The role of the administrative, management and supervisory bodies

The Executive Board manages FUCHS on the basis of various financial performance indicators. The most important of these key performance indicators (KPIs) is the FUCHS Value Added (FVA). It is characterized by the strategic objective and combines profit with capital employed. In addition, other key performance indicators are regularly reported to the Executive Board and the Supervisory Board.

Supervisory Board Responsibilities

The Supervisory Board held five meetings in the reporting year, all of which were conducted in person. Additionally, two topics were dealt with in writing. During these meetings, the Supervisory Board regularly addressed the business performance of FUCHS and the Group companies. They dealt with the budget and strategic focus as well as numerous governance topics, as well as the 2025 budget, including the investment budget. Additionally, the committee addressed matters related to Executive Board compensation and preparations for the 2025 Annual General Meeting.

The Supervisory Board approved the 2024 Declaration of Compliance with the German Corporate Governance Code and adopted adjustments to its rules of procedure, as well as those of the Executive Board. The amended allocation of responsibilities plan presented by the Executive Board was approved. Based on the recommendations of the Personnel Committee, the Supervisory Board established the sustainability factor for the Executive Board's variable compensation for the financial year 2024. It also decided on the criteria for measuring the sustainability factor for 2025 and the target total compensation for 2025.

There was an update on opportunity and risk management, compliance, and the results and recommendations of the internal audit. The Supervisory Board was informed about the current status of the implementation of the CSRD at FUCHS. It also dealt with the procedure and the assessment of the effects, risks and opportunities in accordance with the CSRD. Additionally, an update was given on the company's sustainability strategy.

Committee Structure

Audit Committee

The Audit Committee held five meetings in the reporting year. Two of the meetings were held via videoconference and three in person. The CFO and heads of the Finance and Controlling as well as Accounting departments regularly attended the meetings. The auditor was present at three meetings for individual agenda items. The committee focused on the annual financial statements and the audit of the annual financial statements of FUCHS SE and the consolidated financial statements together with the Combined Management report, the non-financial declaration, the Compensation Report, the requirements of the CSRD on sustainability reporting and compliance issues.

Other main topics were assessment of the quality of the auditor and a detailed discussion of the quarterly statements and half-year financial report prior to their publication. The Audit Committee, together with the external auditor, determined the key areas of focus for the audit of the reporting year, issued the audit mandate, granted general approval for permissible non-audit services by the auditor, and addressed new accounting and reporting regulations.

Additionally, the Audit Committee reviewed financial reporting, monitored the financial reporting process, and assessed the effectiveness of the internal control system, risk management system, and internal audit function.

Personnel Committee

The Personnel Committee advises the Supervisory Board on personnel matters pertaining to the Executive Board and prepares its decisions. In the reporting year, three meetings were held, all of which were conducted in person. In its meetings, the committee focused particularly on the upcoming changes in the Executive Board in 2025, especially the new appointments and the related resolution recommendations to the full committee. Other topics included the new Executive Board remuneration system, including the corresponding adjustment of Executive Board service contracts, the adjustment of pensions for former Executive Board members, the assessment of variable remuneration for the 2024 financial year, and the target remuneration for 2025.

Nomination Committee

The Nomination Committee advises the Supervisory Board on suitable candidates and nominates such candidates for the Board's proposals to the Annual General Meeting for the election of Supervisory Board members. The Nomination Committee convened once in person during the 2024 financial year and issued its recommendation for the election of shareholder representatives at the 2025 Annual General Meeting.

Supervisory Board Composition

As a financial expert, Ingeborg Neumann has expertise in accounting and auditing within the meaning of Section 100(5) of the German Stock Corporation Act (AktG) and of Recommendation D.3 p. 1 of the Corporate Governance Code. As Chairwoman of the Audit Committee, she thus also meets the requirements of Recommendation D.3 on p. 2 of the Code. Dr. Markus Steilemann is also a financial expert with expertise in the field of accounting within the meaning of Section 100(5) of the German Stock Corporation Act (AktG) and of Recommendation D.3 p. 1 of the Code.

Mr. Jens Lehfeldt and Ms. Cornelia Stahlschmidt are the employee representatives on the Supervisory Board.

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

There was an update on opportunity and risk management, compliance, and the results and recommendations of the internal audit. The Supervisory Board was informed about the current status of the implementation of the CSRD at FUCHS. It also dealt with the procedure and the assessment of the effects, risks and opportunities in accordance with the CSRD. Additionally, an update was given on the company's sustainability strategy.

The Supervisory Board established the sustainability factor for the Executive Board's variable compensation for the financial year 2024. It also decided on the criteria for measuring the sustainability factor for 2025 and the target total compensation for 2025.

The committee focused on the annual financial statements and the audit of the annual financial statements of FUCHS SE and the consolidated financial statements together with the Combined Management report, the non-financial declaration, the Compensation Report, the requirements of the CSRD on sustainability reporting and compliance issues.

Integration of sustainability-related performance in incentive schemes

The Supervisory Board established the sustainability factor for the Executive Board's variable compensation for the financial year 2024. It also decided on the criteria for measuring the sustainability factor for 2025 and the target total compensation for 2025.

Variable compensation for local, regional and global management is based on FVA (FUCHS Value Added). Entitlements to variable compensation are only granted when positive added value has been generated in the respective financial year.

Risk management and internal controls over sustainability reporting

There was an update on opportunity and risk management, compliance, and the results and recommendations of the internal audit. The Supervisory Board was informed about the current status of the implementation of the CSRD at FUCHS. It also dealt with the procedure and the assessment of the effects, risks and opportunities in accordance with the CSRD.

Additionally, the Audit Committee reviewed financial reporting, monitored the financial reporting process, and assessed the effectiveness of the internal control system, risk management system, and internal audit function.

In particular, the auditor confirmed that the Executive Board had set up a suitable monitoring system in accordance with Section 91 (2) of the German Stock Corporation Act (AktG) capable of identifying developments that jeopardize the continued existence of the company at an early stage.

Strategy, business model and value chain

LUBRICANTS. 100% focus

Our focus is 100% on the production, development, and distribution of highly efficient lubricant solutions and functional fluids. And on a high level of technical service. This clear orientation defines us. Our holistic products are tailored and customer-specific. We respond flexibly and quickly to challenges in a wide range of application areas and meet a wide range of national and international standards. We have a broad range of more than 10,000 products. It is roughly divided into automotive and industrial lubricants. In a highly fragmented market, FUCHS is a leading provider of systemic solutions with global reach. We are present in virtually all industry segments and provide holistic support to customers throughout the entire product lifecycle. Everywhere in the world.

TECHNOLOGY. Holistic solutions

Advanced, process-oriented and holistic solutions for lubricants and functional fluids are central to FUCHS' success. Almost 10% of employees are active in research and development. A worldwide network of professionals supports them with specialized skills so that intelligent solutions are created, tailored and customized: whether it is a single product, services or a digital solution. Or everything as a whole package. Our products and solutions reduce friction and wear, and sometimes even improve the manufacturing process itself, for example, with 360-degree project monitoring, digital lubricant monitoring, and sustainable supply processes. We continue to build our technology leadership in strategically important application areas. These include the areas of digitalization, new mobility, and sustainability. In doing so, we rely on the effectiveness, safety and sustainability of our lubricants and functional fluids along the entire process and value chain.

PEOPLE. Personal commitment

Over 6,700 employees around the world are committed to satisfaction of our customers and thus form the basis of our success. In an intensive and trusting dialogue with our customers, they are constantly working to offer the best lubricant solution and to fulfil our purpose of MOVING YOUR WORLD.

Global customer service through internationality and scale

FUCHS' business success is based on our global presence and our extensive product and customer portfolio. We are where our customers are. As of the end of the reporting period, out of our 80 operating subsidiaries and our 11 companies consolidated at equity, 58 were active in the Europe, Middle East, Africa (EMEA) region, 11 in the Americas, and 22 in the Asia-Pacific region. This broad geographical structure allows FUCHS to serve global customers worldwide while also offering local customers tailor-made solutions on site.

With more than 10,000 products, FUCHS not only ensures that the increasing specialization requirements of mature markets are met, but is also able to participate in the growth of developing markets. The diversification across regions and industries helps to balance economic and sector-specific cycles.

Group structure

Simple Group structure with largely decentralized management

FUCHS' Group structure has been kept intentionally simple. FUCHS usually holds 100% of the shares in its subsidiaries. Exceptions to this are the joint ventures and associates in Germany, Africa, the Middle East, Saudi Arabia, and Turkey.

The companies are organized into the three geographical regions of EMEA, Asia-Pacific, and North and South America, which is reflected in the management and reporting system. Business is generally managed by the local subsidiaries and the regional managers in charge of them. In addition, local managers are increasingly included in our global excellence networks. Within these networks, joint solutions for current challenges and issues are developed based on an exchange of experience and knowledge across national and corporate boundaries.

Customer Segmentation

Product Portfolio

FUCHS 2025 Strategy

With digitalization, e-mobility, globalized customer requirements, and sustainable products and solutions, FUCHS lives in a highly dynamic world full of new challenges. We see these challenges as opportunities to shape our future and continue to succeed. Our FUCHS 2025 strategy and transformation program, published in July 2020, represents this commitment, and we will continue its consistent implementation through 2025.

Being First Choice Vision

With the "Being First Choice" vision, we are reinforcing and expressing our sharpened focus. Building on our strengths, we want to be first choice worldwide: for customers, employees, and investors.

Six Strategic Pillars

Global strength

• Use segmentation as a basis for strategic and global business development and align the organization accordingly
• Generate above-average growth in Asia-Pacific and North and South America, thereby achieving a balance between our regions
• Enhance brand appeal by 2025 with strong, differentiated positioning and clear brand architecture in all relevant FUCHS segments

Customer and Market Focus

• Establish the greatest possible proximity to customers – strengthen the principle of "one face to the customer" and take advantage of cross-selling opportunities: become the full-line supplier for our customers
• Increase our market share in order to taking a leading position in our target segments
• Develop a global service portfolio by 2025 – from a product-oriented to a solution-oriented approach
• Systematically introduce new business models in the broader lubricant environment

Technology leadership

• Encourage innovation-oriented thinking and strengthen our innovative capabilities. Strengthen / establish our technology leadership in all defined target segments
• Introduce digital solutions and platforms to establish even closer connections with our customers beyond lubricants
• Strengthening regional structures and leveraging the expertise and know-how of the three R&D centers in China, the USA and Germany at a global level

Operational Excellence

• Establish a global production and sales network; independent supply and technology centers in the three global regions by 2025
• Further standardize production and procurement processes, equipment, and output in order to improve efficiency in the supply chain
• Establish data transparency on the basis of global structures and harmonization of systems

People and Organization

• Be the preferred employer for existing and future employees
• Optimize working conditions and promote global cooperation
• Further improve development programs, skills models, and succession planning; strengthen global recruitment and retention of talented employees
• Promote the internationalization of business units, remote leadership, international job changes, etc.

