since 1 January 2023.

Responsibilities: Project Management & PMO, Customer Services, Health Safety Environment (HSE) Management, Group Governance, Processes & Efficiency, Quality Management, Safety Management, Group Management.

Peter Skerlan has been Chief Financial Officer (CFO) of Frequentis AG since 16 April 2021.

Responsibilities: Finance, Human Resources, IT, Legal, Facility Management, Environment, Social & Governance (ESG), Internal Audit & Compliance.

Hermann Mattanovich was a member of the Executive Board of Frequentis AG from January 2009 and stepped down from the Executive Board on 30 June 2024 as part of the long-term succession plan.

Karl Wannenmacher was appointed by the Supervisory Board as a member of the Executive Board and successor to Mr. Hermann Mattanovich in his function as Chief Technology (CTO) from 1 July 2024.

Responsibilities: Technology Management, Production & Logistics, Procurement, Product Management, Security.

In 2024, the Supervisory Board of Frequentis AG comprised the following members:

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

ESG organisation

In response to the broadly based environmental, social, and governance aspects and to improve their presentation to stakeholders, at the start of 2022 Frequentis pooled its expertise in these three areas in a Group-wide ESG organisation. As a representative of the Executive Board, CFO Peter Skerlan bears executive-level responsibility for ESG topics. This was defined by the Supervisory Board at its meeting on 30 March 2022 in the rules of procedure for the Executive Board of Frequentis AG.

The interdisciplinary ESG team is coordinated by an ESG Steering Group, which involves and works closely with the Executive Board. Alongside the CFO, the members of the ESG Steering Group are the staff responsible for environmental, social, governance, and compliance aspects and the ESG Group Coordinator. The ESG team maintains regular contact with Frequentis' stakeholders.

Specific projects are analysed, prioritised, and driven forward at a monthly jour fixe. Current sustainability measures are continuously examined and modified, and new sustainability projects are initiated as necessary. At the annual ESG management review led by the CFO, the past year's ESG activities and ESG indicators are discussed and actions to achieve targets and further improvements are defined.

The CFO and the members of the ESG Steering Group regularly attend specialist congresses and events to network with experts and enhance their knowledge. Reading relevant literature is also very important. The knowledge gained in this way is shared widely within Frequentis. This ensures that the company always has up-to-date knowledge of the fast-changing fields of sustainability and transparent ESG reporting.

The Executive Board and Supervisory Board, as the highest governance bodies, support all measures. The Supervisory Board regularly considers ESG topics and ESG is a recurrent item on the agenda for Supervisory Board meetings.

Integration of sustainability-related performance in incentive schemes

To strengthen the sustainable development of the company, in addition to financial targets, the variable remuneration of every Executive Board member includes ESG targets for 2024 and 2025. The ESG targets cover energy, the circular economy, compliance, and cybersecurity.

The ESG targets are used as a calculation factor for the variable remuneration of every Executive Board member. At the end of the agreed performance period, the variable remuneration resulting from the financial targets may be increased or decreased depending on the degree of achievement of the ESG targets. The targets are set by the remuneration committee on the basis of the remuneration principles for the members of the Executive Board.

Statement on due diligence

The next table shows where key aspects and steps in the due diligence compliance procedure can be found in this consolidated non-financial statement.

Risk management and internal controls over sustainability reporting

For information on risk management and internal controls over sustainability reporting, see ↗ Opportunity and risk management and ↗ Internal control system (ICS) for the accounting process.

Strategy, business model and value chain

Business model

Wherever Frequentis' solutions are used, people bear responsibility for the safety of other people and property. Its mission is "For a safer world". The Frequentis Group is an international provider of communication and information systems for safety-critical control centres. Custom-tailored control centre solutions are developed and marketed by the Air Traffic Management segment (for civil and military air traffic control, AIM [aeronautical information management], and air defence) and the Public Safety & Transport segment (police, fire service, emergency rescue services, railways, coastguards, and port authorities).

The primary objective of a control centre is to protect people and property from danger. Optimised solutions for this are especially important to customers operating in safety-critical sectors. More than 90% of the customers are state-run authorities / individual governments or the administrative arms of other public authorities. The products supplied by the Frequentis Group are part of the safety-critical infrastructure of the respective country. This underscores the robustness and long-term nature of Frequentis' business model. It is difficult to reduce or halt investment in safety-critical infrastructure. It has to be available and ready for operation at all times – irrespective of the number of flights / flight movements or how often the police, fire service, and emergency rescue services are deployed.

Customer requirements often include requests for even more efficient and sustainable solutions and the need to adapt quickly to constantly changing conditions. That increases the demand for integrated solutions. A human-centric design process enables the provision of a secure, efficient, and stable working environment for operators, air traffic controllers, and dispatchers. As a recognised specialist for the supply of safety-critical infrastructure, Frequentis develops future-oriented solutions for control centres in collaboration with key account customers and makes new technologies usable for safety-critical applications. Frequentis has an international network of companies and local representatives in more than 50 countries. In addition to its headquarters in Vienna, Austria, Frequentis' locations include Australia, Brazil, Canada, the Czech Republic, France, Germany, Italy, Norway, Romania, Singapore, Slovakia, Switzerland, the UK, and the USA.

The central focus is on long-term customer relationships. Customers – public authorities, organisations, and companies with safety-critical tasks – often use the solutions provided for several decades. That requires a deep understanding of the customer's requirements, maximum reliability, and long-term trust. The extensive installed base also drives the sustained growth of the Frequentis Group.

Governance organisation

Frequentis' business model is based on a strong governance organisation, which is reflected in a three-dimensional matrix and ensures optimised interaction between the central units, the business domains, and the international subsidiaries.

Frequentis' two segments and the business domains grouped in these segments focus on successful business operations as their contribution to the Group's overall performance. The main responsibility is allocated to local value-generating functions such as Domain Sales, Key Accounts, Product Management, and Project Management. Innovation is very important to Frequentis. At all stages in the Frequentis innovation process, close and interdisciplinary collaboration with the business domains is ensured on topics with high relevance for the business.

As an integral part of the value chain, the subsidiaries and equity investments make a significant contribution to the overall success of the Frequentis Group. They have different areas of responsibility and competencies within the value chain. Governance and process orchestration take place within the framework of the management of the Frequentis Group to ensure harmonised rollout of governance requirements based on accountability.

The Central Group Functions, most of which have governance responsibility, are divided into value-generating functions such as Sales, Production, and the provision of services, and central functions with a statutory governance remit, such as Human Resources, IT, Finance & Controlling, and Compliance.

Strategy

The Frequentis Group's objective, as set out in its vision, is to be the global number one on the market for safety-critical control centres. Its strategy defines the direction to be pursued. It is influenced by the wide range of industries and solutions covered. Internally, the strategy is divided into a corporate strategy and the strategies of the segments, business domains, and all other areas.

The segment and business domain strategies form the heart of the Group's strategy. They comprise specific strategies for the industries they serve or the products and solutions within these industries. Other areas such as the regions and central functions develop their strategies in conformance with the corporate strategy and the business domain strategies in order to provide the best possible support.

Frequentis' aspiration includes a sustained growth strategy which aims to raise profitability while keeping risk exposure reasonable. To this end, the first step is to fully utilise the potential of existing products and solutions before investing in significant new solutions. The strategy defines guidelines for sustained growth, for example focused growth in the regions, driven by the Regional Sales Units, and scope for interesting equity investments to extend the product portfolio.

Further, the strategy is aligned with the three relevant megatrends, i.e. mobility, safety & security, and technological change, which have a major influence on the future development of the industries served. These megatrends are still responsible for the steadily rising demand for additional safety-critical infrastructure.

Value chain

The value chain is defined as the entire spectrum of activities, resources, and relationships associated with the company's business model and the external environment in which it operates. In this context, Frequentis concentrates on monitoring its direct upstream and downstream relationships.

In the upstream value chain, these are mainly relationships with suppliers and subcontractors and various service partners up to and including company catering. The focus of Frequentis' own value chain is on product development and production, domain sales, key accounts, and product and project management.

Downstream activities comprise implementation partners and service providers who support delivery and the wide range of customers. Customers are organisations and authorities to which the Frequentis Group supplies its solutions (air traffic management, emergency services, railways, and the air traffic controllers, operators, and dispatchers they employ); these are the end-users of Frequentis systems.

Further, domain partners, affiliated companies, and financial partners make a contribution to both the upstream and the downstream value chain.

Interests and views of stakeholders

In the materiality assessment conducted in late 2023 / early 2024, the following stakeholder groups of key significance for Frequentis were asked to assess the relevance of the ESRS topic list (37 ESRS sub-topics) plus four sub-topics relating to the entity-specific issue of safety & security:

• Employees • Supervisory Board • Managers • Executive Board members and Managing Directors of Frequentis companies • Shareholders / capital market representatives • Banks • Suppliers and subcontractors • Customers • NGOs and advocacy groups • Project partners (sales, execution)

Active engagement with these stakeholders and target-group specific reporting remain important to Frequentis. Regular dialogue with stakeholders plays a key role in this. Here is an overview of current communication measures:

For communication with stakeholders, extensive use is made of digital platforms – videoconferencing, virtual training sessions, social media. In addition to this, personal contact is very important, for example, through local meetings and at a wide range of international trade shows.

Furthermore, Frequentis offers all internal and external stakeholders a whistleblower service, which is available via the Frequentis website www.frequentis.com/whistleblowing. This service allows simple and anonymous reporting of concerns about possible non-compliant behaviour.

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

The double materiality assessment identified the six material ESRS sustainability topics E1, E5, S1, S2, S4, and G1 and one entity-specific sustainability topic: safety & security. The outcome is presented in a materiality matrix encompassing three dimensions:

• Impact materiality on the x axis shows the outcome of the expert workshop. This identifies sustainability aspects that are connected with the company's impact on people and the environment. • The y axis shows financial materiality. This assesses the impact of sustainability aspects on the company's financial and business performance. • The size of the dots indicates the significance of the topics identified in the stakeholder survey. The larger the dot, the more significant the topic is for the stakeholders.

