Fuchs Petrolub

The role of the administrative, management and supervisory bodies

Reference: pages 99-106.

FUCHS SE has a two-tier board: an Executive Board of five members and a Supervisory Board of six, four elected by shareholders and two by employees (pages 99-100). Five of the six Supervisory Board members are independent (83%). Women hold 50% of Supervisory Board seats and 20% of Executive Board seats (page 102).

Allocation of responsibility (pages 102-103):

• The CFO is responsible for the methodology and execution of the materiality assessment, and for governance and compliance.
• The CTO is responsible for sustainability, purchasing and health and safety.
• The CEO is responsible for corporate culture, strategic planning, HR and corporate citizenship.
• The full Executive Board manages and monitors all material IROs. The Audit Committee of the Supervisory Board oversees IROs in connection with sustainability reporting (page 103).

The Governance department, under the CFO, coordinates sustainability across the Global Functions and subsidiaries (page 103). The report publishes a skills matrix for the Supervisory Board (page 101), and both boards received targeted training on the CSRD and ESRS (page 105).

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

Reference: pages 106-107.

The Governance department presented the results of the materiality assessment to the Executive Board and the Supervisory Board, and the Executive Board approved the identified material IROs (page 106).

IRO updates run bottom-up. All FUCHS companies and the Global Functions submit contributions twice a year in a Group-wide impact, risk and opportunity report, which Governance consolidates for the Executive Board (page 106). The Audit Committee gets a written report on the key IROs at least once a year, and the Supervisory Board hears about strategic sustainability matters and target status at its meetings (page 106).

The Executive Board takes budget, project and transaction decisions with input from the risk management system and from the Chief Sustainability Officer and Governance reports (page 106). Both boards "have determined and assessed the 15 material IROs and the associated actions" (page 107).

Sustainability is one of six strategic pillars of the FUCHS 2025 strategy (page 106).

Integration of sustainability-related performance in incentive schemes

Reference: page 107.

Executive Board variable pay is set by the Supervisory Board and has three parts: FUCHS Value Added (FVA), an individual performance component, and a sustainability factor. The factor applies uniformly to all Executive Board members and covers three categories: Ecology, Economics and Social. Possible subcategories include CO2 reduction and the circular economy (ecology), EBIT and cash flow (economics), and personnel management, corporate culture and corporate governance (social).

Target attainment is assembled in December each year as an overall picture, since the aspects "are not assessed individually or weighted". The statement refers to the remuneration report for detail and gives no weight for the factor.

Variable pay is 45% short-term and 55% long-term incentive. Board members must put the net long-term payout into preference shares with a four-year lock-up. Supervisory Board members receive fixed remuneration only, so their pay is not tied to sustainability goals or impacts.

Statement on due diligence

Reference: page 108.

A table maps the core elements of due diligence to sections of the statement (page 108):

• Embedding due diligence in governance, strategy and business model: GOV-2 (page 106), GOV-3 (page 107), SBM-3 (page 117).
• Engaging with affected stakeholders: GOV-2, SBM-2 (page 115), IRO-1 (page 121), and MDR-P in the topical standards.
• Identifying and assessing adverse impacts: IRO-1 (page 121) and SBM-3 (page 117).
• Taking action: MDR-A and the transition plans in the topical standards.
• Tracking effectiveness and communicating: MDR-M and MDR-T in the topical standards.

On the human rights side, the Human Rights Officer reviews the own workforce each year using the IntegrityNext ESG portal (page 180) and reports each year to the Executive Board under the Supply Chain Due Diligence Act, LkSG (page 199). The GOV-4 datapoint (paragraph 30) is listed against page 108 in the table of datapoints from other EU legislation (page 132).

Risk management and internal controls over sustainability reporting

Reference: pages 108-110.

The Group-wide risk management system and internal controls also cover sustainability reporting. Their aim is the early identification of material errors, "in particular those that might result from human error or incomplete data" (page 108). Data runs through web-based SharePoint solutions, the HR system FUCHS CONNECT, the IntegrityNext ESG portal and the Group compliance management system (page 108).

A table lists six reporting risks with mitigation and controls (page 109): failure to comply with regulatory requirements, unclear responsibilities, incompleteness, errors or inaccuracies, unchangeability and timeliness. Controls include access controls, change logs, completeness dashboards, dual-control approvals, data validations and plausibility checks, write protection after submission, and binding deadlines.

