Fresenius

Reference: page 159.

Management sits with the general partner Fresenius Management SE, whose Management Board has five members. The Supervisory Board of Fresenius SE & Co. KGaA has 12 members, 6 shareholder and 6 employee representatives (page 159). Women hold 20% of Management Board seats and 33% of Supervisory Board seats (page 160). The company counts 50% of the Supervisory Board as independent if employee representatives are viewed as non-independent (page 160).

Sustainability is anchored with one Management Board member, who also holds Legal Affairs, Compliance, Risk Management, Human Resources (Labor Director), Corporate Audit and Vamed; in 2025 this was Dr. Michael Moser (page 161). The five-member Audit Committee pre-audited the Sustainability Report, and Dr. Zindel was appointed as its ESG expert (page 161).

The Group Sustainability function acts as "a center of expertise for all sustainability aspects within the Group" (page 162). Sustainability risks run through the Group risk catalogs; the Management Board receives quarterly risk reporting, the Audit Committee is informed "bi-annually" and the Supervisory Board "two times a year" (page 162).

Reference: page 164.

In 2025 Fresenius set up a Group Sustainability Committee, chaired by the Sustainability Board member, to decide on the strategic and substantive design of the Sustainability Framework; it first met in November 2025. It replaces the ESG Steering Committee, whose regular meetings are not planned to continue (page 164).

The Head of Group Sustainability informs the Sustainability Board member bi-weekly, and the Audit Committee at least once a year (page 164). Through risk reporting, the Management Board is informed quarterly, the Audit Committee "bi-annually" and the Supervisory Board "two times a year" (page 162). The Audit Committee received CSRD reporting updates on October 15 and December 3, 2025, and in December discussed the update of the double materiality analysis and the revised IROs (page 163).

The Supervisory Board's 2025 agenda included the #FutureFresenius transformation, restructuring and divestment at Fresenius Vamed, IT transformation programs and cybersecurity (page 164). An External Sustainability Advisory Board of four experts advises the Sustainability Board member (page 164).

Reference: page 165.

ESG targets carry 15% weight in the Management Board's short-term variable compensation (one-year measurement), focused on medical quality and employees. In the long-term variable compensation (four-year measurement), ESG criteria account for 25% of target achievement and are measured on CO2e reduction (pages 165-166). The Supervisory Board of Fresenius Management SE approves the compensation system; the Supervisory Board itself gets no variable pay (page 165).

2025 results against target (page 165):

• Audit & Inspection Score (Fresenius Kabi): 0.9 against a 2.3 target, 138.89% achievement
• Inpatient Quality Indicators (Fresenius Helios): Germany 91.9% against 88.0%, Spain 77.4% against 75.0%, 128.38% achievement
• Total Scope 1 and 2 CO2e (market-based): 120.83% achievement
• Employee Engagement Index: 4.14 against 4.33, 85.61% achievement

The report states "not all ESG targets for the members of the Management Board were achieved" (page 166). The flagged indicators carry reasonable assurance (pages 165-166).

Reference: page 166.

The statement on due diligence is a cross-reference table. It maps the five core elements of due diligence to where each appears in the sustainability statement (page 166):

• Integration into governance, strategy and business model: GOV-2 (page 164), GOV-3 (page 165), SBM-3 (page 180)
• Involvement of affected stakeholders in all key steps: GOV-2 (page 164), SBM-2 (page 170)
• Identification and assessment of negative impacts: IRO-1 (page 172) and SBM-3 (page 180)
• Measures to counter negative impacts: MDR-P in each topical standard, plus MDR-A and transition plans
• Tracking effectiveness and communication: MDR-M and MDR-T in each topical standard

The operating detail sits in the human rights chapter (S2, pages 262-268) and the business conduct chapter (G1, pages 311-322).

Reference: page 166.

GOV-5 points back to GOV-1 for the risk management and internal control description. The report says "No new risks were identified in relation to sustainability reporting in the reporting year" and that the processes and controls for sustainability reporting "have been further improved" (page 166).

The internal control system covers financial reporting, quality and patient safety management, cybersecurity, inventory, supply chain management, data protection and sustainability management, documented in one Group-wide framework (page 162). The Group Sustainability function and the Sustainability Accounting department within Group Accounting are responsible for sustainability reporting (page 162). The Corporate Audit function runs independent, risk-oriented audits that include sustainability, cybersecurity and compliance (page 163).

Reference: page 167.

Fresenius is a global healthcare group with two operating companies run by the holding Fresenius SE & Co. KGaA: Fresenius Kabi (therapy and care products for critically and chronically ill patients) and Fresenius Helios (Europe's largest private hospital operator, with Helios in Germany and Helios in Spain). The Corporate / Other segment holds the holding functions, Fresenius Digital Technology and Fresenius Health Services, founded in 2025 (page 167).

Care provision (Helios) is about 60% of revenue and healthcare products (Kabi) about 40% (page 167). The Group is active in more than 60 countries, with more than 50 production sites and more than 130 hospitals (page 169).

The 2025 Sustainability Framework sets nine focus topics across people, environment and ethical foundation; KPIs are due to be defined by the end of 2026 (page 168). Procurement is coordinated centrally in each operating company; Kabi sells through group purchasing organizations in the United States and public tenders internationally (pages 169-170). The ESRS index marks partial use of the phase-in option for SBM-1.40b and c (page 188).

Reference: page 170.

Fresenius engages stakeholders by topic and area. Corporate functions focus on Group-wide groups such as investors and analysts; the operating companies deal with patients, employees, customers and regulators (page 170). Inputs listed include authority contacts, questions at the last Annual General Meeting, quality due diligence findings, ESG rating criteria, employee surveys, works council dialogue and patient and customer surveys (page 171).

Strategic memberships include the AMR Industry Alliance, ENHA, IQM, Medicines for Europe, MedTech Europe, PSCI, UN Global Compact and VCI (page 171). Where stakeholder views point to material impacts, risks or opportunities, they are documented in the internal process and passed to the Management Board and Supervisory Board (page 172).

For the materiality analysis itself, the report says "external stakeholders or affected communities were not directly involved" and internal experts stood in for them (page 173).

Reference: pages 180-185.

