Fresenius Medical

The role of the administrative, management and supervisory bodies

Reference: pages 64-66 (Sustainability management). Board composition and independence datapoints (ESRS 2, 21 d-e) are on pages 64-65.

The Management Board sets strategy and builds in sustainability, including identifying material impacts, risks and opportunities. The CEO guides the approach and each member owns their own area. In 2025 it had six executive members, two of them women (page 64).

The Supervisory Board oversees the Management Board and covers sustainability in its meetings. Its Audit Committee oversees how ESG topics are managed and reviews assurance of the sustainability reporting. The Supervisory Board decided that the Chairman of the Audit Committee should have expert knowledge in ESG (pages 64-65).

The Supervisory Board has twelve non-executive members: six employee representatives, four independent members (33%) and six women (page 65). Skills are checked against board competency profiles, and members received training on sustainability and sustainability reporting in 2025 (page 65).

Below board level sit the Global Sustainability department, the Human Rights Office and cross-functional steering committees. The Corporate Sustainability Committee "did not convene" in 2025 (page 66).

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

Reference: pages 64-66 (Sustainability management).

The Management Board and Supervisory Board, including the Audit Committee, "receive regular updates on material developments and strategic initiatives in environmental, social, and governance aspects" from the responsible function or segment heads. Updates are monthly, quarterly or annual depending on the topic, and some are ad hoc (page 66). The Global Head of Sustainability reports on progress with ESG regulation, reporting, risks and global targets (pages 65-66). The Corporate Risk Committee compiles risk results twice a year for the Management Board (page 65).

Topics covered in 2025 (page 66):

• rollout of the new company strategy
• new ESG regulatory requirements and compliance measures
• sustainability reporting developments and ESG data quality
• ESG controls in the Internal Control System and internal audit results
• progress on global ESG targets, including scope 3 targets and virtual power purchase agreements
• global employee engagement survey, human rights due diligence and cybersecurity
• compliance initiatives, Compliance Action Line rates and training

Trade-offs, "for example, the profit and loss (P&L) impact of sustainability initiatives", are also considered (page 66).

Integration of sustainability-related performance in incentive schemes

Reference: page 64. Further datapoints (ESRS 2, 29a-e) are incorporated by reference to the Compensation report, pages 213, 218, 220, 228 and 235 (page 140).

Sustainability targets sit in the short- and long-term compensation plans for the Management Board. They also appear in the Global Bonus Plan and the long-term incentive plan for non-Management Board members, which reach senior executives two levels below the Management Board and further managers and individual contributors below them (page 64).

For 2025 the Supervisory Board set three sustainability targets for Management Board pay (page 64):

• Short-term incentive: two equally weighted sub-targets, patient satisfaction and employee engagement, together 20% of the short-term incentive.
• Long-term incentive: reduction of scope 1 and 2 CO2e emissions, 20% of the long-term incentive.

The patient target is the Net Promoter Score: "Management Board compensation is directly linked to the NPS" (page 100).

Statement on due diligence

Reference: page 67 (Sustainability due diligence). The mapping table "Core elements of due diligence" (table 2.86) is on page 139.

The company builds due diligence into business processes "through policies and procedures". The policies named are the Code of Ethics and Business Conduct, the Human Rights Policy, the Global Environmental Policy and the Global Code of Conduct for Business Partners. Compliance and due diligence procedures also cover grievance mechanisms for affected stakeholders and sustainability in the value chain (page 67).

Through these processes the company says it identifies, prevents, mitigates and reports actual and potential negative impacts on people and the environment (page 67).

Table 2.86 (page 139) points to the chapters and pages for each core element: governance and strategy (pages 54-67), stakeholder engagement, identifying and assessing adverse impacts, actions taken, and tracking effectiveness. The human rights due diligence program is described on pages 123-124.

Risk management and internal controls over sustainability reporting

Reference: pages 66-67.

Risk process (page 66): the corporate risk assessment runs twice a year from a catalog of risks that includes sustainability risks. The Management Board gets the results twice a year plus an annual update on risks on people and the environment. The Audit Committee of the Supervisory Board monitors how well the risk management system works.

Internal controls (page 67): the Internal Control System follows the COSO 2013 framework. The Head of Global Internal Audit reports quarterly to the Management Board and Audit Committee, including findings on sustainability metrics. The company is moving sustainability metrics into the Company-wide system, with defined roles, documented tools and the four-eye principle. In 2025 it "established controls for 20 ESG metrics", focused on environmental metrics.

Strategy, business model and value chain

Reference: pages 54-55. Business model, strategy and market datapoints (ESRS 2, 40a(i), 40e, 40f, 40g) are incorporated by reference to the Group management report, pages 27, 31, 36 and 149 (page 140). Headcount by geography is in the chapter "Working for Fresenius Medical Care" (page 54).

Fresenius Medical Care describes itself as the world's leading provider of products and services for people with kidney disease, based on publicly reported revenue. It cares for 291,902 dialysis patients in 3,601 dialysis centers of its own in more than 30 countries, and runs 35 production sites in 19 countries. Products are sold in more than 140 countries (page 54).

It has three operating segments: Care Delivery, Value-Based Care and Care Enablement (page 54). Upstream, the value chain is mostly suppliers of manufacturing goods and site services; downstream it covers distribution, use and disposal of products in own and third-party care centers (page 54; table 2.19, page 55).

Sustainability priorities under the FME Reignite strategy: advancing care for patients, supporting people to contribute to a sustainable future, and driving sustainable operations and design (page 54). The sector-activity datapoints in ESRS 2, 40d (i-iv) are marked "Not material" (page 144).

