GRENKE AG

Reference: pages 71-73; page 163.

grenke AG has a Board of Directors, a Supervisory Board and an Annual General Meeting. The Board of Directors manages the company and the Supervisory Board monitors and advises it (page 71). The report describes the Board as the CEO, CSO and CFO positions, all male, until August 31, 2025. From September 1, 2025 it has four members, 25% female and 75% male, and the Chief Risk Officer role was replaced by a Chief Operating Officer (page 71). The Supervisory Board has six members, a gender ratio of 1:5 and no employee representatives (page 71).

Sustainability responsibility: it lies with the CEO, Dr Sebastian Hirsch. Dr Mitic has been the Supervisory Board's Sustainability Officer since 2022, and the Audit Committee audits and monitors the Group Sustainability Statement (pages 71-72). The VP Corporate Development & ESG holds overall responsibility for sustainability management and for monitoring material IROs (page 72). A ten-member Sustainability Committee chaired by the CEO evaluates the issues from the double materiality assessment (page 73).

Independence: all Board of Directors members (100%) were deemed independent in the 2025 conflict-of-interest review (page 72).

Reference: pages 71-73; page 88.

The Board of Directors received "comprehensive briefings and training" from the ESG department in 2025 (page 71). The topics listed are: further development of the sustainability strategy and its implementation measures; the update of the materiality assessment and disclosure of IROs; regulatory changes in sustainability reporting; the Scope 3 calculation for lease objects and carbon footprinting; and new communication formats for knowledge sharing (page 71). Board meetings also covered approval of the double materiality results and progress toward the defined targets (page 71).

The VP Corporate Development & ESG gives quarterly ESG updates directly to the full Board and the vice presidents at the quarterly Sustainability Committee meetings, including updates on sustainability-related risks (page 72). The Audit Committee met five times in 2025; its agenda included the CSRD/ESG status, ESG audit services and the Scope 3 calculations for lease objects (page 72). Results of stakeholder dialogue are reported to the Board quarterly and feed into strategy development (page 88). The Board of Directors informs the Supervisory Board on these topics routinely and as required (page 72).

Reference: pages 73-76; page 97.

grenke has sustainability-linked incentive schemes for the Board of Directors. In 2025 the sustainability-related criteria were extended to the first management level below the Board, the vice presidents (page 73). The annual short-term incentive uses a balanced scorecard of up to 35 points: up to 20 for financial targets and up to 15 for non-financial targets (page 73).

The 2025 non-financial targets were leadership (four employee-survey topics at 1.0 point each), environmental management and governance (1.0 point), the internal control system (4.0 points) and role-specific individual targets (pages 74-75). Of the part of variable pay tied to fixed remuneration, 20 percent relates to non-financial indicators (page 75). The Remuneration Control Committee prepares the targets and the Supervisory Board approves them each year. Supervisory Board members receive fixed pay only (pages 74-75).

"No climate-related targets were established for the remuneration of the Board of Directors or the Supervisory Board of grenke AG in the 2025 financial year" (page 76). The TOP KPI for top management positions with a sustainability component in variable pay stood at 12.6% in 2025 (page 84).

Reference: pages 76-78; page 167.

The statement includes a table that maps the five core elements of due diligence to chapters of the report (page 76): embedding in governance, strategy and business model (GOV-2, GOV-5 and the Corporate Governance Statement); engaging affected stakeholders (SBM-2); identifying and assessing adverse impacts (SBM-3, IRO-1); taking action (E1-3, E5-2, S1-4, S4-4); and tracking effectiveness (GOV-5, IRO-1).

It lists the policies and frameworks it relies on: the UN Sustainable Development Goals, the Diversity Charter (signed in 2022), the German Corporate Governance Code, the Code of Conduct and Supplier Code of Conduct, the Health and Safety Policy, the Environmental Policy, the Travel and Car policies and the guidelines for responsible financial products (pages 76-77). Enterprise portfolio management checks new projects for relevance to the material sustainability topics (page 78).

On supply chain due diligence law, grenke continued to prepare for the German Supply Chain Due Diligence Act (LkSG) in 2025 but is not pursuing it further, because the company no longer falls within the scope of the Act (page 167). ESRS 2 Appendix B maps GOV-4 paragraph 30 (statement on due diligence) to this section (page 193).

Reference: pages 78-80.

grenke's internal control system (ICS) for sustainability reporting is based on the COSO Internal Control Over Sustainability Reporting framework (page 78). It covers risk assessment, control activities and monitoring, uses documented controls such as the four-eyes principle, and is reviewed through Internal Audit and external assurance (page 78). In 2025, 21 departments took part. The ESG team coordinates the inputs and each specialist department is responsible for the accuracy and completeness of its own data (page 78).

The reporting risks it names are misreading legal requirements, late publication, and incomplete or inaccurate disclosures. Mitigations are EFRAG guidance, structured record-keeping, assigned data responsibilities, training sessions ("Easy Go ESG") and the four-eyes check (pages 78-79). In 2025 grenke launched an in-house IRO dashboard that supports data entry in line with ESRS requirements and the identification of actions and controls (page 79). The ESG team updates the Board of Directors quarterly on reporting status, and Risk Control gives the Board monthly risk updates (page 79). A table sets out the ICS by business area, process and tools such as Diligent, Excel and Netigate (page 80).

