HELLA GmbH & Co. KGaA

Reference: pages 85-87.

HELLA GmbH & Co. KGaA is a partnership limited by shares with four governing bodies: the general partner (whose five-member Management Board runs the group), the Shareholder Committee, the Supervisory Board and the Annual General Meeting (page 86).

• The Chief Executive Officer holds Management Board responsibility for sustainability and chairs the Sustainability Council, a cross-functional steering committee that meets fortnightly (page 85). The CEO role passed to Prof. Dr. Peter Laier on 16 February 2026 (pages 86-87).
• The Shareholder Committee has eight members and the Supervisory Board has 16. The Shareholder Committee validates the report and the double materiality analysis; the Supervisory Board approves the report and validates the analysis (page 86).
• Women hold 20.0% of Management Board seats, 25.0% of Shareholder Committee seats and 43.75% of Supervisory Board seats (page 86).
• The Compliance Office reports quarterly on anti-corruption, antitrust law and incident management to the Management Board and every six months to the Audit Committee (page 87).

Reference: page 88.

The Management Board receives regular status reports on environment, social and governance topics, including targets, actions and metrics, from the Sustainability Office or the relevant departments, and it decides on targets and significant actions.

During the reporting period the Supervisory Board received reports on the Non-financial reports for 2024 and 2025 and "took note of and approved the materiality assessment and the material reporting topics for the 2025 financial year". The Shareholder Committee gets sustainability reporting once a year on the Non-financial report and was consulted on diversity and climate change targets in 2025. A compliance report on anti-corruption and whistleblowing goes to the Audit Committee twice a year.

The report says impacts, opportunities and risks were considered in decisions on significant business transactions that change the business model or portfolio, including acquisitions and disposals.

Reference: pages 88-89.

ESG targets sit in both variable pay components for the Management Board.

• Annual pay: CO₂ intensity (Scope 1 and 2) and a lower accident rate, with a combined ESG weighting of 8% (2024: 7.5%), about 3.8% of total variable remuneration at 100% target achievement.
• Long-term pay: gender diversity (10% weighting) and CO₂ emissions reduction (15%), a combined 25%, about 13.0% of total variable remuneration.
• Across both components, ESG targets carry around 16.9% of variable pay.
• Climate-related reduction targets account for around 9.3% of total variable remuneration, or 6.4% of total remuneration (page 89).
• No sustainability components apply to Supervisory Board or Shareholder Committee pay.

For the first time in 2025, CO₂ intensity, accident rate and gender diversity targets also count toward the bonus of about 2,250 non-tariff employees, at a 15% ESG share.

Reference: pages 89-91.

HELLA states that it "complies with international standards such as the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises when implementing its sustainability-related due diligence" (page 89). The statement names its components as risk and impact analysis, preventive and mitigation actions, systematic monitoring and grievance mechanisms.

Pages 90-91 hold a table that maps each core due diligence element to chapters of the report: embedding in governance, strategy and business model (GOV-2, GOV-3, SBM-3); engaging affected stakeholders (SBM-2, IRO-1); identifying and assessing adverse impacts (IRO-1, SBM-3); taking action (the chapters on managing impacts, risks and opportunities for climate, pollution, circular economy, own workforce, value chain workers, consumers and business conduct); and tracking effectiveness (the matching metrics and targets chapters).

Reference: page 92.

Sustainability risks sit inside HELLA's Enterprise Risk Management (ERM). The report says they are labeled in the ERM and assessed and managed on a quarterly basis, but "not prioritised in the analysis of all identified risks in the ERM". Technical experts review their assigned risks each quarter and a Risk Champion approves the assessments.

The internal control system for non-financial reporting is the responsibility of the central departments and the Sustainability Office. Each department identified and evaluated risks for its area in an annual risk assessment, and named risks include data quality and completeness. Controls described: scope, structure and templates set centrally; data entered by local units and reported to central functions monthly, quarterly or annually; plausibility checks by the Sustainability Office; validation of results by central functions; and HELLA says it "introduced dual controls to prevent misuse and ensure data integrity". Management and supervisory bodies are informed at least once a year.

The content index gives page 90 for GOV-5; the section sits on page 92.

Reference: pages 92-95.

HELLA is a listed automotive supplier headquartered in Lippstadt and part of the FORVIA Group, with three business groups: Lighting, Electronics and Lifecycle Solutions (page 92). It had 34,046 employees at 31 December 2025 at over 125 locations (page 93). Currency- and portfolio-adjusted sales were EUR 7.86 billion: Lighting EUR 3.6 billion (46%), Electronics EUR 3.2 billion (41%) and Lifecycle Solutions EUR 1.0 billion (13%) (page 93).

Value chain (page 95): production materials come from over 2,000 suppliers with an annual purchasing volume of over EUR 4.5 billion, mainly semiconductors, printed circuit boards, plastic parts, metal components and chemical raw materials. Indirect purchasing and services exceed EUR 1.2 billion. Output goes to vehicle manufacturers and workshop wholesalers; end users meet the products in their vehicles or as spare parts.

Sustainability targets for climate, circular economy, water, ISO certification, health and safety, training, diversity, human rights, supplier ESG assessment and compliance training are listed on pages 94-95.