Interests and views of stakeholders

Reference: pages 56-57 (table 2.20). Stakeholder input to the materiality assessment is described on page 59.

Key stakeholders are patients, employees and their representatives, customers and shareholders (page 56). Table 2.20 also covers suppliers, physicians, research and scientific communities, and policymakers. For each group it lists how the company engages, the topics raised and how the outcome is used (pages 56-57). Examples: patient experience surveys and grievance channels, the annual employee engagement survey and works council dialogue, supplier days and audits, and quarterly earnings calls.

The company has "formalized annual engagement with patients and employees" (page 56). The Management Board hears stakeholder views from the functional leads who own material impacts, risks and opportunities, and the Audit Committee and Supervisory Board are informed through the Management Board and those leads (page 56).

In the materiality assessment, stakeholder views were "considered by proxy" through senior executives and subject matter experts (page 59). On impacts on people, the company says it has limited primary information beyond tier-one suppliers (page 51).

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

Reference: pages 57-63 (table 2.23, pages 62-63). Each topical chapter holds its own IRO table.

The company reports IROs "related to 25 material matters" (page 57). Most sit in own operations. "The majority of sustainability matters fall within the social dimension"; value chain IROs mostly concern suppliers' workers and environmental topics (page 57).

Material topics (page 58): climate change (energy, mitigation, adaptation), water, resource use and circularity (inflows, outflows, waste), quality of care and patient experience, product stewardship, innovation and R&D, business ethics, employer attractiveness and equal opportunity, information security and data protection, and human rights and health equity. Four are entity-specific: innovation and R&D, health equity, ethical conduct in clinical research and anti-competitive behavior (pages 58, 62).

In 2025 the IROs were reviewed and the company reports "around 20 IROs less" than in 2024 (page 57). Pollution (E2) and biodiversity (E4) are not material (page 57). A transitional provision is applied to ESRS 2, SBM-3, 48(e) (page 51). The company considers its business model resilient (page 57).

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

Reference: pages 57-61 (Double materiality assessment). Environmental assessments are on pages 59-61.

A full double materiality assessment ran in 2023 across the whole consolidation scope, own operations and the upstream and downstream value chain (pages 57-58). The company plans a full assessment every three to five years with a review in between; the next annual review is planned for 2026 (page 57).

• Long list: more than 180 topics and subtopics from the earlier assessment, internal experts, ESRS 1 Appendix A, ESG ratings, media and stakeholder requests (page 58).
• Impact materiality: a 0 to 3 scale for likelihood, scale, scope and irremediable character, with a materiality threshold of 1.5 (pages 58-59).
• Financial materiality: a qualitative 0 to 3 scale with the same 1.5 materiality threshold, tied to corporate risk management (page 59).
• Validation: workshops with senior management; the Management Board discussed and validated the results and the Supervisory Board was informed (page 59).
• Environment: climate scenario analysis, the WRI Aqueduct water risk atlas, the WWF Biodiversity Risk Filter and local community assessments (pages 59-61).

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

Reference: pages 140-143 ("Disclosure requirements context index"), plus pages 51 and 59. The index "includes a list of all ESRS disclosure requirements and where in the Sustainability statement they are reported" (page 140).

Marked "Not reported" in the index: E1-7, E1-9, E3-5, E5-6, S1-11 and S1-15 (pages 141-142). Marked "Not material": G1-2 and G1-6 (page 143). E2, E4 and S3 do not appear in the index; the report states that pollution (E2) and biodiversity (E4) are not material (page 57).

Transitional provisions under Commission Delegated Regulation (EU) 2025/1416 are applied to ESRS 2, SBM-3, 48(e), E1-9, E3-5, E5-6, S1-11 and S1-15 (page 51).

One datapoint is excluded as not material: water storage (E3-4, 28d). No metrics are reported for the entity-specific topic health equity (page 59).

Pages 144-148 list the datapoints derived from other EU legislation (ESRS 2, Appendix B), each with a "Not material" flag or a page reference. Page 139 maps the core due diligence elements and page 140 lists incorporations by reference.

Transition plan for climate change mitigation

Reference: page 79 (Technical guidance on specific reporting requirements); targets on pages 75-77.

The report states that no transition plan is in place: "No transition plan is currently in place. We plan to evaluate the need to formalize our climate actions as part of a transition plan in the medium-term" (page 79).

What it discloses instead:

• A climate action plan built on four decarbonization levers: energy efficiency, alternatives to fossil fuel energy carriers, renewable electricity, and scope 3 reduction (page 73).
• SBTi-validated targets: net-zero across the value chain by 2050, and a 50% cut in combined scope 1 and market-based scope 2 emissions by 2030 from 2020. A 90% cut by 2040 is not externally validated (page 76).
• No significant capex or opex for the described actions in 2025, and no capex expected for short-term scope 3 measures because suppliers carry most of the actions (page 79).
• No sector-specific SBTi decarbonization pathway applies to the business (page 79).

The datapoint table marks E1-1 paragraphs 14 (climate neutrality by 2050) and 16(g) (exclusion from EU Paris benchmarks) "Not material" (page 144).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 59-60). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A climate scenario analysis was done in 2024 following TCFD recommendations and "updated the analysis in 2025 to incorporate recent business developments" (page 59). The physical analysis covers own operations; the transition analysis extends to the upstream and downstream value chain (page 59).

Physical risk (page 59): IPCC RCP8.5 high-emission scenario, a world more than 4°C warmer by the end of the century. Chronic risks (water stress, heat stress, drought, sea level rise, precipitation) and acute risks (floods, storms, wildfires, landslides, tornados) were assessed for care centers and production sites to 2030 and 2050. Table 2.22 (page 60) lists each hazard. Water stress, drought and heat stress had the highest impact (pages 59-60).