Reference: pages 81-86; page 70.

The sustainability strategy has three dimensions: Climate and Environment, Social Contribution, and Responsibility and Trust. Its vision is "An enabler for sustainable SMEs", and nine TOP KPIs track progress (pages 81-82). One TOP KPI changed in 2025: "Number of contracts per active specialist reseller partner" replaced training days (pages 70, 86).

grenke provides small-ticket lease financing to small and medium-sized enterprises, with factoring and banking segments alongside leasing (pages 87, 156). It reports 546,750 SME customers, 34,548 active specialist reseller partners, 2,439 employees and 125 locations in more than 30 countries (pages 129, 153). The value chain is own operations plus eleven activities, and "software development" was added in 2025 (page 100). Upstream activities are market research and product development, acquisition and support of specialist reseller partners, customer acquisition, and external financing and liquidity management. Downstream activities are the return and recycling of objects and their reuse in a second life cycle (page 86). The revenue breakdown sits in the financial report (page 196).

Reference: pages 86-88; pages 153-154.

grenke names six stakeholder groups (pages 86-87): internal stakeholders (Supervisory Board, Board of Directors, employees); business partners (lessees, customers and specialist reseller partners across leasing, factoring and banking); the capital market (investors, banks, analysts); supervisory authorities and regulators (including audit firms and legislators); civil society (potential employees, media, local stakeholders, non-profits, associations); and "silent stakeholders", meaning nature and the environment.

A table sets out, for each group, the engagement formats, channels and frequency, how results are used and the related materiality topics (page 87). Examples are the annual employee survey, partner satisfaction surveys, analyst and investor conferences, exchanges with ESG rating agencies and supervisory meetings (page 87).

The Board of Directors is told the results of internal and external stakeholder dialogue in its quarterly report, and the results feed into corporate strategy (page 88). The 2025 materiality survey was widened to selected external stakeholders in academia, NGOs and associations (page 92). The S4 chapter reports the 2025 partner survey in Germany, Austria, Switzerland and the Netherlands (pages 153-154).

Reference: pages 88-90; topical IRO tables on pages 94-96 (E1), 120 (E5), 130 (S1), 149-150 (S4) and 162 (G1).

Five of the ten topical ESRS are material: E1, E5, S1, S4 and G1 (pages 68, 92). Each topical chapter opens with a table that gives every IRO's type, whether it is actual or potential, time horizon, value chain position, the measures and policies that address it and the TOP KPI that manages it (pages 94-96, 120, 130, 149-150, 162).

Examples are emissions from the manufacture and use of lease objects (E1 impacts), acute, chronic and transition risks in the credit portfolio (E1 risks), electronic waste from lease objects (E5 impact), staff fluctuation from uncompetitive pay (S1 risk), data breaches and AI-enabled identity theft (S4 impacts) and insufficient money laundering prevention (G1 impact). Several IROs were new or split in 2025, including those on AI, Scope 3 from lease objects and the whistleblower platform (page 89).

On financial effects: "We do not anticipate any significant risk of material adjustments to carrying amounts within the next 12 months." "A quantification of these potential financial effects was not carried out during the reporting year" (page 90). Physical and transition risks are expected to weigh more on credit risk over time, mainly indirectly through customers (page 90).

Climate resilience analysis is also presented under E1-3 (2025 ESRS numbering).

Reference: pages 91-92; page 68; page 88.

The 2025 process had five steps (pages 91-92): a long-to-medium list built from the ESRS long list and the topics and sub-topics in ESRS 1 AR 16; identification of potential short-, medium- and long-term impacts, risks and opportunities along the value chain, using stakeholder dialogue, ESG benchmarking and the ESG risk inventory; setting the materiality threshold; an online survey assessment; and approval by the Sustainability Committee with a report to the Board of Directors.

Impacts were scored on scope, scale and irremediability, plus likelihood for potential impacts. Risks and opportunities were scored on financial scale, scope and likelihood. The scale runs from 1 (not material) to 4 (material), and the materiality threshold was set at 2.5 (page 92). The survey went to the Board of Directors, vice presidents, managing directors and the Sustainability Committee, and in 2025 also to selected external stakeholders in academia, NGOs and associations (page 92).

"Our analysis indicates that our activities do not present an elevated risk of negative impacts in relation to geographical factors, business relationships, or specific types of activity" (page 91). A full update of the assessment is planned for the 2027 financial year (page 68), and an ESG dashboard was introduced in 2025 (page 92).

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

Reference: pages 92-93; content index on pages 196-200; phase-in table on pages 201-203.

"Based on the results of our materiality assessment, five of the ten ESRS topic standards are material for grenke": E1 Climate change, E5 Resource use and circular economy, S1 Own workforce, S4 Consumers and end-users, and G1 Business conduct (pages 92-93). The summary on page 92 also lists "Risk management" under ESRS 2.

Content index: the Appendix has tables for ESRS 2 (BP-1 to IRO-2), E1, E5, S1, S4 and G1. Each row names the disclosure requirement and the chapter that covers it. The tables carry chapter references, not page numbers or datapoint lists; the contents pages give the chapter pages (pages 64-65, 196-200). "The disclosure requirements of the ESRS topic standards that are not classified as material are not included" (page 93).