The following tables list the material impacts, risks, and opportunities identified:

E1 – Climate change

E5 – Circular economy

S1 – Own workforce

S2 – Workers in the value chain

S4 – End-users

G1 – Business conduct

Safety & security

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

The ESG Steering Group started to examine the extended requirements of CSRD reporting at the beginning of 2023. Based on the previous materiality assessments, the standardised ESRS list of environmental, social, and governance topics was supplemented by an entity-specific "Safety & Security" section. A corresponding concept was presented to the Executive Board and Supervisory Board. The Executive Board approved its implementation in summer 2023.

For the inside-out perspective (impact materiality), the relevant stakeholders were included through an anonymous online questionnaire. The stakeholder groups were modified and greatly extended compared with the previous materiality assessments. In all, about 3,250 people were addressed. The questionnaires were distributed by the parent company, Frequentis AG, to the entire Frequentis Group. To obtain a geographical perspective, the regions were included.

This process was accompanied by two workshops that brought together internal experts at Frequentis' headquarters, firstly for a more detailed discussion of impact materiality, and secondly to assess the financial materiality (outside-in perspective).

Phases 1 to 3 were performed in 2023. Phases 4 and 5 were completed in 2024. Based on the evaluations by Frequentis experts and the risk management team, the sustainability topics were compared and all relevant topics were presented in a materiality matrix. The outcome was presented to the Executive Board and the Supervisory Board. Together, they discussed the material topics and defined the principal areas of action. The outcome of the materiality assessment was subsequently used in planning and actions.

The following methods were used to assess the impacts, risks, and opportunities:

Impacts: The first step was determining whether Frequentis' business activities or its value chain had a positive and/or negative impact on people or the environment in connection with the specific sustainability aspect. In addition, the type of impact, time horizon, and location of the impact were established. The second step was assessing whether the impact is material. The assessment was based on a score (1-4) calculated from the average of scale, scope, irremediable character, and likelihood, depending on the type of impact. The results were compared with the stakeholder survey.

Risks and opportunities: In addition to the material impacts already identified, the risk assessment examined the dependence on resources, physical risks, and transition risks. Five risk categories were used. For each risk category, thresholds were defined for the EBIT impact in the event of the risk or opportunity materialising and assigned a score (1-4). Moreover, time horizons and probabilities were defined for the assessment.

Climate-related impacts, risks, and opportunities

The process of identifying and evaluating climate-related impacts, risks, and opportunities used the materiality assessment steps described in ESRS 2 IRO-1.

Impacts: The climate-related impacts were analysed as part of the expert workshop. This included Frequentis' own business activities and the upstream and downstream value chain. In addition, an analysis of the Scope 3 categories was performed. The business activities and value chain were analysed in particular with a view to greenhouse gas emissions.

Climate-related physical risks: A climate risk and vulnerability analysis of Frequentis' own business activities and assets was performed for the Frequentis Group's locations in 2023. As part of the materiality assessment, this was extended to the upstream and downstream value chain. The evaluation was based on three climate scenarios (SSP1-2.6, SSP2-4.5, and SSP5-8.5), reflecting different temperature developments and the related risks. Short, medium, and long-term climate risks were taken into account. Identified vulnerabilities in connection with climate-related physical risks and transition risks to assets were adapted as necessary.

Climate-related transition risks to Frequentis' own business activities, assets, and the value chain were evaluated on the basis of five risk categories. These are based on the TCFD (Task Force on Climate-related Financial Disclosures) classification of climate-related transition events. Short, medium, and long-term time horizons and one climate scenario were used in the assessment. No assets or business activities were identified that are incompatible with the transition to a climate-neutral economy or where considerable efforts would be required to make them compatible.

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

The material information relating to the impacts, risks, and opportunities to be disclosed as material were determined on the basis of the list of ESRS datapoints (EFRAG implementation guide 3 "List of ESRS Datapoints"). The ESRS metrics were evaluated for their relevance and their ability to support users of the consolidated non-financial statement in their decisions. Following a thorough analysis, some metrics were classified as not relevant and are therefore not reported. Supplementary entity-specific metrics are included. Policies, actions, and targets – where available – are reported for material sustainability aspects in accordance with the ESRS minimum disclosure requirements.

The following table lists the ESRS disclosure requirements covered in the consolidated non-financial statement, together with information on where they can be found:

| ESRS E1 | Climate change | | | E1-1 | Transition plan for climate change mitigation | ↗ E1 – Climate change / Actions | | E1-2 | Policies related to climate change mitigation and adaptation | ↗ E1 – Climate change / Policies | | E1-3 | Actions and resources in relation to climate change policies | ↗ E1 – Climate change / Actions | | E1-4 | Targets related to climate change mitigation and adaptation | ↗ E1 – Climate change / Targets | | E1-5 | Energy consumption and mix | ↗ E1 – Climate change / Energy consumption and mix | | E1-6 | Gross Scopes 1, 2, 3 and Total GHG emissions | ↗ E1 – Climate change / Greenhouse gas emissions | | E1-9 | Anticipated financial effects from material physical and transition risks and potential climate-related opportunities | Disclosure omitted in the first year of preparation as permitted by ESRS 1 Appendix C. |

| ESRS E5 | Resource use and circular economy | | | E5-1 | Policies related to resource use and circular economy | ↗ E5 – Circular economy / Policies | | E5-2 | Actions and resources related to resource use and circular economy | ↗ E5 – Circular economy / Actions | | E5-3 | Targets related to resource use and circular economy | ↗ E5 – Circular economy / Targets | | E5-4 | Resource inflows | ↗ E5 – Circular economy / Resource inflows | | E5-5 | Resource outflows | ↗ E5 – Circular economy / Resource outflows | | E5-6 | Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities | No financial risks and opportunities identified. |

| ESRS S1 | Own workforce | | | S1-1 | Policies related to own workforce | ↗ S1 – Own workforce / Policies | | S1-2 | Processes for engaging with own workers and workers' representatives about impacts | ↗ S1 – Own workforce / Engaging with own workers | | S1-3 | Processes to remediate negative impacts and channels for own workforce to raise concerns | ↗ S1 - Own workforce / Processes to remediate negative impacts and channels to raise concerns | | S1-4 | Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions | ↗ S1 – Own workforce / Actions | | S1-5 | Targets related to managing material impacts, advancing positive impacts, and managing material risks and opportunities | ↗ S1 – Own workforce / Targets | | S1-6 | Characteristics of the undertaking's employees | ↗ S1 – Own workforce / Metrics | | S1-7 | Characteristics of non-employee workers in the undertaking's own workforce | ↗ S1 – Own workforce / Metrics | | S1-8 | Collective bargaining coverage and social dialogue | ↗ S1 – Own workforce / Metrics | | S1-9 | Diversity metrics | ↗ S1 – Own workforce / Metrics | | S1-10 | Adequate wages | ↗ S1 – Own workforce / Metrics | | S1-11 | Social protection | ↗ S1 – Own workforce / Metrics | | S1-13 | Training and skills development metrics | ↗ S1 – Own workforce / Metrics | | S1-14 | Health and safety metrics | ↗ S1 – Own workforce / Metrics | | S1-15 | Work-life balance metrics | ↗ S1 – Own workforce / Metrics | | S1-16 | Compensation metrics (pay gap and total remuneration) | ↗ S1 – Own workforce / Metrics | | S1-17 | Incidents, complaints and severe human rights impacts | ↗ S1 – Own workforce / Metrics ↗ G1 – Business conduct / Compliance |

| ESRS S2 | Workers in the value chain | | | S2-1 | Policies related to value chain workers | ↗ S2 – Workers in the value chain / Policies | | S2-2 | Processes for engaging with value chain workers about impacts | ↗ S2 – Workers in the value chain / Engaging with value chain workers | | S2-3 | Processes to remediate negative impacts and channels for value chain workers to raise concerns | ↗ S2 – Workers in the value chain / Processes to remediate negative impacts and channels to raise concerns | | S2-4 | Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions | ↗ S2 – Workers in the value chain / Actions | | S2-5 | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | ↗ S2 – Workers in the value chain / Targets |

| ESRS S4 | Consumers and end-users | | | S4-1 | Policies related to consumers and end-users | ↗ S4 – End-users / Policies | | S4-2 | Processes for engaging with consumers and end-users about impacts | ↗ S4 – End-users / Actions | | S4-3 | Processes to remediate negative impacts and channels for consumers and end-users to raise concerns | ↗ S4 – End-users / Actions | | 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 | ↗ S4 – End-users / Actions | | S4-5 | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | ↗ S4 – End-users / Targets |

| ESRS G1 | Business conduct | | | G1-1 | Corporate culture and business conduct policies | ↗ G1 – Business conduct / Policies | | G1-2 | Management of relationships with suppliers | ↗ S2 – Workers in the value chain / Actions | | G1-3 | Prevention and detection of corruption and bribery | ↗ G1 – Business conduct / Anti-corruption and anti-bribery | | G1-4 | Confirmed incidents of corruption or bribery | ↗ G1 – Business conduct / Anti-corruption and anti-bribery | | G1-5 | Political influence and lobbying activities | ↗ G1 – Business conduct / Political influence | | G1-6 | Payment practices | ↗ G1 – Business conduct / Payment practices |

Transition plan for climate change mitigation

Overview

Frequentis will define science-based targets and a transition plan for climate change mitigation by the end of 2026.

SBTi Commitment

Within the context of its sustainability strategy, Frequentis has decided to sign the SBTi (Science-Based Targets initiative) Commitment Letter in 2025. The SBTi offers companies a science-based method of setting CO2 targets. Emission reduction pathways are calculated on the basis of the company's total CO2 emissions (corporate carbon footprint). Frequentis will define science-based targets and a transition plan for climate change mitigation by the end of 2026. This will take into account achieving climate neutrality by 2040 and the new targets defined in this process.

Current Actions

GHG Inventory and Data Collection

In 2024, energy data were compiled for all Group companies for the first time for 2023 and 2024. Until then, the focus had been on Frequentis AG. Moreover, for the first time, a Group-wide GHG inventory was compiled on the basis of standardised emission factors from international sources. Significant Scope 3 GHG emissions were identified and included in the GHG inventory. This created the basis for measuring decarbonisation Group-wide in the future and for establishing reduction targets.