Reference: pages 96-99.

A table on pages 96-97 lists stakeholder groups, how HELLA engages each one and what the exchange produces. Groups: employees (surveys, works councils, townhalls), customers and vehicle manufacturers (portals, strategic annual meetings), suppliers (supplier portal, a two-yearly Suppliers Day and Sustainability Day), investors, authorities, local communities, NGOs, industry associations and end users. The administrative, management and supervisory bodies are informed about stakeholder interactions through reporting on the Non-financial report (page 98).

On value chain workers, HELLA says supplier interests enter strategic planning and that "Workers in the value chain are therefore indirectly involved" (page 98). On end users, the company "generally has no direct points of contact with end-users", so their interests are taken into account through the authorities and vehicle manufacturers (page 99).

Reference: pages 99-101.

The double materiality analysis produced 24 numbered impacts, risks and opportunities (IROs) across seven topical standards: E1 (IROs 1 to 5), E2 (6 to 8), E5 (9 to 13), S1 (14 to 18), S2 (19 and 20), S4 (21 and 22) and G1 (23 and 24) (page 100). The company says "the material topics identified in 2024 were reaffirmed", with two sub-topics new in 2025: E2 substances of concern and of very high concern, and G1 management of supplier relationships including payment practices (page 99).

Examples (page 100): production losses from extreme weather in own plants and supply chains (IROs 1 and 2); HELLA's footprint of 12.9 million tonnes of CO₂e in 2025 (IRO 4); waste in own production and upstream (IROs 11 and 12); potential accidents in production (IRO 16); injuries in car accidents caused by product safety defects (IRO 21); delayed payments to small and medium-sized enterprises (IRO 24).

The report states: "no material risks or opportunities have been identified where there is a significant risk that balance sheet values of assets and liabilities recognised in the corresponding financial reports will be materially adjusted in the next reporting period" (page 101). No entity-specific topics were identified beyond the ESRS (page 101).

Reference: pages 101-105.

HELLA ran a comprehensive double materiality analysis in 2024 and had the specialist departments review it in 2025 (page 102). An independent third party assisted and a CSRD working group led by the Sustainability Office ran it. The company says its methodology "complies with the requirements of the ESRS published in July 2023" (page 101). The first pass recorded over 200 IROs (page 103).

• Impact materiality: scale, scope and irreversibility are each rated 1 to 3; a mean above 2 counts as significant. Potential impacts also get a likelihood rating, but it is not applied to potential negative impacts rated above 2, to show the worst case (page 103).
• Financial materiality: financial effect set at EUR 25 million, 75 million or 150 million and likelihood at 17%, 50% or 83%; "All risks with a value of more than 50 million euros from the multiplication of these parameters were classified as material" (page 103).
• Stakeholders: eight interviews in 2024 with core suppliers, strategic customers, associations and research partners; none in 2025 (page 103).

Topic notes follow for E1 (physical risk modeled with FORVIA and Swiss RE under SSP4 and SSP5-8.5, plus a 1.5°C scenario), E2, E3, E4, E5 and G1 (pages 104-105). The Management Board validated the 2025 results and the Supervisory Board and Shareholders' Committee approved them (page 104).

Reference: pages 83, 106-109, 113, 117.

The IRO-2 table on pages 106-109 is the company's own list of the requirements it followed "based on the results of the materiality assessment". It covers the ESRS 2 requirements and, by topic: E1 (E1-1 to E1-6); E2 (E2-1, E2-2, E2-3, E2-5); E3 and E4 (the IRO-1 process entry only); E5 (E5-1 to E5-5); S1 (S1-1 to S1-10, S1-12, S1-13, S1-14, S1-16, S1-17); S2 (S2-1 to S2-5); S4 (S4-1 to S4-5); and G1 (G1-1, G1-3, G1-4, G1-6).

Not in the index: E1-7, E1-8, E1-9, E2-4, E2-6, the E3 and E4 requirements, E5-6, S1-11, S1-15, S3 and G1-2 and G1-5. Appendix B (pages 109-117) marks the E2-4, E3, E4 and S3 datapoints "Not material". Page numbers in the index do not always match the pages where content sits: S1 entries run up to four pages ahead.

Basis of preparation (page 83): the report is prepared "in partial application of the first set (as at July 2023) of the European Sustainability Reporting Standards (ESRS)" as a framework under the German Commercial Code, and "Data points that are not fulfilled are shown in the topical chapters". Datapoints incorporated by reference to the corporate governance declaration and the financial report are listed on page 117.

Reference: pages 129-133, 137-138.

HELLA states it has a transition plan for climate change mitigation as a company of the FORVIA Group, built on the net zero standard and "validated by the Science-Based Targets Initiative (SBTi) for the parent company FORVIA in June 2022". HELLA is seeking revalidation in the medium term, and the plan is described as compatible with limiting warming to 1.5°C (page 129).

Targets (pages 129-130): net zero along the value chain by 2045; a 45% cut in Scope 1, 2 and 3 emissions by 2030 against 2019; a 90% cut in Scope 1, 2 and 3 emissions by 2045, with the remaining 10% offset; and an 80% cut in Scope 1 and 2 by 2025.