Phase-in: grenke applies the phase-in to E1-9 and E5-6, and to S1-12 (page 93). The phase-in table lists E2, E3, E4, S2 and S3 as "No relevant content of the report" (pages 201, 203).

Other EU legislation: Appendix B (pages 193-195) maps SFDR, Pillar 3, Benchmark Regulation and EU Climate Law datapoints to chapters and marks those of the non-material standards "Not material".

Reference: pages 102-104.

grenke's Climate Action Plan is its transition plan. It aims for net-zero emissions by 2050 "within our sphere of influence" and states that it supports limiting warming to 1.5°C above pre-industrial levels (page 102). The targets take SBTi recommendations into account, but "Validation by the SBTi is currently in the planning phase" (page 102). They cover material Scope 1, 2 and 3 activities; Scope 3 emissions from lease objects "are not yet included" (page 103).

Levers (page 103): electrify the company fleet (60% lower fleet emissions by 2030); renewable electricity at sites where grenke buys its own energy (90% lower electricity emissions by 2030); travel policy (27% lower travel emissions by 2030); commuting incentives (8%); purchased goods and services (27%); downstream transport by asset brokers (25%).

The Board of Directors adopted the plan and the ESG team coordinates delivery (page 103). The risk of locked-in emissions "is considered low given our business model" (page 103). grenke has "not identified any significant financial impacts" from its reduction targets and books reduction costs within overall cost planning (page 103). In 2025 emissions were 3,037 t CO2e below the base year, "achieving 84 percent of our 2030 interim target" (page 104). Remuneration carries no climate targets (page 76).

Reference: pages 97-102.

Back-filled from ESRS 2 SBM-3 / IRO-1, where this content is disclosed in the FY2025 report as "Our climate resilience analysis" (pages 97-102). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk types: physical risks (acute, chronic) and transition risks (policy and law, technology, market) are defined and applied to the credit portfolio and customer sites, following the TCFD recommendations (pages 97-98).

Method: an annual ESG risk inventory, with workshops on how ESG drivers affect liquidity, credit, market price, operational and reputational risk (page 98); an internal ESG score by lessee country and sector, with physical risk located by NUTS3 or NUTS2 region code (page 100); and quarterly ESG stress tests over one year (economic) and at least three years (normative) (page 100).

Scenarios: "In addition to NGFS scenarios, RCP scenarios from the ICCP may be used". The modeled pathways available are RCP4.5 and RCP8.5, and RCP8.5 was "chosen in line with a conservative perspective" (page 100). No 1.5°C scenario is named and no temperature projection is given. grenke states that a comprehensive scenario analysis "based on two high-emission climate scenarios and one aligned with limiting global warming to 1.5°C was not conducted in 2025" (page 102).

Exposure: sectors seen as particularly exposed made up 9.42% of the leasing business in 2025 (2024: 9.33%, restated) (page 101).

Reference: pages 97, 101-102.

Back-filled from ESRS 2 SBM-3 / IRO-1, where this content is disclosed in the FY2025 report as "Our climate resilience analysis" (pages 97-102). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The analysis looks at how the strategy and business model respond to climate change, assessing the resilience and exposure of the credit portfolio and customer locations, with indirect exposure viewed from the customer side (page 102).

Result: "The current findings indicate that grenke is well positioned to adapt its business model to climate change over all time horizons and has a highly diversified portfolio and limited direct exposure to carbon-intensive sectors" (page 102). The reasons given are short lease terms, geographic diversification (extreme weather is generally localized) and the requirement of property insurance for lease objects (page 101).

Limits: no comprehensive scenario analysis was run in 2025, and grenke plans to "review the requirements for a climate scenario analysis tool suitable for grenke" in the coming year (page 102). The report gives no separate statement on uncertainty or on the ability to redeploy assets.

Opportunities named: green economy objects, government-sponsored funding and AI. The sustainability strategy is "fully embedded within our overarching business strategy" (page 102).

Reference: page 104.

The Climate Action Plan "outlines our approach to both climate change adaptation and climate change mitigation", including resource conservation, more renewable energy and energy efficiency (page 104). Four further policies support mitigation, in own operations and in part across the value chain. They are reviewed annually and apply globally (page 104):

• Environmental Policy: focuses on cutting greenhouse gas emissions and environmental risks and sets internal responsibilities for environmental matters.
• Car Policy: moves the company fleet to electric vehicles and sets eligibility for company cars.
• Travel Policy: for trips of up to 500 km one way, employees are encouraged to use pool vehicles or rail, with air travel only for longer distances.
• Supplier Code of Conduct: covers environmental responsibility and responsible sourcing of materials.

The report tags the Supplier Code of Conduct as the MDR-P disclosure and says the policies are available on the company website (page 104).

Reference: pages 104-108.

Fleet: the electric share (PHEV and BEV) of the Group fleet rose to 47% (2024: 38%), and 86% of vehicles newly ordered in Germany were electric (2024: 64%). Electrification saved 940 t CO2e in 2025, 31% below the 2022 base year, and fleet emissions fell 15% year on year (pages 104-105). The appendix gives 35% for the 2024 share (page 204).

Electricity: 28 of 32 German sites use green electricity; electricity emissions fell 12% year on year and 309 t CO2e (37%) against 2022 (page 105).