The report presents 47 numbered material IROs in a table (pages 184-185). Counts by topic: E1 8 (7 risks, 1 negative impact), E2 2, E3 1, E5 2, S1 10, S2 4, S4 6 and G1 5. A further 9 sit in company-specific topics: Innovation (1), Digital transformation (4) and Cybersecurity (3), plus a supply-chain compliance risk shown under G1 (page 311).

The IROs arise from production and upstream procurement in own operations, and from effects on patients and other consumers and end-users (page 180). Fresenius says no events during the year led to material financial effects from the IROs, and no material adjustment to assets and liabilities is expected next year (page 182).

The 2025 review cut the IRO count: positive impacts were reassessed as remedial measures or reclassified, and the number of positive impacts "now falls below the total number of negative impacts or risks" (page 177). The index marks partial use of the phase-in option for SBM-3.48e (page 188).

Reference: page 172.

Fresenius has run a double materiality assessment since 2023. A full assessment is typically done every three years and the IROs are reviewed annually; a full reassessment will not happen before 2027 (pages 172, 177). Group Sustainability owns the process. Topics were drawn from ESRS 1 AR 16, SASB and CDP requirements (page 173).

Impacts are scored on extent (1 to 4), scope (1 to 4) and irreversibility (1 to 4), with a maximum of 12; positive impacts use extent and scope only. An impact is material when its weighted score exceeds half of the possible total (pages 174-175). Financial materiality multiplies extent by probability, with a maximum of 4, and the cutoff is at least half of that maximum (page 176). IROs were assessed gross, before mitigation (page 174).

Stakeholders were represented by internal experts; "external stakeholders or affected communities were not directly involved" (page 173). The 2025 update removed one S2 positive impact, reclassified a cybersecurity positive impact as a financial risk and merged two E3 negative impacts (page 176). S1-11, G1-2 and G1-6 are no longer reported because no related IRO was material (page 177).

Reference: pages 180, 188-190.

The ESRS index at the end of ESRS 2 lists the reported disclosure requirements with page references (pages 188-190). A second table maps ESRS 2 Appendix B datapoints from other EU legislation to pages, marking non-material ones (pages 186-187).

The index shows "Not material" for E1-8, E2-5, E4 (all of it), S1-11, S3 (all of it), G1-2 and G1-6. It shows use of the phase-in option for E1-9, E2-6, E3-5, E5-6 and S1-15, and partial use for SBM-1.40b and c, SBM-3.48e, S1-7, S1-13 and S1-14 (pages 188-190). Three company-specific topics, Innovation, Digital transformation and Cybersecurity, are indexed through ESRS 2 MDR-P, MDR-A, MDR-T and MDR-M (page 190).

On method: "No thresholds were applied when determining the material information to be disclosed" and a qualitative mapping was done instead (page 180). Note that BP-2 lists S1-7, S1-13 and S1-14 as the phase-in cases (page 158), while the index also marks S1-15.

Reference: page 201.

Fresenius aims for net zero across Scopes 1 to 3 by 2050. For "unavoidable GHG emissions (maximum 10%)" it wants to offset and will evaluate permanent CO2 removal later (page 201). The report says the target is "in line with the scientific goal of the Paris Agreement to limit global warming to 1.5°C" (page 201); it has not been validated by SBTi (page 207).

Four levers: energy efficiency; fuel, technology and process change (biofuels, heat pumps); electrification of the vehicle fleet; and more renewable energy, including self-generated photovoltaic power (page 201). Scope 3 work so far is a supplier hotspot analysis in 2024 and closer supplier engagement in 2025 (page 202).

The Management Board approved the climate target, and management committees approve plan components during budget planning (page 202). The plan forms part of the general business strategy and the overall financial planning (page 202). Scope 1 and 2 emissions are down 33.3% since the 2020 base year (page 202). Locked-in emissions were evaluated, with no figures given, and the company expects no significant change to its path from them (page 202). Fresenius says it is excluded from the "EU reference values agreed in Paris" (page 202).

Reference: pages 177-180.

Back-filled from ESRS 2 IRO-1 (the E1 climate-related scenario analysis section), where this content is disclosed in the FY2025 report (pages 177-180). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk: material locations were analyzed under three IPCC AR6 scenarios, SSP1-2.6 (1.8°C by 2100), SSP2-4.5 (2.7°C) and SSP5-8.5 (4.4°C), so a high-emission scenario and temperature projections are both stated (page 178). Production sites and hospitals were screened by geocoordinates with an external tool for temperature, wind and water hazards. Horizons are short (1 to 3 years), medium (2030) and long (2050) (page 178). Work was led by Group Sustainability with the Insurance department and Risk Management, following TCFD (page 178).

Transition risk: drivers include regulation, the energy industry, society, technology and climate-related investment (page 178). The quantified case is higher greenhouse gas pricing at sites under an emissions trading system, assessed on the IEA Net Zero Emissions by 2050 scenario (page 179). The supply chain was pre-screened with EEIO data, with no detailed value chain assessment (page 179).

Reference: pages 179-180.

Back-filled from ESRS 2 IRO-1 and SBM-3 (the resilience analysis and E1 SBM-3 sections), where this content is disclosed in the FY2025 report (pages 179-180, 200). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Fresenius ran a resilience analysis on its production sites and hospitals across scenarios and horizons in 2024. It covers own operations only, "not conducted for the up- and downstream value chain" because of limited location and adaptation data (page 179). Result: sites and supply chains face physical climate risks, mainly heat stress, water stress and flooding, but "these do not currently require Fresenius to adapt its business model" (page 180).

Uncertainty is stated: the scenario analysis "is inherently subject to uncertainty and does not represent a forecast", and it rests on past climate data (page 180). Adaptation measures named are flood protection, lower water use in water-stressed areas and earthquake emergency plans (page 180). Transition assumptions cover energy efficiency, renewable energy and economic growth (page 179). Fresenius says it has found no business activity inconsistent with a carbon-neutral economy, though investments are needed (page 179).

Reference: page 203.