Sustainability

• Economic sustainability: Annual sales revenues growth in the mid-single-digit percentage range, EBIT of €500 million as the target and an EBIT margin of around 15% at Group level in the long term, an average cash conversion rate of 0.8 and an annual increase in the dividend
• Environmental sustainability: Net zero emissions targets for Scope 1 and 2 emissions by 2040 and Scope 3 emissions by 2050. Conversion of FUCHS sites to green electricity by 2025
• Social sustainability: Each FUCHS company invests at least 0.1% of local EBIT in social projects every year

Further development FUCHS 100

Our FUCHS 2025 strategy cycle ends with the 2025 financial year. We are already working on its evolution through our new strategy program, FUCHS 100, which will be published at the end of 2025. Building on FUCHS2025, FUCHS100 will be more of an evolution than a revolution. We plan to increase focus and achieve disproportionate growth in a few defined areas. And of course, we will set new goals – for 2031, the year in which FUCHS will celebrate its 100th anniversary.

Increase in company value

With FUCHS 2025, FUCHS is continuing to pursue the objective of continually increasing the company's value. We create value for our customers, employees and shareholders. Securing and strengthening our market position in mature markets and sustainably expanding our market position in emerging markets form the basis for this. The conditions for achieving these goals are created through organic growth and – insofar as prudent and possible – external growth, as well as through activities to secure the technological leadership of the FUCHS Group.

Independent lubricant manufacturer

Maintaining the independence of FUCHS SE remains a factor of particular strategic importance. Our independence enables us to focus on lubricants and related specialties in an efficient environment, while providing scope to further increase company value. It is based, firstly, on the Fuchs family as an anchor shareholder and, secondly, on stable financial support, which allows a sustainable dividend policy and also creates scope for acquisitions.

Interests and views of stakeholders

FUCHS relies on an intensive dialogue with its shareholders, analysts and all other capital market participants. The aim is to strengthen trust in our company on a sustained basis. All capital market participants are always informed promptly, transparently, and comprehensively of all major events in the FUCHS Group.

In recent years, the company stepped up its investor relations activities. In 2024, the Chair of the Executive Board, the Chief Financial Officer, and the Investor Relations team shared information through international conferences and roadshows as well as in numerous one-on-one meetings with institutional investors and maintained regular contact with retail investors.

The public were also kept regularly informed of current developments through press releases and ad hoc disclosures. Furthermore, the Investor Relations team was always available by phone and email.

In an intensive and trusting dialogue with our customers, they are constantly working to offer the best lubricant solution and to fulfil our purpose of MOVING YOUR WORLD.

FUCHS SE has been offering employees at the companies in Germany employee shares at preferential conditions since 1985. In 2024, each employee could purchase a maximum of 30 shares at a discount of €5 per share. Overall, 386 (402) employees made use of this opportunity, purchasing 10,893 (11,483) shares in total.

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

List of Material IROs

FUCHS has identified 16 material impacts, risks and opportunities (IROs) as part of the double materiality analysis in accordance with ESRS 1 3.3. These IROs are included in the opportunity and risk reporting and taken into account in the Group's overall risk profile.

Material Impacts, Risks and Opportunities:

Linkage to Strategy and Business Model

Strategic Pillars: Six strategic pillars were defined as part of the FUCHS2025 Strategy: "Global Strength," "Customer & Market Focus," "Technology Leadership," "Operational Excellence," "People & Organization," and "Sustainability."

The positive and negative impacts of FUCHS' activities on the environment and people can be attributed to the strategic pillars "People & Organization," "Technology Leadership," and "Sustainability."

Business Model Alignment:

• Since the FUCHS business model is designed for the long term, all positive and negative impacts, as well as all risks and opportunities, are short-, medium-, and long-term in nature.
• The mobility transition is addressed within the strategic pillar "Customer & Market Focus" to continue meeting customer needs in the future.
• With the FUCHS2025 strategy, FUCHS aims to achieve technology leadership in its business fields.
• Employee development and workforce engagement are core elements of the strategic pillar "People & Organization."

Interaction with Strategy and Business Model

Climate Change:

• The Net-Zero strategy aims to reduce CO2 emissions for Scope 1 and 2 to near zero by 2040 and for Scope 3 by 2050.
• FUCHS is actively engaged in the development, production, and distribution of lubricants for alternative technologies such as e-mobility, fuel cells, and alternative fuels.
• The transition in mobility brings additional requirements for lubricants and creates significant opportunities for the development of new products.

Resource Use and Circular Economy:

• As part of the Net-Zero strategy, FUCHS aims to continuously switch to biomass-based raw materials or recycled materials from circular sources.
• FUCHS products extend the service life and enhance energy efficiency of customer equipment, thereby conserving resources.

Own Workforce:

• Attracting and retaining the best employees is crucial to FUCHS' success.
• FUCHS places great emphasis on employee promotion, development, and health programs.
• The company is committed to protecting employee rights and fostering respectful and fair interactions.

Value Chain Workers:

• FUCHS considers the protection of human rights a prerequisite for sustainable business relationships.
• The company has implemented the Supplier Code of Conduct (SCoC) and uses IntegrityNext software for supplier assessments.

Business Conduct:

• FUCHS is committed to clear principles and values, assuming corporate, ethical, environmental, societal, and social responsibility.
• Corporate culture is regarded as an essential element of the corporate strategy and is systematically developed in every strategic cycle.

Financial Effects

There have been no current financial impacts from significant risks and opportunities on the financial position, financial performance, or cash flows in the current financial year.

The possible risks and opportunities could have the following financial effects on EBIT and cash flow in the financial year 2025 (95% Value at Risk in € million):

FUCHS' process technologies for manufacturing engine and transmission oils can be adapted for the production of other industrial oils in the event of a decline in demand.

Resilience to Material IROs

Business Model Resilience: The FUCHS business model and strategy demonstrate high resilience to potential sustainability-related risks:

• FUCHS can rely on a broad network of suppliers for various raw, auxiliary, and operational materials, which can be sourced from multiple world regions.
• The diversified product portfolio includes over 10,000 products that can be manufactured at multiple global locations.
• The customer portfolio is extensive and geographically diverse.
• The skilled workforce is trained and encouraged to adopt a "growth mindset" that embraces change.
• FUCHS' financial strength, combined with its research and development capabilities, enables the company to continuously adapt to market and environmental developments.

Climate Resilience: A climate resilience analysis was conducted in 2024 covering approximately 88% of the replacement value of fixed assets across all FUCHS companies. The analysis examined both physical climate risks (floods, wildfires, droughts) and transitional climate risks (regulatory and societal shifts toward a carbon-neutral economy).

Key findings:

• Physical climate risks: Sites in Mannheim (Germany) and Suzhou (China) face high flood risk; Castellbisbal (Spain) faces high drought and wildfire risk. After resilience-enhancing measures, net risks were assessed at medium to moderate levels.
• Transitional climate risks: Limited availability of biogenic materials combined with increased demand could lead to rising prices. FUCHS is adapting by transitioning to biomass-based and recycled raw materials and expanding its product portfolio to align with technological shifts.
• No significant "locked-in" emissions have been identified that would hinder the achievement of the 2040 targets for Scope 1 and 2.

Supply Chain Resilience: FUCHS is less vertically integrated, allowing the company to replace certain suppliers or raw materials if needed, provided that product performance and customer approval allow it. Through its decentralized structure with 42 production sites worldwide and local procurement capabilities, FUCHS ensures its supply chains.

Workforce Resilience: To mitigate risks associated with demographic change and labor shortages, FUCHS implements various strategic countermeasures including strengthening the employer brand, implementing training and development programs, exploring automation and digitalization, and strengthening knowledge transfer and succession planning.

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

Double materiality assessment methodology

The starting point for the double materiality assessment was a stakeholder survey in which representatives from ten different stakeholder groups evaluated the relevant topics, subtopics, and sub-subtopics of the ESRS using a questionnaire. In a second step, key topics were identified through a materiality assessment or an IRO assessment. Workshops with FUCHS experts and external consultants were conducted to discuss the relevant sustainability matters of ESRS 1 AR16 for each topic. The aim was to identify sustainability-related topics where FUCHS' activities either have an impact on the environment or people (inside-out perspective) or where there are risks and opportunities for FUCHS (outside-in perspective). A topic is considered material if a significant IRO is present in either dimension (double materiality).

Inputs to the assessment

Stakeholder survey: Representatives from ten different stakeholder groups evaluated the relevant topics, subtopics, and sub-subtopics of the ESRS using a questionnaire.

IRO workshops: Workshops with FUCHS experts and external consultants were conducted to discuss the relevant sustainability matters of ESRS 1 AR16 for each topic. Participants were selected to ensure that FUCHS internal experts could incorporate the perspectives of stakeholders. For example, the interests of customers, suppliers, employees, and ESG rating agencies were specifically taken into account through internal representatives. Additionally, all workshops were accompanied by external experts from a consulting firm.

Data sources for climate risk analysis:

• Double materiality assessment
• Procurement list of key raw materials and suppliers
• Risk management information
• Overall strategy and governance structures
• Building energy performance certificates and resilience measures
• Building values and insured risks
• Sustainability strategy
• CO2 emissions
• Share of coal, gas, and oil in total energy consumption
• Revenue and margins with key customers and key product groups

Value chain coverage

The evaluation covered the entire FUCHS value chain. Since FUCHS operates under a homogeneous business model focused on the production and distribution of lubricants and functional fluids, neither the consultants nor the working groups deemed it necessary to analyze specific activities separately. The upstream and downstream value chain was considered in all workshops.

In the IRO workshops, every analysis included the assessment of impacts, risks, and opportunities related to FUCHS' own operations as well as its business relationships. For this purpose, a tabular overview was used to record, in separate columns, where in the value chain the impact, risk, or opportunity could occur.

Scoring criteria for impact materiality

Actual impacts: The severity score was determined by summing:

• Scale (the gravity of the negative impact or the benefit of the positive impact)
• Scope (the extent to which positive or negative impacts are widespread)
• Irremediability (whether and to what extent the negative impact can be remediated)

Each parameter has a maximum of 5 points, resulting in a maximum score of 15 for actual impacts. The median is 7.5 for actual impacts.