Electric Vehicle Fleet

To reduce greenhouse gas emissions, when procuring new company cars, priority is given to electric vehicles. This is supported by charging stations at the company car park at Frequentis AG, Frequentis Comsoft and Frequentis Orthogon. In 2024, the proportion of electric and hybrid company cars in the Frequentis Group's fleet increased to 54% (2023: 42%). 34% (2023: 23%) of these vehicles were entirely electric.

Energy Efficiency Measures at Frequentis AG

Frequentis is concerned about the efficient use of energy. The focus is on Frequentis AG, which employs about 40% of the workforce and where actions have the greatest leverage. Thanks to a range of measures, Frequentis AG has successfully managed energy consumption despite rising sales:

• Following modernisation of measuring and control technology at Frequentis AG in 2022, heating, cooling, and ventilation systems have been optimised. This includes prioritising the use of heat pumps and making optimum use of exhaust heat. Since 2024, a more detailed breakdown of individual electricity consumers (e.g. electric charging stations) has been possible, allowing more accurate planning of effective measures to reduce consumption.
• Lighting in buildings is currently being converted to LED. When completed, this will reduce the energy required for lighting by about 65%.
• There has been a further significant reduction in the use of gas for heating to 28 MWh in 2024 (2023: 187 MWh). This is mainly attributable to optimisation of the measuring and control system and the resulting improvement in the use of exhaust heat, as well as higher ambient temperatures.

Product Impact

In addition to other products, Frequentis develops and delivers solutions for the safe management of traffic: railways, air traffic, and shipping. The company aims to structure its solutions to ensure that traffic can be managed both safely and efficiently. These solutions also bring a lasting reduction in the CO2 emissions of the traffic managed.

ISO 50001 Certification

Initial certification under ISO 50001 is planned for Q1 2025. ISO 50001 aims to reduce energy consumption, increase energy efficiency and reduce greenhouse gas emissions, as set out in the Environmental & Energy Policy. The certification covers Frequentis AG in Vienna, which employs about 40% of Frequentis' workforce, giving the greatest leverage for energy management. Examples are the operation and optimisation of an energy-monitoring system and switching the fleet of company cars to electric vehicles.

Renewable Energy

An important element on the path to climate neutrality is the use of renewable energy at business locations. In 2024, renewable energy accounted for 58% of the Frequentis Group's total energy consumption.

This was mainly because the entire energy supply at Frequentis AG, which employs around 40% of the workforce and includes one production facility, comes from renewable sources such as hydroelectric power, wind power, and other ecological energy sources. According to the energy supplier, no CO2 emissions occur in the generation of electricity from renewable resources. Overall, renewable energy accounted for 94% of total energy consumption at Frequentis AG in 2024.

In addition, at two sites, Frequentis AG in Vienna and Frequentis Australasia in Brisbane, energy is generated by in-house photovoltaic installations on the roofs of company buildings. Approximately 1% of energy used by the Frequentis Group comes from its own photovoltaic installations.

Value Chain (Scope 3)

In the value chain (Scope 3), the biggest emission drivers are purchased goods and services and business travel. Business trips are very important at Frequentis because of the international nature of its business activities. For Frequentis AG and selected subsidiaries, business travel is organised centrally by Frequentis Travel Management. Group-wide, all business trips are organised in compliance with a defined travel policy, which specifies that business trips may only be undertaken for business reasons and if the tasks cannot be done in another form (email, phone, online meetings, or video conferencing). Decisions on business travel are taken on the basis of cost-efficiency and sustainability.

Policies related to climate change mitigation and adaptation

Frequentis has set out its strategic focus on the environment and energy in its Environmental & Energy Policy. This policy covers both climate change mitigation and energy.

Environmental & Energy Policy

Key content and principles:

• Reducing greenhouse gas emissions
• Efficient use of energy
• Improving energy performance in design activities
• Including energy-efficient products and services in the procurement process

Scope:

• Binding for all companies included in the management system certified in accordance with ISO 14000
• The Global Corporate Policy (GCP) requires all other companies to define their own local policy on the basis of the Environmental & Energy Policy

Governance:

• The Executive Board of Frequentis AG and the Managing Directors of each company are responsible for applying the policy

Availability:

• Made available to relevant stakeholders either via the intranet or directly, if stakeholders do not have access to the intranet

Limitations: The company notes that although the policy does not directly address the identified material impacts, risks, and opportunities, it sets the direction in the environmental and energy areas.

Travel Policy

For Scope 3 emissions management, particularly business travel (identified as one of the biggest emission drivers), the company applies a travel policy which specifies:

• Business trips may only be undertaken for business reasons and if the tasks cannot be done in another form (email, phone, online meetings, or video conferencing)
• Decisions on business travel are taken on the basis of cost-efficiency and sustainability

Scope:

• Group-wide application
• For Frequentis AG and selected subsidiaries, business travel is organized centrally by Frequentis Travel Management

Actions and resources in relation to climate change policies

Energy data compilation and GHG inventory (2024)

Action description:
In 2024, energy data were compiled for all Group companies for the first time for 2023 and 2024. Until then, the focus had been on Frequentis AG. For the first time, a Group-wide GHG inventory was compiled on the basis of standardised emission factors from international sources. Significant Scope 3 GHG emissions were identified and included in the GHG inventory.

Scope: Own operations (Group-wide)

Expected outcomes:
This created the basis for measuring decarbonisation Group-wide in the future and for establishing reduction targets.

Resources: Not quantified. Statement notes: "The personnel and monetary resources required to perform these actions are included in the overall budget for the department responsible for implementing them."

---

Company car fleet electrification (ongoing)

Action description:
To reduce greenhouse gas emissions, when procuring new company cars, priority is given to electric vehicles. This is supported by charging stations at the company car park at Frequentis AG, Frequentis Comsoft and Frequentis Orthogon.

Scope: Own operations

Expected outcomes / KPIs:

• In 2024, the proportion of electric and hybrid company cars in the Frequentis Group's fleet increased to 54% (2023: 42%)
• 34% (2023: 23%) of these vehicles were entirely electric

Resources: Not quantified.

---

Energy efficiency measures at Frequentis AG

Focus: Frequentis AG, which employs about 40% of the workforce and where actions have the greatest leverage.

Actions implemented:

1. Modernisation of measuring and control technology (2022)

   • Heating, cooling, and ventilation systems have been optimised
   • Prioritising the use of heat pumps and making optimum use of exhaust heat
   • Since 2024, a more detailed breakdown of individual electricity consumers (e.g. electric charging stations) has been possible, allowing more accurate planning of effective measures to reduce consumption

2. LED lighting conversion (ongoing)

   • Lighting in buildings is currently being converted to LED
   • When completed, this will reduce the energy required for lighting by about 65%

3. Gas heating reduction

   • Significant reduction in the use of gas for heating to 28 MWh in 2024 (2023: 187 MWh)
   • This is mainly attributable to optimisation of the measuring and control system and the resulting improvement in the use of exhaust heat, as well as higher ambient temperatures

Resources: Not quantified.

---

Frequentis systems for optimal traffic management

Action description:
Frequentis develops and delivers solutions for the safe management of traffic: railways, air traffic, and shipping. The company aims to structure its solutions to ensure that traffic can be managed both safely and efficiently. These solutions also bring a lasting reduction in the CO2 emissions of the traffic managed.

Scope: Downstream value chain (customers' operations)

Examples:

• Air traffic management products for safe and efficient traffic management in all flight phases, enabling airlines to save kerosene on the ground, during take-off and landing, and in flight, thus reducing their total carbon emissions
• Involvement in SESAR research programme (for around 20 years) - a research programme set up by the European Commission and EUROCONTROL to realise a digital European airspace in order to make European airspace the most efficient and environment-friendly in the world

Resources: Not quantified.

---

General note on resources:
"If not explicitly explained, the actions outlined are continuously applied as part of the Frequentis Group's ordinary business activities. The personnel and monetary resources required to perform these actions are included in the overall budget for the department responsible for implementing them."

Targets related to climate change mitigation and adaptation

Climate Neutrality Target

Target: Climate neutrality by 2040

Status: Frequentis has decided to sign the SBTi (Science-Based Targets initiative) Commitment Letter in 2025. Frequentis will define science-based targets and a transition plan for climate change mitigation by the end of 2026. This will take into account achieving climate neutrality by 2040 and the new targets defined in this process.

Baseline: Not yet disclosed

Scope: To be defined as part of science-based targets by end of 2026

Science-based validation: SBTi commitment planned for 2025; targets to be formally defined by end of 2026

Current Status

Frequentis does not currently have any measurable outcome-oriented targets that meet the ESRS minimum disclosure requirements as set out in MDR-T, but tracks the effectiveness of policies and actions relating to the material impacts, risks, and opportunities through the following activities:

• Initial certification under ISO 50001 planned for Q1 2025, covering Frequentis AG in Vienna (approximately 40% of workforce)
• ISO 50001 aims to reduce energy consumption, increase energy efficiency and reduce greenhouse gas emissions
• Examples of actions include operation and optimization of energy-monitoring system and switching fleet of company cars to electric vehicles

Progress Indicators (2024)

• Renewable energy: 58% of Frequentis Group's total energy consumption
• At Frequentis AG: 94% renewable energy of total energy consumption
• Electric and hybrid company cars: 54% of fleet (2023: 42%)
• Fully electric vehicles: 34% of fleet (2023: 23%)

Energy consumption and mix

Disaggregated energy consumption

Energy consumption by type and country (2024)

Scope and methodology

Data from all Group companies were used to calculate energy consumption. Energy consumption from fossil sources comprises purchased electricity, natural gas, district heating, and fuel consumption by company cars. Nuclear energy consumption comprises purchased electricity. Energy consumption from renewable sources comprises purchased electricity, electricity from in-house photovoltaic installations, and district heating.