Local companies and Global Functions report IROs above a defined threshold twice a year in the risk reporting process; the report does not give the threshold (page 109). Control effectiveness is checked in internal assessments at regular intervals (page 108), and the Vice President Governance informs both boards on material IROs and control effectiveness (page 110).

Strategy, business model and value chain

Reference: pages 110-114.

FUCHS develops, produces and distributes more than 10,000 specialty lubricants and functional fluids, and provides services such as lubricant monitoring (page 110). It has 6,932 employees (EMEA 4,567; North and South America 1,201; Asia-Pacific 1,164) and 38 production sites worldwide (pages 110, 113). Main customers are automotive manufacturers and suppliers, mechanical engineering, metalworking, mining, aerospace, energy, construction and transport (page 110).

Value chain (page 114): raw materials come from refineries, traders and additive suppliers (base oil, additive and packaging suppliers). Production is mainly blending and cooking at over 38 sites. Products reach customers through direct sales, distributors or digital platforms. End-of-life support includes biodegradable products and oil recycling where local infrastructure allows.

Sustainability objectives (page 111): Net-Zero strategy (Scope 1 and 2 down at least 90% by 2040, Scope 3 down at least 90% by 2050); no separate circular economy targets; own workforce targets on training, eNPS, turnover and ISO 45001; no specific S2 targets yet; an 85% target rate for two compliance courses.

Sustainability is one of six pillars of the FUCHS 2025 strategy, which the FUCHS100 strategy replaces from 2026 (page 112).

Interests and views of stakeholders

Reference: pages 115-116.

An internal expert group identified stakeholders in 2023, scored them on a longlist and shortlisted ten groups: shareholders, analysts, the Supervisory Board, ESG rating agencies, global and local executives, customers, suppliers, FUCHS employees, the Executive Board, and nature as a silent stakeholder (page 115).

Representatives, including the Global Functions and the SE Works Council, answered a structured questionnaire covering all ESRS 1 AR 16 topics and entity-specific topics. It asked for perceived impact on a five-tier scale and relevance of sub-topics and datapoints on a six-tier scale (page 115). Topics rated relevant: climate change, resource use and circular economy, own workforce, workers in the value chain, and business conduct. Where survey results and the IRO workshop findings differed, "the IRO workshops took precedence" (page 115).

Workers' interests enter through works councils, worker representatives on the Supervisory Board, the Code of Conduct and the Human Rights Principles, monitored by a Human Rights Officer who reports to the Executive Board (page 115). Value chain workers' views came through the purchasing and sales functions and IntegrityNext supplier assessments (page 116). The Executive Board and Audit Committee were briefed on the survey results (page 116).

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

Reference: pages 117-121.

FUCHS reports 15 material IROs (page 107), set out with value chain position, time horizon and response (pages 117-120):

• E1 Climate change (5): negative impact from GHG emissions, including from fossil raw materials; risks from floods and forest fires, from fewer new combustion-engine registrations, and from legal and regulatory change; opportunity from the mobility transition.
• E5 Resource use and circular economy (2): risk from the switch to biomass-based and recycled raw materials (availability and price); positive impact from longer service life of customers' equipment.
• S1 Own workforce (5): positive impacts from diversity and from employee development; negative impacts from unequal treatment in exceptional cases and from work-related accidents; risk from demographic change.
• S2 Workers in the value chain (1): potential negative impact from human rights violations in the supply chain.
• G1 Business conduct (2): positive impact from corporate culture; risk of bribery and corruption.

"All identified IROs fall under the ESRS disclosure requirements" so no entity-specific disclosures were added (page 117). The identified material risks and opportunities "did not have a financial impact" in the current year (page 121). Climate resilience is also presented under E1-3 (2025 ESRS numbering).

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

Reference: pages 121-129.

The process has five steps: status quo analysis, identification, assessment, consolidation and validation (page 121). A survey of ten stakeholder groups came first. IROs were then identified in workshops with the Global Functions across own operations and the value chain; no central consultation of affected communities took place (page 121).