Potential impacts: For potential impacts, the severity score was multiplied by likelihood of occurrence. With a likelihood of, for example, 50%, a maximum score of 7.5 applies to potential impacts. The median is 3.75 for potential impacts.

Scope of impact scale:

Geographical impact was included as part of the scale used to assess the scope of impact. Specific geographical factors were conceptually integrated into a five-tier scale used to evaluate all impacts.

Likelihood for potential impacts: For potential impacts, risks, and opportunities, the likelihood of occurrence was also taken into account to determine the materiality level.

• Likelihood of occurrence ≤ 10% (unlikely)
• Likelihood of occurrence > 10% to ≤ 25% (possible)
• Likelihood of occurrence > 25% to ≤ 50% (likely)
• Likelihood of occurrence > 50% (very likely)

Scoring criteria for financial materiality

Impacts, risks, and opportunities were assessed based on scale, scope, time horizon, irremediability, and likelihood. The financial effect of risks and opportunities was assessed using a five-tier scale in line with the risk management system.

IRO workshops assessed risks and opportunities with regard to their impact on the value chain, the short, medium or long-term monetary impact on the financial position, financial performance and cash flows, the geographical impact, the regional impact of the FUCHS sites and the regional impact on the people affected.

Sustainability risks are assessed in the same way as other risks within the risk management system.

Threshold for materiality

Actual impacts: The threshold for actual impacts was set at 6, meaning only one value below the median had to be reached for an impact to be classified as material. This analysis represents a conservative approach and tends to classify impacts as material even when the median has not yet been reached.

Potential impacts: The threshold for potential impacts was set at 3.

Threshold values were set for impacts, risks, and opportunities. Impacts, risks, and opportunities were classified as material if the materiality score exceeded these thresholds.

Stakeholder consultation process

The affected stakeholders were initially consulted as part of the stakeholder survey. During the IRO workshops, participants were selected to ensure that FUCHS internal experts could incorporate the perspectives of stakeholders. Nature was considered as a silent stakeholder in the workshops for the discussions and evaluations.

The results of the stakeholder analysis were compared with the findings from the IRO workshops. If topics were classified as material or non-material in both the stakeholder analysis and IRO workshops, they retained that classification. In cases of differing classifications, the IRO workshop results took precedence over the stakeholder analysis, as they were based on a more in-depth assessment conducted by experts under the guidance of an external consultancy.

Material topics identified

As a result, the topics of climate change, resource use and circular economy (excluding waste), own workforce, workers in the value chain, and business conduct (excluding management of relationships with suppliers, political influence and lobbying activities, and payment practices) were classified as material for FUCHS.

Process to identify, assess, prioritize, and monitor impacts

The prioritization of actual and potential impacts is based on the materiality assessment. For actual impacts, materiality assessment was equivalent to severity assessment.

The monitoring of impacts is operationally managed by the Global Functions for global impacts, while local impacts are overseen by the respective management teams. Overall responsibility lies with the company's Executive Board.

Frequency of review

The annual review of IROs within the risk reporting framework ensures continuous updating, evaluation, and prioritization of the IROs.

Integration with risk management

The risk management system has been adapted to meet the requirements of CSRD reporting. Starting from the financial year 2024, impacts, risks, and opportunities related to sustainability can be assigned to a sustainability topic under ESRS 1 AR16. These sustainability-related IROs are now part of the established risk management system. IROs are recorded twice a year by local companies or, for group-wide relevant topics, at the Global Functions level within the risk reporting system.

Methodology alignment

The fundamental approach and scales used align with the EFRAG IG 1: Materiality Assessment Implementation Guidance, May 2024 (formerly: [Draft] ESRG 1 Double materiality conceptual guidelines for standard-setting Working paper, January 2022).

Transition plan for climate change mitigation

Scope and coverage

The FUCHS Net-Zero strategy aims to reduce CO2 emissions for Scope 1 and 2 to near zero by 2040 and for Scope 3 by 2050. The scope of the 'FUCHS Net Zero 2040/50 Strategy' includes all fully consolidated FUCHS companies as well as associated companies and joint ventures through their contribution to Scope 3 category 15.

The scope is global and refers to the "cradle-to-grave" approach.

Net-zero target years and interim milestones

Scope 1 and 2 targets:

• 2030 short-term target: At least 42% reduction by 2030 (baseline year: 2021)
• 2040 net-zero target: At least 90% reduction by 2040 (baseline year: 2021)
• Near-zero Scope 1 and 2 GHG emissions by 2040

Scope 3 targets:

• 2035 short-term target: At least 25% reduction by 2035 (baseline year: 2023)
• 2050 net-zero target: At least 90% reduction by 2050 (baseline year: 2023)
• Total cradle-to-grave emissions reduction by at least 90% by 2050, including Scope 3

Baseline years:

• Scope 1 and 2: 2021
• Scope 3: 2023

Performance to date:

• Scope 1 and 2 GHG emissions reduced by around 29.9% compared to base year 2021
• Scope 3 GHG emissions marginally increased by 0.4% compared to base year 2023

Alignment with Paris Agreement / SBTi validation

FUCHS aligns with the Paris Climate Agreement of 2015, aiming to limit global warming to 1.5 degrees Celsius, and follows the guidelines of the Science Based Targets Initiative (SBTi). The underlying emissions calculations are based on the GHG Protocol Corporate Accounting and Reporting Standard.

The ambition and timeframe for the Scope 1 and 2 reduction-targets are in line with the SBTi guideline for 1.5 degrees Celsius at the time the target is officially set.

The timeframe for the short-term Scope 3 reduction target is in accordance with the SBTi guideline with the earliest officialization of the targets in 2025, whereby the ambition of the Scope 3 target corresponds to a "well below 2 degrees Celsius pathway".

FUCHS has decided not to seek an official validation of its targets by SBTi at this time. The targets have not been externally audited. FUCHS is closely following the development of a sector specific SBTi standard for the chemical industry, which has not yet been released.

There is currently no binding sectoral decarbonization pathway for the lubricants or chemical industry.

Key decarbonization levers and actions

Scope 1 reduction measures:

• Lowering fossil fuel consumption
• Electrifying the vehicle fleet and processes
• Gradually converting the global vehicle fleet to zero-emission vehicles
• Converting heating systems to low-emission alternatives

Scope 2 reduction measures:

• Transitioning to renewable, low-emission energy sources
• Switching all global sites to green electricity by 2025, where technically feasible
• Increasing the share of renewable energy in the power supply
• Expanding on-site solar power installations to cover base-load electricity consumption
• Energy savings through ISO 50001 certification of key production sites by 2027

Scope 3 reduction measures:

• Continuously switching to biomass-based raw materials or recycled materials from circular sources
• Promoting the circular economy
• Reducing emissions along the entire value chain
• Replacing fossil-based materials by renewable alternatives wherever possible
• Minimizing waste
• Product portfolio transition from fossil-based raw materials to renewable raw materials

Product-related actions:

• FUCHS lubricants are designed to enhance efficiency across a wide range of applications, reducing wear and corrosion and extending service life
• Development, production, and distribution of lubricants for alternative technologies such as e-mobility, fuel cells, and alternative fuels
• Thermofluids for cooling batteries and functional fluids for electric drivetrains

Energy efficiency measures:

• General process improvements
• Product-specific process optimizations
• Investments in alternative heating systems
• Thermal insulation of buildings
• ISO 50001 energy management standard adoption

Green electricity procurement instruments:

1. Direct power purchase agreements for green electricity with local energy suppliers ("bundled")
2. Power Purchase Agreements (PPAs) directly with electricity producers
3. Purchase of Guarantees of Origin (CoO/GoO) or Renewable Energy Certificates (REC/I-REC) from the regional power grid ("unbundled")

CapEx and investment commitments

In 2024, €64.2 million of FUCHS' total €214.9 million in investments were allocated to sustainable investments. These primarily include investments in electric vehicles, EV charging stations, energy-efficient technologies, and energy-efficient building renovations.

Investment budget targets:

• Investments to reduce Scope 1 and 2 GHG emissions may account for up to 10% of the annual CapEx
• Additional costs to reduce Scope 3 GHG emissions from purchased alternative raw materials may amount to a maximum of €3 million annually

Given FUCHS' decentralized organizational structure, there is no central budget or investment plan dedicated to achieving sustainability targets. It is the responsibility of each subsidiary to plan the required budget locally. Subsidiaries are encouraged to allocate up to 10% of their annual CapEx budget for sustainable investments aimed at reducing Scope 1 and 2 GHG emissions.

Locked-in emissions and stranded assets

Potential significant "locked-in" emissions could arise from production sites and the installed heating systems within those facilities. However, due to the nature of FUCHS' production processes and the relatively lower energy demand compared to other chemical industry companies, Scope 1 and 2 GHG emissions represent a smaller share of total emissions. According to current projections, no 'locked-in' emissions have been identified that would hinder the achievement of the 2040 targets for Scope 1 and 2 under the "FUCHS Net Zero 2040/50 Strategy".

The transition of FUCHS' product portfolio to renewable raw materials does not require major changes in technical production processes. As a result, no significant "locked-in" emissions exist within production facilities.

FUCHS products themselves do not contain "locked-in" emissions, as lubricants are designed to reduce emissions by enhancing efficiency and minimizing friction.

FUCHS has no significant CapEx amounts to report for the financial year in connection with economic activities in the coal, oil, and gas sectors.

FUCHS is not exempt from the Paris-aligned EU benchmarks.

Use of carbon credits and removals

Not disclosed in the provided excerpts.

Governance and accountability

Responsibility and monitoring of the climate protection strategy lies with the Chief Technology Officer (CTO), a member of the Executive Board.

The sustainability strategy, including the Net-Zero strategy, was presented to the Group Management Committee (GMC) and approved by the Executive Board. The key points of the "FUCHS Net Zero 2040/50" strategy were also presented to the Supervisory Board during the reporting year.

The initial Net-Zero strategy was approved in April 2023, including further adjustments in 2024, such as guidelines for cost allocation for measures to reduce Scope 1, 2 and 3 GHG emissions.

Detailed Scope 1, 2, and 3 reduction targets have been assigned to FUCHS subsidiaries. Individual target breakdowns for each subsidiary and calendar year up to 2040 and 2050 are provided to all FUCHS subsidiaries.