Non-assignable energy consumption relates to companies for which no energy consumption data are available as a result of contractual agreements (rented office premises). For these companies, energy consumption is estimated on the basis of the size of the building. In 2024, 5% of energy consumption was calculated on the basis of estimates using this method.

Energy intensity

As a consequence of its production and systems integration operations, Frequentis falls within the scope of the NACE Code C (as defined in Regulation (EU) 2022/1288). The company notes that it is not possible to allocate revenues among high climate impact sectors in order to calculate energy intensity in connection with activities in high climate impact sectors. No energy intensity figure is disclosed.

Gross Scopes 1, 2, 3 and Total GHG emissions

Greenhouse gas (GHG) emissions (E1-6)

Notes:

¹ Including indirect GHG emissions for upstream leased assets (Scope 3 Category 8)

² Market-based GHG data are only available for Frequentis AG; for the other Group companies, gross location-based Scope 2 GHG emissions were used. Biogenic CO2 emissions from the market-based approach at Frequentis AG amounted to 834 t CO2e in 2024 (2023: 783 t CO2e).

³ Product and project-based procurement and services

⁴ Travel by air, rental car, and rail

GHG intensity based on net revenue

Calculation methods:

Scope 1: Fuel consumption by the heating system and by the fleet of company cars have been identified as direct Scope 1 GHG emissions sources that are owned or controlled by the company. Refrigerant losses from air-conditioning units are not included in Scope 1.

Scope 2: Indirect GHG emissions from purchased energy (electricity and purchased heat). 100% of the energy supply at Frequentis AG comes from renewable energy sources. IEA (International Energy Agency) emission factors are used to calculate location-based Scope 2 emissions, based on the 2006 IPCC Guidelines and most recent IPCC Assessment Reports (AR4, AR5, AR6). GHG emissions calculations cover carbon dioxide, methane, and nitrous oxide, converted into CO2 equivalents (CO2e) using the corresponding global warming potential (GWP-100). Upstream emissions and grid transmission and distribution losses are not included in Scope 2 as they are included in Scope 3 Category 3.

Scope 3: Significant Scope 3 categories were identified Group-wide for the first time for 2023 and included in the GHG inventory:

• Category 1 – Purchased goods and services: Product and project-related goods and services (IT consulting, software development) were converted into t CO2e using spend-based emission factors from Climatiq. Data cover Frequentis AG and 16 other subsidiaries. Other companies were not included due to lack of reliable data but are classified as immaterial.

• Category 6 – Business travel: Comprises travel by air, rental car, and rail. For air travel and rental cars, CO2 emissions reports from travel agencies were used; for Group companies where data were unavailable (2024: 17%, 2023: 27%), estimates were made based on kilometres. For rail travel, activity-based emission factors from Climatiq were used. Business travel in private cars was not included due to lack of reliable data but is classified as immaterial.

Scope 3 categories not reported:

• Categories 2, 3, 4, 5, and 15 were classified as insignificant (< 1% of total emissions)
• Category 8 is included in the Scope 2 data
• Categories 10, 13, and 14 are not relevant for Frequentis
• Categories 7, 9, 11, and 12 cannot be determined at present due to lack of reliable data

Primary data account for 4% (2023: 3%) of the calculation of Scope 3 emissions for the Frequentis Group (Category 6 Business travel based almost entirely on emissions reports from travel agencies).

To calculate greenhouse gas intensity, total revenues of the Frequentis Group are used.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Phase-in exemption

As permitted by ESRS 1 Appendix C List of phased-in disclosure requirements, the disclosures pursuant to ESRS E1-9 on the expected financial effects of material physical and transition risks and potential climate-related opportunities have been omitted in the first year of preparation.

Disclosure status in index tables

The company explicitly states across multiple index references that E1-9 disclosures are omitted:

• E1-9 Anticipated financial effects from material physical and transition risks and potential climate-related opportunities: Disclosure omitted in the first year of preparation as permitted by ESRS 1 Appendix C.

• E1-9 Exposure of the benchmark portfolio to climate-related physical risks paragraph 66: Disclosures omitted in the first year of preparation as permitted by ESRS 1 Appendix C.

• E1-9 Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a): Disclosures omitted in the first year of preparation as permitted by ESRS 1 Appendix C.

• E1-9 Location of significant assets at material physical risk paragraph 66 (c): Disclosures omitted in the first year of preparation as permitted by ESRS 1 Appendix C.

• E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes paragraph 67 (c): Disclosures omitted in the first year of preparation as permitted by ESRS 1 Appendix C.

• E1-9 Degree of exposure of the portfolio to climate-related opportunities paragraph 69: Disclosures omitted in the first year of preparation as permitted by ESRS 1 Appendix C.

Policies related to resource use and circular economy

Frequentis addresses resource use and circular economy through multiple policies at different stages of development and implementation.

Environmental & Energy Policy

Key content:

• Includes improving the use of materials and resources
• Includes reducing waste in the company's own operations and in the value chain
• Addresses material impacts related to circular economy

Scope:

• See E1 – Climate change section for full details of scope

Governance:

• See E1 – Climate change section for accountability details

Public availability:

• See E1 – Climate change section for availability details

Circular Economy Policy

Status:

• In development during 2024
• To be embedded in the overall strategy
• Resulting actions will be prioritised in 2025 and rolled out to Group companies step by step

Development process:

• Various departments at Frequentis involved in development
• Six Frequentis-specific topics along the value chain identified, initially focused on Frequentis AG in Vienna: (1) Procurement, design, logistics; (2) Development, production; (3) Installation, testing; (4) Shipping, transport; (5) Operation, service; (6) Waste disposal
• Analysis takes as guide the R principles of circular economy set out by Austrian Federal Ministry for Climate Action (BMK based on Potting et al. 2017)
• Examined at monthly meetings of core team in 2024
• Core team comprises experts from affected departments

Timeline:

• Executive Board aims to draw up Circular Economy Policy by 2025

Procurement Policy

Key content:

• Addresses requirements of circular economy
• Specifies that procurement must take into consideration environmental impacts related to circular economy

Scope:

• Does not directly address the identified material impacts, risks, and opportunities

Public availability:

• Available to employees in relevant departments and companies either via intranet or directly if they do not have intranet access

Governance:

• Executive Board of Frequentis AG and, through the Global Corporate Policy, the managing directors of each company are responsible for applying this policy

Corporate Social Responsibility (CSR) Code for Suppliers

Key content:

• Addresses requirements of circular economy
• Specifies that procurement must take into consideration environmental impacts related to circular economy

Scope:

• Does not directly address the identified material impacts, risks, and opportunities
• See S2 – Workers in the value chain for details

Public availability:

• Available to employees in relevant departments and companies either via intranet or directly if they do not have intranet access

Governance:

• Executive Board of Frequentis AG and, through the Global Corporate Policy, the managing directors of each company are responsible for applying this policy

Waste Management Policy

Scope:

• Applies to Frequentis AG in Vienna
• Based on Vienna waste management law (AWG)
• At other companies, waste is managed in compliance with local statutory regulations

Key content:

• Outlines waste occurring at Frequentis AG
• Addresses related statutory provisions on correct disposal
• Addresses material impacts related to hazardous and electronic waste

Public availability:

• Available to employees in relevant departments and companies either via intranet or directly if they do not have intranet access

Governance:

• Executive Board of Frequentis AG and, through the Global Corporate Policy, the managing directors of each company are responsible for applying this policy

Actions and resources related to circular economy

Frequentis' products and systems are designed with essential circular economy elements already implemented:

• Long system life cycles
• Largely free of toxic substances
• Repairable and upgradeable
• Service-based business models
• Energy efficiency
• Waste avoidance and reduction

Six Frequentis-specific topics along the value chain

In 2024, six topics were identified as part of the development of the Circular Economy Policy, initially with a focus on Frequentis AG in Vienna:

1. Procurement, design, logistics
2. Development, production
3. Installation, testing
4. Shipping, transport
5. Operation, service
6. Waste disposal

The analysis follows circular economy principles (R principles) set out by the Austrian Federal Ministry for Climate Action (BMK based on Potting et al. 2017).

Implementation approach:

• Monthly meetings of core team throughout 2024
• Core team comprises experts from affected departments
• Meetings to be continued in 2025
• Related expenses are included in the budgets of the relevant departments (no specific amounts disclosed)

1. Procurement, design, logistics

Actions taken:

• Increasing offering of software-centric solutions, reducing hardware purchases
• Compressed system dimensions to improve utilization of customers' space
• Modular structure and high repairability enabling long-term operation
• New options for system use through scalability and divisibility (mobile systems, remote digital towers)
• Focus on short procurement routes and local value-added
• Most suppliers of Frequentis AG located in Europe

2. Development, production

[Content continues but is cut off in provided excerpts]

Targets related to circular economy

Frequentis does not currently have any measurable, outcome-oriented targets that meet the ESRS minimum disclosure requirements as set out in MDR-T.

Planned Activities

The company tracks the effectiveness of policies and actions relating to material impacts, risks and opportunities through the following activities:

• Circular Economy Policy development: The Executive Board aims to draw up a Circular Economy Policy by 2025. This will include a range of possible actions which will be evaluated, prioritised, and a timeline will be set.

• Packaging Regulation compliance: Higher priority is given to all actions relating to the Packaging Regulation as this takes effect in January 2025 (packaging must contain a certain proportion of recycled materials and be recyclable).

• Implementation focus: In the first step, the focus is implementing measures at the company's headquarters in Vienna as this is where the highest proportion of production in the Frequentis Group takes place.

• ISO 50001 certification: Initial certification of conformance with ISO 50001 (energy management), which is planned for Q1 2025, will make an important contribution to the circular economy.

Progress is measured at regular meetings of the core team and interim steps are presented to the Executive Board.

Resource outflows

Frequentis' products and solutions are designed for long-term use by customers, often for decades. The company supports this extended life cycle through extensive service and maintenance programmes and life cycle management. Customer Service offers various service levels and service teams are available worldwide around the clock.

For a number of years, Frequentis has repurchased hardware components from its customers. Repurchased parts are subject to a quality control check and then stored. Some of these components are refurbished to good-as-new assemblies and reused for many years in customer projects.