Assessment (pages 122-123): impacts are scored on scale, scope, irremediability and likelihood; risks and opportunities on financial effect (from up to €2 million to above €20 million, judged mainly through EBIT) and likelihood. A matrix rates IROs high, medium or low, and only high and medium are material. Validation happens twice a year through risk management.

Climate (pages 125-128): the physical risk analysis (2024) covered 17 sites in 10 countries under SSP5-8.5; the transition analysis used the IEA Net Zero Emissions by 2050 scenario; both cover 2030 and 2050.

Outcome (pages 123-129): the material topics are E1, E5, S1, S2 and G1. Biodiversity, pollution, water and waste were assessed and classed immaterial (pages 128-129).

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

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

Reference: pages 130-133.

IRO-2 is a content index that lists each disclosure requirement with a page number (pages 130-131). It covers:

• ESRS 2: BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2
• E1: E1-1 to E1-8
• E5: E5-1 to E5-5
• S1: S1-1 to S1-7, S1-9, S1-13, S1-14, S1-16, S1-17
• S2: S2-1 to S2-5
• G1: G1-1, G1-3, G1-4

A table of datapoints from other EU legislation (pages 132-133) marks the E1-9 datapoints "not stated (phase-in)". It marks the E2, E3, E4, S3 and S4 datapoints, E5-5 paragraphs 37 d and 39, and G1-1 paragraph 10 d "immaterial". A third table maps the ESRS topics to the five HGB non-financial statement aspects (page 133).

On what was left out: "Where it was determined that a specific disclosure obligation cannot be allocated to an IRO classified as material, the corresponding datapoint or the disclosure requirement was not reported in accordance with the ESRS specifications" (page 133).

Transition plan for climate change mitigation

Reference: pages 142-145.

The "FUCHS Net Zero 2040 / 50 Strategy" targets cuts of at least 90% in Scope 1 and 2 emissions by 2040 against 2021, and at least 90% in Scope 3 by 2050 against 2023. Interim targets are at least 42% (Scope 1 and 2, 2030) and 25% (Scope 3, 2035) (pages 142-143, 155). The plan follows SBTi guidelines: a 1.5°C pathway for Scope 1 and 2, and a "well below 2 degrees Celsius" ambition for the short-term Scope 3 target (page 144). No SBTi validation is being sought (page 149).

Levers (page 144): less fossil fuel and electrified vehicles and processes (Scope 1), renewable electricity (Scope 2), renewable materials and waste prevention (Scope 3).

Funding (page 144): no central budget. Subsidiaries are expected to reserve up to 10% of annual CapEx for Scope 1 and 2 cuts. No locked-in emissions were identified that would block the 2040 target.

Progress (page 145): Scope 1 and 2 are down 43.6% on 2021. Scope 3 is up 4.4% on 2023 because purchase volumes rose and renewable raw material actions "were not yet sufficiently effective". The Executive Board approved the strategy and the Supervisory Board saw the key points (page 145). "FUCHS is not exempt from the EU Paris-aligned Benchmarks" (page 144).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate sections, where this content is disclosed in the FY2025 report (pages 125-129, 145-148). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 125-128.

Physical risk (pages 125-127): the 2024 analysis assessed 17 sites in 10 countries, chosen for strategic and economic importance, under the high-temperature scenario SSP5-8.5 for 2030 and 2050. Ten hazards were included in the site risk assessments, 14 showed no or low risk and 4 were not relevant. High gross risk: floods at Mannheim, Suzhou and Fairhaven; forest fires at Castellbisbal, Ambernath and Beresfield. No material physical risk was found in the value chain.

Transition risk (pages 127-128): the analysis used the IEA Net Zero Emissions by 2050 scenario (World Energy Outlook 2024) for 2030 and 2050, with political, reputational, technological and market levers, validated by an external consulting firm. Inputs included crude oil price forecasts, CO2 price and tax developments and global passenger car fleet development. Results: medium upstream risk from biomass-based raw material supply and price; medium downstream risk from fewer combustion-engine registrations, offset by a medium opportunity in new mobility.

SSP5-8.5 "assumes a global temperature increase of more than 4 °C" (page 128).

Resilience in relation to climate change

Back-filled from the E1 section on ESRS 2 SBM-3 (E1.SBM-3) in the FY2025 report (pages 145-149). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 145-149.