Levers (pages 131-133): energy savings and renewable electricity for Scope 1 and 2, with heat pumps and a full switch from fossil heating planned by 2032; for Scope 3, weight reduction, sustainable materials, recyclability, electrification of the product mix, supplier practices, waste and logistics. Scope 1 and 2 levers are expected to contribute 12.21 kt CO₂e by 2030. The Scope 3 quantities relate to FORVIA, not HELLA alone (page 132).

Funding: EUR 242 million in 2025 and EUR 1,420 to 1,530 million planned for 2026 to 2030 (page 138). Emissions tied to material assets are not treated as relevant, at around 0.2% of total emissions (page 133).

Reference: pages 104, 134, 136.

Back-filled from ESRS 2 IRO-1 and the E1 resilience and adaptation passages, where this content is disclosed in the FY2025 report (pages 104, 134, 136). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk (page 104): HELLA analyzes exposure together with FORVIA and the reinsurer Swiss RE, covering all FORVIA sites including HELLA's, "according to the SSP4 and SSP5-8.5 scenarios", with a scenario in line with the 1.5°C target also taken into account. Raw material availability, loss of key suppliers and infrastructure are not part of this analysis. Page 136 describes HELLA's own site analysis under two IPCC scenarios (SSP2-4.5 and SSP5-8.5) for 2030 and 2050, covering acute risks (floods, storms, heat waves) and chronic risks (temperature, humidity, water stress). The report names SSP4 on page 104 and SSP2-4.5 on page 136 without reconciling them.

Transition risk (page 104): identified in strategic planning for short and medium-term horizons; "Climate scenarios are taken into account indirectly in this process" through assumptions on customer preferences and market developments.

The pages cited give no global average temperature projection per scenario.

Reference: pages 101, 134.

Back-filled from ESRS 2 SBM-3 and the E1 resilience passages (page 134), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Transition risk (page 134): HELLA says its portfolio is, with a few exceptions, "not dependent on drive technologies", and that R&D investment is aimed at electromobility. It notes continuing regulatory uncertainty over the pace of electrification, reviews market development in its annual strategic planning, and runs a Group-wide CO₂ network with FORVIA.

Physical risk (page 134): in 2023 and 2024 FORVIA commissioned Carbone 4 to run an OCARA climate resilience analysis for the 2030 and 2050 horizons at five FORVIA sites on three continents, including one HELLA site. It produced a list of critical production processes and a catalog of adaptation measures. HELLA says it will also assess natural hazards at higher-risk locations with external experts.

More broadly, HELLA states it can respond in good time to changes in material IROs through quarterly risk analyses and a five-year strategic planning horizon (page 101).

Reference: pages 94, 134-135.

Climate change is anchored in company-wide policies for all financially consolidated HELLA companies except Docter Optics and Beijing Hella BHAP Automotive (page 134).

• Own operations: the environment and health and safety (EHS) policy covers resource protection, renewable energy and GHG reduction, and a dedicated energy policy was rolled out in 2025 on energy saving and green electricity purchase (pages 134-135).
• FORVIA Excellence System: "Protect the climate" is the first of the 10 Green Fundamentals, which also set requirements for climate change adaptation (pages 94, 135).
• Supply chain: climate requirements sit in the supplier code of conduct and the quality guidelines, which refer to the FORVIA targets set against the SBTi net zero scenario. The HELLA Chief Executive Officer countersigns them (page 135).

Customer and investor expectations on climate performance were considered when drafting the policies, and they are published on the company website, in presentations and in the Non-financial report (page 135).

Reference: pages 135-138.

Actions are set in the annual strategic planning cycle and the technology roadmap, with CO₂ campaigns included in budget plans (page 135).

• Energy savings: the "Think.Act.Save!" initiative completed over 237 projects in 2025, saving 25.5 GWh of electricity and fossil fuels (2024: 343 projects, 44.8 GWh) (page 135).
• Renewable electricity: 99.9% of electricity came from renewable sources, up from 54.5% in 2024, partly through certificates for virtual power purchase agreements with FORVIA. Heat pumps were installed at the Shanghai and Changchun plants (page 136).
• Scope 3: category 3.1 emissions rose by 21,000 tonnes CO₂e (+1%), which HELLA attributes mainly to better primary data. Category 3.11 fell by 558,000 tonnes (-5.3%) with market electrification (page 136).
• Adaptation: site risk analysis under two IPCC scenarios and an early warning system for natural hazards (pages 136-137).
• Funding: taxonomy-aligned CapEx of EUR 134.4 million (20.7%) and OpEx of EUR 95.1 million (12.4%) in 2025; EUR 242 million of mitigation spend in 2025 and around EUR 1,420 to 1,530 million expected for 2026 to 2030, of which around EUR 1,200 to 1,300 million is electrification and battery management products (pages 137-138).

Reference: pages 138-139.

Targets set by the Management Board with FORVIA (page 138): an 80% absolute cut in Scope 1 and 2 market-based emissions in 2025 against 2019; renewable electricity at all locations over 900 square meters from 2025; energy intensity down at least 20% by 2025 and 30% by 2027 (base year 2019); and net zero along the value chain by 2045, with a 90% cut in market-based emissions and the remaining 1.7 million tonnes CO₂e offset or processed into materials.