The modular structure and high repairability of Frequentis systems make them suitable for long-term operation. The product portfolio includes options for the use of systems through scalability and divisibility, including mobile systems and remote digital towers.

Products are designed to be:

• Largely free of toxic substances
• Repairable and upgradeable
• Energy efficient

No specific percentages of recyclable materials or recycled content in products are disclosed.

Waste

Waste Management Approach

Most of Frequentis' waste is non-hazardous and occurs in the production and transport of Frequentis' systems. Hazardous waste accounts for less than 5%.

For Frequentis AG in Vienna, there is an extensive Waste Management Policy (based on the Vienna waste management law [AWG]) in place. This outlines the waste occurring at Frequentis AG and the related statutory provisions on correct disposal. At the other companies, too, waste is managed in compliance with local statutory regulations.

Thanks to a mindful waste avoidance approach and systematic sorting of waste in line with local regulations, Frequentis' waste impact is low. An annual HSE (Health&Safety and Environment) audit evaluates the action taken to reduce and dispose of waste and recommends new initiatives to ensure correct sorting of waste and help avoid waste.

Waste Data (Frequentis AG only)

Waste data are only disclosed for Frequentis AG in Vienna as this is the largest production location. No reliable data on waste volumes are available for other manufacturing companies in the Group; however, the amount of waste is not considered to be material.

Waste Diversion and Disposal (Frequentis AG)

¹ Data not available

Policies related to own workforce

Frequentis has several policies governing its own workforce that address material impacts and risks related to working conditions, equal treatment, health and safety, training, and data protection.

General Policy on Recruiting, Promotion and Retention

Scope: The Frequentis Group

Key content:

• Employment conditions for the workforce
• Fair and market-oriented remuneration
• Work-life balance
• Diversity and equality of treatment
• Corporate and working culture

Material topics addressed: Working conditions and equal treatment and opportunities for all

Alignment with international standards: The policy complies with the United Nations Guiding Principles on Business and Human Rights, the declaration of the ILO (International Labour Organisation) and the OECD Guidelines for Multinational Enterprises. Frequentis explicitly rejects human trafficking, forced labour, and child labour.

Code of Conduct of the Frequentis Group

Scope: All employees of the Frequentis Group

Key content:

• Principles for working together
• Business ethics
• Prohibition of discrimination on grounds of gender, age, sexual orientation, race, ethnic background, or religion
• Equal opportunity employment

Governance: Approved by the Executive Board of Frequentis AG. The Executive Board and Managing Directors of each company are responsible for applying the policies.

Public availability: Available to stakeholders via the intranet or directly if they do not have intranet access. Also publicly available at www.frequentis.com > Sustainability & CSR > Customers & markets

Alignment with international standards: Complies with the United Nations Guiding Principles on Business and Human Rights, the declaration of the ILO (International Labour Organisation) and the OECD Guidelines for Multinational Enterprises

Monitoring: Mandatory training module "Business ethics & Code of Conduct" with 92% successful completion rate in 2024 (Frequentis Group)

Occupational Health and Safety Policy

Scope: All companies covered by ISO 45001 management certification and all other companies through the Global Corporate Policy (GCP)

Key content:

• Creating and maintaining a healthy and safe working environment
• Avoiding work-related injuries, accidents, and ill health

Material topics addressed: Positive impacts in connection with preventive health and safety

Alignment with international standards: ISO 45001:2018 certification (initial certification 2005)

Anti-Corruption Policy

Scope: The Frequentis Group

Key content: Avoiding all forms of corruption and providing guidance on ensuring legally compliant conduct when dealing with business partners

Governance: Approved by the Executive Board of Frequentis AG

Public availability: Available to stakeholders via the intranet or directly if they do not have intranet access

Monitoring: Mandatory training modules:

• "Anti-corruption and anti-bribery" with 94% successful completion rate in 2024 (Frequentis Group)
• Extended module for high-exposure employees (customer contact, sales, procurement, management) since May 2024

Policy on Handling Reports of Discrimination or Sexual Harassment

Key content: Defines the process to be followed if an employee reports an (alleged) case of discrimination or sexual harassment

Whistleblowing Policy

Scope: All employees of the Frequentis Group

Key content:

• Platform to report irregularities and risks or put forward suggestions for improvement
• Protection from reprisals

Governance: Approved by the Executive Board of Frequentis AG

Public availability: Available via the intranet; key elements included in "Business ethics & Code of Conduct" training module

Alignment with international standards: Implements EU Directive (EU) 2019/1937

Data Protection Manual (Data Protection Policy)

Scope: The Frequentis Group

Key content:

• Employee data protection (processing employee data)
• Protecting customer data in Marketing
• Video surveillance at headquarters (works agreement)
• Protecting customer data when implementing projects
• Data protection in products
• Data protection in the "Cloud"
• Artificial intelligence (AI) and data protection

Governance: The Data Protection Officer, appointed in 2018, advises and instructs the company. The Data Protection Officer is responsible for ongoing development of company-specific data protection measures, awareness-raising and sensitization measures, and monitoring and documentation.

Alignment with international standards: European General Data Protection Regulation (EU GDPR); uses structures from ISO 27001 (information security) and ISO 9001 (quality management)

Monitoring: Mandatory training "Personal data protection" with 92% successful completion rate in 2024 (Frequentis Group), required every 2 years

Global Corporate Policy (GCP)

Scope: All Group companies

Key content: Defines basic rules of conduct for Group-wide collaboration based on responsibility and integrity

Procurement Policy

Scope: Binding for Frequentis AG; all companies required to draw up local policy based on defined guidelines under GCP

Key content:

• Procurement guidelines and processes
• Environmental and social aspects in procurement

Governance: Director of Procurement bears operational responsibility for implementation

Material topics addressed: Material impacts relating to workers in the value chain

Additional governance mechanisms

ISO certifications: Frequentis' integrated management system is based on internationally recognised standards:

• Quality management (ISO 9001:2015) - certified since 1993
• Environmental management (ISO 14001:2015) - certified since 2005
• Information security (ISO 27001:2013) - certified since 2011
• Occupational health and safety (ISO 45001:2018) - certified since 2005

Monitoring: Internal audits check process application and compliance. Certified sites are regularly audited by accredited certification organisations.

Taking action on material impacts on own workforce

Frequentis states that if not explicitly explained, the actions outlined are continuously applied as part of ordinary business activities. The personnel and monetary resources required to perform these measures are included in the overall budget for the department responsible for applying them.

Working conditions

Work-life balance

Flexible working time models

• Applied throughout the Group after adaptation to comply with regional legislation
• Based on principles of performance, respect for individual personality, and mutual trust
• Supported by modern IT landscape (Microsoft Teams and other web-based platforms) for mobile working and working from home
• Offers: temporary part-time working conditions, sabbaticals, and educational leave

Occupational health and safety

ISO 45001 management certification

• Covers Frequentis AG and five subsidiaries (approximately 60% of Group employees)
• Frequentis UK Limited newly certified as compliant with ISO 45001 in 2024
• Other companies required to define own policies and measures per Global Corporate Policy (GCP)

Training and continuing professional development programme

• Wide range of occupational health and safety offerings
• Compulsory safety training for specific groups of workers
• Regular refresher courses in accordance with mandatory country-specific legislation (e.g. Section 14 of Austrian Occupational Safety Act)

Occupational health and safety team (Frequentis AG, ~40% of Group workforce)

• Resources: medical officer, psychologist, two safety specialists, eight-member team of safety officers, extensive first aid organisation
• Activities: machinery inspection, preventive measures, personal protective equipment use, standard operating procedures on handling dangerous chemicals and machinery, specific safety training, chemical substitution analysis, regular inspections

Preventive healthcare measures (Frequentis AG)

• Vaccination programmes
• Health checks (heart checks, lung function tests)
• Psychological support
• Frequentis Vital programme (healthy eating, exercise, running training, massages)
• Other Group companies offer preventive healthcare programmes, check-ups, and activities where possible

Equal treatment and opportunities for all

Data protection

Mandatory e-learning modules

• Frequency: every two years
• Scope: all employees in Frequentis Group
• Content: personal data protection (employees, customers, suppliers)
• Special training programme for departments handling significant personal data

Safety competence development

Safety Academy

• Operational since 2005
• Leads to safety certificate award
• 141 employees certified to date, including 24 from subsidiaries
• New continuity level provides deeper safety knowledge and builds Group-wide safety competence
• Trains safety peers across organizational units
• Offers role-specific safety training modules: hazard management, system safety, reliability engineering, compliance engineering, human factors, software safety

Targets related to own workforce

Frequentis does not currently have any measurable, outcome-oriented targets that meet the ESRS minimum disclosure requirements as defined in MDR-T, but tracks the effectiveness of policies and actions relating to material impacts, risks and opportunities through the following activities:

Qualitative goals

Long-term goal of HR management: To ensure the performance, commitment, and innovative power of employees. Based on the HR strategy and clearly defined focus topics, attention is paid to:

• Attracting and developing talented employees and retaining them in the long term
• Flexible organisational structures to allow rapid response to market and environmental changes
• Openness to networking and cooperation
• Continuous professional and personal development of employees, measured by their professionalism, competence, and excellent results both within the company and beyond

No quantified targets, target years, baseline years, or baseline values are disclosed.

Characteristics of the undertaking's employees

Total headcount and FTE

The total workforce of the Frequentis Group comprises employees with permanent and temporary contracts and non-guaranteed hours employees. The average headcount increased from 2,377 in 2023 to 2,584 in 2024. About 40% work for Frequentis AG in Vienna. The internationality of the workforce is reflected in the fact that Frequentis Group employees come from 65 nations and are employed at companies and locations in 17 countries.

No assumptions were used in the compilation of the data; the data are taken from the HR master data system. The total number of permanent employees, expressed as full-time employees (FTEs) is also disclosed in the Frequentis Group's consolidated financial statements.