An external consulting firm ran the climate resilience analysis between October and December 2024 with Strategy, Procurement, Operations, Sales, Governance and Sustainability (page 145). No material transition risks were found in own operations, and no material physical risks in the value chain, so no further analysis was done there (page 145).

Results (page 148):

• Flood risk at Mannheim, Suzhou and Fairhaven and drought and forest fire risk at Castellbisbal, Ambernath and Beresfield: high gross, medium net after municipal flood protection, a flood management plan, an on-site fire department and water protection actions.
• Group level: medium gross physical risk, "no longer classified as a relevant net risk" after resilience actions.
• Transition: medium upstream risk gross and net. The downstream combustion-engine risk is "no longer classified as a significant net risk", and the medium new-mobility opportunity stays medium net.

Capacity to adapt rests on over 10,000 products made at multiple sites, a broad customer base, positive cash flow and a low debt ratio (page 149). The scenarios "involve uncertainties due to long timeframes, regional differences, and other factors" (page 149).

Policies related to climate change mitigation and adaptation

Reference: pages 149-151.

Net-Zero strategy (pages 149-150): guided by SBTi guidelines, with no official validation sought. It applies to all fully consolidated companies and, through Scope 3.15, to associates and joint ventures. The CTO is responsible, and "cradle-to-grave" emissions are calculated each year and compared with the target pathways. Focus areas: emission targets set at subsidiary level; energy efficiency (ISO 50001 certification of the most important production sites by 2027); green electricity at all FUCHS-owned sites where feasible, through bundled supply, PPAs, or guarantees of origin and certificates; and conversion of the vehicle fleet to zero-emission vehicles.

Adaptation (page 150): local policies based on site risk analyses, run by the national companies and supported by ISO 14001 certification.

Mobility transition (pages 150-151): a business and segmentation policy, approved by the Executive Board, that focuses on markets with lasting demand for combustion engines while preparing for electric drivetrains and non-fossil fuels.

Regulatory change (page 151): continuous monitoring by the responsible departments across all areas and regions, with Executive Board responsibility.

Actions and resources in relation to climate change policies

Reference: pages 152-154.

Mitigation (page 152): electrification of the vehicle fleet and of processes and cuts in fossil fuel use (Scope 1); green energy supply (Scope 2); renewable materials and waste reduction at FUCHS (Scope 3). The page gives time horizons from 2025 to 2050 for each lever. By the end of 2025 many subsidiaries had switched to green electricity through green tariffs or guarantees of origin. Since May 2024 all FUCHS-owned small automotive core-design packaging used in Europe has 100% post-consumer recycled content (page 153).

Resources (page 153): beyond the EU Taxonomy CapEx figures, "no significant current or future financial or other resources exist" for these actions. The report defines significant as above €5 million. Switching raw materials needs no extra CapEx or OpEx, and there are no centrally managed action plans.

Adaptation (pages 153-154): water retention basins, fire protection pools, municipal drainage and flood infrastructure, and a Group-wide property and business interruption insurance policy.

Mobility and regulation (page 154): the BlueEV product series, added staff and a dedicated product development and sales position, and membership of lubricant associations (UEIL, ATIEL, ALIA, API, ILMA) to spot regulatory trends early.

Targets related to climate change mitigation and adaptation

Reference: pages 154-159.

The Scope 1 and 2 targets follow a 1.5°C pathway and the Scope 3 targets a "well below 2 degrees" pathway (page 155). "No official validation by the Science Based Targets Initiative (SBTi) has been sought so far", the targets were set "without the involvement of external stakeholders", and no external audit of the targets has taken place (pages 155-156).

Current actions are projected to meet the 2030 Scope 1 and 2 target (page 152), but the report says current and planned actions "will not be sufficient" for the 2035 Scope 3 target (page 153).

Adaptation and other risks (page 159): no central tracking of adaptation targets, and no specific targets for the mobility transition or regulatory change. Sales and earnings metrics are used to track effectiveness instead.

Energy consumption and mix

Reference: pages 160-161.

The fossil share fell from 72% to 65% and the renewable share rose from 27% to 35% (page 160). Of the renewable total, 91,650 MWh was purchased and 4,352 MWh self-generated (2024: 69,918 and 3,492).