Stakeholder engagement

The "FUCHS Net Zero 2040/50 Strategy" has been largely shaped by customer interests, which are driven by new regulatory requirements. In its latest form, the strategy was presented to a selected group of investors at the Capital Market Day on December 5, 2024. The presentation was published on the FUCHS website. FUCHS sales units present the strategy to customers as needed, and the procurement organization regularly shares it with selected suppliers.

FUCHS has set the targets without involving other stakeholders in the target-setting process.

Climate risk management

Physical risks: The identified physical climate risks primarily relate to flood risks in Mannheim, Suzhou (China), and Fairhaven (USA), as well as wildfire risks in Castellbisball (Spain), Ambernath (India), and Beresfield (Australia). Additionally, other individual plants and locations could be affected by natural disasters, which may intensify due to climate change.

In 2024, a climate risk analysis was conducted for the first time with the support of an external consulting firm to assess the impact of climate change on the FUCHS business model.

To mitigate potential climate risks, FUCHS relies on a combination of internal and external measures, including:

• Establishment of rainwater retention basins and fire ponds
• Collaboration with local authorities to implement drainage and flood control measures
• Group-wide property and business interruption insurance policy with a deductible of €5 million

FUCHS companies with increased climate risk potential continuously develop local concepts for climate change adaptation. Where legally required, the adaptation concepts are coordinated with local authorities. Responsibility for creating these adaptation concepts lies with regional or local production managers.

Transition risks identified:

• Higher costs and investments due to the transition to low-emission energy and lack of availability of low-emission energy
• Changes in the legal and regulatory environment (e.g. sustainability reporting and due diligence obligations)
• Decline in the market share of combustion engines in certain regions
• Transition from fossil to biomass-based and recycled raw materials – availability and price

Business model considerations

FUCHS will largely maintain its overall business model while gradually transitioning its products from fossil-based raw materials to renewable raw materials to reduce its carbon footprint. The development, manufacture and distribution of lubricants are outside the scope of the EU Taxonomy Regulation, so revenues that are subject to Taxonomy cannot be derived.

FUCHS is exploring long-term business model innovations to transition from a linear to a circular value chain, with a primary focus on reintroducing used lubricants into material recycling to create new raw materials for lubricants. Achieving this goal requires collaboration with partners across the downstream value chain.

Within the strategic pillar "Customer & Market Focus," FUCHS addresses the mobility transition to continue meeting customer needs in the future. FUCHS is actively engaged in the development, production, and distribution of lubricants for alternative technologies such as e-mobility, fuel cells, and alternative fuels.

Policies related to climate change mitigation and adaptation

FUCHS Net Zero 2040/50 Strategy

Policy name and scope: FUCHS has developed the "FUCHS Net Zero 2040/50 Strategy" to reduce the company's CO₂ emissions for Scope 1 and 2 to zero by 2040 and for Scope 3 by 2050. The scope includes all fully consolidated FUCHS companies as well as associated companies and joint ventures through their contribution to Scope 3 category 15.

Key content and principles:

• FUCHS is committed to reducing Scope 1 and 2 GHG emissions by at least 42% by 2030 and by at least 90% by 2040, each compared to the base year 2021
• FUCHS aims to reduce Scope 3 GHG emissions by at least 25% by 2035 and by at least 90% by 2050, each compared to the base year 2023
• The strategy includes decarbonization levers covering measures to reduce direct emissions (Scope 1) through lowering fossil fuel consumption and electrifying vehicle fleet and processes; indirect emissions from purchased energy (Scope 2) by transitioning to renewable, low-emission energy sources; and indirect emissions in the upstream and downstream value chain (Scope 3) by utilizing renewable materials and minimizing waste
• FUCHS has committed to switching all global sites to green electricity by 2025, where technically feasible
• The strategy includes transitioning from a linear to a circular value chain, with primary focus on reintroducing used lubricants into material recycling
• The business model will gradually transition products from fossil-based raw materials to renewable raw materials

International standards and guidelines: The strategy aligns with:

• The Paris Climate Agreement of 2015, aiming to limit global warming to 1.5 degrees Celsius
• Guidelines of the Science Based Targets Initiative (SBTi)
• GHG Protocol Corporate Accounting and Reporting Standard
• The ambition level and timeline for the Scope 1 and 2 reduction targets are consistent with the SBTi's 1.5 degrees Celsius guideline
• The timeframe for the short-term Scope 3 reduction target corresponds to a "well below 2 degrees Celsius pathway"

Governance and oversight:

• Responsibility and monitoring of the climate protection strategy lies with the Chief Technology Officer (CTO), a member of the Executive Board
• The initial Net-Zero strategy was approved by the Executive Board in April 2023, with further adjustments in 2024
• The strategy was presented to a selected group of investors at the Capital Market Day on December 5, 2024

Public availability: The presentation was published on the FUCHS website. FUCHS sales units present the strategy to customers as needed, and the procurement organization regularly shares it with selected suppliers.

Implementation monitoring:

• FUCHS calculates its "cradle-to-grave" emissions annually and compares them with the defined target pathways
• Individual target breakdowns for each subsidiary and calendar year up to 2040 and 2050 are provided to all FUCHS subsidiaries, which also include the reduction effect of the planned decarbonization levers
• In 2024, FUCHS achieved a reduction in Scope 1 and 2 GHG emissions of around 29.9% compared to the base year 2021
• Progress is tracked through the course book process for Scope 1 and 2, with Global Purchasing function responsible for monitoring Scope 3
• Subsidiaries are encouraged to allocate up to 10% of their annual CapEx budget for sustainable investments aimed at reducing Scope 1 and 2 GHG emissions
• In 2024, €64.2 million of FUCHS' total €214.9 million in investments were allocated to sustainable investments, primarily including investments in electric vehicles, EV charging stations, energy-efficient technologies, and energy-efficient building renovations

Climate Change Adaptation Policies

Scope: FUCHS conducted a climate risk analysis in 2024 to address physical risks related to climate hazards such as floods and wildfires.

Key content:

• FUCHS continuously develops local concepts for climate change adaptation
• FUCHS focuses on companies with increased climate risk potential when developing climate change adaptation concepts
• Where legally required, the adaptation concepts are coordinated with local authorities

Governance: Responsibility for creating adaptation concepts lies with regional or local production managers.

Implementation monitoring: The implementation of adaptation concepts is monitored by the national companies within the framework of the decentralized FUCHS organization. Local regulatory and country-specific requirements are taken into account and supported by key certifications such as ISO 14001 "Environmental Management Systems".

Green Electricity Transition Policy

Scope: FUCHS has committed to switching all global sites to green electricity by 2025, where technically feasible and where green electricity or comparable contractual instruments are available.

Key content: This early transition is a core element of the climate protection strategy and ensures FUCHS cost-effective and long-term access to global green electricity markets.

Governance: The Chief Technology Officer (CTO) is responsible for overseeing the progress of this transition.

Implementation monitoring:

• During the reporting year, additional FUCHS companies engaged with potential suppliers of green electricity or relevant contractual instruments
• In the course of 2024, the share of green electricity in the total electricity consumption of all FUCHS subsidiaries has risen to 76%
• Customers requesting a switch to green electricity are continuously updated on FUCHS' objectives

Mobility Transition Strategy

Scope: The FUCHS strategy for the mobility transition, approved by the Executive Board and applied globally, primarily concerns the downstream value chain and directly impacts customers.

Key content:

• FUCHS views the mobility transition and associated additional requirements for lubricants as an opportunity to demonstrate its technological leadership
• The trend toward electric motors creates opportunities for demand in new product categories, particularly thermal fluids for battery cooling and specialized fluids for electric drivetrains
• FUCHS focuses on regions where internal combustion engines will continue to be used for an extended period while preparing to serve alternative technologies, including non-fossil fuels

Implementation monitoring: The effectiveness of these measures is tracked within the normal sales processes using both qualitative and quantitative indicators, such as the strength of the project pipeline and sales figures at the customer segment level.

Targets related to climate change mitigation and adaptation

Climate change mitigation targets

Scope 1 and 2 GHG emissions reduction

Scope 3 GHG emissions reduction

Total cradle-to-grave emissions (Net Zero target)

Energy transition targets

Investment budget targets

2030 projected emissions (from waterfall chart)

• 2030 emissions after target measures: 31,839 t CO2e (Scope 1+2)
• Reduction contributions quantified:
  • Scope 1 electrification of fleet and processes: -7,822 t CO2e
  • Scope 1 reduction in fossil fuel use: -9,119 t CO2e
  • Scope 2 transition to renewable energy: -13,151 t CO2e
• 2030 short-term target: 36,004 t CO2e (representing 42% reduction from 2021 baseline)
• 2040 long-term target: 6,208 t CO2e (representing 90% reduction from 2021 baseline)

Energy consumption and mix

FUCHS reported energy consumption for the 2024 financial year in accordance with ESRS E1-5 (now E1-7). The scope covers all fully consolidated subsidiaries globally. Methodology follows the GHG Protocol Corporate Accounting and Reporting Standard. Data for fuel consumption from natural gas and LPG (crude oil products) are reported in gross calorific value.

Energy consumption by source (2024)

Additional metrics

• Generation of non-renewable energy: 14,158 MWh
• Generation of energy from renewable sources: 3,645 MWh
• Total energy consumption from activities in high climate impact sectors: 274,210 MWh
• Net revenues from activities in high climate impact sectors: €3,525 million
• Energy intensity: 77.8 MWh per €1 million revenue

Scope and methodology notes

• All FUCHS activities fall under NACE category C.19.20.0 (Mineral oil processing), classified as a 'high climate impact sector' under ESRS.
• Green electricity share in total electricity consumption reached 76% in 2024, including contractually sourced green electricity (bundled and unbundled) and self-consumed electricity from own generation.
• For nuclear sources, national electricity mix assumptions are used where applicable.
• Gross calorific values used for natural gas and LPG fuel consumption; corresponding emission factors applied accordingly.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1: Direct GHG emissions

Total Scope 1 emissions (2024): 30,848 t CO₂e (2023: 30,917 t CO₂e)

Scope 1 sub-breakdown:

Biogenic CO₂ emissions (2024): 52 t CO₂ (2023: 155 t CO₂)

Scope 2: Indirect GHG emissions from purchased energy

Scope 3: Indirect GHG emissions from value chain

Total Scope 3 emissions (2024): 2,296,024 t CO₂e (2023: 2,211,700 t CO₂e)

Scope 3 breakdown by GHG Protocol category:

Total GHG emissions

GHG intensity

Methodology and scope notes

• Consolidation approach: Operational control
• Reporting period: January 1 to December 31, 2024
• Standard used: GHG Protocol Corporate Accounting and Reporting Standard
• Scope 1: Includes stationary combustion (natural gas, heating oil, LPG) and mobile combustion (company vehicles). Calculations based on consumption data and IEA, IPCC, and GEMIS emission factors.
• Scope 2: Location-based approach uses IEA emission factors. Market-based approach uses supplier-specific factors where available, residual mix factors for green electricity contracts, and location-based factors otherwise.
• Scope 3: Category 1 (Purchased goods and services) represents the largest share. Calculations partially based on spend-based method using Quantis emission factors and supplier-provided data where available. Categories 2, 5, 8-15 not disclosed.
• Biogenic emissions: Reported separately from Scope 1, arising from biodiesel use in company vehicles.
• Intensity metrics: Based on market-based Scope 2 emissions. Net revenue of €3,525 million and product sales volume of 558,721 tonnes.
• Coverage: All fully consolidated entities included. Joint ventures and associates considered only for Scope 3.15 (not disclosed separately).
• Acquisitions: LUBCON Group and STRUB AG acquired in 2024; data estimated based on comparable FUCHS entities.