Transition risk (page 60): net-zero 1.5°C and NDC scenarios to 2040, built on IPCC, IEA and NGFS scenarios. Three relevant risks: rising CO2e prices, rising supply chain costs, and the effect of the circular economy on the business model.

The report acknowledges "potential limitations and uncertainties of our current transition scenario analysis" (page 60).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 72-73, with the scenario basis on pages 59-60). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A resilience analysis was done in 2024 and reviewed in 2025 with updates from the climate scenario analysis (page 72). Time horizons are short-term under 1 year, medium-term 1-5 years and long-term over 5 years, matched to corporate risk management and asset lifetimes. The analysis covers all operations (pages 72-73).

Conclusion (page 73): "overall, our strategy and business model are resilient to climate change". No material climate or transition risks or opportunities were found for the short or medium term under the physical scenario to 2050 and the transition scenario to 2040. Some locations may see limited long-term local impacts, such as water stress.

Capacity to adapt (pages 59, 73): the company expects to keep access to financing, flexibility in deploying assets, adaptable products and services, and workforce skills for the transition. It says this rests on professional judgment.

Uncertainty (page 73): "uncertainties in assessing the long-term impacts of climate scenarios and resilience beyond a ten-year horizon", notably policy, regulation and CO2e pricing.

Policies related to climate change mitigation and adaptation

Reference: pages 70-71 (Environmental management) and page 73 (Climate change).

Climate is covered by the Global Environmental Policy. The Management Board approves it and it applies to all employees and the whole company in every geography (page 70). Under "Climate change and energy" the company commits to assess environmental risks and develop mitigation and adaptation strategies, including energy efficiency and renewable energy deployment (page 71). The policy covers all material IROs and indirectly addresses the value chain (page 71).

Supporting pieces:

• The Global Code of Conduct for Business Partners sets emissions-related standards for suppliers (page 71).
• Internal environmental standards and certifications to ISO 14001 and ISO 50001 (page 71).
• The Global Sustainability department develops and oversees the global climate strategy on the Management Board's mandate (page 70).
• Environmental data controls sit in the Internal Control System (page 70).
• More than 90 environmental measures were completed at production sites in 2025 under the Green & Lean initiative (page 70).

Actions and resources in relation to climate change policies

Reference: pages 73-74; expenditure on page 79.

The climate action plan has four levers: energy efficiency, alternatives to fossil fuel, renewable electricity and scope 3 reduction (page 73).

• Energy efficiency (page 73): 2025 projects at production sites are expected to save about 39,000 MWh a year (over 2% of site energy) and avoid about 9,400 tCO2e a year.
• Fossil fuels (page 74): about 80% of scope 1 emissions come from natural gas and LPG; eight sites use around 98% of site natural gas and St. Wendel over 40%. Alternatives at the largest sites were evaluated in 2025, and an initial set of clinics was picked for heat pumps.
• Renewable electricity (page 74): five virtual PPAs with 10 to 15 year terms fed 529.3 GWh into the grid in 2025 (2024: 27.2 GWh), about 41% of grid electricity, cutting market-based scope 2 by 185,300 tCO2e.
• Scope 3 (page 74): a supplier engagement program; suppliers covering 11% of emissions in three categories had set SBTi targets by the end of 2025.

Resources: "no significant capex or opex spending related to the described actions" in 2025 (page 79). The company calls climate projects labor-intensive and says future success depends on resources being available (page 72).

Targets related to climate change mitigation and adaptation

Reference: pages 75-77; methodology on page 79.

SBTi validated the near-term and long-term scope 1, 2 and 3 targets in 2025 (pages 76, 79).

• 2030 (SBTi-validated): cut combined scope 1 and market-based scope 2 emissions by 50% (457,866 tCO2e) from the 2020 base of 915,732 tCO2e. 2025 stood at 649,608 tCO2e, over 29% below base (page 76).
• Scope 3 near-term: cut emissions in three categories (3.3, 3.6, 3.11) by 25% from the 2024 base; those categories were up about 3% in 2025. A supplier engagement target has suppliers covering 70% of emissions in categories 3.1, 3.2 and 3.4 setting science-based targets; 11% reached so far (pages 76-77).
• 2040: 90% cut in scope 1 and 2 versus 2020, not externally validated (page 76).
• 2050: net-zero across the value chain, SBTi-validated, meaning 90% cuts in scope 1 and 2 versus 2020 and in scope 3 versus 2024 (page 76).

Near-term scope 1 and 2 targets and all long-term targets follow SBTi's 1.5°C scenario. The near-term scope 3 target follows a "well-below 2°C" scenario; a 1.5°C scenario would need a 42% cut by 2030 (page 79).

Energy consumption and mix

Reference: page 77 (tables 2.30 and 2.31); methodology on page 80 (table 2.35); intensity on page 79.

Total energy consumption: 2,991,160 MWh in 2025 (2024: 2,962,975 MWh). Fossil share 78% (2024: 81%); renewable share 18% (2024: 15%) (page 77).

Own energy production was 148,728 MWh, of which 1,660 MWh renewable (solar at three plants and 24 clinics). The 2025 boundary was widened to include Japan, U.S. training centers and logistics centers (page 77). Care Enablement counts as a high climate impact sector; its energy intensity was 0.00021029 MWh per euro of net revenue (page 79).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 78 (table 2.32); category shares on page 75; methodology on pages 81-82; intensity on page 79.