Climate policy sits in the Group-wide Environmental Policy, which covers climate protection, water, and resources and circular economy and is published on the corporate website. The company says it wants to "go beyond the legal requirements" (page 203). The policy applies to all operating companies, the own workforce and third parties working at Fresenius sites, and sets expectations for business partners (page 203).

The Management Board reviewed and approved the policy; the Sustainability Board member steers Group guidelines and operating company management runs operations (page 203). Environmental management is decentralized, with ISO 14001 as the common base and ISO 50001 for energy; the number of certified sites keeps growing (page 203).

Effectiveness is checked through internal audits and multi-site external certification audits; in 2025 no systematic deviations were identified. Consumption data goes quarterly to the central function, and significant deviations trigger analysis and corrective action (page 204).

Reference: pages 204-206.

Actions cover Fresenius's own operations only (page 204). The resource table gives bands, not exact figures: achieved 2025 reductions were a double-digit percentage of base year emissions; expected 2026 to 2028 reductions are at least a low single-digit percentage a year; CapEx for 2025 to 2028 is a middle double-digit million euro amount and OpEx a low single-digit million euro amount (page 204). The report adds that no significant extra financial or human resources beyond regular budgets were required (page 204).

Renewable energy use was about 905,385 MWh in 2025 (2024: 853,194 MWh), from photovoltaic, biomass, cogeneration and pellet boilers (page 204). Efficiency work included pump and compressor replacement, condensate reuse, insulation and the Helios Germany 100-point energy checklist (page 205).

Fuel and technology changes: Kabi heat pump and steam reduction projects, anesthetic gas replacement in Spain and capture systems in all German intensive care units, with the effect counted from 2026 (page 205). Fleet electrification advanced at Kabi (page 206). Water for Injection production moved to a process using substantially less energy and water at two Kabi sites (page 206).

Reference: pages 206-207.

Group targets (page 206):

• Reduce Scope 1 and 2 emissions 50% in absolute terms (gross) by 2030 against 2020
• Greenhouse gas neutrality in Scope 1 and 2 by 2040, with at least a 90% gross reduction and a maximum of 10% offset through permanent removal
• Net zero across Scopes 1 to 3 by 2050

Scope 2 is calculated market-based. Scope 3 emissions "are not currently covered by the target of greenhouse gas neutrality by 2040" (page 206). Of the reduction to be delivered, about 45.9% sits in Scope 1 and 54.1% in Scope 2 (page 206). The base year value of 708,364 t CO2e was raised by 22,680 t CO2e in 2025 after a methodology change, with the targets unchanged (page 206).

The 2030 target follows SBTi near-term criteria and the SBTi cross-sector pathway, with no sector-specific pathway, and has not been validated by SBTi (page 207). Emissions are reviewed quarterly against base and target year (page 207). Scope 1 and 2 reduction carries a 25% weight in the Management Board's long-term variable pay (page 206).

Reference: page 208.

Total energy consumption was 2,936,900 MWh in 2025, down 5.0% from 3,090,443 MWh in 2024 (page 208). Fossil sources made up 1,962,068 MWh (66.8%), nuclear 69,447 MWh (2.4%) and renewable sources 905,385 MWh (30.8%, up from 27.6%). Gas and electricity were the main sources (page 208).

Energy intensity was 130 MWh per EUR 1 million of net revenue (2024: 134), on revenue of EUR 22,569 million (page 208). For activities in high climate impact sectors, covering Fresenius Kabi's pharmaceutical manufacturing, consumption was 1,733,176 MWh, or 202 MWh per EUR 1 million of Kabi revenue (2024: 206) (page 208).

Some figures are estimates: outpatient clinics, offices, research sites and units without data are extrapolated from per-FTE values collected at Bad Homburg, and Spanish outpatient health centers were extrapolated from energy use per square meter (pages 208-209). Remaining Vamed units are no longer included from 2025 (page 208). A January 2026 power outage at a Berlin hospital will show up in 2026 oil consumption (page 208).

Reference: pages 209-213.

2025 gross emissions (market-based) were 4,258,997 t CO2e (2024: 4,289,740). Scope 1 was 317,448 t (-9.6%), Scope 2 market-based 170,497 t (-9.0%), Scope 2 location-based 405,513 t, and Scope 3 3,771,052 t (+0.5%) (page 209). Total location-based was 4,494,013 t (page 213). Intensity was 189 t CO2e per EUR 1 million of net revenue market-based and 199 location-based (page 209).

Scope 1 and 2 market-based emissions are about 33.3% below the 2020 base year, at 487,945 t CO2e (page 210). Biogenic Scope 1 emissions were 34,870 t CO2e (page 210). Purchased goods and services, the largest Scope 3 category, rose 4.4% to 1,706,509 t; capital goods fell 23.7% to 109,365 t (page 213). 33.0% of Scope 3 is calculated from primary supplier data; categories 1, 2 and 4 use a spend-based method (page 211).

Prior-year totals were restated upward: total market-based by 90,397 t and Scope 3 by 67,934 t, after a methodology change and a corrected calculation error (pages 209, 213). Scope 1 and 2 market-based emissions carry reasonable assurance (page 210).

Reference: pages 206-207.

E1-7 is disclosed within the E1-4 targets section. The answer is nil: "Fresenius does not currently carry out any activities to reduce greenhouse gases via carbon removal, carbon storage, or carbon credits" (page 207).

Future plans are described. Unavoidable emissions of at most 10% are to be neutralized through reduction or removal and storage, within or outside own activities and the value chain, and only after emissions have been cut as far as possible (page 207). Permanent CO2 removal is something the company will evaluate later (page 201).

The renewable-electricity instruments described under E1-6 are guarantees of origin, green electricity tariffs, power purchase agreements and energy attribute certificates used for Scope 2 accounting (pages 205, 210). The report does not call them carbon credits.

Reference: page 214.

Pollution is covered by the Group-wide Environmental Policy, which commits Fresenius to comply with legal guidelines and "threshold limits" at its sites, set procedures to prevent environmental incidents and limit harm if one occurs (page 214). Local regulation and internal guidelines on hazardous substances apply on top, and each operating company runs its own environmental management system (page 214).