Pollution of air, water and soil

Materiality Assessment

FUCHS conducted a review of its locations and business activities to assess actual and potential impacts, risks, and opportunities related to pollution. Both its own activities and the upstream and downstream value chains were considered. The review was conducted as part of a stakeholder survey in which various stakeholder groups were directly or indirectly involved.

Relevant departments (Sustainability, Operations, EH&S) have detailed knowledge about the production process, which does not differ significantly at the location level. This process was analyzed concerning air, soil, and water pollution and was deemed not material, provided that local regulations on water purity, soil contamination, and air emissions are met.

Pollution Prevention Measures

The results showed that pollution in the lubricant manufacturing process does not play a significant role, as legal limits are adhered to and measures to prevent contamination are implemented.

Water Discharges

FUCHS' water usage in production is comparatively low compared to other industries, with water consumption largely limited to sanitary facilities. Moreover, FUCHS complies with local regulations for wastewater discharge at its locations.

Environmental Obligations (Soil Contamination)

The provisions for environmental obligations focus on rehabilitation work at contaminated sites and cover costs associated with the elimination of soil contamination.

Non-current provisions for environmental obligations:

Conclusion

No quantified emissions to air (NOx, SOx, SO2, PM, VOC, heavy metals), water (heavy metals, nutrients, BOD/COD), or soil are disclosed. The topic was assessed as not material based on compliance with local regulations.

Impact metrics related to biodiversity and ecosystems change

Land Use

Fuchs Petrolub states that in investments in own energy production, the company mainly focuses on PV roof systems to avoid additional land use. No quantified land use footprint in hectares or km² is disclosed for own operations or value chain.

Other Biodiversity Impact Metrics

No quantified metrics are disclosed for:

• Deforestation footprint
• Operations or sites in or near protected areas or Key Biodiversity Areas (KBAs)
• Species impact metrics (e.g., Red List species affected)
• Ecosystem condition metrics
• Restoration metrics

ESRS E5-4 Resource Inflows

Disclosure Statement

Fuchs Petrolub reports resource inflow information in the context of its Net-Zero strategy and transition from fossil to biomass-based and recycled raw materials. However, no quantitative breakdown of total inflows by weight, biological vs. non-biological materials, or percentages of renewable/recycled materials is provided in the sustainability statement.

Qualitative Context on Resource Inflows

The company states that "most of the raw materials and packaging used by FUCHS are based on fossil resources" (p. 177). The procurement strategy is described as "Reduction of total cost of ownership while enabling transformation to net zero".

Key Resource Categories

Key resource inflows include (p. 177):

• Base oils
• Additives
• Packaging materials (metal and plastic)
• Water (in smaller quantities for production and sanitary purposes)
• Technical equipment and machinery for manufacturing

Transition to Renewable Materials

FUCHS has identified the use of recyclable materials (recycled, renewable, biogenic) as a key decarbonization lever to reduce Scope 3 emissions (p. 177). The company aims to:

1. Recycled raw materials, mainly sourced from used oil recycling or other post-consumer recycling streams. Available quantities with sufficient quality at market-competitive prices remain limited.

2. Biogenic/bio-based materials produced from plant-based materials, preferably from biomass waste streams to avoid conflict with food production. These materials are available today but in very limited quantities and at prices not yet comparable to fossil resources (p. 174).

Packaging Recyclability

The recyclable proportion of packaging is approximately 74% (p. 179). This was determined based on an expert assessment by the global purchasing department, weighted by packaging mix. Since May 2024, all FUCHS-owned small automotive core-design packaging used in Europe has reached 100% post-consumer recycled (PCR) content (p. 157).

Product Recyclability

The recyclable proportion of products is approximately 60% (p. 179), determined by global product managers using known recyclable shares in product categories weighted by product mix.

Data Limitations

No quantitative data on total weight of materials used, biological vs. non-biological split, or percentages of renewable/recycled materials in the overall material mix is disclosed for the 2024 reporting period. The company notes it is transitioning its procurement strategy but does not provide baseline resource inflow metrics.

Policies related to own workforce

Fuchs Petrolub has implemented several policies addressing own workforce matters, focusing on human rights, labor standards, and corporate conduct.

FUCHS Code of Conduct (CoC)

Policy name: FUCHS Code of Conduct (CoC)

Scope: All employees worldwide

Approval and oversight:

• Overall responsibility lies with the Executive Board of FUCHS SE
• Implementation is carried out by various specialist departments and the compliance organization under the leadership of the Chief Compliance Officer (CCO)
• Local Compliance Officers (LCOs) are responsible in each group company

Key content/principles:

• Compliance with local, national, and international laws and regulations
• Corporate social responsibility
• Protection of human rights
• Mutual respect
• Leadership and management responsibility
• Explicitly prohibits all forms of slave labor, human trafficking, illegal child labor, illegal prison labor and physical abuse of the workforce
• Fair, equal, and respectful treatment of all employees regardless of origin and nationality, religion and beliefs, gender and sexual orientation, political or union activities, age, illness or disability, or other personal characteristics
• Commitment to equal opportunity for employees within the framework of applicable legal provisions
• Promotes legal, social, environmental, and ethical aspects within FUCHS' corporate social responsibility

Public availability:

• Available externally on the FUCHS website
• Available internally via the intranet
• Assigned to all employees worldwide with access to FUCHS CONNECT via the e-learning tool
• New employees must acknowledge and agree to the CoC upon starting employment (electronically via FUCHS CONNECT or by signing a document for their personnel file)

Links to international standards:

• Supports the international conventions for the protection of human rights
• UN Declaration of Human Rights
• ILO Declaration of Principles
• UN Global Compact (explicitly commits to the 10 principles, including the 10th principle on fighting corruption)

Monitoring and implementation:

• Mandatory global online training program via FUCHS CONNECT
• Regular training sessions and communications
• Regular audits and reviews
• Documented acknowledgments tracked
• Whistleblower portal for anonymous reporting
• Compliance risk assessments
• Human Rights Officer monitors compliance
• Annual compliance and anti-discrimination training
• Participation rates in training monitored
• As part of annual Performance Management process, employees are assessed on their implementation of FUCHS values

FUCHS Human Rights Principles

Policy name: FUCHS Human Rights Principles

Scope: All employees worldwide and all FUCHS locations

Approval and oversight:

• Overall responsibility lies with the Executive Board of FUCHS
• Within the Executive Board, the CEO and CTO are responsible for these principles
• A Human Rights Officer has been appointed with delegated monitoring responsibility

Key content/principles:

• Based on internationally recognized standards
• Protection against human trafficking, forced labor, child labor, and discrimination
• Promotion of equal opportunities and freedom of association
• Fair working conditions
• Respect for human rights
• Promotion of health and safety in the workplace
• Specific commitments include: prohibition of child labor, prohibition of forced labor and slavery, equal opportunity and non-discrimination, freedom of association and the right to collective bargaining, fair wages, working hours and social benefits, workplace safety and occupational health protection, environmental responsibility and accountability towards suppliers

Public availability:

• Available on the FUCHS website
• Global intranet page on human rights where the Human Rights Principles can be accessed

Links to international standards:

• United Nations Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• German Supply Chain Due Diligence Act (LkSG)
• Aligned with the UN Universal Declaration of Human Rights
• ILO Conventions (ILO Declaration on Fundamental Principles and Rights at Work)
• United Nations Global Compact

Monitoring and implementation:

• Human Rights Officer conducts annual risk analyses using IntegrityNext software
• Mandatory global training on the Supply Chain Due Diligence Act (LkSG) for all employees
• Whistleblower portal monitoring
• IntegrityNext portal used for systematic assessment
• Compliance organization (Chief Compliance Officer, Group Compliance Office, global compliance network) ensures adherence
• Regular meetings with local management and town hall meetings
• SE Works Council and employee representatives on Supervisory Board ensure participation

FUCHS Principles on Health, Safety, Environment, Energy, Quality and Sustainability Management

Policy name: FUCHS Principles on Health, Safety, Environment, Energy, Quality and Sustainability Management

Scope: All employees and workplaces

Key content/principles:

• Regulates health, safety, environment and human rights in the workplace
• Focus on protecting employee health and safety
• Systematic risk and exposure assessments
• Regular safety inspections
• Targeted training

Monitoring and implementation:

• Implementation of structured occupational health and safety management system in accordance with ISO 45001
• Regular safety training
• Continuous monitoring of changes in laws and regulations

FUCHS Supplier Code of Conduct (SCoC)

Policy name: FUCHS Supplier Code of Conduct (SCoC)

Scope: All current and future direct suppliers worldwide (also mentioned as extending expectations to the value chain)

Key content/principles:

• Contains the same human rights standards for suppliers as the FUCHS Human Rights Principles for FUCHS' own organization
• Covers working conditions, particularly working hours, work-life balance, fair wages, safe workplaces, social dialogue, freedom of association, including the existence of works councils and collective bargaining
• Ensures compliance with global labor and social standards among suppliers

Public availability: Available on the FUCHS website

Links to international standards:

• OECD standards
• ILO standards

Monitoring and implementation:

• Regular adjustments and voluntary expansions that go beyond the requirements of the Supply Chain Due Diligence Act
• New internal procedures and guidelines to ensure compliance
• Planned social audits to monitor adherence
• IntegrityNext software for supplier assessments

FUCHS Anti-Corruption Policy/Directive

Policy name: FUCHS Anti-Corruption Policy/Directive (also referred to as Anti-Corruption Directive)

Scope: All employees

Approval and oversight:

• Part of the Compliance Management System (CMS)
• Overall responsibility lies with the Executive Board of FUCHS SE
• Chief Compliance Officer (CCO) manages implementation
• Within the Executive Board, the Chief Financial Officer (CFO) has supervisory responsibility following delegation
• Supervisory Board of FUCHS SE oversees and advises the Executive Board on compliance matters

Key content/principles:

• Zero-tolerance approach to misconduct
• Clear conveyance of company values
• Prevention and detection of violations

Public availability:

• Accessible to employees via the global intranet
• Information available on the website through annual report

Links to international standards:

• Aligned with the United Nations Convention Against Corruption
• UN Global Compact 10th principle on fighting corruption
• CMS follows IDW PS 980 new version (09.2022)

Monitoring and implementation:

• Online and offline training programs
• Compliance risk assessments identify areas with elevated risk
• Whistleblower portal for anonymous reporting with protection from retaliation
• Compliance Office reviews and monitors reported cases
• Regular training for employees
• Group Compliance Office (GCO), Regional Compliance Officers (RCO), and Local Compliance Officers (LCO)
• Electronic case handling program integrated into whistleblower portal
• Investigation Standard defines responsibilities and inspection steps

Additional workforce-related policies and practices

The company also implements several management processes and initiatives that function as policy mechanisms:

Performance Management Process: A standardized global approach to goal setting, performance evaluation, and professional development for all employees worldwide, including year-end performance reviews and regular one-on-one meetings where employees are assessed on implementation of FUCHS values.