Scope 1 rose 1.2% and market-based scope 2 fell 12.9% in 2025 (page 78). Scope 3 covers nine of 15 categories. The largest are purchased goods and services (39.9% of total emissions) and use of sold products (23.3%) (page 75). Primary supplier data covers 0% of scope 3, and categories 3.1, 3.2, 3.4 and 3.6 are spend-based (pages 78, 81).

Intensity: 0.00020 tCO2e per euro of net revenue location-based and 0.00019 market-based, on revenue of €19,628 M (page 79). The 2024 spend-based figures for categories 3.1, 3.2 and 3.4 were restated (page 78).

Internal carbon pricing

Reference: page 79 (Technical guidance on specific reporting requirements). The content index lists E1-8 under the Climate change chapter (page 141).

The company reports that it has no internal carbon price: "We do not currently use an internal carbon pricing scheme due to its significant bureaucratic complexity and the challenge of establishing an effective incentive structure" (page 79).

Carbon prices appear in the scenario analysis rather than as an internal price. The transition analysis assessed "a range of CO2e prices based on different net-zero and NDC scenarios until 2030 and 2040", and rising CO2e prices are one of three relevant transition risks, particularly if applied to scope 3 emissions (page 60).

Policies related to water and marine resources

Reference: pages 70-71 (Environmental management) and page 83 (Water). Datapoints E3-1, paragraphs 9 and 13, are on pages 84 and 70-71 (page 145).

Water is covered by the Global Environmental Policy. The company commits to using water efficiently, minimizing water-related adverse impacts and assessing risks and mitigation, and to managing water across the value chain, including use and sourcing, treatment, and prevention and abatement of pollution (page 71). The report adds that, while its water actions focus on areas at water risk, "our policy does not explicitly mention our stated commitment to reducing water withdrawal" (page 71).

A global water strategy, which the Management Board is responsible for implementing, covers awareness activities, practice sharing, internal guidance and key action areas. It focuses on sites most likely to face water stress (page 83). For Care Delivery it aims to improve the water footprint of care centers in areas of extreme water stress; for Care Enablement it supports Green and Lean projects at production sites (page 83).

The E3-1 datapoint on sustainable oceans and seas (paragraph 14) is marked "Not material" (page 146).

Actions and resources related to water and marine resources

Reference: pages 83-84.

Water projects completed at production sites in 2025 are expected to save more than 128,000 m3 a year, about 2% of site water withdrawal (page 83). Examples: wastewater now tops up the cooling towers at Changshu (China); reverse osmosis brine is reused in manufacturing at Guadalajara (Mexico); water is reused to rinse the cooling towers at L'Arbresle (France) (page 83).

In Care Delivery the focus is U.S. clinics. An initiative at nearly all facilities cuts the carbon filter backwash from three times a week to once. The aim is to apply it at about 50% of U.S. clinics by 2026, with potential savings of 230,000 m3 a year (page 83).

Water stress assessments covered all dialysis clinics and production sites: 10% of clinics (2024: 11%) and 9% of production sites (2024: 11%) are in areas of extremely high water stress. The analysis was extended to climate scenarios for 2030 and 2050 and feeds group-wide risk management (pages 83-84).

Resources: the action plan "does not require significant investments, nor does it generate significant costs or leads to relevant cost savings" (page 83).

Targets related to water and marine resources

Reference: page 84.

The company has "not established quantified water targets" at present and plans to add them to its water strategy later. The stated goal is qualitative: develop water action plans by 2026 that set targets for production sites and dialysis clinics located in areas of extremely high water stress (page 84). The wider aim is to reduce the water footprint and put in place measures that improve water efficiency (page 84).

Effectiveness of policies and actions is judged against this qualitative goal. Status of the action plans is reviewed regularly with stakeholders and management to confirm the company is on track for 2026 (page 84).

No withdrawal or consumption reduction figure is set as a target. The 2025 production-site projects (expected savings of more than 128,000 m3 a year) are reported as actions, not targets (page 83).

Water consumption

Reference: page 84 (table 2.39); methodology on page 85 (table 2.40).

Consumption is reported for production sites only (withdrawal minus discharge); for clinics the company treats water in as equal to water out (page 84). Reuse figures are extrapolated from the largest plants (at least 80% of withdrawal) and from reverse osmosis system data, and can exceed 100% of withdrawal because some water cycles repeatedly (pages 84-85). Water storage (E3-4, 28d) is excluded as not material (page 59).

Policies related to resource use and circular economy

Reference: pages 70-71 (Environmental management) and page 87 (Resource use and circular economy).

The Global Environmental Policy sets principles, objectives and minimum standards for environmental protection, including resource use and waste (page 71). The company plans to update it in 2026 to add its circular economy approach, with plans to reduce reliance on primary raw materials where possible and reinforce sustainable sourcing (page 71).

The global circular economy framework (page 87, chart 2.42) has four focus areas:

• Product design: specifications that consider circularity while keeping performance, patient safety and regulatory compliance; wider portfolio and packaging assessments are planned.
• Material use: analyze the materials in products and packaging and work with suppliers to cut reliance on primary raw materials.
• Product end-of-life: improve recovery, reuse and recycling of selected products with suppliers, waste collectors and research institutes.
• Waste management: reduce landfill and improve segregation at source; waste is currently managed regionally or locally.

The Global Code of Conduct for Business Partners covers suppliers' resource use, waste management and handling of hazardous substances (page 71). Disposables and some packaging "are currently not designed for circularity" because of regulatory requirements (page 87).

Actions and resources related to resource use and circular economy

Reference: page 88.