The main specific commitment is antibiotic manufacturing. Fresenius Kabi has been a member of the AMR Industry Alliance since 2020, is introducing the Common Antibiotic Manufacturing Framework and the 2022 Antibiotic Manufacturing Standard, and uses a mass balance template to compare wastewater antibiotic concentrations with the Predicted No-Effect Concentrations set by the alliance (page 215). In 2025 Kabi obtained AMR certificates for four antibiotics at three European production sites (page 215).

Sites and clinics must identify and assess environmental impacts, including toxic emissions to air, water or soil; internal audits run every one to four years (page 215). Environmental incidents are reported on a five-level scale (page 216).

Reference: page 216.

The report is plain that no Group measure exists: "In the reporting year, Fresenius did not adopt any central guidelines for measures relating to the prevention of potential environmental pollution" (page 216). Environmental management systems of the operating companies provide the framework, and the focus is on identified risks and on complying with applicable guidelines and limits (page 216).

Concrete pollution measures reported elsewhere in the chapter are antibiotic wastewater control at Kabi production sites, with AMR certificates for four antibiotics in 2025 (page 215), and incident reporting and follow-up, including preventive training after local incidents (page 216).

Reference: page 216.

There is no quantified pollution target: "there is no overarching Group target in connection with potential environmental pollution" (page 216). The stated ambition is to avoid or minimize negative environmental impact, and the goal of the Group and the operating companies is to comply with legal guidelines and threshold limits at the sites, backed by an environmental management system (page 216).

Effectiveness is monitored through defined KPIs. If pollutant concentrations exceed the defined limits, the Group initiates countermeasures (page 216). In 2025 no environmental incident was reported whose impact was material to the financial position or reputation, and no incident directly harmed the environment or the public (page 216).

Reference: page 217.

Fresenius records air and water pollutant emissions at production sites under legal regulations, by direct measurement at exhaust gas or wastewater points. Where annual measurement cycles delay data, emissions are estimated from the previous year, and the company rates the uncertainty as low (page 217).

The one pollutant reported is total organic carbon in emissions to water: 885,207 kg a year in 2025 (2024: 844,147 kg, restated up from 698,284 kg). Emissions not stated "did not exceed the thresholds defined in the E-PRTR regulation", the European Pollutant Release and Transfer Register (page 217).

At one site the E-PRTR reporting threshold for total organic carbon is exceeded for production reasons; the water is treated at the local wastewater plant at Fresenius's cost and stays within the permitted range on discharge to the public sewer. Two more sites also exceed the E-PRTR threshold but meet local discharge requirements, and are assessing options (page 217). The increase on 2024 is attributed to production volumes (page 217). For air emissions, the report refers to the climate chapter, section E1-6 (page 217).

Reference: page 218.

Water is covered by the Group Environmental Policy: responsible use of water and compliance with wastewater rules such as limits. In water-stressed areas Fresenius aims to reduce process water withdrawal at production sites (page 218). The policy sits in the E1-2 section and has Management Board approval (page 203).

Local management systems, process owners and operating procedures apply the guidelines. Controls focus on wastewater quality and, by sampling, on quantity, and water management is tied to hygiene management (page 218). Risk procedures run in all facilities for water quality deviations, with local authorities informed of critical drinking water deviations; some German clinic laboratories are accredited drinking water testing centers (page 219).

Fresenius states that beyond quality and hygiene it does not set water-reduction goals in product and service design, "as water is indispensable wherever Fresenius uses it as a component" (page 219). All hospitals have emergency plans for supply bottlenecks, and most Spanish clinics hold water tanks (page 219). Most withdrawal in production and healthcare facilities is from municipal supply (page 219).

Reference: page 220.

Production: Fresenius Kabi began measures at production sites in water-stressed areas in 2025, budgeted through 2028. Wastewater is treated and reused for cooling, and conventional vacuum pumps are being replaced by water-free or closed-loop models. At one site, river-water cooling will be replaced by heat pumps that feed waste heat into the municipal network. Kabi plans water maps of selected sites by the end of 2026 (page 220).

Healthcare facilities: Fresenius does not implement measures against increased water demand there, because fresh water is essential for hygiene and patient safety. It uses water-saving fittings and kitchen appliances where possible, and does not reuse water or use gray water (page 220).

Risk identification uses the WRI Aqueduct Water Risk Atlas; sites in extremely high or high water scarcity areas were identified. No material financial risk was found in the freshwater dependency assessment, and the value chain is excluded from the water risk assessment (page 220).

Reference: page 221.

Target: reduce process water withdrawal of production facilities in water-stressed areas by 20% in absolute terms by 2030, from a 2023 baseline of 3,518,096 m3 (page 221). The target was set in 2024 as a voluntary goal. In 2025 the scope was widened from high and extremely high water stress to medium-to-high stress, raising the baseline by 205,096 m3 from 3,313,000 m3 (page 221).

Process water withdrawal in water-stressed areas was 3,427,196 m3 in 2025, a 2.6% reduction, which the company says keeps it on track (page 221). The report states "The improvement of water quality is not addressed" by the target (page 221).

Method: own consumption and sources were analyzed, and 2030 and 2050 optimistic and pessimistic scenarios were run in the Aqueduct tool. Internal stakeholders joined assessment meetings; external stakeholders were considered indirectly through public opinion and available standards (page 221).

Reference: page 221.

In 2025 Fresenius withdrew 14,284,759 m3 of water, 4.5% less than in 2024 (14,959,196 m3). Water consumption, the difference between withdrawal and discharge, was 2,392,745 m3, up 3.6% (2024: 2,310,508 m3) (page 221). Of this, 1,737,162 m3 was in areas at water risk; 451,905 m3 of water was recycled and reused and 41,866 m3 was stored (page 221).

Water intensity was 106 m3 per EUR 1 million of net revenue (2024: 100) (page 222). 72.0% of the quantitative water data is measured and 28.0% estimated; outpatient clinics, offices, research sites and locations without data are extrapolated from per-FTE values collected at Bad Homburg (pages 221-222).

Material locations were evaluated for water risk and stress with the Aqueduct tool (page 222). At ISO 14001 certified sites the water management systems behind these figures are externally audited (page 222). Remaining Vamed units are excluded from 2025 (page 221).

Reference: page 223.