Career and development plans: Long-term career and development plans, succession planning conducted annually at local, regional, and global levels.

Health and safety programs: Extensive safety measures including systematic risk and exposure assessments, regular safety inspections, and targeted training to reduce work-related injuries and maintain employee health.

Characteristics of the undertaking's employees

As of December 31, 2024, the FUCHS Group had 6,781 (6,272) employees, of whom 133 (123) were trainees. The total workforce increased by 509 people, or 8% compared with the previous year.

Geographical staff structure

Functional workforce structure (excluding trainees)

Compared with the reporting date of the previous year, the number of employees, including trainees, in the EMEA region (Europe, Middle East, Africa) increased, particularly due to acquisitions, by 430 (+11%), in the Asia-Pacific region by 57 (+5%) and in North and South America by 18 (+2%).

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

Total non-employee workers

Our own workforce includes a total of 925 external workers (non-employees).

Breakdown by type

Methodology

• The number of externally employed individuals was gathered through a country-specific survey and aggregated
• A standardized definition of what constitutes an external worker was used as the basis for reporting
• The number of external workers has been tracked internally within FUCHS for several years
• The number of external employees is reported as a headcount
• Reporting date: At the end of the reporting year in accordance with the reporting date principle

Definition of external workers

External workers are individuals who do not have a direct employment relationship with FUCHS but are contracted through third parties to work for the company. These may include temporary workers, agency workers, contractors, freelancers, or seasonal employees. They are typically employed by a third party, which manages their employment conditions and handles all applicable taxes and social security contributions. The requirement is that they are integrated into FUCHS' business processes.

Service contracts, such as those for cafeteria employees or security personnel, are not considered external workers, as these individuals are not directly involved in core business processes.

Collective bargaining coverage and social dialogue

Collective bargaining coverage

Overall coverage rate: 56% of employees are covered by collective bargaining agreements.

Reporting on collective bargaining coverage and social dialogue

The company provides a breakdown by coverage rate bands across geographic regions:

Social dialogue structures

European Works Council: The company has agreements in place that allow employees to be represented by the works council of FUCHS SE. This body serves as an important information and consultation entity, ensuring that the interests of employees are considered at the European level.

Employee representation on Supervisory Board: Two employee representatives serve on the Supervisory Board of FUCHS SE (out of six total members). The current employee representatives are:

• Jens Lehfeldt (Chairman of the Works Council of FUCHS LUBRICANTS GERMANY GMBH, Chairman of the Group Works Council, Chairman of the SE Works Council)
• Cornelia Stahlschmidt (Chairwoman of the Works Council and representative for disabled persons at FUCHS LUBRICANTS GERMANY GMBH)

Engagement mechanisms: Employee engagement is supported through:

• Regular meetings with local management
• Town hall meetings
• Involvement through the SE Works Council
• Employee representatives on the Supervisory Board
• Cultural Scouts program

Reporting scope and methodology

The data covers countries with more than 50 employees representing more than 10% of the total workforce. For non-EEA regions, coverage rates are based on estimations.

Diversity metrics

Top management diversity

FUCHS defines top management levels as individuals at Level 1 and Level 2 within the management hierarchy:

• Level 0: Executive Board
• Level 1: Managing Directors / Group Management Committee (GMC)
• Level 2: Senior Management, Vice President

Gender distribution at top management level (Level 1 and Level 2):

Age band distribution of total workforce

Supervisory Board diversity

Gender and age distribution:

¹ The members of the Executive Board have either worked abroad for several years or have extensive experience in an international business environment.

Additional diversity information

Persons with disabilities: The FUCHS Group currently employs 160 people with disabilities, representing 2.3% of employees. In most countries, employees are not required to disclose their disabilities; therefore, the reported data are subject to some uncertainty.

Adequate wages

Fuchs Petrolub states that all employees are paid appropriately according to the relevant reference values of their respective countries. This determination was made through a survey of local companies.

No specific living wage benchmark is disclosed. The company references "relevant reference values" without specifying what methodology or standard is used to assess adequacy. There is no mention of living wage assessments, external benchmarks (such as Fair Wage Network, WageIndicator, Anker Methodology, etc.), or internal living wage calculations.

No coverage percentages, geographic scope details, or targets related to adequate wages are provided. The disclosure does not distinguish between minimum wage compliance and living wage adequacy.

In the context of the supply chain, the company mentions that "business partners are empowered to ensure fair wages and working conditions for their workers according to international standards" through the Supplier Code of Conduct (SCoC) and General Purchasing Conditions (GPC), but no specific living wage assessment or targets are disclosed for the supply chain.

Social protection

All employees are covered by public programs against income loss due to:

• Sickness
• Unemployment from the moment they are working for the company
• Employment injuries and acquired disability
• Retirement

Coverage is in accordance with national legal regulations or benefits provided by FUCHS.

Specific exclusions

India: Only women are insured against income loss due to parental leave. This restriction does not exist in any other countries.

Coverage type

Public programs, supplemented by benefits provided by FUCHS in accordance with national legal regulations.

Persons with disabilities

According to our records, the FUCHS Group currently employs 160 people with disabilities. The proportion of employees with disabilities in our company is 2.3%.

Methodology and limitations

In most countries, employees are not required to disclose their disabilities. Therefore, the reported data are subject to some uncertainty. The disclosure of disabilities is generally voluntary for employees.

The number of employees with disabilities was determined through a country survey and aggregated based on the respective national definitions of disability. We have evaluated the cases known to us and recorded in our HR systems.

Training and skills development metrics

Training Programs

As at December 31, 2024, 80 (78) young people were in dual vocational training at the German companies. 18 (24) trainees and dual students completed their training in the reporting year.

We provide training in different commercial and technical professions. We also offer goal-oriented and qualified high school graduates the opportunity to attend a dual study program, which leads to a bachelor's degree, in cooperation with the Duale Hochschule Baden-Württemberg (DHBW).

Dual study programs are a key building block for junior staff development at FUCHS. In addition to the various training courses and DHBW study programs, we also offer involvement in cross-group, international projects. Many of our current top performers are former FUCHS students, trainees and interns. Many management positions throughout the Group have now been filled by our former students.

Research and Development

In the reporting year 2024, 641 (597) employees, and thus around 10% of the total workforce, were engaged in research and development (R&D), working on around 650 projects (680). R&D expenditures amounting to €79 million (71) contributed to further expanding the innovative strength of FUCHS.

Health and safety metrics

Scope and methodology:

All figures refer exclusively to FUCHS' own employees. The number of working hours and paid leave used to calculate the rate of recordable workplace accidents was estimated based on the number of Full-Time Employees (FTEs), multiplied by contractual working hours and workdays, adjusted by subtracting the total number of days with paid absences.

A structured occupational health and safety management system is implemented and certified according to ISO 45001 at all FUCHS production sites (92.4% coverage). The company has set the goal of maintaining zero fatalities resulting from work-related injuries or illnesses in the future.

Work-life balance metrics

Social protection coverage

All employees are covered by public programs against income loss due to:

• Sickness
• Unemployment from the moment they are working for the company
• Employment injuries and acquired disability
• Retirement

Coverage is provided in accordance with national legal regulations or benefits provided by FUCHS.

Parental leave entitlement and gender-specific restrictions

In India, only women are insured against income loss due to parental leave. This restriction does not exist in any other countries.

Note: The company references work-life balance in its supplier requirements and social protection programs, but does not disclose specific metrics on:

• % of employees entitled to family-related leave (maternity/paternity/parental)
• % of entitled employees who took family-related leave by gender
• Return-to-work rates after parental leave by gender

Compensation metrics (S1-16)

Pay gap

The Gender Pay Gap is expressed as a percentage and provides insight into gender-based salary differences within the company. This figure was 13.7% in the reporting year.

Remuneration ratio

In the reporting year, the ratio of the annual total compensation of the highest-paid individual to the median total compensation of all employees was 62.5. This means that the highest-paid individual earned 62.5 times the median employee salary.

Methodology

Gender Pay Gap calculation:

For the calculation of the Gender Pay Gap, the individual Gender Pay Gaps of the subsidiaries are reported and consolidated into a weighted average based on the number of employees.

Due to its decentralized organizational structure, FUCHS SE does not have direct access to the compensation data of its subsidiaries. Each subsidiary is independently responsible for calculating its own compensation metrics. Certain compensation components for the employees of the largest single company, FUCHS LUBRICANTS GERMANY GMBH, were extrapolated on the basis of salary data, as a change of external payroll provider made it considerably more difficult to consolidate the data consistently. These metrics are then consolidated by the global HR department to determine compensation indicators for FUCHS.

Annual Total Remuneration Ratio calculation:

Due to data protection regulations, the direct calculation of the Annual Total Remuneration Ratio is not possible, as not all salaries are centrally available. However, salaries for certain management functions are centrally recorded. This allows for the identification of the highest-paid individual.

To calculate the Annual Total Remuneration Ratio for the FUCHS Group, the median wages of all subsidiaries are first recorded. The overall group median is then determined by calculating the weighted median, with weighting based on the number of employees. The salary of the highest paid person was set in relation to the Group median to determine the Annual Total Remuneration Ratio.