Total number of employees by gender (average headcount)

Includes permanent, temporary, and non-guaranteed hours employees

Total number of employees by country (average headcount)

Includes permanent, temporary, and non-guaranteed hours employees

Headcount by employment contract type and employment type

The majority of employees (99% in 2024) have an employment contract for an indefinite term (permanent employees). These are full-time and part-time employees, employees on parental leave, and apprentices. Temporary contracts relate to holiday and professional internships; non-guaranteed hours contracts relate to freelancers and student employees.

Employees by contract type (average headcount)

¹ Includes permanent, temporary, and non-guaranteed hours employees ² Employees with employment contracts for an indefinite term ³ Employees with employment contracts for a limited period ⁴ Employees with employment contracts for an indefinite term

Employee turnover and new hires

Employee turnover has been constant in the Frequentis Group for years (2024: 9.4%), the average length of employment is eight years.

Employee turnover (headcount in reporting period)

Includes permanent employees

Non-employee workers

In addition to its own employees, in 2024 the Frequentis Group had 96 non-employee workers, leased workers, and external workers.

Number of non-employees (average headcount)

Additional information

The number of employees at the end of the financial year was 2,486 (2023: 2,318), measured as full-time equivalents (FTEs). The average number of employees was 2,422 FTEs (2023: 2,217 FTEs). In both cases, the data refer to employees with contracts for an indefinite period.

In 2024, the proportion of female employees who were new hires was 19% at both the Frequentis Group and at Frequentis AG.

Characteristics of non-employees in the undertaking's own workforce

Number of non-employee workers

In addition to its own employees, in 2024 the Frequentis Group had 96 non-employee workers, leased workers, and external workers.

Methodology

Average headcount methodology is used for counting non-employee workers.

Collective bargaining coverage and social dialogue

Coverage rates

57% (2023: 58%) of employees in the Frequentis Group are covered by collective bargaining agreements. At companies where there is no collective bargaining agreement, salaries are adjusted on the basis of external benchmarks and statutory requirements. However, the mode is up to the individual company.

By country/region:

• All employees in Austria (100%) are covered by collective bargaining agreements; the majority of them are at Frequentis AG and are covered by the Austrian collective bargaining agreement for the metalworking sector
• No collective bargaining agreements are applicable in Germany
• Collective bargaining agreements are applicable in Brazil, France, Romania, and Italy

65% (2023: 67%) of employees in the Frequentis Group are represented by workers' councils.

By country:

• Austria: 95% are represented
• Germany: 61% representation
• Workers' councils also exist in Romania and Italy

Coverage breakdown table

¹ Countries/regions with > 50 employees representing > 10% of total employees in the Frequentis Group
² Including Frequentis AG (100%)

Social dialogue mechanisms

The workers' council at Frequentis AG is in constant communication with the Executive Board and is involved in key corporate decisions. Social dialogue takes place through a range of formats, including a digital community, works meetings, involvement in internal committees, and networking with interest groups.

Diversity metrics

Gender distribution

The Frequentis Group employs staff from 65 nations. In 2024, female employees accounted for 23% of the total workforce (2023: 23%). The percentage of female employees was also stable in the Executive Board (highest management level) and among vice presidents, managing directors, and other managers. In both the Frequentis Group and at Frequentis AG, the proportion of new hires who were female was 19% in 2024.

Frequentis Group

Frequentis AG

The data relate to permanent employees

Age distribution

Frequentis Group

Frequentis AG

The data relate to permanent employees

Adequate wages

Frequentis references wage-related requirements in its CSR Code for Suppliers, which applies to workers in the value chain. The company states that it requires "paying the collectively agreed and statutory minimum wage" for suppliers.

No disclosure was found regarding adequate wages benchmarked against a living wage standard for Frequentis' own workforce (ESRS S1-10). The company references minimum wage and collective bargaining agreements in the context of supplier requirements only.

Benchmark used: Statutory minimum wage and collectively agreed wages (for suppliers)

Coverage: Not disclosed for own workforce

Geographic scope: Not disclosed

Targets/commitments: None disclosed

Methodology: Not disclosed

Social protection

Coverage by major life event

The Frequentis Group endeavours to protect all employees against a loss of income due to the following major life events:

Exclusions

Due to the statutory framework, social protection is not provided for all the listed life events in the Philippines, Brazil, the United Arab Emirates, and Singapore.

Methodology note

Since the statutory framework differs in different countries, employees are either covered by public programmes or by benefits offered by Frequentis.

Related information on retirement benefits

Voluntary and statutory defined contribution pension payments of EUR 3,232 thousand were made in the reporting period (2023: EUR 2,669 thousand).

Pension benefit obligations are defined benefit obligations arising from individual commitments to current members of the Executive Board and 3 former members of the Executive Board, as well as commitments to 4 employees of Frequentis Orthogon GmbH.

Training and skills development metrics

Frequentis has an extensive internal training offering comprising virtual and face-to-face training in the areas of marketing, sales, technology, project management, management and leadership skills, personal development, business economics, and languages. In addition, employees have access to the O'Reilly online learning platform with more than 60,000 modules, especially in the areas of technology and software development, including advanced content on programming languages, frameworks, cloud computing, and machine learning. 20 companies in the Frequentis Group currently use this offer.

Training hours

¹ Calculated on the basis of full-time equivalents (FTEs) to show training time per full-time employee

Performance and career development reviews

The central tool for fostering and developing employees is the annual performance and career development review. This is a snapshot that gives employees guidance for their personal development. Digital documentation facilitates tracking of the agreed targets and development measures. 83% of employees in the Frequentis Group had a documented performance and career development review (appraisal interview) in 2024 (2023: 78%).

¹ Calculated on the basis of employees at companies connected to the Frequentis Group's IT landscape as data on performance and career development reviews are available electronically. When calculating the percentage of employees that participated in performance and career development reviews, it is assumed that the percentage is similar at other Group companies.

Total investment in training

Not disclosed.

Health and safety metrics

Frequentis discloses health and safety metrics in accordance with ESRS S1-14. The company maintains an ISO 45001-certified occupational health and safety management system covering approximately 60% of Group employees (Frequentis AG and five subsidiaries, with Frequentis UK Limited newly certified in 2024). Other companies define their own policies and measures through the Global Corporate Policy.

Coverage of health and safety management system

The ISO 45001 management certification covers Frequentis AG and five subsidiaries, representing approximately 60% of Group employees. Other Group companies are required to define their own policies and measures under the Global Corporate Policy.

Health and safety performance metrics

¹ Work-related accidents and ill health with more than three days lost, excluding accidents on the way to work

² Number of cases per 1 million hours worked, based on an average of 1,700 working hours per employee per year and the total number of employees

³ Calendar days, including weekends and public holidays

Commentary

In 2024, all work-related accidents were non-serious accidents with minimal consequences. The incidents were investigated, and corresponding action taken to prevent a recurrence. Special attention is paid to carefully analysing every accident and deriving action for improvement to prevent similar accidents occurring in the future.

Work-life balance metrics

Family-related leave entitlement

All employees (100%) have a statutory entitlement to leave for family reasons after the birth of a child. The number of days granted varies by country due to differences in the statutory framework. In some countries Frequentis offers leave beyond the statutory requirements.

97% of employees can take leave to care for relatives. Due to the statutory framework, this option is not available in the Philippines, Brazil, the United Arab Emirates, and Singapore.

Supporting work-life balance

Frequentis successfully established flexible working time models many years ago to accommodate personal needs and enable employees to achieve a work-life balance. After adaptation to comply with regional legislation, these are applied throughout the Group. The Frequentis working time model is based on the principles of performance, respect for individual personality, and mutual trust. A modern IT landscape (Microsoft Teams and other web-based platforms) provides extensive support for mobile working and working from home.

To make it easier for staff to pursue their personal interests, in addition to statutory dispensations, Frequentis offers staff throughout the Group temporary part-time working conditions, sabbaticals, and educational leave.

Compensation metrics

Pay gap

Group-wide calculation of the remuneration metrics gender pay gap and annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees was calculated for the first time for 2024 (reference year: 2023).

¹ Difference in average pay levels between male and female employees, expressed as a percentage of the average pay level of male employees, without taking into account employee category

² Ratio of the annual total remuneration of the highest paid individual to the median annual remuneration for all employees

Remuneration ratio

The annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees was:

• Frequentis Group 2024: 13.8
• Frequentis AG 2024: 13.6

(2023 data not available for remuneration ratio)

Methodology

Gender pay gap: The gender pay gap is calculated from the average gross annual income of female and male employees based on full-time equivalents (FTE). Differences in purchasing power between countries are taken into account using the World Bank's purchasing power parity conversion rates. The gender pay gap is the difference between the average income of male and female employees, divided by the average income of male employees. The gender pay gap at Frequentis is attributable to the low proportion of female employees, especially in management positions.

Annual total remuneration ratio: The ratio of the annual total remuneration of the highest paid individual to the median annual total remuneration for all employees is calculated using the average gross annual remuneration in the Group, based on FTEs, after adjustment for differences in purchasing power. The median was estimated using the distribution of remuneration at Frequentis AG because both the mean and the median are known for Frequentis AG. It is assumed that the distribution is similar for the Frequentis Group.

Incidents, complaints and severe human rights impacts

No allegations of discrimination were reported via formal processes in 2024.

For details of the whistleblower and compliance management system, see G1 - Governance.

Incidents and complaints metrics

There were no incidents of discrimination (including harassment), nor any incidents of violation of human rights in 2024.

Whistleblowing system

A whistleblower system was introduced in December 2021, initially at Frequentis AG and subsequently rolled out to subsidiaries required by EU directive to implement such a system. The system is available to all Frequentis Group employees worldwide via the intranet and to customers and external partners via the company website (https://frequentis.integrityline.com). It allows anonymous reporting of suspicions of criminal offences, unequal treatment, discrimination, breaches of the Anti-Corruption Policy, and breaches of EU law. All reports are treated as confidential and whistleblowers acting in good faith are protected from reprisals.

Policies related to value chain workers

Frequentis has established policies addressing material impacts relating to workers in the value chain, with criteria including ethics, compliance with labour standards, and environmental protection.