• Product design: a global sustainable product development guideline was written in 2025 to set requirements for reducing environmental impact across the product life cycle. It will apply to new products and redesigns. The company joined the European ENKORE eco-healthcare project on circular and safe single-use devices and sustainable packaging, which runs 48 months to December 2028.
• End-of-life: a project to explore recycling of dialysis machines in U.S. care centers began in 2025 and continues in 2026. A reuse program for blue acid concentrate drums reused more than 900 metric tons of drums in 2025.
• Waste: a U.S. waste reduction program is being rolled out, with a guide written in 2025 and teams at 17 care centers trained; implementation continues in 2026. A pilot to improve non-hazardous waste reporting, mainly for care centers outside the U.S. where figures relied on estimates and public data, ran in selected countries in 2025 and is designed to give better data by 2026.

Targets related to resource use and circular economy

Reference: page 88.

Since 2024 the company has set local internal waste management targets at all manufacturing sites, aiming to raise recovery rates by 0.5% to 3% a year. The targets favor diverting waste from landfill and incineration, in line with the recycling tier of the waste hierarchy (page 88).

Each site is judged by comparing its recycling and recovery data with the prior year. In 2025 the average recovery rate improved globally by 1.4% (page 88). Care Enablement management approves the targets and an environmental representative at each manufacturing site oversees them (page 88).

For the circular economy strategy the company defined workstreams with yearly deliverables, discussed within each workstream and reported to the Steering Committee. Next year's deliverables follow from what was met (page 88).

The targets described are local site waste targets and workstream deliverables. The report gives no group-wide quantified circularity target.

Resource inflows

Reference: pages 86 and 88 (table 2.43); methodology on page 90 (table 2.47).

Resource inflows are mainly raw materials for dialysis machines and disposables. Key materials are plastics, chemicals and (semi-)manufactured parts such as electronic components from third parties, plus third-party products used to deliver services (page 86).

Method (pages 88, 90): material weights come from life cycle assessment data multiplied by production volume; for services the weights of major purchased products are estimated from reference values. The 2024 figures were updated to match a new metric. The company flags a related risk: replacing certain raw materials at reasonable cost is hard because of strict medical technology rules (page 86).

Resource outflows

Reference: pages 86-89 (tables 2.44 to 2.46).

The product portfolio is machines, disposables and fluids for dialysis therapies (page 86). A significant share of products are single-use plastic items with limited recyclability, often because of blood contamination or mixed plastics (page 86). Disposables used in patient treatment are blood-contaminated, count as hazardous waste and are not recycled (page 87).

• Durability: an internal study of field data puts dialysis machine durability at about 10 years; it has not been externally validated (page 87). Machines are built so that wear parts such as valves, detectors and rotors can be replaced (page 87).
• Recyclable content (page 88, table 2.44): machines 24% (2024: 24%) and packaging 79% (2024: 79%), weighted by production volume. Only machines are assessed for recyclable content because other products are blood-contaminated or consumed in use.
• Reuse: more than 900 metric tons of acid concentrate drums reused in the U.S. in 2025 (page 88).

Waste amounts are under the Waste disclosure (page 89). The datapoints on non-recycled waste (paragraph 37(d)) and hazardous and radioactive waste (paragraph 39) point to page 89 (page 146).

Waste

Reference: pages 89-90 (tables 2.45 and 2.46); methodology on page 90 (table 2.47).

Total waste: 185,315 tonnes in 2025 (2024: 199,407).

The non-recycled share is 69% (2024: 70%). No radioactive waste was generated (page 89).

By treatment (page 89): hazardous waste diverted from disposal 501 t, directed to disposal 48,882 t (incineration 12,549 t, landfill 35,397 t, other 937 t); non-hazardous waste diverted 62,963 t, directed to disposal 72,969 t. Footnote 2 says waste was reclassified into specific disposal categories in 2025, which shrank "Other disposal operations".

Care Delivery data come from supplier reports and internal systems; where primary data are missing the company extrapolates, and an internal study assumes non-hazardous waste in in-center clinics equals blood-contaminated waste (pages 89-90). Most waste stems from patient care (page 86).

Policies related to own workforce

Reference: pages 115, 117, 121-122, 124-125 and 129. The datapoint table points S1-1 paragraphs 20 to 22 to pages 124-125 and paragraph 23 to page 122 (page 146).

Policies named in the chapter:

• Global Employee Value Proposition Policy and Voice of the Employee and Engagement Policy (page 115).
• Global Social and Labor Standards Policy: minimum standards on non-discrimination, non-harassment, workplace safety, freedom of association, collective bargaining, child and forced labor, non-retaliation and working time, guided by the Universal Declaration of Human Rights and the ILO Declaration (page 117).
• Global Prohibition of Discrimination, Harassment, Sexual Harassment, and Bullying Policy and the Fair Pay Statement (page 117).
• Development Conversations and Development Policy (page 121).
• Global Occupational Health and Safety Policy, which covers contractors too (page 122).
• Human Rights Statement and the Code of Ethics and Business Conduct (pages 124-125).
• Global Privacy Principles (page 129).

The Management Board member responsible for Legal, Compliance and Human Resources oversees the HR policies (pages 115, 117).

Taking action on material impacts on own workforce

Reference: pages 115-118, 121-123 and 130-131.