By weighting medians according to employee numbers, larger subsidiaries that have a greater impact on the company as a whole are given appropriate consideration. From the company's perspective, this method provides a well-founded estimate.

A scenario analysis has tested that the results of the applied methodology do not significantly deviate from the calculated values.

Policies related to value chain workers

Fuchs Petrolub has identified a potential risk that, in exceptional cases, human rights violations could occur in the supply chain. To address this risk, various concepts and guidelines have been developed to ensure respect for human rights within the upstream supply chain and within the FUCHS organization when interacting with business partners.

The following policies are publicly available on the FUCHS website:

FUCHS Supplier Code of Conduct (SCoC)

Scope: All suppliers in the supply chain

Key content:

• Social responsibility
• Child labor
• Forced labor and choice of employment
• Equal opportunities
• Freedom of association
• Wages and working hours
• Health and safety in the workplace
• Pollution
• Land rights
• Use of security forces
• Community engagement
• Animal welfare
• Discrimination
• Working conditions and compensation
• Freedom of assembly and collective bargaining
• Impact on local communities
• Diversity and inclusion

Link to international standards: The SCoC contains the same human rights standards for its suppliers as the FUCHS Human Rights Principles do for FUCHS's own organization (which reference UN Universal Declaration of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, UN Global Compact, and OECD Guidelines for Multinational Enterprises).

Public availability: Available on the FUCHS website

Oversight and governance: Adopted by the Executive Board, which holds overall responsibility. Monitoring is carried out by purchasers.

Implementation and monitoring:

• The voluntary expansion of sustainability standards for suppliers to include the Supplier Code of Conduct exceeds the requirements of the German Supply Chain Due Diligence Act (LkSG)
• Self-disclosures are requested and managed via IntegrityNext, a cloud-based software platform for exchanging sustainability-related information
• In cases of increased risk or lack of self-disclosure, results are discussed between FUCHS's purchasers and the suppliers' representatives to improve working conditions
• Internal, globally applicable process regulations govern and ensure the implementation of measures to minimize risks and safeguard human rights within the procurement organization
• No violations from the supply chain were reported through the anonymous whistleblower portal in fiscal year 2024
• Social audits are planned to monitor adherence

Time horizon: The expansion applies to all current and future suppliers

FUCHS General Purchasing Conditions (GPC)

Scope: All suppliers

Key content:

• Fundamental contractual terms outlining payment and delivery conditions
• Suppliers are expected to acknowledge the Supplier Code of Conduct

Public availability: Available on the FUCHS website

FUCHS Human Rights Principles

Scope: All employees and all FUCHS locations (also referenced for supply chain expectations)

Key content: Offers a framework for handling human rights that applies to all employees and all FUCHS locations.

Link to international standards:

• United Nations Universal Declaration of Human Rights (UDHR)
• ILO Declaration on Fundamental Principles and Rights at Work
• United Nations Global Compact (Initiative for Sustainable and Responsible Corporate Governance)
• OECD Guidelines for Multinational Enterprises

Public availability: Available on the FUCHS website

Role in value chain: The SCoC contains the same human rights standards for suppliers as the Human Rights Principles do for FUCHS's own organization.

FUCHS Code of Conduct (CoC)

Scope: All employees within the group; FUCHS is committed to extending the core values and contents to its value chain

Key content:

• Explicitly prohibits all forms of slave labor, human trafficking, illegal child labor, illegal prison labor and physical abuse of the workforce
• All employees must be treated fairly, equally, and with respect
• Compliance with all applicable laws and regulations

Link to international standards: References internationally recognized labor rights

Oversight and governance: The company expects all employees to commit to adhering to the CoC

Extension to value chain: FUCHS is committed to extending the core values and contents of the Code of Conduct to its value chain. In 2024, FUCHS established the Supplier Code of Conduct (SCoC).

FUCHS Principles on Health, Safety, Environment, Energy, Quality and Sustainability Management

Scope: Regulates issues of health, safety, the environment and human rights in the workplace

Public availability: Referenced as available on the FUCHS website

Overall approach to respect for human rights in the supply chain

FUCHS assumes corporate and social responsibility, encompassing legal, social, environmental, and ethical aspects. The business is conducted in a fair, responsible, and transparent manner. This ensures that activities worldwide are based on respect for laws, order, and ethical and social standards.

FUCHS respects and observes international standards and has implemented extensive internal guidelines such as the Supplier Code of Conduct. Despite regular adjustments and voluntary expansions that go beyond the requirements of the Supply Chain Due Diligence Act, violations cannot be completely excluded.

Taking action on material impacts on value chain workers

FUCHS has implemented several measures to ensure respect for human rights in the upstream and downstream value chain. All measures are valid indefinitely and intended to avoid, minimize, or remedy potential negative impacts on workers in the supply chain.

Four-Category Framework for Supplier Management

FUCHS implements preventive and corrective measures across four categories:

1. Contractual Measures

• Supplier Code of Conduct (SCoC) or similar agreements with suppliers
• General Purchasing Conditions (GPC) include provisions on payment and delivery terms to enable business partners to ensure fair wages and working conditions according to international standards

2. Supplier Risk Management Measures

• IntegrityNext software implementation for supplier assessments, including human rights questions
• Continuous monitoring of supplier evaluations to track effectiveness of actions
• Recording of both positive and negative changes in evaluations
• Supplier Relationship Management (SRM) system: Global implementation starting in 2025 to identify supplier risk data and profiles, including human rights-related risks identified through IntegrityNext
• Planned extension of on-site supplier audits to cover social topics

3. Documentary Measures

• Internal management of SCoC or similar agreements with suppliers
• Software-supported procedure for purchasing employees to view, manage, and measure sustainability results from electronic self-disclosure portal
• Documented action plans created for specific deviations
• Globally applicable processes for supplier management that account for sustainability matters, including human rights
• Electronic recording and evaluation of supplier contracts through globally implemented ERP systems
• Assignment and tracking of data from self-assessments, action plans, and confirmed SCoCs

4. Concrete On-Site Measures

• Supplier audits conducted when necessary to review systems, certificates, and sustainability matters
• Individual action plans developed together with suppliers to implement necessary improvements when deviations are found

Risk-Based Action Plans for Affected Workers

Based on risk analysis, measures are designed to support affected workers employed by suppliers:

• Verification and documentation of supplier's affirmation of SCoC
• Required improvements in areas marked as inadequate in self-disclosure through implemented measures
• On-site audits at supplier locations depending on number and severity of issues, resulting in action plans
• Planned online training for suppliers to address identified deficiencies in specific areas
• Business relationship termination if suppliers demonstrate insufficient cooperation or fail to achieve desired improvements

Internal Training and Awareness

• Internal training on human rights in the supply chain offered, with documented participation

Resources Allocated

Non-Financial Resources:

• Dedicated Human Rights Officer who reports directly to the Executive Board at least once a year (in accordance with LkSG)
• Global procurement function leadership representing supplier interests in stakeholder surveys and IRO workshops
• Various internal data sources made available to employees and supervisors in procurement
• Data, values, and statistics shared with relevant management levels through electronic supplier self-assessment portal

Financial Resources: Not quantified.

Time Horizon

• All measures valid indefinitely
• SRM system implementation: starting in 2025
• Since the FUCHS business model is designed for long term, all impacts, risks and opportunities are short-, medium-, and long-term in nature
• FUCHS100 strategy planning horizon extends to 2031 (replacing FUCHS2025 strategy on January 1, 2026)

Scope

• Upstream value chain (suppliers)
• No geographic restrictions, supplier size/profitability restrictions, or specific vulnerable group restrictions (in accordance with materiality approach)

Expected Outcomes and Effectiveness

• Specific goals and metrics for managing risks related to workers in supply chain to be established in 2025
• Data from concepts and measures developed in 2023, introduced starting 2024, forms basis for future goal-setting
• Effectiveness monitoring currently uses evaluation of suppliers based on IntegrityNext
• Planned effectiveness review will check whether actions achieved anticipated improvements
• No cases of human rights violations within supply chain identified to date; effectiveness assessment pending should violations be identified

Link to Policies

• Linked to FUCHS Human Rights Principles
• Linked to Code of Conduct (CoC) and Supplier Code of Conduct (SCoC)
• Supports strategic pillar "People & Organization"
• Compliance with LkSG (German Supply Chain Due Diligence Act)

Business conduct policies and corporate culture

Fuchs Petrolub has implemented several policies related to business conduct and corporate culture, embedded in its ethical standards and compliance framework.

FUCHS Code of Conduct (CoC)

Scope: Applies to all employees worldwide.

Governance: Overall responsibility lies with the Executive Board of FUCHS SE. Implementation is carried out by various specialist departments and the compliance organization under the leadership of the Chief Compliance Officer (CCO). Local Compliance Officers (LCOs) are responsible in each group company.

Key content/principles: The CoC commits the company to compliance with local, national, and international laws and regulations. It includes corporate social responsibility, protection of human rights, mutual respect, and leadership and management responsibility. The CoC aims to promote legal, social, environmental, and ethical aspects within the framework of FUCHS' corporate social responsibility. It strictly prohibits any form of slavery, illegal child labor, human trafficking, unlawful forced labor, and physical abuse of employees. All employees must be treated fairly, equally, and with respect, regardless of their origin and nationality, religion and beliefs, gender and sexual orientation, political or union activities, age, illness or disability, or other personal characteristics.

Public availability: The CoC is publicly available on the FUCHS website and has been assigned to all employees worldwide with access to FUCHS CONNECT via the e-learning tool.

International standards: With the CoC, FUCHS supports the international conventions for the protection of human rights and the environment, including the UN Declaration of Human Rights, the ILO Declaration of Principles and the UN Global Compact. FUCHS explicitly commits to the UN Global Compact in its CoC, including the 10th principle regarding the fight against corruption. Both the CoC and the Anti-Corruption Directive are in line with the United Nations Convention against Corruption.

Monitoring: New employees must acknowledge and agree to the CoC upon starting their employment, either electronically via FUCHS CONNECT or by signing a document for their personnel file. Documented acknowledgments of the CoC are tracked. The company has implemented mechanisms including an Internet-based whistleblower portal for anonymous reporting of violations.

FUCHS Human Rights Principles

Scope: Applies to all employees worldwide.

Governance: Overall responsibility lies with the Executive Board of FUCHS. Within the Executive Board, the CEO and CTO are responsible for these principles. A Human Rights Officer has been appointed, and monitoring responsibility has been delegated to them.