Travel and commuting: 777 train journeys (2024: 511) and 170 flights (2024: 110) in Germany; commuting emissions fell from 1,383 to 1,297 t CO2e (pages 105-106). Purchased goods and services fell from 1,435 to 846 t CO2e in the text (page 106); the GHG table shows 843 (page 116).

Digitalization: eSignature in 24 countries (2024: 27), 129,951 e-signed contracts (2024: 128,095), an eContract ratio of 40.1% (2024: 40.5%) and e-invoicing in 26 countries (pages 106-107).

Other: green economy financing, New Work office space and TÜV SÜD energy audits in Germany (pages 105, 107-108). Fleet electrification "does not lead to additional costs", and key 2025 measures "are reflected in our capital expenditures" (pages 104-105).

Reference: pages 108-111.

grenke sets absolute 2030 reduction targets against a 2022 base year (page 109): Scope 1 minus 50%, Scope 2 minus 50% (based on location-based emissions) and Scope 3 excluding lease objects minus 25%, with net zero by 2050. The targets cover the seven GHG Protocol gases, apply globally and are described as consistent with the 1.5°C goal and SBTi recommendations (pages 109-110).

Progress in 2025 against 2022 (page 110): Scope 1 down 32%, Scope 2 down 54%, Scope 3 excluding lease objects down 25%. The planned 2030 cuts total 2,453 t CO2e for Scopes 1 and 2 and 1,158 t CO2e for Scope 3 (page 111).

Gaps: "Our climate targets were not externally validated by initiatives such as the SBTi during the reporting year" (page 111). Lease objects account for 99.8% of emissions and have no target yet; "next year we intend to work on defining specific Scope 3 targets" (page 108). Appendix B maps the E1-4 GHG reduction target datapoint to this section (page 193).

Reference: pages 111-112.

Total energy consumption in 2025 was 4,613 MWh (2024: 5,491 MWh), with 22% from renewable sources (page 111).

The figures come from utility billing data. Where bills were not yet available, grenke estimated from the prior year's figures, or from site size if prior-year data were also missing. All data run through the central corporate carbon footprint tool, and German sites work with TÜV on regular energy audits (page 111).

Reference: pages 112-117.

For 2025, category 2 (manufacture of lease objects) is 1,674,264 t and category 13 (downstream leased assets) is 933,002 t (page 116). 2025 is the first year lease objects are measured, using a spend-based method with Exiobase factors, and the share of primary data in Scope 3 "amounts to almost zero percent" (pages 114-115). Excluding lease objects, emissions fell 17% year on year (page 115).

Intensity is 0.0027367 t CO2e per EUR of net revenue (location-based, including lease objects) on net revenue of EUR 955,062,757 (page 117). Biogenic emissions were 25 t CO2e (2024: 105) (page 115). The factoring companies and the entities in Turkey and Singapore, in wind-down, are excluded (page 112).

Reference: page 117.

The report covers E1-7 and E1-8 in one statement headed "Statement on emission certificates and internal CO2 pricing", and the content index lists them together (pages 117, 197). On removals it says: "In the 2025 financial year, we did not undertake any greenhouse gas removals from the atmosphere using carbon credits" (page 117). No removals and no mitigation projects financed through carbon credits are therefore reported, and the climate targets are absolute reductions in emissions (page 109).

Appendix B maps the E1-7 datapoint (paragraph 56, GHG removals and carbon credits) to this section (page 193). Biogenic emissions from biofuels, 25 t CO2e in 2025 (2024: 105 t), are reported separately outside the footprint (page 115).

Reference: page 117.

The report states: "We do not currently use an internal CO2 pricing scheme. We continuously monitor regulatory and market developments on this topic and derive suitable measures for grenke" (page 117). This is a nil return, given in the combined E1-7/E1-8 statement that the content index lists as a single entry (page 197). No carbon price, scope of application or planned introduction date is given.

Reference: pages 121-122.

grenke has no standalone circular economy policy: it "has not yet implemented a standalone circular economy policy" and says introducing one is "generally conceivable in the future" once it has consistent data in all countries where its asset brokers operate (page 122). The commitments sit in two documents, the Environmental Policy and the published Guideline for Responsible Financial Products (page 122).

The Environmental Policy commits grenke to reuse usable materials from goods received (cartons, films, pallets, especially Euro pallets) for outbound shipments, and to recycle what cannot be reused (page 122). The Guideline sets out how returned lease objects are handled and how this is explained to SME customers (page 122). Two internal work instructions, "Technical inspection of incoming goods" and "Processing of incoming goods", are technical and "do not address the concept of promoting the circular economy" (page 122). The report tags the Guideline and Environmental Policy as the MDR-P disclosure (page 122).

Reference: pages 122-124.

Most lease objects are resold to specialist reseller partners at the end of the term. For the rest, grenke runs asset brokers in Germany, France and Italy that check function and resell objects for a second life (page 122). The report says its approach addresses four of the ten R-principles (reuse, repair, refurbish, remanufacture) and does not address refuse, rethink, reduce, repurpose, recycle and recover (pages 122-123).