Progress (page 139): energy intensity was 103.9 MWh per EUR million of net product sales, down 26.9% on 2019 against the 20% target. Green electricity reached 99.9% (2024: 54.5%). Total emissions (Scope 1, Scope 2 market-based and Scope 3) were 12,908,000 t CO₂e, down 25.8% on 2019, against a 2030 target of minus 45%.

HELLA says it "has not set a quantitative climate change adaptation target" for the period and does not plan one in the short term. The report says external stakeholders were not directly involved in setting the emissions targets.

Reference: page 140.

Total energy consumption was 784,825 MWh in 2025 (2024: 807,097 MWh). Renewable energy rose to 655,746 MWh, 84% of the total (2024: 45%). Fossil energy fell to 129,079 MWh, 16% (2024: 443,373 MWh, 55%). Natural gas was 115,323 MWh, and purchased fossil electricity, heat, steam and cooling fell from 314,957 MWh to 11,403 MWh. Nuclear consumption was zero.

Energy intensity was 103.89 MWh per EUR million of net product revenue, 98.19% of the 2024 value. HELLA reports as a climate-intensive sector under NACE code C 29.3.2.

Data cover January to October 2025; November and December are estimated from the prior year's consumption. The report states that fuel consumption is determined from calorific values, "Deviating from the ESRS definition".

Reference: pages 141-144, 146-147.

2025 gross emissions (pages 141-142): Scope 1 was 28,000 t CO₂e; Scope 2 was 246,000 t location-based and 3,000 t market-based (2024 restated: 132,000 t); Scope 3 was 12,877,000 t, of which category 3.11 (use of sold products) was 9,976,000 t. Total emissions were 12,908,000 t market-based and 13,151,000 t location-based. Against the restated 2019 base year, market-based total emissions are down 25.8%.

Intensity was 1,709 t CO₂e per EUR million of net product revenue (market-based), 95.4% of the 2024 level; 98.7% of Scope 2 emissions are covered by contractual instruments (page 143). Categories 3.13 and 3.14 do not apply. Primary data make up 4% of the GHG calculation (page 144).

Base year and 2024 values were restated after method changes in categories 3.1, 3.4, 3.9, 3.11 and 3.12 (pages 146-147). The narrative on page 142 gives Scope 1 for 2025 as 30,000 t, while the table shows 28,000 t.

Reference: pages 148-149.

IROs 6, 7 and 8 (substances of concern and of very high concern) are managed through the environment, health and safety (EHS) policy, the environmental norm restricting hazardous substances, the health and safety norm, the 10 Green Fundamentals of the FORVIA Excellence System and, in the supply chain, the supplier code of conduct and global purchasing conditions (page 148).

Product development applies an environmental standard that requires a test for substitution, and the occupational safety standard sets procurement approval and a duty to substitute: "a hazardous substance may only be used if no less hazardous alternative is available" (page 149). The relevant Green Fundamentals are "Keep soil and water clean", "Protect the air" and "Manage impact". The EHS policy covers all HELLA companies except Beijing Hella BHAP Automotive Lighting and Docter Optics, which manage the requirements independently. Stakeholders were not directly involved in creating the policies (page 149).

Reference: page 150.

HELLA describes Group-wide, ongoing actions to control substances of concern and very high concern and to prevent releases to the environment. Substances of very high concern (SVHC) are used in production because they give technical properties that are hard to replace, for example in painting and gluing and when cleaning production lines. A network of EHS managers manages their use, and internal and external environmental audits at production sites check the standards, with results reported to local management and the Management Board.

Site guidelines cover storage, use and disposal of chemicals, regular measurements check impacts, and remediation is monitored on site. For products, HELLA checks whether the substances are necessary and replaces them where economically viable, monitors the EU REACH Regulation (EC No. 1907/2006) and uses the International Material Data System (IMDS). Actions exclude Docter Optics and HELLA BHAP Automotive Lighting. The section gives no resource amounts.

Reference: pages 148, 150.

HELLA sets requirements for pollution prevention and employee health, including evaluating carcinogenic, mutagenic or reprotoxic (CMR) substances in production and analyzing safety data sheets (page 150).

It has no quantified pollution target: "In the reporting period, HELLA did not implement any voluntary group-wide pollution targets that go beyond compliance with legal regulations." The long-term intention is "to gradually replace substances of very high concern where this is technically and economically feasible", and the report says "no further information is provided on the target definition" because compliance with substance laws is monitored through procedural requirements (page 150). The IRO table records "No objective that goes beyond compliance with legal regulations." (page 148).

Reference: pages 148, 151.

HELLA states that it "uses substances of very high concern (SVHC) in mixtures in numerous production processes such as painting processes, soldering processes or cleaning, and products" (page 151).

It gives no amounts: "it is not possible to provide quantitative disclosures on the total quantity of substances of very high concern (SVHC) generated, used or procured during production in this reporting period", citing the large number of materials and components in the automotive industry. "Data availability is to be established in the medium term", and the company has not defined any targets. The section gives no amounts for substances leaving its facilities and no split by hazard class.