Energy intensity for high climate impact sectors is 76.1 MWh per € million of net revenue (2024: 77.8); FUCHS assigns all activities to NACE C.19.20.0, mineral oil processing (page 161). Own generation was 11,810 MWh (7,201 non-renewable, 4,609 renewable). Data are primary, and leased sites without consumption data use regional medians per square meter (page 161).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 162-166.

Scope 2 market-based fell 91.4% and Scope 3 rose 4.8% (page 162). Base years are 2021 (Scope 1 and 2) and 2023 (Scope 3: 2,301,566 tCO2e) (page 163). Scope 3 reporting covers categories 1 to 7, 11, 12 and 15; categories 8, 9, 10, 13 and 14 are excluded with stated reasons (pages 164-166).

Intensity is 684.1 tCO2e per € million of net revenue, market-based (2024: 662.8) (page 166). Biogenic Scope 1 emissions were 387 tCO2e (2024: 431). Primary supplier data covers 8% of Scope 3.1 (page 164). An external provider calculates the footprint, and "The accuracy of the results is limited by the use of secondary data sources" (page 163).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 167.

FUCHS "does not engage in or support any third-party activities aimed at actively removing greenhouse gases". Each year it voluntarily offsets its gate-to-gate emissions by retiring carbon credits from projects outside its own value chain, drawn from a stock acquired in 2021. The offsets do not change the reported gross or net emissions.

The credits retired for 2025 covered 62,965 tCO2e (2024: 79,377), made up of Scope 1 and 2 market-based emissions and Scope 3 categories 3.3, 3.5, 3.6 and 3.7. By standard, 87% were VCS and 13% Gold Standard. None came from projects in the EU and none qualified as corresponding adjustments.

No instrument has been chosen to neutralize the emissions that remain at the 2050 target year. FUCHS made no public statements on emissions neutrality based on offsetting carbon credits in 2025.

Internal carbon pricing

Reference: page 167.

FUCHS "does not currently use any internal carbon pricing schemes". E1-8 is listed in the content index against page 167 (page 130), and this one sentence is the whole answer: no price per tonne, scope or use in investment decisions is given.

Investment planning for climate actions is decentralized. The report says there is no central budget dedicated to the sustainability targets, and that local subsidiaries are responsible for their own budget planning, with up to 10% of their annual CapEx expected to go to Scope 1 and 2 reductions (page 144).

Policies related to resource use and circular economy

Reference: pages 169-170.

The Net-Zero strategy carries the circular economy policy, and FUCHS describes defossilization as becoming independent of fossil primary raw materials step by step (page 169). It names two material flows to replace fossil raw materials: recycled raw materials, mainly from used oil recycling and other post-consumer streams, and biogenic or biomass-based materials, preferably from plant-based waste streams to avoid conflict with food production. Both are available only in limited quantities and, for biogenic materials, at higher cost (page 169).

Sustainable sourcing follows the General Purchasing Conditions, the Supplier Code of Conduct, the Human Rights Principles and the Code of Conduct. At present "no certification system is used", and "the cascade principle is not formally applied" (page 169).

The purchasing strategy includes a full switch to raw materials from circular sources by 2050 and is the CTO's responsibility (pages 169-170). A second policy strand is longer service life and higher efficiency of customers' equipment, pursued through R&D in which roughly 10% of about 7,000 employees take part (page 170).

Actions and resources related to resource use and circular economy

Reference: pages 170-171.

Raw materials (pages 170-171): FUCHS aims to replace fossil materials with renewable ones where technically and economically possible, and to secure scarce biomass-based or recycled quantities early. Named actions:

1. Redesign product formulations to use more circular base oils, recycled or biomass-based.
2. Raise the share of post-consumer recycled content in packaging where FUCHS can influence it.
3. Use the Advanced Circular Technology (ACT) approach to market recyclable products.

Customers remain price-sensitive: "price premiums for more sustainable raw materials are accepted to only a limited extent" (page 171). Purchasing of circular base oils and packaging sits upstream, and marketing of recyclable products sits downstream.

Service life (page 171): improved product properties to extend system life and cut machine downtime, condition monitoring of process fluids to manage change intervals, and a larger Smart Services catalog. These actions are continuing and relate mainly to the downstream value chain.

The report gives no separate budget for these actions; it points to the Net-Zero strategy chapters (pages 171, 153).