Since 2024 grenke has added a dedicated Head of Circular Economy role. Its investment in Miete24 lets it test the secondary market, and since 2024 AfB gGmbH collects its employees' IT hardware (page 123). 2025 actions were: building remarketing into customer outreach (the German asset broker's online shop was redesigned), usage-based offers, DHL GoGreen shipping and reusable pallets (pages 123-124). In Germany, recovery brought in about EUR 3.4 million, with around 14,000 items sold a year; collection about EUR 110k (262 collections); certified data deletion about EUR 20k (587 invoices) (page 124).

Reference: page 124.

grenke sets no circular economy target: "Until now, we have not defined specific targets related to resource conservation and circular economy" (page 124). It plans, over the next two years, to "systematically gather more data on the handling of used lease objects and significantly enhance data quality", and then to set a measurable target (page 124). It says differing data sources and the difficulty of operationalization have so far kept it from defining a realistic company-wide KPI (page 124). A TOP KPI for the circular economy is expected once data quality and availability are sufficient (page 86). The report tags this statement as MDR-T and the content index lists E5-3 for this chapter (pages 124, 197).

Reference: page 125.

grenke separates two kinds of resource inflow (page 125): inflows from buying IT products and services for its own operations, such as laptops and furniture; and inflows set by its customers' own investments in lease objects. For the second kind it says it "has no influence over their resource use or the selection of the lease objects", and adds "We cannot directly control the resource inflows generated by our customers."

For its own IT, grenke works with AfB gGmbH to understand and manage inflows, and it aims to move employee hardware into a second life cycle (page 125). It points to its remarketing and asset broker services as the way it supports a functioning circular economy beyond the lease term (page 125). The report gives no tonnage or percentage for either kind of inflow.

Reference: pages 125-127; page 205.

grenke defines resource outflows by the expected lifespan of the objects it places on the market, taken as the term of its own lease financing, "typically four years". For durability it uses the depreciation (AfA) tables of the German Federal Ministry of Finance, a source it first applied in 2025 (page 125).

Most objects are sold on to specialist reseller partners at the end of the term, and "less than 2 percent" of lease objects return to grenke (page 125). In 2025 the asset brokers sold 18,986 items from central warehouses in Germany (9,393), France (7,277) and Italy (2,316) (pages 125, 205). Remarketing in Germany brought in about EUR 3.4 million, with around 14,000 items sold a year through the online shop and on site (page 124). A KPI table by object category and country covers average durability in months, items sold and scrapped, and waste volumes (page 127).

Reference: pages 125-127; page 69.

Recycling and waste data come from direct measurements by grenke's asset brokers in Germany, Italy and France. grenke states "We do not apply estimates or extrapolations to recovery, waste, or recycling data" and reports only values validated in those core markets (page 69). The three country datasets began moving to weight-based measurement in 2025 (page 125).

Germany, recovery routes at the asset broker (2025, with 2024 in brackets): reuse 1.33% (3.07%); material recycling 93.82% (88.63%); energy recovery 4.26% (6.47%); disposal 0.59% (1.82%). The recycling partner Der Steg gGmbH supplies recovery rates and data on hazardous substances in waste (page 125).

France: waste electrical and electronic equipment goes to an approved operator, RSB, under the 2020 AGEC law, with waste tracking documents kept for five years. Italy: registration in the RENTRI electronic waste register has been mandatory since February 13, 2025, and grenke Italy has its waste disposal company enter the data (pages 125-126).

Appendix B maps non-recycled waste (paragraph 37(d)) and hazardous waste (paragraph 39) to the E5-5 chapter (page 194).

Reference: pages 132-134.

grenke's Code of Conduct excludes child labor, forced and compulsory labor, modern slavery and human trafficking across the value chain, and bans discrimination on grounds including origin, religion, sexual orientation, age and disability (page 132). Recruitment, placement, training and promotion rest on qualifications, skills and experience. The VP Compliance oversees the Code (page 132). The report adds: "We have no concrete political commitments relating to inclusion or support measures for people from groups that are particularly vulnerable within our own workforce" (page 132).

The Health and Safety Policy applies to all companies in Germany and is the responsibility of the VP Work Environment (page 133). Training runs through the grenke Talent Lab with more than 197 courses; employees completed an average of 22.5 learning hours, and the 2025 Learning Week had 70 offers and 2,451 participants (page 133). Policies are guided by the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the UN Global Compact and the ILO core labor standards (pages 133-134). The policies address three impacts: diversity-driven productivity, work-life balance and insufficient workplace health and safety (pages 132-133).

Reference: pages 136-139.

grenke lists actions that address the risk of social factors impairing the business (page 136):

• Pay and benefits: the Compensation Raster project (started in 2023, continued in 2025) and a salary benchmarking exercise, plus benefits such as bike leasing, an occupational disability insurance subsidy and meal allowances.
• Family-friendly offers: childcare and dependent-care subsidies, flexible schedules, hybrid work and sabbaticals.
• Health@grenke: ergonomic workstations, sports groups, health checks and Mental Health First Aider training.
• Development and culture: a buddy program, mentoring, training, Family Day and the digital recording of working hours in Germany (pages 136-137).

These are bundled as the "House of Benefits" (page 138). The Human Resources and Work Environment departments provide the resources (page 139). The report states that "no significant capital expenditure was incurred to implement actions related to employee satisfaction, retention, and development" (page 139) and that grenke "has not identified any new material opportunities" for its own workforce, so it has not implemented opportunity measures (page 137). Effectiveness is judged through the annual survey, the fluctuation rate and exit interviews (page 139).