Procurement Policy

• Scope: Binding for Frequentis AG; under the Global Corporate Policy (GCP), all companies are required to draw up a local policy based on the defined guidelines
• Content: Defines procurement guidelines and processes, taking into account environmental and social aspects; addresses material impacts relating to workers in the value chain
• Availability: Made available to relevant stakeholders via the intranet or directly if they do not have intranet access
• Oversight: Director of Procurement bears operational responsibility for implementation

Corporate Social Responsibility (CSR) Code for Suppliers

• Scope: Applicable to all Frequentis suppliers
• Content: Highlights Frequentis' commitment to protecting the environment, respecting human rights and labour standards, and fighting corruption. Suppliers are obliged to act in accordance with these principles. Key elements include:
  • Rejecting forced and compulsory labour, child labour, moonlighting, and discrimination of employees
  • Observing working hours
  • Ensuring a safe working environment
  • Paying the collectively agreed and statutory minimum wage
  • Compliance with the declaration of the International Labour Organisation (ILO) on fundamental principles and rights of workers
  • Addressing "modern slavery"
• International standards: Linked to ILO fundamental principles and rights of workers
• Availability: Available to stakeholders in the intranet and on the Frequentis website at www.frequentis.com > About us > Sustainability & CSR > Customers & Markets
• Oversight: Executive Board is responsible for applying this policy
• Scope (extended): Applicable for all Group companies; included in contractual documents for subcontractors, suppliers, coaches, and employment agencies

Code of Conduct of the Frequentis Group

• Scope: Applicable for all Group companies
• Content: Includes provisions on "modern slavery" and is referenced in contractual documents for subcontractors, suppliers, coaches, and employment agencies
• Availability: Available to stakeholders in the intranet and on the Frequentis website at www.frequentis.com > About us > Sustainability & CSR > Customers & Markets
• Oversight: Executive Board is responsible for applying this policy

Monitoring

Observance of the CSR Code for Suppliers is strictly monitored. Compliance is checked as part of annual supplier assessments. There are no known incidents of failure by suppliers and subcontractors to respect these standards in recent years.

Taking action on material impacts on value chain workers

Frequentis has implemented several continuous actions and initiatives to manage material impacts on workers in the value chain, primarily focused on supplier management and engagement.

Selection of suppliers

When selecting suppliers, priority is generally given to existing, well-established business relationships. The process for approving new suppliers includes obtaining extensive information to check their performance, including their sustainability performance. Where necessary, the supplier self-assessment is supplemented by screening the company or obtaining creditworthiness information.

An important aspect in this is the sustainability screening, especially in the case of planned long-term partnerships or if the supplier has its head office or operations in countries that constitute a risk in respect of sustainability or social criteria.

Purchasers and Strategic Procurement Managers in the department are involved in the supplier assessment by obtaining information and evaluating and checking the documents.

Scope: Upstream value chain
Time horizon: Continuous/ongoing
Resources: Personnel and monetary resources required are included in the overall budget for the department responsible for applying them
Link to policy: CSR Code for Suppliers, Procurement Policy

Annual supplier assessments

Frequentis AG assesses its established suppliers once a year in the first quarter using revised criteria:

• Quality: e.g. product quality, product complexity, quality assurance system
• Price: e.g. development of prices and comparison with the previous year and market prices
• Support quality: e.g. commercial, personal, and technical support
• Delivery performance: adherence to delivery dates and volumes; environment-friendly and sustainable packaging
• Sustainability of suppliers: assessment of the business environment (stability, performance, flexibility, environmental management, etc.) and social aspects (social competence)

Assessments are performed for suppliers that account for the highest order volume (top 10%) and those that play a key role in the supply of specific groups of products. The assessment for 2024 will be performed in Q1 2025 as planned. The 2023 assessment, which was performed in 2024, covered 101 suppliers accounting for procurement volume of EUR 48.1 million at Frequentis AG. The top three suppliers received performance awards and certificates. There is a separate evaluation for the suppliers with the highest scores in the sustainability category.

Suppliers are informed of the results. A range of measures is agreed with suppliers whose performance needs to be improved and implementation is monitored.

Scope: Upstream value chain
Time horizon: Annual/continuous
Resources: Personnel and monetary resources included in the overall budget for the department responsible
Expected outcomes: Top suppliers receive performance awards; improvement measures agreed with underperforming suppliers
Link to policy: CSR Code for Suppliers, Procurement Policy

Supplier audits

Frequentis AG regularly conducts supplier audits; these are conducted at the end of a year for the following year. Reasons for a supplier audit include:

• To get to know a potential new supplier
• The supplier accounts for significant order volume or has increased risk potential
• Difficulties in the relationship with the supplier over the past year (e.g. delivery, quality, communication – based on the supplier assessment)

Audits are always performed on-site because this is essential to secure the quality of the audit. The audit plan can be modified in the light of events during the year. Procurement governance principles are in place at subsidiaries with sales responsibility based on the GCP set out in the procurement guidelines and supplier audits are conducted on an ad-hoc basis.

Scope: Upstream value chain
Time horizon: Annual/ongoing
Resources: Personnel and monetary resources included in the overall budget for the department responsible
Link to policy: CSR Code for Suppliers, Procurement Policy, Global Corporate Policy (GCP)

Global procurement team

Extensive internal work has been carried out on a common understanding of supply chain management and current requirements in all departments of relevance for procurement. The aim is to establish a strong global procurement team with effect from 1 January 2025. This team will be responsible for the Group-wide rollout of supply chain management.

This initiative, which is transforming the Central Procurement function into Group Procurement, started in 2023. Based on intensive research and analyses, the first steps were identifying Group-wide needs, selecting suitable procurement tools, and developing an appropriate Group-wide organisational structure. The policy is being implemented stepwise.

Group Procurement will play a key role in meeting the relevant standards and certificates, e.g. ISO 27001 (Information Security), which are a key aspect of supplier management.

Scope: Upstream value chain, Group-wide
Time horizon: Implementation from 1 January 2025 (started 2023)
Resources: Related expenses are included in the budgets of the relevant departments
Link to policy: Procurement Policy, Global Corporate Policy (GCP)

Training for supply chain management staff

Supply chain management staff and managers receive regular training in the principles of transparency along the supply chain, including strict avoidance of slavery, human trafficking, any form of forced or compulsory labour, child labour, and all types of discrimination. Training is generally incorporated into the monthly meetings of the Procurement department.

Scope: Own operations (procurement staff)
Time horizon: Regular/ongoing
Resources: Personnel resources included in departmental budgets
Link to policy: Code of Conduct, CSR Code for Suppliers, Modern Slavery Statement

Performance metrics (2024)

Frequentis is not aware of any violations of human rights by suppliers in 2024.

Targets related to value chain workers

Frequentis does not currently have any measurable, outcome-oriented targets that meet the ESRS minimum disclosure requirements as defined in MDR-T.

Planned activities

Frequentis tracks the effectiveness of policies and actions relating to material impacts, risks and opportunities through the following activities:

• The dialogue with suppliers and subcontractors is to be extended, especially in the area of sustainability, allowing evaluation of the scope for improvement.

Policies related to consumers and end-users

Frequentis has established several policies applicable to consumers and end-users:

Safety Guidelines

• Scope: Attached to the delivery of every customer project and apply to end-users of Frequentis' systems
• Governance: Project managers at the highest level in the organisation are responsible for compiling, distributing, and implementing the Safety Guidelines and for organising training
• Key content: Rules of conduct for end-users, extensive training documents on using and caring for personal protective equipment, and specific operating procedures
• Material impacts addressed: Safety of end-users, minimisation of risk, and the material impacts and risk of accidents in the use of Frequentis' products

Code of Conduct of the Frequentis Group

• Scope: Applies to end-users of Frequentis' systems (referenced from G1 – Governance / Policies)
• Key content: Respecting human rights and protecting whistleblowers are integral parts
• Linkage to international standards: Complies with the United Nations Guiding Principles on Business and Human Rights, the declaration of the ILO (International Labour Organisation), and the OECD Guidelines for Multinational Enterprises

Data protection policies

• Scope: Cover end-users of Frequentis' systems
• Key content: Set out in the Data Protection Manual produced in 2024, including protecting customer data when implementing projects and data protection in products
• Material impacts addressed: Material impacts and risks relating to data protection
• Reference: See S1 – Own workforce / Data protection for detailed information

All specified and referenced policies cover end-users of Frequentis' systems.

Taking action on material impacts on consumers

Life Cycle Engagement Processes

Extensive processes at all stages in the life cycle of Frequentis' systems ensure that end-users can operate them safely and without problem:

• Offer phase: Workshops held in major customer projects to respond to customer requirements
• Delivery and acceptance phase: Workshops and training in operation of systems organized; all information and training documents made available to end-users in written form

Scope: Own operations and downstream (end-users)

Regular User Group Conferences

User Group Conferences organized for established customers of individual business areas. At these conferences:

• Sector trends and challenges in individual industries discussed at management level
• Current customer requirements provide impetus for ongoing development of portfolio of solutions
• Foster long-term, trusting collaboration through direct feedback from end-users

Scope: Downstream (end-users)

Customer Satisfaction Process

Regular customer satisfaction process performed by account managers using standardized questionnaire:

• Feedback obtained at customer workshops, user groups, trade shows, conferences
• Responses and feedback analyzed
• Action planned to implement improvements and remediate shortcomings where necessary
• All steps and data documented in management report and tracked
• Customer satisfaction serves as indicator of quality and effectiveness of customer retention measures

Scope: Downstream (end-users)

Feedback and Reporting Channels

• End-users can report concerns and requirements via Frequentis homepage
• Anonymous reporting of irregularities and risks via whistleblower website
• Negative feedback forwarded to relevant department for action

Scope: Downstream (end-users)

Control Room Consulting Advisory Services

Advisory services offered to customers as part of projects through Control Room Consulting team:

• End-to-end analyses help end-users optimize operating processes, decision making, and strategic planning of workflows
• Close exchange of information provides insights into end-users' perspectives and operations
• Target group-specific interaction generates positive results for both sides

Scope: Downstream (end-users)

UX@Frequentis Project

New Control Room Consulting project launched in 2024 to deepen long-term exchange between end-users and developers:

Objectives:

• Enhance user satisfaction
• Speed up development process and reduce redesign iterations

Planned activities:

• First UX@Frequentis meetings for end-users and developers planned for 2025
• Use of prototypes, support for implementation teams, and clear design specifications for user interfaces
• Trial in two major programmes in 2025

Time horizon: Short-term (2025) Scope: Own operations and downstream (end-users)

Resources Allocated

The personnel and monetary resources required to perform these actions are included in the overall budget for the department responsible for implementing them. No specific amounts disclosed.