Key content/principles: Based on international standards such as the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the German Supply Chain Due Diligence Act (LkSG). The principles are aligned with the UN Universal Declaration of Human Rights and the ILO Conventions and contain clear guidelines against human trafficking, forced labor, child labor, and discrimination while promoting equal opportunities and freedom of association. They aim for fair working conditions, respect for human rights, and the promotion of health and safety in the workplace. Specific commitments include the prohibition of child labor, the prohibition of forced labor and slavery, equal opportunity and non-discrimination, freedom of association and the right to collective bargaining, fair wages, working hours and social benefits, workplace safety and occupational health protection, as well as environmental responsibility and accountability towards suppliers.

Public availability: The FUCHS Human Rights Principles are publicly available on the FUCHS website.

International standards: The principles are based on international standards such as the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the German Supply Chain Due Diligence Act (LkSG). They are aligned with the UN Universal Declaration of Human Rights and the ILO Conventions.

Monitoring: Compliance is reviewed annually by the Human Rights Officer using IntegrityNext. Additionally, the whistleblower portal is used to monitor human rights compliance. Furthermore, mandatory global training on the Supply Chain Due Diligence Act (LkSG) for all employees is regularly monitored. The Human Rights Officer annually identifies potential discrimination risks as part of the human rights risk analysis.

Anti-Corruption Directive

Scope: Part of the global Compliance Management System (CMS) applicable to the company's own business operations, generally applicable globally.

Governance: Ultimate responsibility lies with the Executive Board of FUCHS SE and the Managing Directors of the FUCHS subsidiaries. The Executive Board has appointed a Chief Compliance Officer (CCO) and delegated the establishment, operation, and further development of the FUCHS CMS to them. Within the Executive Board, the remaining supervisory responsibility for the FUCHS CMS, following this delegation, lies with the Chief Financial Officer (CFO). The Supervisory Board of FUCHS SE oversees and advises the Executive Board in managing the company, including on compliance matters.

Key content/principles: The Anti-Corruption Directive is aligned with the United Nations Convention Against Corruption. The general goal of the CMS is to prevent violations of applicable anti-corruption laws and relevant internal regulations (CoC/Anti-Corruption Directive) or to mitigate the consequences of such violations. The CoC and the Anti-Corruption Directive clearly convey the company's values and the principle that misconduct will not be tolerated.

Public availability: The Anti-Corruption Directive is available externally on the FUCHS website and internally via the intranet.

International standards: The Anti-Corruption Directive is aligned with the United Nations Convention Against Corruption. The FUCHS CMS regarding the anti-corruption section also follows the IDW PS 980 new version (09.2022).

Monitoring: Compliance risk assessments help identify areas with an increased risk of bribery and corruption. These areas are subject to additional compliance measures to mitigate any potential risks. Online and offline training programs support the messages of the CoC and anti-corruption policy. The whistleblower portal allows for anonymous reporting and protects whistleblowers from retaliation. The Compliance Office reviews and monitors reported cases. Internal and external audits, as well as safety inspections, help monitor compliance. The effectiveness is monitored through tracking and analyzing whistleblowing cases and participation in compliance and anti-discrimination training.

FUCHS Supplier Code of Conduct (SCoC)

Scope: Applies worldwide to supplier contracts in the upstream supply chain. According to the general purchasing conditions, the SCoC applies to all current and future direct suppliers worldwide.

Governance: The Executive Board holds overall responsibility. Monitoring is carried out by the Human Rights Officer.

Key content/principles: With this code of conduct, FUCHS fulfills its due diligence obligations to uphold human rights in the supply chain. It covers topics such as social responsibility, child labor, forced labor and choice of employment, equal opportunities, freedom of association, wages and working hours, health and safety in the workplace, pollution, land rights, the use of security forces, community engagement, and animal welfare. The SCoC contains the same human rights standards for its suppliers as the FUCHS Human Rights Principles do for FUCHS's own organization. The voluntary expansion of sustainability standards for suppliers through the SCoC exceeds the requirements of the Supply Chain Due Diligence Act (LkSG) and covers working conditions, particularly working hours, work-life balance, fair wages, safe workplaces, social dialogue, freedom of association, including the existence of works councils and collective bargaining.

Public availability: The FUCHS Supplier Code of Conduct is publicly available on the FUCHS website.

International standards: The SCoC is expected to align with OECD or ILO standards and human rights conventions. It is designed to ensure compliance with internationally recognized standards.

Monitoring: Self-disclosures on relevant human rights topics are obtained annually from suppliers of production materials and selected suppliers of non-production materials via IntegrityNext, a cloud-based software platform for exchanging sustainability-related information. The questionnaire for supplier self-disclosures was developed by IntegrityNext, with particular attention to the requirements of the Corporate Sustainability Reporting Directive (CSRD) and the Supply Chain Due Diligence Act (LkSG). In the case of increased risk or lack of self-disclosure, the results are discussed between FUCHS's purchasers and the suppliers' representatives to improve working conditions in the supply chain. Section 4.5 of the SCoC specifies that whistleblowers will not face any disadvantages or retaliation. A supplier risk management system has been established, which manages and evaluates supplier self-disclosures via IntegrityNext, including ongoing annual updates and monitoring the effectiveness of measures.

FUCHS General Purchasing Conditions (GPC)

Scope: Applies to supplier contracts.

Key content/principles: These contractual terms outline fundamental elements such as payment and delivery conditions. In addition, suppliers are expected to acknowledge the SCoC.

Public availability: The FUCHS General Purchasing Conditions are publicly available on the FUCHS website.

FUCHS Principles on Health, Safety, Environment, Energy, Quality, and Sustainability Management

Scope: Applies globally to all FUCHS companies worldwide.

Governance: Overall responsibility lies with the Executive Board, with operational responsibility assigned to the Chief Technology Officer (CTO) as per the business distribution plan.

Key content/principles: These principles provide the framework for occupational health and safety, environmental protection, and quality, energy, and sustainability management. FUCHS is committed to ensuring a safe working environment by implementing strict safety protocols and conducting regular accident prevention training. The principles regulate the issue of health, safety, the environment and human rights in the workplace.

Public availability: The concept is publicly available on the FUCHS homepage.

Monitoring: Internal and external audits, as well as safety inspections, help monitor compliance and drive continuous improvements in occupational health and safety measures.

Corporate Culture Development Initiatives

Fuchs has embedded corporate culture as a strategic pillar in its FUCHS 2025 strategy. The company communicates and promotes its corporate culture through various initiatives:

• FUCHS Values: The five FUCHS values (Trust, Creating value, Respect, Reliability, and Integrity) serve as a guide for entrepreneurial actions and shape the daily behavior of employees. These values were developed through a bottom-up process with extensive employee surveys and workshops.

• Train the Trainer: A global "Train the Trainer" program called "The essence of leadership in changing times" was introduced to establish a shared understanding of management expectations and behaviors.

• Cultural Scouts: Employees across different countries have been appointed as Cultural Scouts, whose role is to promote FUCHS values throughout the company. This approach aims to strengthen trust, agility, and engagement while also fostering better cross-functional and cross-regional collaboration.

• Performance Management: The FUCHS values are directly discussed and evaluated as part of the annual Performance Management process, and a performance goal linked to FUCHS 2025 is defined.

These initiatives collectively promote a culture of hierarchy-free communication, open feedback, and a "growth mindset."

Incidents of corruption or bribery

Confirmed incidents

Fuchs Petrolub reported a total of zero convictions for breaches of bribery and corruption regulations in the reporting period (2024).

The company stated: "There were no convictions for breaches of bribery and corruption regulations in the reporting period."

Convictions and fines

No convictions or fines related to corruption or bribery were reported for the 2024 financial year.

Investigation procedures and speak-up mechanisms

Fuchs has established a comprehensive Compliance Management System (CMS) based on the IDW PS 980 auditing standard. Key components include:

• Whistleblower Portal: An electronic whistleblowing system available to both internal and external stakeholders, allowing confidential and anonymous reporting of concerns regarding potential misconduct, including corruption and bribery.

• Reporting Channels: Three reporting channels are provided:

  • Electronic whistleblowing system
  • Functional email address
  • Personal consultation with members of the Group Compliance Office (GCO), Regional Compliance Officers (RCO), or Local Compliance Officers (LCO)

• Investigation Standard: Fuchs issued a dedicated Investigation Standard on July 18, 2024, which defines responsibilities, processes, and reporting duties for internal investigations. The standard ensures independence of investigators and objectivity of investigations.

• Complaints Procedure: Reports submitted through the whistleblower portal are processed in accordance with the Fuchs Complaint Procedure Guidelines. Receipt of complaints is acknowledged, and a response is provided within three months. The procedure is designed to prevent, eliminate, or minimize negative impacts.

• Protection Against Retaliation: Fuchs complies with the prohibition of retaliation as stipulated in the EU Whistleblower Protection Directive and corresponding national implementation laws. Strict adherence to confidentiality and the need-to-know principle is considered the most important measure to prevent retaliation.

• Communication: Information about reporting channels is communicated internally through the Code of Conduct, e-learning, the intranet, and the website. A publicly accessible procedure manual provides further details on principles and processes.

The Group Compliance Office (GCO) is responsible for receiving and following up on reports at Fuchs. The compliance organization has a global structure with Regional Compliance Officers (RCOs) and Local Compliance Officers (LCOs).

Training

Fuchs provides mandatory online compliance training for all commercial employees:

• "Fundamentals of Compliance": Assigned to all commercial employees with access to Fuchs Connect, to be repeated every three years. As of December 31, 2024, 5,668 employees were assigned this training, with 5,224 having passed it (92% training rate).

• "Protection Against Corruption": Assigned to employees with management responsibility and those in sales and purchasing, to be repeated every two years. As of December 31, 2024, 1,976 employees were assigned this training, with 1,935 having passed it (98% training rate).

Fuchs has set an internal target rate of 85% for both compliance trainings for 2024 and the following year.

Payment practices

Disclosure

Fuchs Petrolub has determined through its double materiality assessment that payment practices are not material for the company. The sustainability report explicitly states:

"The results showed that business conduct is generally relevant for FUCHS, particularly in the subcategories of 'Corporate culture' as well as 'Corruption and bribery.' Other aspects included in the standard, such as supplier relationship management, payment practices, political influence, and animal welfare, were determined to be irrelevant for FUCHS."

Limited financial statement information

The only quantitative payment-related information disclosed relates to trade payables maturity from financial reporting:

Maturities of contractual cash flows - Trade payables (as of December 31)

No specific ESRS G1-6 payment practice metrics (average payment time in days, contractual payment terms, late payment proceedings, or prompt payment code compliance) are disclosed.