Reference: pages 139-140; page 142.

grenke sets four own-workforce targets (pages 139-140, 142):

• Fluctuation rate: below the financial and insurance sector average of 16.3% (2023, German Federal Statistical Office). The 2025 rate was 7.8% (2024: 8.9%), with 190 leavers.
• grenke Engagement Score: at least 2.2; the 2022 base year was 2.0 and 2025 was 2.2.
• Training days: 3.5 to 4 days per employee. The 2025 average was 2.81 days (2024: 2.96), and the report says the target level was not achieved.
• Gender diversity: 33% women on the Supervisory Board (17% in 2025), 25% on the Board of Directors (25%) and 30% in top management at grenke AG (34%) and across the Group (29%).

Targets apply to the own workforce and business operations, over short, medium and long term, and are coordinated with the Human Resources department (pages 139-140). Employee views enter through the survey, the Engagement Score and the materiality assessment (page 140). The report tags the targets as MDR-T and the metrics as MDR-M.

Reference: pages 140-142.

grenke employed an average of 2,439 people in 2025 (2024: 2,295; 2023: 2,157): 1,334 women, 1,105 men and none recorded as "others" (page 140). All 2,439 are permanent; there are no temporary employees and none without guaranteed hours. 2,119 work full-time and 321 part-time (page 141). Entries were 414 and departures 190 (page 141).

By location: Germany 1,021, France 235, Italy 217, United Kingdom 103, Spain 94, Finland 70, Portugal 68 and Poland 51 (page 142). Germany plus international locations are 1,021 and 1,418 respectively (page 140).

Headcount is a cumulative annual average, the sum of monthly headcount divided by twelve, including employees on maternity and parental leave. HR Analytics collects the data, with SAP SuccessFactors as the source, and the indicator is reported quarterly (page 140).

Reference: page 142; page 131.

The index lists S1-7 and S1-8 together in one section, "Characteristics of non-employee workers, collective bargaining coverage, and social dialogue" (pages 142, 198). On non-employees, the report says: "All of our employees are employed by grenke. However, to secure specialised expertise for projects, for example in IT, we collaborate with staffing agencies who provide us temporary personnel on demand" (page 142). The S1 chapter also says its workforce view takes into account temporary workers, self-employed individuals and third-party service providers (page 131).

No headcount, FTE or breakdown of non-employee workers is given. The phase-in table does not list S1-7 as phased in (page 202).

Reference: page 142.

The report states: "Our employment relationships are not subject to collective bargaining agreements" (page 142). Coverage by collective bargaining agreements is therefore nil, and no social dialogue arrangement or worker representative body is described in this section. In S1-2 grenke says it has not entered into any agreements with employee representatives concerning the observance of human rights (page 135). The content index lists S1-8 together with S1-7, and the phase-in table says no phase-in applies (pages 198, 202).

Reference: pages 142-143.

Gender in governance and management (page 142): women held 17% of Supervisory Board seats (target 33%; 2024: 17%) and 25% of Board of Directors seats (target 25%). In top management at grenke AG, defined as the first and second levels below the Board, the share was 33.8% (2024: 32.4%), or 24 of 71 positions, above the 30% target. Group-wide the share was 28.7% (2024: 27.2%), with 69 women in 239 positions, against a target of at least 30%.

Women are 1,334 of 2,439 employees (page 140).

Age (page 143): under 30 years 20%, 30 to 50 years 66%, over 50 years 14% (2024: 22%, 64%, 14%). The text says 65% of the workforce is between 30 and 50 while the table shows 66% (page 143).

grenke reports on its diversity strategy and Board statement under Section 289f (2) No. 6 HGB in Chapter 8 of the annual report (page 143).

Reference: page 143.

The report states: "All employees receive appropriate remuneration in line with the relevant reference benchmarks" (page 143). It supports this with the Compensation Raster project, launched in 2023 to meet the EU Pay Transparency Directive. The project groups employees by role and hierarchy, finds deviations and benchmarks salaries against external data (page 143). It started at the German entities and in 2025 extended to nine more countries: France, Finland, the United Kingdom, Ireland, Italy, Spain, Brazil, Portugal and Poland. It is now in its final phase, and 2026 plans cover broader analyses and action on any remaining pay gaps (page 143). Another nine countries follow in 2026, for reporting in 19 countries from 2027 (page 145). No adequate wage benchmark, country list or share of employees below it is given.

Reference: page 143.

The report states that "grenke offers all employees protection in the event of illness, unemployment, work accidents and disability, parental leave, and retirement within the framework of statutory regulations" (page 143). It adds that grenke complies with the relevant national regulations at its subsidiaries and takes the appropriate actions (page 143). The coverage described is statutory. No employee numbers, no list of countries and no gaps in coverage are given. The phase-in table does not list S1-11 as phased in (page 202).

Reference: pages 143-144.

grenke discusses performance, potential and skills with each employee in the annual review, and the results feed the annual training plan; since 2022 the review also covers the first management level below the Board (page 143). A table gives the split of employees with regular performance and career reviews as 47.7% male and 52.3% female in 2025 (2024: 48.5% and 51.5%) (page 144).