IROs 6 and 7 cover the use of substances of concern and of SVHC in products and own production (page 148).

Reference: pages 152-153.

Policies behind IROs 9 to 13: the environmental standard (design for resource preservation, avoiding waste and pollutants, lightweight construction, and the waste hierarchy of avoiding, reducing, reusing and recycling), product development specifications on quality and product safety, the 10 Green Fundamentals of the FORVIA Excellence System, the supplier code of conduct and project-specific requirements on secondary materials (pages 152-153).

The supplier code asks partners to support closed-loop systems, report secondary material use at product level and manage waste systematically (page 153). The Management Board signed off the concepts; the Development department and Purchasing Sustainability implement them. The requirements apply to all financially consolidated companies except Docter Optics and Beijing HELLA BHAP Automotive Lighting, and stakeholder interests were considered indirectly (page 153).

Reference: pages 105, 154-155.

HELLA says contributions to the circular economy sit in the product range of all financially consolidated companies, and it plans to expand its focus on the topic in the long term (page 154).

• Life cycle analysis and product carbon footprint: simplified LCAs guided by ISO 14040 and ISO 14044, often with customers (page 154).
• Circular design: the Nalyses research project looks at the full life cycle of headlamps, from materials to repair and recyclability. HELLA names scientific partners such as Fraunhofer IEM and, in the value chain, the supplier Covestro on recyclates (pages 105, 154).
• Resource efficiency: secondary materials such as recycled plastics and metals are considered project by project (page 154).
• Purchasing: environmental data requested in requests for quotations since 2025, covering GHG data, recycled and bio-based shares, scrap rates and renewable energy use (page 155).
• Rare earths: the CIPOS contactless inductive position sensor works without rare earth magnets (page 155).
• Spare parts and waste: over 45,000 spare parts, remanufactured brake calipers, IMDS tracking and reusable packaging. HELLA says further group-wide waste prevention actions upstream and downstream have not yet been implemented (page 155).

Reference: pages 155-156.

The Management Board set these circular economy targets, which HELLA calls voluntary; ecological thresholds were not taken into account (page 155).

• Waste intensity (waste per net product sales): down 9% by 2025 and 13% by 2027 against 2019. The base year 2019 value was 4.7. The target is broken down to all production sites (page 156).
• Recycled plastic pellets in total purchased plastic pellets, by mass: 25% by 2030. The actual level in the base year 2025 is 2.3% (page 156).
• Recycled material in new products going into series production from 2030: at least 20% by mass (page 156).

The two secondary material targets were set for the first time in 2025, developed by Purchasing and the CO₂ Scope 3 organization and based on sales and purchasing forecasts (page 156). The waste target ties to the Green Fundamental "Reduce waste".

Reference: pages 156-157.

HELLA's production materials supply chain has an annual purchasing volume of over EUR 4.5 billion and over 2,000 suppliers. The largest spend areas after purchasing costs are active electronics (semiconductors and printed circuit boards), injection-molded and die-cast plastic parts, metal parts, chemicals, lighting technology, passive electronics and mechatronics. Electronic components contain critical raw materials such as rare earths, cobalt and mica (page 156).

Resource inflows weighed 420,479 tonnes in 2025 (2024: 428,442). Secondary components, products and materials reused or recycled came to 17,106 tonnes, 4.07% of inflows (2024: 17,765 tonnes, 4.15%). Validated weight data exist for 94.7% of materials; the rest is estimated by extrapolation (page 157). Data on recycled and bio-based content cover plastics, chemicals and packaging only, and HELLA says no substantiated information is available for other purchasing groups (page 157).

Reference: pages 157-158.

HELLA's output covers headlamps and lighting modules, electronics for energy management (battery management systems, sensors, radar) and lighting and electronics for special vehicles (page 157). Some product packaging is reusable.

Durability generally matches the expected vehicle service life, and no central durability metric exists because requirements vary by product and customer (page 158). The recyclable share of products and packaging "is determined together with the customer for each project", and there is no portfolio-wide metric; HELLA says it will collect this in the medium to long term (page 158).

Potential recyclability of HELLA products is 16.9% in 2025. It is a theoretical value that "does not represent the actual recycling rate of the products". The prior-year estimate of 10% is only comparable to a limited extent after a method change (page 158). Waste is covered under the waste entry for E5-5 (pages 159-160).

Reference: pages 159-160.

Production sites generated 34,033 t of waste in 2025 (2024: 34,194 t), excluding non-recurring waste such as demolition waste: 1,938 t hazardous and 32,096 t non-hazardous, with no radioactive waste. Of the total, 29,808 t were diverted from disposal and 4,226 t went to disposal. Non-recycled waste was 8,738 t, 26% of the total (2024: 25%), and the recycling rate was 74% (2024: 75%) (page 159).

Waste intensity was 4.5 against a 2025 target of 4.3 (base year 2019: 4.7). HELLA says the target was missed because of, among other things, an increased rate of rejects in production (page 159).

Actual data cover January to October 2025, with November and December estimated from the prior year. Data come through the Tennaxia platform from waste service provider invoices and acceptance documents (page 160).

Reference: pages 162-165.