Resource use and circular economy sit in the Group Environmental Policy. Fresenius commits to efficient resource use and to sustainably sourced, renewable or recycled materials in place of new raw materials where regulation allows, supports the transition to a circular economy, and applies the waste hierarchy (prevention, preparation for reuse, recycling, energy recovery, disposal) (page 223).

Waste handling in health care is strictly regulated; internal requirements sit in environmental standard operating procedures, and safe disposal has to meet hygiene and sterility requirements (page 223). Waste management is decentralized under site managers, local EHS managers or waste officers. Helios Spain applies one procedure to all Spanish hospitals, updated in 2025 (page 224). Kabi is developing an internal framework for Product Carbon Footprints and Life Cycle Assessments on a cradle-to-gate basis, with first assessments done (page 224).

The two E5 IROs, resource consumption (IRO 12) and waste with reduced circularity (IRO 13), are both actual negative impacts, driven by quality, safety and hygiene requirements that favor single-use items (page 223).

Reference: page 225.

No central action: "In the reporting year 2025, Fresenius did not adopt any central guidelines for measures relating to resource use and circular economy" (page 225). Approaches are organized locally under the environmental management systems of the operating companies (page 225).

Local activities reported (page 225):

• Kabi reduces plastic in containers where product quality allows
• Hospitals clean, sterilize and repackage instruments and supplies for reuse, except legally defined single-use items
• Helios Germany introduced standardized surgical packs for hip and knee surgery, cutting plastic by about 80% against the earlier solution
• Helios Spain piloted filtering of liquid hazardous waste from orthopedic and urology surgery; evaluation is planned for 2026

Helios Germany reworked its waste container color scheme in 2024, rolled out gradually, with an employee awareness campaign in fall 2025 (page 224).

Reference: page 225.

Fresenius has no measurable circular economy target. The report says "there is currently no measurable Group target for the use of resources and the circular economy" and that it plans to set one in the future (page 225).

The stated ambitions are to maximize material lifespan, reduce waste generated, raise the share of recyclable materials in its own waste streams and cut material consumption through systematic waste management (page 225). Effectiveness of the policies is tracked through defined metrics, described in the Metrics section that follows (page 225).

Reference: page 226.

Kabi's most important production inputs are active pharmaceutical ingredients and excipients, followed by plastic parts and primary and secondary packaging. Helios's main inflows are consumables for nursing care and treatment, pharmaceuticals and prostheses (page 226). Upstream, the Group sources metals, plastics, silicone and rubber components, water, wood, chemicals, and animal and plant products (page 226).

Some organic inputs are certified, such as fish oil certified by Friend of the Sea and soybean oil under the ProTerra Standard. The share of sustainably sourced biological materials fell because certifications expired; renewal is intended (page 226).

The inflow table reports the total weight of products, technical and biological materials used and the reused share (page 226). Helios assumes material outflows equal inflows; Kabi derives weights from master data multiplied by invoiced amounts, with manual adjustments where master data is missing (page 226). Conflict minerals are covered in S2-1 (page 226).

Reference: pages 226-227.

Products: Kabi devices such as infusion pumps and blood collection equipment are built to last several years and can be repaired by certified service staff. Spare parts are kept for seven to ten years after a device is discontinued (page 226). Product durability ranges from 7 to 15 years with regular maintenance; one example, the AmiCORE Apheresis System, has a minimum expected lifetime of 7 years or 7,000 operating hours (page 226). Fresenius has no repairability assessment for reusable products and does not assess it for disposables (page 226).

Recyclability: options for medical products are limited by law and hygiene. Paper manuals and corrugated packaging are recyclable, but Fresenius "does not yet systematically record the recycling share of its products" (page 227).

Waste is reported in the waste table: 151,234 t generated in 2025, of which 59.1% was non-recycled (89,414 t) (page 227).

Reference: page 227.

Fresenius generated 151,234 t of waste in 2025 (2024: 161,723 t): 25,549 t hazardous (2024: 29,314 t) and 125,686 t non-hazardous (page 227). There was no radioactive waste (page 227).

Of the total, 111,451 t was diverted from disposal and 39,783 t directed to disposal. Non-recycled waste was 89,414 t, or 59.1% (2024: 97,448 t, 60.3%) (page 227). Hazardous waste directed to disposal was 10,512 t (page 227).

Waste is recorded under European waste classification codes where required or voluntarily, with local codes mapped to them. Where the treatment route is unknown, country statistics allocate waste to recovery and disposal types (page 227). Outpatient clinics, offices, research sites and locations without data are estimated from per-FTE values collected at Bad Homburg, and the remaining Vamed units are excluded from 2025 (page 227). The narrative says disposal routes "were not fully recorded in the reporting year and therefore will not be disclosed" (page 224), while the table splits waste by treatment type (page 227).

Reference: pages 229-240.

S1 policies sit with a Group Human Resources function created in 2024 and rolled out step by step from 2025; its Chief Human Resources Officer reports to the Sustainability Board member (pages 229-230). Working-condition policies include the Code of Conduct and the Group Policy on Social and Labor Standards, based on the Universal Declaration of Human Rights, ICCPR, ICESCR and the ILO Declaration; third parties are required to follow comparable standards (pages 230-231). Pay is meant to be market-oriented and appropriate, at least matching living wages (pages 232-233).

Occupational health and safety is decentralized by operating company, with ISO 45001 at some sites, risk assessments at least every three years and workplace reintegration procedures in Germany, Spain and Colombia (pages 234-237). Equal treatment is covered by the Code of Conduct, the Diversity Charter and a Human Rights Statement; discrimination "of any kind" is rejected (page 238). Employees with disabilities are covered by local committees and, at Helios Germany, an inclusion agreement (page 240).

The S1 IROs (IRO 14 to 23) are tied to these policy sections (pages 228-229).

Reference: pages 244-245.

Actions are limited. The report says "No further central requirements for measures were drawn up, and therefore no further Group-wide measures were developed" beyond the safety reporting system and the annual employee survey (page 244).

The main 2025 action is the start of a Group-wide Safety Compliance Management System, built on eight core areas and the IDW PS 980 compliance audit standard, first for fire protection. Helios Germany realigned its fire protection function, a Group safety network was set up, and external advice in 2024 cost about EUR 1 million; 2025 work used internal resources and is not material (page 245).