Training metrics (page 144): a Group training rate of 98.4% (2024: 98.8%) and an average of 22.50 training hours per employee (2024: 23.65; 2023: 29.39). The text also gives an average of 2.8 training days per employee (2024: 3) (page 144). The S1-5 chapter reports 2.81 days against a target of 3.5 to 4 (page 140). Training offers are listed on the company website (page 144). The phase-in table says no phase-in applies to S1-13 (page 202).

Reference: page 144.

Health and safety is set out in the Health and Safety Policy, which applies to all grenke entities in Germany; subsidiaries follow local rules (page 144). Officers for occupational health, workplace safety and fire protection are appointed in Germany under the ASiG and the DGUV Regulation 2 (page 144).

2025 results: no fatalities from work-related injuries or illness; 5 reportable occupational accidents among employees (2024: 13), a rate of 0.2%; an average of 9 sick days per employee (2024: 9) (page 144). By entity, grenke AG recorded 4 and GRENKE BUSINESS SOLUTIONS 1 (2024: grenke AG 7, grenke Bank 3, GRENKE digital 2, GRENKE BUSINESS SOLUTIONS 1) (page 144). The report calls high-risk occupational hazards "extremely low" and not a material risk to the business model (page 144). Appendix B maps the S1-14 datapoints 88(b), (c) and (e) to this section (page 194).

Reference: page 145.

Only German entities are covered. All employees in Germany are potentially entitled to parental leave, with exceptions for those already on leave or long-term absence and for probationary staff; trainees and students are eligible (page 145). Of 1,079 eligible employees, 7% took parental leave in 2025. Leave for other family-related reasons (the Special Life Situations and Welcome Newborn models) was taken by 5.2% of 1,008 eligible employees (page 145).

By headcount in 2025, women and men respectively: parental leave 58 and 18, return from parental leave 25 and 16, newborn arrival 0 and 17, special life situations 23 and 12 (page 145). grenke plans to include more entities in future and says technical reasons prevented it this year (page 145).

Reference: pages 145-146.

Only German entities are included. The adjusted gender pay gap for total annual compensation was 2.98%, below grenke's internal tolerance level of 5% and the German national average of 6% (Federal Statistical Office, 2024). The consulting firm Lurse ran the pay equity analysis on 2024 median salaries, considering age, job role and job family, and grenke received a two-year certification (page 145).

The unadjusted gender pay gap for total annual compensation was 17.52%, against a market average of about 16%. The calculation follows the formula in ESRS S1-16 AR 98 and covers base salary and total annual remuneration (page 145). The total compensation ratio, the highest-paid individual outside the Board of Directors against the median of all Group employees, was 6.45 (page 146). The analysis will be repeated in 2026 under the EU Pay Transparency Directive (page 145). Appendix B maps S1-16 datapoints 97(a) and 97(b) to this section (page 194).

Reference: page 146.

The number of reports submitted through channels where employees can raise concerns, including grievance mechanisms, was 23 in 2025 (page 146). There were no complaints filed with the OECD National Contact Points for Multinational Enterprises, and no material fines, sanctions or compensation payments arose from incidents and complaints (page 146).

"No serious human rights issues or incidents occurred involving our own workforce", and serious incidents in breach of the UN Guiding Principles, the ILO Declaration or the OECD Guidelines did not occur (page 146). The number of reported cases of work-related discrimination, including harassment, was zero (page 146). Appendix B maps S1-17 datapoints 103(a) and 104(a) to this section (page 194).

Reference: pages 151-153.

grenke defines consumers and end-users as its SME customers and specialist reseller partners (page 151). Its policy base is the Code of Conduct, which governs dealings with customers and partners, the Supplier Code of Conduct, which extends the same principles to partners, and the Guideline for Responsible Financial Products (pages 152-153). The Supplier Code draws on the Universal Declaration of Human Rights, the EU Charter of Fundamental Rights, the UN Guiding Principles on Business and Human Rights, the Children's Rights and Business Principles, the UN Global Compact and the ILO core labor standards (pages 152-153).

In 2025 the Guideline was revised to add guidance on product risks, responsible marketing and sustainable performance commitments, and to clarify contract terms (page 153). The whistleblower system takes reports of breaches, including human rights issues, and grenke starts corrective measures and sanctions against business partners where rules are broken (page 153). "Based on our business model, we have not identified any consumer or end-user groups that are subject to a significantly higher risk of harm" (page 152). Appendix B maps S4-1 paragraphs 16 and 17 to this section (page 195).

Reference: pages 156-158.

Three risks are named, each with measures (page 157):

• Rising insurance premiums from extreme weather: revised products and terms to stay attractive, and raising customer awareness of public funding for climate-resilient investments, with sales training on funding programs from 2026.
• Pandemics and global health events: risk management, small-ticket leasing, grenke Bank products and the international footprint to absorb local disruption.
• Global economic crises: enterprise-wide risk management, geographic diversification, default-rate monitoring and annual risk analyses and stress tests.

grenke says it has "no direct control over the supply chains of leased objects" (page 157). Responsible sales practices include annual Business Partner Check training, annual compliance confirmation by managers and credit checks (page 156). grenke Bank granted 2,158 microloans in 2025 (2024: 2,034) (page 156). The report says "A low or non-existent rate of crisis-related impacts or payment defaults serves as a strong indicator of the effectiveness of our mitigation efforts" (page 158). An internal ESG score rates risk by lessee country and sector (page 158).