HELLA's own workforce policies are the code of conduct, the human rights policy and the environmental protection, health and safety (EHS) policy, supplemented by process guidelines, collective labor agreements and operating agreements. The Chief of Human Resources is responsible for personnel policies and the Chief Executive Officer for occupational safety concepts (page 162).

The human rights policy rests on the International Bill of Human Rights, the fundamental ILO conventions, the UN Guiding Principles and the OECD Guidelines. It sets principles on child labor, forced labor, freedom of association, non-discrimination, wages, working hours, training and health and safety (pages 163-164). HELLA "rejects all forms of forced and compulsory labour, modern slavery and human trafficking" (page 163). Supplementary guidelines on preventing child labor and forced labor were rolled out. The policies apply to all employees including temporary workers, and staff are trained on the code of conduct (page 164). Safety policy relies on preventive risk assessment and the 7 Mandatory Safety Rules (pages 164-165).

Reference: pages 166-171.

Actions are coordinated centrally by specialist departments and carried out through a network of HR managers; effectiveness is tracked through metrics and audits (page 166).

• Working conditions: temporary and agency workers are 10.4% of the workforce; flexible working models and site-level family services apply (page 167). An employee app was piloted at nine locations under the "We CARE" project (page 168).
• Diversity: HELLA signed the Women's Empowerment Principles, requires one of two shortlisted candidates to be female, and runs the RISE nine-month program for female talent. Women-in-management targets now count in the pay of all non-tariff employees (page 168).
• Training: the My Talent Compass platform and the FORVIA Learning Lab with over 2,000 programs; 1,500 feedback providers trained under "Guide, Empower, Recognise" (pages 169-170).
• Human rights: annual risk analysis under the German Supply Chain Due Diligence Act, with remediation required if violations are found (page 170).
• Health and safety: gradual introduction of the 7 Mandatory Safety Rules and 13 Mandatory Logistic Guidelines, not at Docter Optics or Beijing Hella BHAP (page 171).

Reference: pages 171-172, 175.

Targets set by the Management Board (page 172): an Employee Engagement Index of 80 out of 100 by the end of 2025; 25 training hours per employee per year by 2030; women among managers and professionals at 26.6% in 2025 and 28.3% in 2027, with 12% at the first and 18% at the second management level in 2027; no gender-specific pay gap; adequate wages; an accident rate of 2.2 in 2025 and 1.0 in 2027; and ISO 45001 certification of all production sites by the end of 2027 (excluding Docter Optics).

Respect for human rights has no quantitative target; due diligence runs through the human rights risk analysis. Each target is mapped to IROs 14 to 18. Employee representatives are not directly involved in setting objectives (page 171). The engagement index reached 69 out of 100 and missed the target (page 175).

Reference: pages 173-175.

At 31 December 2025 HELLA had 38,014 employees (24,174 male, 13,840 female, none other), against 40,185 a year earlier. The core workforce of permanent active employees was 34,046 (2024: 36,413) (page 173). Countries with at least 50 employees making up 10% or more of the total: Germany 7,535 (19.8%), China 6,434 (16.9%), Mexico 5,215 (13.7%) and Romania 4,737 (12.5%) (page 173).

The report breaks employees down by contract type, gender and region (page 174). Total turnover was 16.7% (2024: 18.2%), with 5,722 leavers; employee-initiated turnover was 6.5% (2024: 8.1%) (page 175). Data come from central SAP records, with Docter Optics and Beijing Hella BHAP Automotive Lighting reporting monthly (page 173).

Reference: page 176.

External employees numbered 3,968 at 31 December 2025, 10.4% of the workforce (2024: 3,772, 9.4%). All 3,968 are persons placed by companies that mainly carry out "employment activities"; no self-employed people are reported. HELLA says it uses them to react quickly to fluctuating order situations and to provide specialized skilled workers for short-term project tasks. Data come from central SAP records, with Docter Optics and Beijing Hella BHAP Automotive Lighting reporting monthly.

Reference: pages 176-177.

In the European Economic Area (EEA), 100.0% of employees are represented by at least one body in 2025 (works council, European Works Council, trade union or other representative), and 99.5% are covered by at least one collective agreement (company agreements and regional or national sector agreements). The 2024 figures, 99.2% and 86.5%, covered all employees worldwide, so the two years are not comparable (page 176).

Germany, Romania, Slovakia, the Czech Republic, Slovenia, Lithuania, Austria, Spain, France and Denmark all fall in the 80 to 100% band for both collective agreement coverage and worker representation (page 177). A European Works Council operates across the EEA (page 176).

Reference: page 177.

Women are 36% of the entire workforce at 31 December 2025. Among managers and professionals the share of women is 26.8% (2024: 26.2%) against a target of 26.6%, which the company says was achieved; Docter Optics is excluded. At top management level (the top management circle and the management circle) 77 of 522 are women, 14.8% (2024: 67 of 512, 13.1%).

By age: under 30, 6,961 people (18%); 30 to 50, 23,806 (62%); over 50, 7,346 (19%). The gender split of the Management Board, Supervisory Board and Shareholders' Committee is in the corporate governance declaration.

Reference: page 178.

HELLA states: "All employees worldwide receive adequate remuneration that corresponds to the applicable reference values. The target was therefore met in 2025."