On employee satisfaction, survey results now count for 20% of target agreements for about 1,000 managers at Kabi (2024: 10%), 15% at Helios Germany and 10% at Helios Spain. These actions are not part of a Group action plan with significant OpEx or CapEx (page 245). LinkedIn Learning was launched in November 2025 (page 245). Success is measured through team and function results and their contribution to the EEI next year (page 245).

Reference: pages 246-248.

Employee engagement: the Management Board's short-term variable pay includes the Employee Engagement Index. The 2025 target was at least 4.33 on a 1 to 6 scale; the result was 4.14 (2024: 4.02), so the target was missed, at 85.61% achievement (page 246). The 4.33 value was set in 2022 using results that still included Fresenius Medical Care, and employees and their representatives are not involved in setting it (page 246).

Safety: Fresenius Kabi's Lost Time Injury Frequency Rate target of below 3.0 was replaced by a goal of improving on the prior year; Kabi reached 1.8 against 2.2 in 2024. Helios Germany and Spain track the rate but have no target (page 247).

Equal treatment: the general ambition is stated in words, to keep developing the corporate culture and to attract, promote and retain talent (page 247). The quantified targets are gender targets for Fresenius SE & Co. KGaA were 30% women at the first and second management levels below the Management Board; 2025 results were 26.3% and 20.6%, so the targets were not achieved. A new definition with the same 30% target applies from January 1, 2026 to December 31, 2030 (page 248).

Reference: pages 248-249.

At year-end 2025 the Group had 178,583 employees by headcount (2024: 179,884). By region: Europe 144,733 (Germany 86,606), Latin America and other regions 19,981, Asia-Pacific 9,539 and North America 4,330 (page 248). Germany (86,606) and Spain (43,530) are the only countries above 10% of headcount (page 249).

By gender: 120,465 female, 58,101 male, 9 other and 8 undisclosed. By contract: 154,241 permanent and 24,268 temporary employees (page 249). The temporary share at Helios is 17.2%, driven by short-term staffing in nursing and medicine (page 249).

Turnover was 25.8% (2024: 25.3%), or 23.7% after adjusting for recurring short-term contracts in Spain; voluntary leavers were 9.6% (page 249). There were 46,095 terminations in total (page 250). The report says the headcount differs only slightly from the Group financial statements, with definitions being harmonized (page 249).

Reference: page 250.

5,254 people worked for Fresenius as non-employees in 2025 (2024: 5,234, adjusted by 100 persons after a recategorization), about 3% of the number of employees (page 250). The report states the figure "includes in the operating company Fresenius Helios only the German entities", so Quirónsalud units are not counted, and it is "voluntarily reported by Fresenius in 2025, as this is a phase-in KPI" (page 250).

No split between self-employed people and people supplied by employment agencies is given: "Compared to 2024, no further differentiation will be made" (page 250). The ESRS index shows partial use of the phase-in option, including a deviation in scope of consolidation (page 189).

Non-employees are defined as self-employed people and people provided by undertakings primarily engaged in employment activities who work under Fresenius's direction; people under a third party's direction, such as canteen workers, are counted as value chain workers (page 250). Temporary workers fill short-term gaps, especially in care (page 231).

Reference: pages 250-251.

74.4% of employees worldwide were covered by a collective bargaining agreement in 2025 (2024: 73.9%), or 132,939 employees (page 251). In Germany coverage was 81.5% and in Spain 100.0% (page 251). Workplace representation covered 85.7% of employees in Germany (2024: 82.7%) and 97.1% in Spain (2024: 98.5%) (page 251). For the non-EEA regions with more than 50 employees and over 10% of headcount, the report shows Latin America at 22.6% (2024: 21.9%) (page 251).

Germany has several agreements: Helios hospitals fall under the Helios Group agreement, the public service agreement TVöD or company-specific ones; Fresenius Corporate and Kabi follow the chemical and plastics processing industry agreements negotiated between IGBCE and the employers' federation BAVC (pages 250-251). In Germany most workers are represented by ver.di, and contingency plans keep hospitals running during local strikes (page 251). Spanish clinic staff are covered by legally binding tariff agreements (page 251).

Reference: pages 252-253.

Women are 67.5% of employees (2024: 67.4%), and 74.3% at Helios (page 252). At the two levels below the Management Board, women held 70 of 266 positions, or 26.3% (2024: 99 of 351, 28.2%), after the number of management positions fell with the Vamed exit and other restructuring (page 252).

Age structure at December 31, 2025: 21.8% under 30, 52.5% aged 30 to 50 and 25.7% over 50 (page 252). Employees come from about 160 nationalities; the most common citizenships are German (73,635 employees) and Spanish (39,421), based on about 78% of employees (page 253). The Group does not collect data split by ethnicity (page 253).

The EWC had 18 employee representatives from 9 countries on December 31, 2025 (page 252). Board diversity figures sit in GOV-1 (page 160).

Reference: page 253.

Fresenius reports against the applicable national minimum wage: "As in the previous year, all employees will receive appropriate compensation" (page 253). Interns, trainees, apprentices, voluntary service participants, clinical trainees, medical students in their practical year, students, pharmacists in training and fellows are excluded (page 253).

In EEA countries without a minimum wage, the benchmark is the higher of 60% of the national median wage or 50% of the gross average wage; outside the EEA, an internationally recognized living wage value is used (page 253). Comparative data comes from a global salary database (page 253).

Local HR teams check compliance with minimum wage laws, the Global HR organization monitors it using the HR system of record, and in high-inflation countries local salary levels are checked against the statutory minimum twice a year (page 253).

Reference: page 253.

3.1% of employees had a disability in 2025, or 5,540 employees (2024: 3.1%, 5,482) (page 253). The figure is surveyed globally only in countries where the survey is legally permitted, and some countries do not distinguish between people with and without disabilities in employment (page 253). The report defines a disability as an impairment of physical function, mental ability or mental health expected to last longer than six months, and accounts for different legal definitions (page 253).