Targets related to resource use and circular economy

Reference: pages 171-172.

"FUCHS has not defined separate targets for resource use and circular economy" because the Net-Zero strategy addresses key aspects of the circular economy (page 171). Progress is monitored through GHG reductions, with a particular focus on Scope 3.1 emissions from purchased materials. Replacing fossil purchased materials with circular alternatives is treated as a key decarbonization lever and as an indicator of circular economy progress (pages 171-172).

For longer service life and higher efficiency of customers' systems, the report says "The introduction of concrete targets for these concepts is not foreseeable at this time", though FUCHS is working on concepts to make the efficiency benefits more visible and measurable (page 172). Effectiveness of existing actions is assessed qualitatively through product and application characteristics; "A systematic measurement using set indicators or reference periods is not implemented at this time" (page 172).

Resource inflows

Reference: pages 172-173.

Key resource inflows are base oils, additives, solvents, packaging materials, and technical equipment and machinery for production. Products are mostly based on crude oil and may also contain chemicals, metals, plastics and other solids (page 172). Critical raw materials under the EU list are bought "in immaterial quantities", and the raw materials used contain no rare earths beyond traces (page 172).

No 2024 comparison is given (page 173). The sustainable share is 0% because no recognized external certification system is used, although FUCHS did source biological materials including packaging and plans to report a higher share in future (page 173). Where materials overlap, the calculation prioritizes reuse, then recycling, then biological primary materials. Data come from the ERP systems, with some national companies (including Argentina, Brazil, Russia and Switzerland) collected separately, and packaging weights use central averages (page 173).

Resource outflows

Reference: pages 173-175.

FUCHS sells automotive lubricants, industrial oils, metalworking fluids, greases and pastes, special-application lubricants and Smart Services (pages 173-174). Products are generally recyclable; reuse or remanufacturing is possible in some groups but is a small part of the business (page 174). Non-conforming batches are reprocessed or blended into other batches to avoid waste (page 174).

Both rates rest on expert estimates by global product managers and purchasing (page 175). The report states there is no established system for rating lubricant repairability, and that re-additivation during use is possible for products such as cooling lubricants and transmission oils (page 175).

Policies related to own workforce

Reference: pages 179-182.

The Code of Conduct and the Human Rights Principles address the positive impact "Promoting diversity and equal treatment of all employees" and the potential negative impact "In exceptional cases, unequal treatment of employees" (page 179).

• Code of Conduct: applies to all employees worldwide; new starters confirm it electronically or by signature. The Executive Board owns it, and the Chief Compliance Officer and Local Compliance Officers implement it (pages 179-180).
• Human Rights Principles: rule out trafficking, forced labor, child labor and discrimination, and promote equal opportunity and freedom of association. A Human Rights Officer runs an annual risk analysis, LkSG training is mandatory, and the 2025 global risk assessment found no increased risk of forced or child labor in own operations (pages 179-180).
• Employee promotion and development policy: a training budget guideline of 1-3% of salary costs per company (page 181).
• Employer branding policy: counters the demographic change risk; no formal monitoring is planned (page 181).
• HSEEQ&S Principles: the framework for health, safety, environment, energy, quality and sustainability, with the CTO responsible and monitoring through audits and safety inspections (pages 181-182).

Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

Reference: pages 184-185.

Diversity and equal treatment (page 184): a diversity-oriented recruitment policy and international applicant platform, equal opportunity initiatives for women, minorities and persons with disabilities, and mandatory online training on the Code of Conduct, discrimination and LkSG. Effectiveness is judged from the VOICES OF FUCHS survey and end-of-course knowledge tests.

Development (pages 184-185): performance management with target agreements and yearly reviews, long-term career plans, annual succession planning, and over 100 e-learning courses.

Demographic change (page 185): global employer branding campaigns, culture development and development programs, tracked through voluntary turnover, eNPS, performance reviews and training hours.

Occupational safety (page 185): an ISO 45001 safety management system "due to be implemented gradually by 2029 latest" at all production sites, at least one safety inspection per site each year, an annual safety briefing for all employees, and root cause analysis after serious deficiencies. Effectiveness is measured by accident numbers and days lost. The Head of Global Management Systems coordinates.

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

Reference: pages 186-187.