• Hiring and retention (page 115): a central team for hiring in key U.S. growth markets; talent acquisition exceeded planned hiring demand; engagement check-ins for patient care employees, with higher retention among nurses and patient care technicians who took part; exit surveys.
• Pay structure (page 117): a project to restructure the global job architecture, due for implementation in 2026.
• Working time and discrimination (page 118): local impact assessments, training and policy education for leaders. Nine countries were assessed in 2025, 36 in total, with all to be done by 2030.
• Equal treatment (page 121): an international cultural competency program (about 7,000 enrolled), 16 employee resource groups (about 5,300 participants) and a global mentoring program.
• Learning (page 121): the global learning platform The University and a first global learning month.
• Safety (pages 122-123): annual health and safety training, OHS software in North America and at global production sites, and de-escalation training in Asia-Pacific.
• Data (pages 130-131): privacy and security training, with more than 75,000 employees trained in 2025.

Targets related to own workforce

Reference: pages 116, 118, 121 and 123.

• Engagement: a global employee engagement score of at least 68% by 2027. The score was 66% in 2025 (2024: 63%). The 68% figure replaced a 63% target when the survey provider changed (pages 116-117).
• Gender balance: by the end of 2027, 35% women at the first management level below the Management Board and 45% at the second, for managers employed by Fresenius Medical Care AG. On December 31, 2025 the shares were 33% and 41% (pages 121-122). Earlier targets on women in management globally and on ethnically diverse managers in the U.S. were discontinued (page 121).
• Working conditions: no global targets, because locally run processes have not been consolidated globally at a level that supports them (page 118). The company aims to finish country-level assessments by 2030 (page 118).
• Occupational health and safety: no global targets yet; they are planned over the medium term in an OHS roadmap (page 123).

Characteristics of the undertaking's employees

Reference: pages 109-112 (tables 2.57 to 2.64); turnover on page 118.

At the end of 2025 the company employed 115,400 people including non-guaranteed hours workers. Headcount excluding them was 109,698 and FTE was 101,350 (page 111). The report puts permanent staff at 93%, temporary at 2% and non-guaranteed hours at 5% (page 109).

By gender: 80,428 female (70%), 34,808 male (30%), 19 other and 254 not disclosed (page 111). Care Delivery is 70% of staff and Care Enablement 23% (page 110).

Top countries: U.S. 64,815 (56%), Germany 7,909 (7%), Mexico 7,220 (6%) (page 111). By region, North America has 72,176 employees and Europe, Middle East and Africa 27,307 (page 112).

Turnover (page 118): total rate 20.7% (2024: 21.2%), 24,016 exits, voluntary rate 15.5%.

The fall in headcount comes mainly from planned divestitures of Care Delivery operations in Brazil and of Spectra Laboratories in the U.S. Totals can differ slightly between the financial and HR systems (page 110).

Characteristics of non-employee workers in the undertaking's own workforce

Reference: page 111 (table 2.59); description on page 109.

The company reports 4,574 non-employees in 2025 (page 111). It describes them as self-employed individuals and contractors, including people engaged through third parties such as temporary agency workers who support the workforce at certain locations during the year (page 109). The table has a 2025 column only, so there is no prior-year comparison.

Working-conditions principles apply to non-employees "where legally possible" (page 113), and the occupational health and safety policy covers contractors (page 122). The report gives the total only, with no split by type, region or gender.

Collective bargaining coverage and social dialogue

Reference: page 119 (tables 2.68A and 2.68B); dialogue on pages 114-115.

Global collective bargaining coverage was 19% in 2025 (2024: 21%) and global workplace representation was 17% (2024: 17%) (page 119).

The report breaks coverage down by region outside the EEA and for the EEA as a whole, in bands from 0-19% to 80-100%. It does this because "there is no country" in the EEA where it has significant employment, defined as more than 50 employees representing over 10% of the total (page 119). Data are collected annually as of December 31 by Global Human Resources with an HR representative in each region and country (page 119).

The company respects freedom of association and effective collective bargaining under local law, and works with works councils, unions and other representative groups (pages 114-115).

Diversity metrics

Reference: pages 121-122 (tables 2.72 and 2.73).

Management Board: 6 members, 33% female and 67% male. Supervisory Board: 50% women, six of twelve members (pages 64-65, 122).

Senior levels in Fresenius Medical Care AG: 33% women at the first level below the Management Board and 41% at the second on December 31, 2025, against targets of 35% and 45% by the end of 2027 (pages 121-122).

Age profile (page 122): average age 44 (2024: 44); under 30, 15% (2024: 14%); between 30 and 50, 53% (54%); over 50, 33% (32%).

Women are 70% of the global workforce and 78% in Care Delivery (page 120).

Adequate wages

Reference: page 120 (table 2.69); pay approach on pages 117-118.

In 2025, 99.99% of employees earned at least the relevant living wage benchmark (2024: 99.96%). Benchmark data came from the WageIndicator Foundation. Adequate wages are defined as wages "sufficient to cover the costs of all essentials in line with national or sub-national economic and social conditions" (page 120).

Deviations occurred in the countries and regions listed in table 2.69, which names Kyrgyzstan, Bosnia & Herzegovina, Taiwan, Poland, Ukraine, Kazakhstan, Thailand and Czechia, each with the share of employees below the benchmark (page 120).

Pay is set from market and benchmark data, internal equity, role, location, experience and performance, with regular pay audits (page 118). Compensation "considers local market practices, including living wages" (page 117).

Persons with disabilities

Reference: page 122 (table 2.75).

6% of employees were reported as having disabilities in 2025. The table has a 2025 column only, so there is no prior-year comparison (page 122).

The Global Prohibition of Discrimination, Harassment, Sexual Harassment, and Bullying Policy lists disability among the protected grounds (page 117). The workforce targets described in the chapter cover engagement and gender balance (pages 116, 121).

Training and skills development metrics

Reference: page 122 (table 2.74); approach on page 121.