In Spain, at least 2% of employees must be people with disabilities, and Helios Spain runs dedicated recruitment, integration and development programs and signed an agreement with the Fundación Integralia DKV (page 240). Helios Germany has an overall inclusion agreement with its representative body for people with severe disabilities (page 240).

Reference: page 254.

Employees averaged 19.3 training hours in 2025 (2024: 17.5): 22.5 hours for men and 17.8 for women, on 3,455,080 total hours (page 254). The report attributes the rise partly to new hires with higher training intensity, mandatory production courses recurring at intervals over one year, and a smaller share of estimated data (page 254).

The company set a 2024 sustainability ambition of raising the average training rate by 20% by 2030 (page 254). Hours are taken from the training plan or curriculum rather than time actually spent, and unrecorded hours at Helios Germany, about 14% of total hours, are estimated from the gender split of recorded hours (page 254). The index shows partial use of the phase-in option for S1-13.83a (page 189).

Training examples include mandatory manufacturing and quality training at Kabi, simulation and incident training at Helios Germany and a healthcare management program for middle managers at Helios Spain (page 254).

Reference: pages 255-256.

All employees, 178,515 by headcount, were covered by the health and safety management system (100.0%); non-employee coverage was 88.8% (4,668 people) (page 255). The work-related accident rate was 17.0 per million hours for employees, with 5,330 accidents (2024: 14.6 and 4,641), 10.4 for non-employees with 62 accidents, and 16.9 for the own workforce (page 255). The report states the 2025 metric definition changed and the prior year is not comparable or restated (page 255).

One employee died during working hours, categorized as an accident under local rules and not attributed to misconduct or inadequate occupational health and safety (page 255). Kabi's Lost Time Injury Frequency Rate was 1.8 (2024: 2.2) (page 255).

Work-related ill health is excluded under the phase-in option, and commuting accidents are reported only in selected countries (pages 256, 159). The index shows partial use of the phase-in option for S1-14.88d,e (page 189).

Reference: page 256.

The gender pay gap was 26.2% in 2025 (2024: 26.0%), from average gross hourly pay of EUR 31 for men and EUR 23 for women (page 256). The report ties the gap to the high share of women, 67.5%, in lower-paid occupational groups, while women are under-represented in higher-paid groups (page 256).

The annual total remuneration ratio was 125.7 (2024: 105.8): the highest-paid individual earned EUR 4,431 thousand against a weighted median employee pay of EUR 35,254 (2024: EUR 3,768 thousand and EUR 35,625) (page 256). The ratio rose with the higher short-term variable compensation paid after positive operating development (page 257).

Methods: gross pay includes payroll elements and the company car value, and excludes pension provisions and insurance payments (pages 256-257). Fresenius uses a weighted median across companies, not a true median, and Kabi calculates hourly pay differently from the other units, with standardization planned (page 257).

Reference: pages 257-258.

Fresenius received 509 work-related reports in 2025 (2024: 348), of which 351 went through Compliance Case Management (HR / workplace and health and safety) and 157 came through HR functions directly (2024: 44), now documented in a standardized way (page 257). 51 incidents of discrimination, including harassment, were substantiated or confirmed (2024: 38), and 458 other complaints were filed (2024: 310); fines, penalties and compensation for discrimination were EUR 0 (page 258).

One site breached health and safety requirements that fall under the German Supply Chain Due Diligence Act; a regulatory fine of EUR 6,000 is expected in 2026, with remedial action under way (pages 257-258). Cases of exceeding permitted working hours were also identified (page 258).

No severe human rights incident, such as child labor, forced labor or human trafficking, was reported in the own workforce (page 258). An overview of human-rights-relevant incidents under the German Supply Chain Due Diligence Act is in the S2 metrics section (page 258).

Reference: pages 262-265.

Fresenius commits to human rights in a Group-wide Human Rights Statement that extends to the value chain, with "zero tolerance for using, supporting, or approving exploitation, including child labor, forced labor, and any form of modern slavery such as human trafficking" (page 262). It follows the UN Guiding Principles and the German Supply Chain Due Diligence Act (LkSG) and is published on the company website (page 262).

Business partners are held to the operating companies' Codes of Conduct for Business Partners, using a risk-based approach to partner selection, contract commitments and training (page 262). The Human Rights Program rests on five pillars: governance, risk assessment and impact analysis, prevention and remediation, grievance handling, and documentation and reporting (page 263).

The Management Board oversees the program; the Group Human Rights Office sits in Risk & Integrity, each operating company has a Human Rights Function, and a Human Rights Council meets quarterly (pages 263-264). Fresenius does not purchase conflict minerals directly but cannot exclude them in sourced components (page 263). Supplier human rights training has run since the second half of 2025 (page 265).

Reference: page 267.

The main 2025 action is the Priority Areas and Stakeholder Engagement Project, which added stakeholder input to the existing risk analysis of own sites and Tier-1 suppliers. It identified five priority areas: working conditions, labor exploitation, discrimination, access to and quality of products and services, and a clean and healthy environment (page 267). Potentially affected rights-holders and vulnerable groups were identified (page 267).

Fresenius "also plans to develop additional concrete activities or action plans containing qualitative and / or quantitative targets starting in 2026". The project "does not require significant operational expenditure (OpEx) or capital expenditure (CapEx)", and resources are set case by case (page 267).

Other actions in the chapter are annual human rights risk analyses at own locations and Tier-1 suppliers, standardized preventive measures such as codes and training, and supplier training since late 2025 (pages 264-265). Effectiveness monitoring is planned after implementation (page 267).

Reference: page 268.

"In the 2025 reporting year, Fresenius did not define a Group-wide target related to workers in the value chain" (page 268). The stated ambition is to analyze human rights impacts regularly, prevent violations, minimize risks and carry out remediation, across the value chain and own operations (page 268).

Effectiveness of the Human Rights Program is reviewed internally by Group and operating company functions and externally by independent auditors, and Fresenius plans to formulate quantifiable targets as the program develops (page 268).

Reporting data: 24 human rights reports were received in 2025 (2024: 28), 23 in own operations and 1 in the value chain; 1 was substantiated (2024: 4). No report related to a severe human rights incident (page 268).

Reference: pages 269-278, 292-294.