Reference: pages 158-159.

The TOP KPI "Number of contracts per active specialist reseller partner" is the measurable target for the S4 IROs. It was 9.3 in 2025 against a 2030 target of 11.3, two more contracts per partner than the 2025 reference year (page 159). Active partners are those with at least one inquiry in the past 365 days, a definition that limits comparison with prior years (page 158). At December 31, 2025 grenke had 34,548 active specialist reseller partners and 546,750 SME customers (pages 129, 158). Partners account for 82.1% of sales and direct sales for 17.9% (page 158).

Supporting indicators: 59.3% of active partners have worked with grenke for more than three years (2024: 59.8%), and there were 4,947 follow-on financing contracts with direct customers (2024: 4,994), 43.1% of direct-channel contracts (2024: 42%) (page 159). Better ESG ratings from MSCI, ISS ESG, S&P Global and EthiFinance are a further target for next year (page 159).

Reference: pages 163-166.

grenke describes a culture of "responsible behaviour, diversity, and open communication", tracked with a strategy map and the Overall Strategy Awareness (OSA) Score from the annual employee survey run with Cubia AG (page 163). The OSA Score was 2.7 in 2025 (2024: 2.6) against a 2030 target of 2.5, on a scale where 1 is high awareness (page 163).

The Code of Conduct applies to all employees, is issued with the employment contract and is overseen by the Board of Directors (COO) as the highest authority (page 164). The Supplier Code of Conduct covers suppliers and their subcontractors; the VP Work Environment and the VP Compliance share responsibility (page 164). Whistleblower protection follows the Whistleblower Protection Act and Directive (EU) 2019/1937, and grenke says it will not take steps to identify anonymous whistleblowers (page 165). Mandatory training covers compliance, data protection, workplace safety, IT security, anti-money laundering and loss event reporting, with harassment and discrimination training every three years (page 165). Climate-related factors are not yet linked to variable pay (page 163). Appendix B maps G1-1 paragraphs 10(b) and 10(c) to this section (page 195).

Reference: pages 168, 163, 84.

Back-filled from the business conduct chapter, where targets appear with the MDR-T tags. G1-3 became a standalone disclosure requirement only in the 2025/2026 ESRS; this statement was prepared under the 2023 ESRS.

Three TOP KPIs with targets sit in the G1 chapter (pages 84, 161):

• Internal Audit completion rate: 85% of planned audits fully completed by year-end, with the remaining 15% finished by the end of the following Q1. The 2025 rate was 70% (2024: 65%), below target (page 168).
• Overall Strategy Awareness Score: 2.5 by 2030; 2.7 in 2025 (page 163).
• Share of top management positions with a sustainability component in variable remuneration: the stated aim is a long-term increase in sustainability components to include climate and strategy targets; the 2025 share was 12.6% (page 84).

The targets apply to grenke's own workforce and operations and are pursued jointly with Human Resources and Internal Audit (pages 163, 168).

Reference: page 171; page 168.

The report states that "The Corporate Compliance department has no record of any convictions due to corruption, bribery or violations of competition law of grenke AG, the management of grenke AG, any subsidiary of grenke AG, or any other Company management member" (page 171). No fines were imposed for breaches of anti-corruption or anti-bribery laws, and no confirmed cases led to employees being dismissed or disciplined for corruption or bribery (page 171). No legal proceedings or court rulings on human rights issues were pending in 2025 (page 171).

grenke uses the number of employees covered by corruption and bribery training, the number of anti-financial crime reviews and the number of Integrity Line reports (23 in 2025, 2024: 17) as metrics for performance on these topics (pages 168, 171). Appendix B maps G1-4 paragraphs 24(a) and 24(b) to this section (page 195).

Reference: page 171.

grenke "does not engage in its own lobbying activities or attempt to influence political processes", and makes no financial or in-kind contributions to political parties or for political purposes (page 171). It belongs to the German Federal Association of Leasing Companies (BDL) and Leaseurope, which "may involve occasional political subject-matter discussions". The CEO, Dr Sebastian Hirsch, joined a Brussels delegation with policymakers as part of a BDL committee during the year, sits on the Board of Directors of the Deutsches Aktieninstitut (DAI) and has been a member of the independent Wirtschaftsrat Deutschland since November 2025 (page 171). No member of the administrative, management or supervisory bodies held a comparable position in public administration in the two years before appointment (page 171). grenke is registered in the Transparency Register (page 171). No lobbying spend is given, consistent with the nil-contribution statement.

Reference: page 171; page 168.

grenke states: "We settle invoices from our specialist reseller partners, regardless of the due dates defined in the payment terms, on average within two business days (<48 hours) following the completion of our internal automated approval process" (page 171). It adds that "The time between the invoice due date and the actual payment is not tracked in more detail" (page 171). Most payments are processed centrally from Baden-Baden and executed daily; time zone differences can cause delays, and the two-day goal was met in over 90 percent of cases in 2025 (page 171).

The average comes from a sample of 250 invoices from 2025, randomly selected from invoices due in the period and checked day by day against payment dates (page 171). grenke was not subject to any legal proceedings on payment delays or payment practices in 2025 (page 171). The text gives no breakdown by supplier type or standard payment terms.