Average training: 64 hours per employee in 2025: 52 for men, 69 for women, 210 for people of other gender and 11 for those with no gender recorded. Hours cover online learning, time management systems and documented classroom training for the active population at December 31, 2025 (page 122).

Performance and career reviews: 72% of employees took part (men 67%, women 75%, other 79%, not disclosed 4%). Excluding employees the Management Board does not expect to take part, the rate is 86%. New hires after October 1, 2024 were not eligible (page 122).

Development runs through the Development Conversations and Development Policy, the learning platform The University, and a 360-degree feedback process in countries where it is offered. The performance module is not used in Germany (page 121).

Health and safety metrics

Reference: page 123 (table 2.76); policy and actions on pages 122-123.

Scope: OHS reporting covers 95% of operations, and about 74% of that scope is captured through the global OHS software (page 123). The company has set no global targets and plans to do so over the medium term (page 123). "Heightened or aggressive behavior toward staff" is described as a recognized challenge in clinical settings, and verbal assault data are collected in some countries (page 123).

Compensation metrics (pay gap and total compensation)

Reference: page 120 (tables 2.70 and 2.71).

The gender pay gap is the difference between average pay of female and male employees as a percentage of male average pay. The 2025 figure "is based on improved data availability". The company explains that many women hold lower-paying roles such as nurses and patient care technicians; women are 70% of the workforce and 78% in Care Delivery (page 120).

The highest-paid individual is the CEO. The 2024 ratio was adjusted from 1:75 to 1:94 for improved data availability (page 120). Fixed pay uses annualized HR system data, incentives use actual 2025 payments, and other pay elements are extrapolated for November and December (page 120). CEO and Management Board pay detail is in the Compensation report (page 120).

Incidents, complaints and severe human rights impacts

Reference: page 120 (table 2.70); human rights statement on page 124.

Data come from the global Compliance Action Line system and other tracking tools; severity follows the ESRS definitions (page 120). The company says there were no recorded cases of non-respect of the UN Guiding Principles, the ILO Declaration or the OECD Guidelines (page 124). Figures are aggregated to protect confidentiality and the company states they should not be read as an admission of any legal violation (page 120).

Policies related to value chain workers

Reference: pages 126-127; human rights commitments on pages 124-125. Datapoints S2-1 paragraphs 17 to 19 are on pages 124-127 (page 147).

The Global Code of Conduct for Business Partners replaced the Global Supplier Code of Conduct in 2025. It is binding in supplier contracts, applied across all procurement processes, published on the website and based on ILO standards. Suppliers are expected to monitor their own sub-contractors. It covers compliance and ethics, human rights and working conditions (in particular the ban on forced and child labor and human trafficking), health and safety, environmental protection, quality and governance (page 127).

Related policies: the Conflict Minerals Policy Statement (guided by OECD due diligence guidance and Section 1502 of the Dodd-Frank Act), the Global Third Party Spend Policy, the Code of Ethics and Business Conduct and the Human Rights Statement (pages 125, 127). They are guided by the UN Universal Declaration of Human Rights, the ILO Declaration, the UN Guiding Principles, the OECD Guidelines and the European Green Public Procurement Guidelines. The Management Board or its members oversee them (page 127).

Taking action on material impacts on value chain workers

Reference: pages 127-128; small supplier data on page 126; human rights due diligence on page 124.

• Supplier risk assessment: annual ESG assessments of suppliers worldwide. In 2025 the company began working with EcoVadis and, in the first step, assessed inherent risk for suppliers covering 73% of total spend (page 127).
• Medical gloves: the company continued a value chain analysis of medical gloves, a sector associated with labor and human rights concerns. It interviewed selected suppliers, found "No concrete risks", and set a sourcing strategy to centralize supply and cut the number of suppliers (pages 127-128).
• Training: procurement staff were trained on supplier ESG assessments, conflict minerals and EU Deforestation Regulation compliance. All Legal, Compliance and Procurement staff took mandatory training on the new Code of Conduct for Business Partners, and teams in Canada and Australia were trained on forced and child labor rules (page 128).
• Small suppliers: about 1,400 small and minority-owned U.S. suppliers, with spend of around $255 M (EUR 213 M) (page 126).

The company did not identify negative impacts or concrete risks of forced or child labor in its own operations or value chain in 2025 (page 124).

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

Reference: page 128.

Target: by the end of 2026, assess suppliers for inherent risk covering 85% of total spend through the EcoVadis platform, with 2025 as the base year. The scope includes all previously identified high-risk suppliers and suppliers critical to the business. In 2025 suppliers covering 73% of total spend were assessed (page 128).

The company says it is moving to a new supplier engagement platform. Its focus is on better risk identification and mitigation, working with suppliers on sustainability initiatives, improving data and raising supplier response rates to its risk assessments (page 128). The target covers how much spend is screened for risk; the report states no target on worker outcomes.

Policies related to consumers and end-users

Reference: pages 97, 99-100, 102, 125 and 129-130. For S4 the company defines "consumers" and "end-users" as its patients (page 95).

• Patient care (page 97): the Global Patient Care Policy was updated in 2025 and renamed Global Policy: Patient Experience, Patient Grievances, Quality Data. Patient rights sit in the Code of Ethics and Business Conduct and the Human Rights Statement, with staff training on informed consent, patient rights, data protection and the right to raise concerns.
• Healthcare professionals and patient groups (page 97): the global HCP Policy and the Compliance Policy on Interactions with Patients, Patient Caregivers, and Patient Organizations, both overseen by Compliance.
• Health equity (page 100): the Company Position Statement on Health Equity, with the Management Board responsible.
• Products (page 102): the Global Product Business Policy sets safety and quality standards from development to complaint handling and is overseen by the CEO of Care Enablement.
• Data (page 129): Global Privacy Principles and the Global Information Security Policy.