The eNPS fell from 30 to 24 because of a larger survey population, and the 2025 target was still met (page 186). The accident targets use 2024 as the base year and are not to be exceeded in the medium term, with reductions later (page 187).

Targets were set at the "Strategic Alignment Day" by the Executive Board, HR and strategic Global Functions. "Workers' representatives do not participate" in setting them, though safety actions and targets are coordinated with them (page 187).

Characteristics of the undertaking's employees

Reference: pages 187-188.

FUCHS had 6,932 employees at the end of 2025: 5,118 male, 1,794 female, 0 non-binary and 20 not specified (page 187). The largest countries are Germany (2,010) and the USA (714) (page 188).

Permanent staff are 4,687 male, 1,632 female and 20 not specified; temporary staff are 431 male and 162 female (page 188). A total of 791 employees left in 2025, a turnover rate of 11% (page 188). The count is a head count on the last day of the year taken from FUCHS CONNECT, and includes inactive employment relationships, interns and working students. The financial statements exclude working students and interns, so the two figures differ (page 188).

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

Reference: page 189.

The figure is a head count at the reporting date, collected through a survey of the national companies. Non-employees counted include temporary and agency workers, contractors, freelancers and seasonal staff, as long as they are part of FUCHS business processes. Individuals on service contracts, such as cafeteria and security staff, are excluded (page 189). The S1 chapter describes the own workforce as including non-employee workers who operate within its processes, meaning independent subcontractors and temporary workers supplied by third-country undertakings (page 178). No breakdown by region or gender is given.

Diversity metrics

Reference: page 189.

FUCHS defines the top management level as "two levels below the administrative and supervisory boards": below the Executive Board, the local Managing Directors and Group Management Committee (level 1), and Senior Management and Vice Presidents (level 2) (page 189). Board-level diversity is covered under GOV-1: 20% women on the Executive Board and 50% on the Supervisory Board (page 102).

Training and skills development metrics

Reference: page 190.

Non-binary employees are shown as 0 (page 190). The average of 12.5 training hours compares with 9.4 in 2024 and a 2025 target of at least 9.9 hours (pages 186-187). Reviews and training hours are recorded only in the global HR system FUCHS CONNECT (page 190). The report gives no split by employee category.

Health and safety metrics

Reference: page 190.

The 2024 values in the targets table are 67 accidents, a rate of 5.7 and 2,046 days lost, so all three rose (page 186). The statement gives no reason for the rise; it notes only that the metrics now include employees who left during the year, unlike previously reported figures (page 190).

All figures cover own employees only. Unlike earlier reporting, they now include employees who left during the year, so persons outside the year-end head count can appear. Hours worked come from recorded time where available and are otherwise estimated from employment level and contractual hours less paid absence; the report rates the uncertainty as low (page 190).

Compensation metrics (pay gap and total compensation)

Reference: page 191.

The gender pay gap is the difference between average female and male pay as a percentage of average male pay, calculated as a weighted average of the subsidiaries' own gaps. The remuneration ratio compares the annual total remuneration of the highest-paid individual with the median of all other employees, using a group median weighted by employee numbers (page 191).

Pay is what was actually paid in the year, including monetary benefits. New joiners are counted pro rata, which tends to lower the metrics, and staff without a valid contract at year-end are excluded. Where private use of company cars is booked as expense, the benefit is estimated with the 1% rule. The report rates the resulting uncertainties as low (page 191).

Incidents, complaints and severe human rights impacts

Reference: page 192.

FUCHS counts a case of discrimination or harassment as an incident confirmed in full or in part. A "complaint" is a matter that could not be substantiated after internal investigation, so the complaints figure excludes the confirmed cases. Harassment includes sexual harassment. The count comes from a central register of complaints received through the official channels, mainly the whistleblower portal, supplemented by local surveys because complaints also go to compliance, HR and the works council (page 192).

Policies related to value chain workers

Reference: pages 194-195.

Five publicly available documents form the policy base (page 194): the Human Rights Principles, the Code of Conduct, the Supplier Code of Conduct (SCoC), the General Purchasing Conditions (which require suppliers to acknowledge the SCoC), and the HSEEQ&S Principles. The SCoC covers child labor, forced labor, equal opportunities, freedom of association, wages, working time, health and safety, environment, land rights and animal welfare. The Executive Board adopted these documents and the Human Rights Officer monitors them (pages 194-195).