Method: the lowest wage in each country, based on the basic income guaranteed to all employees, is compared with the local minimum wage or collective labor agreements. Where no statutory minimum wage exists, external salary databases and national legal requirements are used as additional checks, for example the "Progressive Wage Model" for Singapore.

Reference: pages 169, 178.

Persons with disabilities were 1.7% of employees at 31 December 2025 (2024: 1.5%). HELLA says it "fulfils the country-specific legal requirements for employees with disabilities". The report notes that disability is defined by law in each country, so data were requested from local companies, and that HELLA knows of no legal restriction on collecting the figure for its core workforce (page 178).

Inclusion actions at German sites include a special workshop in Lippstadt for severely disabled employees and interpreters for deaf-mute employees when needed. With FORVIA, HELLA ran two disability hackathons in 2025 (page 169).

Reference: pages 172, 178.

67% of men and 46% of women took part in regular performance and career reviews. The metric was collected for the first time, so there is no prior-year comparison, and employees without a computer workstation are not yet included.

Average training was 16.6 hours per employee (2024: 16.8): 16.8 hours per male and 16.2 per female employee. Office employees averaged 20.6 hours and production employees 11.2. Total training hours were 565,587 (2024: 653,306), based on 34,045 employees excluding temporary workers (page 178). The 2030 target is 25 training hours per employee per year (page 172).

Reference: pages 179-180.

HELLA recorded no fatalities among its own employees in 2025 (2024: 1) and none among other workers on its sites. The accident rate was 1.6 accidents per million working hours (2024: 2.4) against a 2025 target of 2.2. Days lost were 200 per million hours worked (2024: 338). There were 110 reportable work-related injuries (2024: 177) and 2 cases of reportable work-related ill health (page 179).

32 of 41 production sites (78%) hold ISO 45001 certification, covering 63% of all employees and 97% of employees at production sites. Docter Optics is excluded from these metrics; its accident rate was 17.6 (2024: 37.8) (page 179). Temporary and contract workers are included, with temporary workers' hours estimated from contracts (page 180).

Reference: pages 85, 180-181.

The unadjusted gender pay gap under the ESRS formula is 33.0% in 2025 (2024: 33.7%) (page 180). HELLA also reports an adjusted gap, weighted by job category and company size, of 2.9% (2024: 2.3%) against a target of no gender pay gap (page 181).

The annual total remuneration ratio of the highest-paid individual to the median of all other employees is a factor of 100.3 (2024: 62.4). It includes all pay components and excludes Management Board members, expatriates and long-term absentees (page 181). The calculation logic changed to include all remuneration components, and prior-year values were not updated because that was impracticable (pages 85, 181).

Reference: page 181.

As in the previous year, HELLA reports no incidents or complaints with severe human rights impacts in its own workforce that resulted in significant fines, sanctions or compensation. It defines severe incidents as "systematic company or local practices which result in a large-scale deprivation of workers' fundamental safety, dignity, and autonomy".

Complaints through grievance channels totaled 120 (2024: 85). Discrimination and harassment cases reported through the tellUS! whistleblower channel were 93 (2024: 74), plus 2 reported outside tellUS!; systematic recording of the cases outside the channel was piloted for the first time in 2025.

Reference: pages 183-184.

The human rights policy and the supplier code of conduct set out HELLA's commitments for value chain workers. The code is part of the General Terms and Conditions of Purchase and the tender documents, and suppliers must accept it with each contract award (page 183). It covers labor and social issues (child and forced labor, equal treatment, wages, working hours, health and safety, freedom of association), pollution and ethical business practices, and refers to ILO standards, the AIAG guiding principle, the Responsible Business Alliance, OECD guidance, the UN Guiding Principles, ISO 14001 and ISO 45001.

The statement says HELLA received no reports of violations of the UN Guiding Principles, the ILO Declaration or the OECD Guidelines involving value chain workers in 2025, as in 2024 (page 183). Docter Optics and Beijing Hella BHAP Automotive Lighting are not part of the process. HELLA also tracks the origin of raw materials, in particular conflict minerals, using Responsible Minerals Initiative templates (page 184).

Reference: pages 185-186.

HELLA includes sustainability performance in contract awards and analyzes supply chain risks each year under the German Supply Chain Due Diligence Act (LkSG), with results going to the Sustainability Council and the Management Board (page 185). EcoVadis is the main rating tool: suppliers with low ratings must take improvement actions, and ISO 14001 and ISO 45001 certification counts in strategic supplier development. HELLA joined the Responsible Business Alliance in 2025, and a third-party sustainability audit of a supplier was carried out in 2025. If suppliers fail to fix severe violations, HELLA reserves the right to end the relationship (page 185).

HELLA requests conflict mineral data with the RMI templates (CMRT for tin, tantalum, tungsten and gold; EMRT for cobalt and mica) and in 2025 added copper, graphite, lithium and nickel (page 186). Docter Optics and Beijing Hella BHAP Automotive Lighting are not part of the management approach (page 185).

Reference: page 187.