Human Rights Monitoring

Frequentis is not aware of any violations of human rights in connection with end-users in 2024.

Targets related to consumers

Frequentis does not currently have any measurable, outcome-oriented targets in the area of S4 – End-users, that are compliant with the ESRS minimum disclosure requirements as set out in MDR-T. The effectiveness of the policies and actions relating to material impacts, risks, and opportunities is measured using the feedback channels outlined above.

Business conduct policies and corporate culture

Frequentis' corporate culture is based on safety-critical DNA and is shaped by responsible conduct, integrity, and high ethical standards. The company has established several policies addressing business conduct:

Code of Conduct of the Frequentis Group

• Key content/principles: Sets out principles and guidelines for responsible conduct based on integrity. Covers employment conditions, fair and market-oriented remuneration, work-life balance, diversity and equality of treatment, corporate and working culture. Explicitly rejects human trafficking, forced labour, and child labour. Does not tolerate any form of discrimination (gender, age, sexual orientation, race, ethnic background, religion). Includes "modern slavery" provisions. Addresses data protection and business secrets.

• Scope: All employees of the Frequentis Group; also applicable to major business partners (suppliers, consultants, contractors)

• Governance: Approved by the Executive Board of Frequentis AG. Executive Board and Managing Directors of each company are responsible for applying the policy.

• Public availability: Available via intranet and on the Frequentis website at www.frequentis.com > About us > Sustainability & CSR > Customers & Markets

• International standards: Complies with the United Nations Guiding Principles on Business and Human Rights, the declaration of the ILO (International Labour Organisation), and the OECD Guidelines for Multinational Enterprises

• Monitoring: Mandatory training module "Business ethics & Code of Conduct" for all permanent employees (92% completion rate in 2024). Compliance Officer supports Executive Board in ensuring Group-wide observance. Compliance management system based on prevention, early detection, and response principles.

Global Corporate Policy (GCP)

• Key content/principles: Defines basic rules of conduct for Group-wide collaboration based on responsibility and integrity. Requires local companies to draw up policies based on defined guidelines.

• Scope: All Frequentis Group companies

• Governance: Approved by Executive Board of Frequentis AG

Anti-Corruption Policy

• Key content/principles: Operational instruction to avoid all forms of corruption. Provides guidance on legally compliant conduct when dealing with business partners. Addresses bribery and corruption (Frequentis does not tolerate bribery and corruption in any form). Includes processes for checking incoming invoices and expense claims for compliance with thresholds on gifts, invitations, and hospitality.

• Scope: All Frequentis Group employees; binding for all companies

• Governance: Approved by Executive Board of Frequentis AG. Compliance Officer responsible for implementation and monitoring.

• Availability: Via intranet or directly to stakeholders without intranet access

• Monitoring: Mandatory training for all permanent employees (94% completion rate in 2024). Additional training for high-risk functions with customer contact. Automated checking processes for receipts exceeding defined limits. Zero confirmed incidents of bribery or corruption in 2024.

Whistleblowing Policy

• Key content/principles: Implements EU directive (Directive (EU) 2019/1937). Provides platform to report irregularities and risks or submit suggestions for improvement without fear of reprisals. Allows anonymous reporting of suspected criminal offences, unfair treatment, discrimination, non-compliance with Group guidelines or EU law. Strictly confidential treatment with protection from reprisals.

• Scope: All Frequentis Group employees worldwide and external stakeholders (customers, partners)

• Governance: Approved by Executive Board of Frequentis AG. Whistleblower officer analyses reports using dual control principle.

• Public availability: Available via intranet and website at www.frequentis.com/whistleblowing or https://frequentis.integrityline.com

• Monitoring: Introduced December 2021. One complaint reported via whistleblower platform in 2024. All reports analysed using clearly defined process.

Corporate Social Responsibility (CSR) Code for Suppliers

• Key content/principles: Highlights Frequentis' commitment to protecting the environment, respecting human rights and labour standards, and fighting corruption. Focus on respecting labour standards: rejects forced and compulsory labour, child labour, moonlighting, and discrimination. Requires observing working hours, ensuring safe working environment, paying collectively agreed and statutory minimum wage. Includes "modern slavery" provisions.

• Scope: All suppliers; suppliers obliged to act in accordance with these principles and ensure their subcontractors comply

• Governance: Executive Board responsible for applying policy

• Public availability: Available via intranet and on Frequentis website at www.frequentis.com > Sustainability & CSR > Customers & Markets

• International standards: References ILO declaration on fundamental principles and rights of workers

• Monitoring: Compliance checked through annual supplier assessments. Obligation integrated into supplier self-assessment; suppliers sign at start of business relationship. Supplier audits performed where necessary.

Capital Market Compliance Policy

• Key content/principles: Implements capital market-relevant laws and regulations. Covers handling and publication of capital market-relevant information, prohibition of trading in shares and other financial instruments of Frequentis AG, obligation to report management transactions ("Directors' Dealings").

• Scope: All Frequentis Group employees

• Governance: Approved by Executive Board. Capital Market Compliance Officer responsible for implementation and monitoring, reports directly to Executive Board.

• Monitoring: Mandatory training for all permanent employees (93% completion rate in 2024).

Additional Policies Referenced

• General Policy on Recruiting, Promotion and Retention: Covers employment conditions, remuneration, work-life balance, diversity and equality
• Policy on Handling Reports of Discrimination or Sexual Harassment: Defines process for reporting alleged discrimination or sexual harassment
• Occupational Health and Safety Policy: Addresses healthy and safe working environment (covers ISO 45001 certified companies and others through GCP)
• Procurement Policy: Defines procurement guidelines and processes, taking into account environmental and social aspects; binding for Frequentis AG; other companies required to draw up local policy through GCP
• Data Protection Manual: Produced in 2024; covers employee data protection, customer data in marketing, video surveillance, customer data in projects, data protection in products, cloud data protection, AI and data protection
• Frequentis Group Security Policy: Security guidance for entire Group in compliance with national and international regulations; based on security strategy
• Safety Policy: Contains safety information and principles for safety management system

Corporate Culture Elements

Frequentis' corporate culture is characterized by:

• Safety-critical DNA influencing daily work
• Open approach to mistakes to learn from them
• Proactive culture with technical and emotional understanding of customer needs
• Openness, flexibility, and transparency in internal collaboration and customer relationships
• Appreciation as key element
• Non-punishment culture
• Principle of lifelong learning

Incidents of corruption or bribery

Confirmed incidents and convictions

Frequentis reported zero confirmed incidents of corruption or bribery during the 2024 reporting period. There were no convictions for breaches of anti-corruption and anti-bribery regulations.

There were no incidents of discrimination (including harassment), nor any incidents of violation of human rights in 2024.

Compliance enquiries and complaints

During 2024, the Compliance Officer received 12 compliance enquiries from employees at the Group level (10 at Frequentis AG). One complaint was reported via the whistleblower platform (1 at Frequentis AG).

Investigation and speak-up mechanisms

Frequentis has established a comprehensive whistleblower system introduced in December 2021, available to all employees worldwide via the intranet and to customers and external partners via the company website (https://frequentis.integrityline.com). The system allows anonymous reporting of:

• Suspicions of criminal offences or attempted offences
• Indications of unequal treatment or other forms of illegal discrimination
• Breaches of the Group's Anti-Corruption Policy
• Breaches of EU law

All reports are treated as strictly confidential and whistleblowers submitting reports in good faith are protected from reprisals. The whistleblower officer analyses reports using a clearly defined process based on the dual control principle.

Prevention and detection measures

Frequentis maintains an Anti-Corruption Policy providing guidance on conduct, with processes to avoid and detect bribery and corruption including:

• Mandatory training for all permanent employees on anti-corruption and anti-bribery (94% completion rate in 2024 for risk-related functions)
• Enhanced training for employees with customer contact
• Review of incoming invoices and expense claims for compliance with defined thresholds on gifts, invitations, and hospitality
• Automated sanction screening against international sanctions lists on a daily basis

Political influence and lobbying activities

Political engagement approach

The Frequentis Group strives to obtain the trust of its stakeholders by implementing high standards of corporate governance, transparency, and reliability. As a company whose business activities primarily include public sector contracts, support for political parties, including donations to such parties, is strictly prohibited.

Political contributions

Frequentis did not make any donations to political parties in either 2024 or 2023.

No member appointed to its administrative, management or supervisory bodies in the reporting period held a comparable position in public administration in the two years preceding their appointment.

EU Transparency Register

Since 2014, Frequentis AG has been registered with the European Transparency Register under the number 878884412932-63 to disclose its activities in the area of research funding in Europe.

Stakeholder engagement on political matters

The company engages with various stakeholder groups including:

• Advocacy groups, associations, and NGOs through the Frequentis website, social media, conferences, research projects, cooperations, and active involvement in associations and committees
• Topics addressed include ESG strategy, innovation, sustainability of products, safety awareness, security, fail-safety of systems, cybercrime, support for women in the company, energy-saving measures, and careful use of resources

Payment practices

The standard payment terms of the Frequentis Group vary from one country to another and from contract to contract. Nevertheless, the aim is to settle invoices as quickly as possible after receipt. On average, 63% of invoices were paid within 21 days in 2024, and 94% were settled within 45 days of receipt.

The standard payment terms of Frequentis AG specify that invoices are paid with a 3% discount within 21 days and net within 45 days. In 2024, 58% of invoices were paid within 21 days, and 94% were settled within 45 days of receipt.

Payment practices metrics

Legal proceedings

There were no court cases as a result of overdue payments in 2024.