The index maps S4-1 to three sub-topics: privacy (page 269), health and safety (page 275) and access to products and services (page 292).

Privacy: a Group-wide data protection concept under the Sustainability Board member, a Group Head of Data Protection and independent data protection experts in each operating company. Binding Corporate Rules cover EU personal data transfers for Corporate / Other (except FHS) and Kabi; other entities use standard contractual clauses. Six data protection audits were run in 2025 (2024: eight) (pages 270-271).

Health and safety: quality management for patient and product safety is set in the Group Code of Conduct and run by each operating company under standards such as ISO 9001, ISO 13485, GMP, IQM and JCI (pages 275-276). Kabi has an early-warning system and pharmacovigilance master file (page 279); Helios applies IQM methodology in Germany (page 280).

Access: strategy covers affordable products, care concepts built on regional clusters and value-based healthcare, and patient support in crises. Fresenius signed the Zero Health Gaps Pledge in 2024 (page 293). Helios completed 21 regional clusters in Germany in 2025 (page 294).

Reference: pages 273, 286, 295.

Privacy: because no material data protection incidents were reported in 2025, "Fresenius has not adopted any central measures in connection with the identified impact and risk" (page 273). Specific actions follow when weaknesses appear or rules change (page 273).

Health and safety: Fresenius "did not adopt any central directives regarding measures and corresponding resources aimed at preventing identified material impacts related to the health and safety of patients" (page 286). Quality and patient safety systems are described as mature, and quality indicators are measured yearly through compensation targets. No incident reported through the channels could have significantly affected reputation or financial position (page 286). Investment is not budgeted separately and sits in general quality and infrastructure spending (page 286).

Access: in 2025 Fresenius adopted a sustainability concept making access to healthcare and products a focus area, with strategic KPIs planned from 2026; no central action was implemented in 2025 (page 295).

Reference: pages 274, 286-287, 295.

Privacy: the ambition is to avoid data protection violations. Effectiveness is tracked by the number of breaches and any recurrence (page 274). 33 reports on data breaches came in through whistleblowing systems in 2025 (2024: 21), none severe (page 274).

Health and safety, Fresenius Kabi: report all periodic safety reports to authorities on time (100%), and achieve an Audit & Inspection Score of 2.3 or better; the 2025 score was 0.9 (pages 286-288). Fresenius Helios: Germany targets 88% achievement of its inpatient quality indicators, Spain 75%; results were 91.9% and 77.4% (pages 287, 290). Both feed the Management Board's variable pay. Helios aims to avoid all avoidable incidents and set a target for Spain; across its German and Spanish hospitals 48 avoidable serious adverse incidents were reported in 2025 (2024: 43) (pages 287, 291).

Access: the report says this ambition "cannot be tracked by targets"; progress is assessed through the expansion of healthcare facilities, patient numbers and patient satisfaction (page 295).

Reference: pages 311-315.

A new Fresenius Code of Conduct was introduced in 2025. It applies to all employees, managers and bodies worldwide, was approved by the Management Board and is owned by the Group function Risk & Integrity (page 311). The Fresenius Principles set the cultural base, and Fresenius has been a UN Global Compact signatory since October 2024 (pages 311-312).

The compliance management system rests on prevention, detection and response. In 2024 the Management Board had it assessed against IDW PS 980; the 2025 second phase delivered 22 projects (page 312). A Group anti-trust policy was added in 2025, and mandatory Code of Conduct training began for all employees (page 316).

Whistleblowing channels are open to employees, suppliers, customers, patients and residents near its sites, by telephone in more than 30 languages and online in up to 27, anonymously where law permits (page 314). Fresenius follows EU Directive 2019/1937 on whistleblower protection, and retaliation against good-faith reporters is not tolerated (page 315). The Group Compliance Management Team meets monthly (page 318).

Reference: pages 320-321.

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

Fresenius sets no quantified Group business conduct target in this chapter. The ambition is "to prevent violations, continuously improve the compliance management system, and to further evolve a living compliance culture", and the operating companies "develop operational goals and programs on an annual basis" (page 320).

Effectiveness is tracked in the absence of a Group target. KPIs are being built into a digital compliance monitoring process, the number of compliance reports is evaluated regularly, and the Compliance function has run Compliance Reviews of the compliance management system since 2024, again in 2025 (page 321). Training coverage in at-risk functions was 94.0% (page 321). Compensation-related targets can be set case by case (page 320). The report states no significant OpEx or CapEx is tied to governance actions (page 320).

Reference: pages 321-322.

In 2025 there were no convictions and no fines of Fresenius for violations of anti-corruption and anti-bribery laws (page 321). The table shows no convictions and no fines for 2024 either (page 321).

Compliance reports in 2025 totaled 1,434 (2024: 1,250), with a 31.3% substantiation rate. Business Integrity accounted for 104 (2024: 98), Misuse of Company Assets 217, HR / Workplace 330, Other 725, Data Protection 33, Environment / Health / Safety 22 and Accounting / Reporting 3 (page 322). The report attributes the rise partly to the Code of Conduct rollout with mandatory training that also covered the reporting channels, and says most of it is patient complaints at Helios Spain that did not reach the level of a compliance violation (page 322).

No incident reported through the channels significantly affected reputation or financial position (page 322). From 2025 human rights-related reports are no longer counted in compliance reports (page 322).

Reference: page 321.

Government relations are run by a Political Affairs department that reports directly to the Chairman of the Management Board, with a Berlin representative office and an EU Relations Office in Brussels (page 321). Political activity by employees is governed by the Code of Conduct and local law (page 321).

Fresenius made no direct or indirect political contributions in 2025, in cash or in kind, including through intermediary organizations, and no donations to politicians (2024: EUR 0) (page 321). It is listed in the German lobby register (R001428) and the EU lobbying register (047428334069), and no member of management or supervisory bodies held a comparable public administration position in the two years before appointment (page 322).

Priority topics are improving the legal and economic framework for business, promoting the industrial healthcare sector, financial sustainability of healthcare systems and quality of care in its own facilities. It also advocates better working conditions for employees (page 322). Lobbying engagement is described as aimed at improving access to medicine and healthcare (page 322).