Human rights commitments for patients are in the chapter "Human rights"; the Patient Rights and Responsibilities Policies are named there (page 125).

Taking action on material impacts on consumers and end-users

Reference: pages 97-101 (Patients), 102-105 (Product stewardship) and 130-131 (Protecting data).

• Access and care (page 97): standardized admission checklists in the U.S., a Continuity of Care team, support for five online home dialysis classes, and the start of high-volume hemodiafiltration. About 62,000 referrals went to U.S. transplant centers in 2025 (2024: more than 64,000).
• Safety and quality (page 98): a "commitment to safety" program in the U.S., quality improvement training, a new EMEA quality dashboard, more than 30 AI and analytics tools, and a global disaster response team.
• Health equity (pages 100-101): a Health Equity Strategic Plan across more than 2,600 U.S. centers, screening for health-related social needs, and food security screening of over 175,000 patients.
• Products (pages 102-104): internal and external quality audits, a quality enhancement program, post-market surveillance, and supplier quality audits every one, three or five years by risk. In 2025 there were 5 U.S. recalls of drugs and devices (2024: 10) (page 104).
• Data (pages 130-131): security based on the NIST Cyber Security Framework, ISO 27001 certification of selected systems, and training of more than 75,000 employees in 2025.

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

Reference: pages 98, 100-101, 103 and 105; data protection on page 131.

Quality indicators are tracked without a fixed target: the quality index was 80 (2024: 81) and the hospitalization rate 9.6 days per patient a year (9.6). Performance is reviewed quarterly and a 2% deviation triggers investigation (page 98).

Not set: global health equity targets (page 101); quantitative cybersecurity and privacy targets, because the company treats them as risk-based rather than outcome-based (page 131); management targets for research (page 107).

Business conduct policies and corporate culture

Reference: pages 133-135; animal welfare commitments on page 106. Datapoints G1-1 paragraph 10(b) (United Nations Convention against Corruption) point to page 136 and 10(d) (protection of whistle-blowers) to page 134 (page 148).

The compliance program rests on the Code of Ethics and Business Conduct, a binding framework for dealings with patients, colleagues, business partners and government officials. It covers patient care, quality, anti-corruption, health and safety, data privacy, supplier selection, whistle-blower protection, fair competition, political activities and human rights (pages 134-135).

Supporting policies: the Anti-Bribery and Anti-Corruption Policy (bans bribery, facilitation payments and gifts meant to improperly influence anyone), the Non-Retaliation Policy and the Public Tender Policy. The Management Board approves the compliance policies, which apply to employees, contract workers and relevant third parties worldwide (page 135).

The Chief Compliance Officer leads the program, supported by more than 150 compliance professionals. Compliance and Legal report to the Management Board member responsible for Legal, Compliance and Human Resources (page 133).

Animal welfare commitments sit in the new 2025 policy on Ethical Conduct in Pre-clinical and Clinical Research, built on the 3R principles (page 106).

Targets related to business conduct

Back-filled from the business conduct chapter. G1-3 became a standalone disclosure requirement only in the 2025/2026 ESRS, and this report was prepared under the 2023 ESRS.

Reference: pages 136 and 138.

Compliance training: "an annual target to train 90% of our global employees on our Code of Ethics and Business Conduct". In 2025 the company trained 90% (2024: 33%). The 2024 shortfall came from a move to a new global training system that pushed training into 2025 (page 136). In 2025, 103,350 employees took part, plus 6 Management Board and 4 Supervisory Board members (page 136).

Lobbying: "We do not set specific targets". Effectiveness is judged through outcomes of meetings with policymakers, association work, position papers and consultation input, and, in the U.S., over each two-year congressional cycle (page 138).

Convictions and fines for anti-corruption and anti-bribery violations are tracked as metrics and were zero in 2025 (page 136).

Incidents of corruption or bribery

Reference: page 136 (table 2.82); policy and process on page 134.

In 2025 there were no convictions for violations of anti-corruption or anti-bribery laws and no fines were paid (2024: none for both) (pages 134, 136).

The company received 3,303 reports through its reporting channels in 2025 (2024: 2,835) (page 136). It notes that the channels also receive reports unrelated to compliance, such as patient care, information security, supply chain or HR matters, which are passed to the right department (page 134). Cases involving senior executives are reported to the Management Board (page 134).

Political influence and lobbying activities

Reference: pages 137-138 (table 2.85).

The company lobbies on health insurance coverage, pricing and reimbursement, and drug and device policy. Lobbying in Germany is registered in the Lobbyregister Deutscher Bundestag (R001098) (page 137). In the U.S., political contributions must follow federal, state and local campaign finance law, and employees can give through the employee-funded Political Action Committee FRE-PAC, which reports monthly to the Federal Election Commission (page 137). Outside the U.S. the company makes no financial or in-kind contributions to parties, elected representatives or candidates (page 137). It made no in-kind political contributions in 2025 (page 138).

Contributions in 2025 in EUR (2024 in brackets). Direct corporate: parties 40,851 (67,379); candidates and campaigns 233,893 (362,885); committees 96,936 (141,881). Through FRE-PAC: parties 102,127 (115,507); candidates and campaigns 140,425 (125,614); committees 51,915 (53,422). Several 2024 values were corrected for earlier calculation errors (page 138).

Management Board members for Care Delivery and Care Enablement oversee lobbying (page 137).