Voluntary target: 75% of the purchasing volume of strategic suppliers (about 400) with a valid EcoVadis rating of at least 50 out of 100 by the end of 2025, rising to 80% with at least 55 out of 100 by 2027. Result: 64% (2024: 60%), so the 2025 target was not achieved, which the company puts partly down to the level of ambition.

53% of total purchasing volume (about 1,700 suppliers in the active panel) holds a valid assessment. 91% of purchasing volume (2024: 84%) sits with suppliers holding a valid assessment, some below HELLA's targets, and those must present improvement plans. Targets were set by the purchasing directors and confirmed by the Management Board; workers in the value chain or their representatives were not included.

Reference: pages 188-189.

The code of conduct (valid for all HELLA companies except Beijing HELLA BHAP Automotive Lighting and Docter Optics) includes a voluntary commitment to product safety, and the quality policy sets product safety as a management requirement. Management Board members are directly responsible for product safety concepts in their business divisions. HELLA follows ISO 26262 for safety-related electrical and electronic systems in vehicles and ISO 21434 for product cybersecurity (page 189).

The human rights policy extends to consumers and end users, covering misleading marketing, privacy and access to legal remedies, though "the interests of end-users are indirectly taken into account" (page 189). The IRO table lists the policy on product safety, the code of conduct, the quality policy and the human rights policy against IROs 21 and 22 (page 188).

Reference: page 190.

The main impact and risk, product safety, is recorded in Enterprise Risk Management and reviewed quarterly by the Product Safety organization, with risk mitigation actions tracked. Internal safety checks and tests in development and production must be passed before delivery; product safety officers receive regular training. Product safety data are recorded digitally at checkpoints so recalls or over-the-air updates can be anticipated with vehicle manufacturers.

Effectiveness checks include internal audits focused on development sites with safety-relevant products, external certification of the functional safety process requirements under ISO 26262, and growing work on cybersecurity under ISO 21434. Violations are escalated to the Product Safety Committee and the Product Safety and Conformity Committee, and an Incident Management Team coordinates security incidents. As in the previous year, there were no indications of severe human rights issues or incidents.

Reference: pages 188, 191.

Stated aim: act in a legally compliant manner and avoid product recalls and the resulting liability claims, loss of sales or reputational damage; negative impacts on human health and the environment should also be avoided (page 191). End users were not directly involved in setting the objectives.

Target: all HELLA production sites hold a quality management system certified to ISO 9001 or IATF 16949, in 2025 and in the medium and long term (page 188). Result: 41 of 41 sites, 100% (2024: 40 sites, 98%) (page 191). HELLA's cybersecurity processes are externally certified under ISO 21434, reconfirmed in July 2025 after initial certification in 2024 (page 191).

Reference: pages 87, 192-193.

The HELLA Code of Conduct is the framework for corporate culture. It covers labor and social standards, data and environmental protection, fair business conduct, antitrust compliance, anti-corruption and conflicts of interest, and the Chief Executive Officer is responsible for implementing it (pages 192-193). The policy set also includes the anti-corruption guideline and the whistleblowing policy (page 192).

A company-wide compliance system built on the IDW PS 980 standard is run by the Compliance Office, which covers anti-corruption and antitrust and reports quarterly to the Management Board and every six months to the Audit Committee (page 87). Whistleblowers can use line managers, HR, compliance contacts or the tellUS! portal, which is anonymous and open around the clock; HELLA protects reporters' identity and lays down protection against retaliation as a principle (page 193).

Reference: pages 192, 194-195.

Back-filled from the business conduct chapter, where targets sit under the MDR-T disclosures rather than a numbered requirement. G1-3 became a standalone disclosure requirement only in the 2025/2026 ESRS.

Stated target: 100% of targeted employees trained on compliance basics and the code of conduct in 2025 (page 192). Result: about 16,700 employees completed the code of conduct e-learning across 2024 and 2025, a 98% completion rate against the 100% target (page 195).

On corruption prevention the stated aim is an effective anti-corruption program under Sapin II, and the report adds: "It is therefore a statutory, not a voluntary target." As the target is qualitative, base year and base value do not apply and stakeholders were not included (page 194). For payment practices HELLA sets no target beyond legal compliance (pages 192, 195).

Reference: pages 193-195.

HELLA reports that, "In the reporting period, as in the previous reporting period, HELLA did not record any convictions or fines or public court proceedings due to violations of corruption and bribery regulations." The section is a single sentence (page 195).

Context: the Compliance Office, independent of management, investigates possible bribery and corruption cases and reports twice a year to the Audit Committee (page 194). The tellUS! portal accepts reports on fraud, theft, corruption and bribery, among other topics (page 193).

Reference: pages 193, 195-196.

HELLA agrees its General Purchasing Terms and Conditions with suppliers at contract award; they cover quality and sustainability requirements and invoicing (page 195). Payment terms for 90% of suppliers are 60 to 120 days, and small and medium-sized enterprises are favored with shorter terms (pages 193, 196).

The report says "Detailed quantitative disclosures and a group-wide target for HELLA payment practices cannot be published in the reporting period due to a lack of data transparency, including for small and medium-sized enterprises" (page 196). HELLA has no voluntary payment practice target beyond legal compliance (pages 195-196). It reports no pending legal proceedings for payment default (page 196).