Suppliers' self-disclosures are analyzed through IntegrityNext on child labor, discrimination, forced labor, working conditions and pay, freedom of assembly, local communities, diversity and health and safety (page 195). One violation from the upstream supply chain was reported through the whistleblower portal in 2025: a working time breach at a service provider, classed as not systemic or severe (page 195). In 2026 FUCHS plans to raise awareness of its complaints channels in the value chain (page 195).

Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions

Reference: pages 197-199.

Actions fall into four groups (page 197):

1. Contractual: supplier terms folded into the SCoC since December 2023, with audit rights. The SCoC was revised at the end of 2025 to add biodiversity, deforestation, rare earths, export compliance, accounting principles and disclosure of information.
2. Supplier risk management: annual IntegrityNext self-disclosures, an LkSG policy statement and a Human Rights Officer.
3. Documentary: central management of SCoCs and documented action plans for deviations.
4. On-site: supplier audits and individual action plans where needed.

A global Supplier-Relationship-Management system has been in use since mid-2025, and FUCHS plans to extend supplier audits to social topics (page 198). "There was no serious violation in connection with human rights in the reporting period" (page 198). Resources include the self-assessment portal, the Human Rights Officer's annual LkSG report to the Executive Board, ERP systems that track supplier agreements, and online training for own staff (page 199).

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

Reference: page 199.

FUCHS has set no targets for workers in the value chain. It says "no specific targets for the management of negative impacts on workers in the supply chain have been defined" (page 199).

Instead, three metrics were introduced in 2025 and are collected yearly and reported internally (page 199):

• the share of supplier expenses for raw materials and packaging covered by an ESG risk analysis;
• the results of those analyses on the IntegrityNext scorecard, in red, yellow and green risk levels;
• the share of purchasers who completed training on responsible procurement.

They are meant to be the basis for concrete targets "in the coming years". Limits: only direct suppliers are covered, and data quality depends on the completeness of supplier data. Effectiveness of actions is currently monitored through the IntegrityNext supplier evaluation (page 199). No metric values are published in the statement.

Business conduct policies and corporate culture

Reference: pages 201-205.

Culture (pages 201-202): five values (trust, creating value, respect, reliability, integrity) built through employee surveys and workshops. "Culture" is one of three core elements of the FUCHS 2025 strategy. Tools include the Code of Conduct, a Global Onboarding Program, Cultural Scouts, a virtual Roadshow, and values assessed in annual performance management. The eNPS is the key culture metric, and the first global survey ran in 2025.

Compliance management system (pages 202-203): it follows the seven elements of IDW PS 980 (09.2022), with a CCO appointed by the Executive Board and the CFO holding remaining board supervision. It applies globally to own operations and reaches the upstream chain through the Supplier Code of Conduct.

Reporting (pages 203-204): a whistleblower portal, a functional email address and personal contact with compliance officers. Receipt is acknowledged within seven days and feedback given within three months, as the EU Whistleblower Directive requires. Retaliation is prohibited.

Training (pages 204-205): "Fundamentals of Compliance" every three years for leaders and commercial employees, and "Protection against Corruption" every two years for leaders, sales and purchasing. Reminders go automatically to users and supervisors.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets sit in the anti-corruption training disclosure. G1-3 became a standalone disclosure requirement only in the 2025/2026 ESRS.

Reference: pages 207-208.

FUCHS sets one measurable business conduct target: an 85% training rate, with target year 2026, for each of its two anti-corruption courses (page 207).

The rate is completed and passed courses as a share of those allocated, measured on the year-end reference date (page 207). It "is a relative metric; intermediate targets and milestones are not determined or measured" (page 207). The Group Compliance Office set the target as a KPI, and "No further stakeholders were involved in this process" (page 208). Subsidiaries that miss 85% are contacted and asked to improve (page 208). Culture is tracked separately through the eNPS (page 202).

Incidents of corruption or bribery

Reference: page 208.

"There were no convictions for breaches of bribery or corruption regulations in the reporting period" (page 208). Following the EFRAG Q&A, a conviction means a conviction of a natural person by a court of first instance. The figures come from a survey of the national companies (page 208). The G1-4 section gives no figure beyond convictions and fines.