Henkel AG & Co. KGaA

Reference: page 153-159

Henkel AG & Co. KGaA is a partnership limited by shares whose sole Personally Liable Partner is Henkel Management AG. The Management Board has five members, four male and one female, a ratio of 80 percent to 20 percent at December 31, 2025 (p.154). The Supervisory Board has sixteen members: eight shareholder representatives (four men, four women) and eight workers' representatives (five men, three women), approximately 56 percent men and 44 percent women; six of the workers' representatives are employed by the Company and its domestic subsidiaries and two represent trade unions (pp.154-155). The Shareholders' Committee has ten members (eight men, two women). Four of the eight shareholder representatives and five of the ten Shareholders' Committee members are independent of the Henkel family share-pooling agreement under recommendation C.9 of the German Corporate Governance Code (p.157).

Seven bodies oversee sustainability impacts, risks and opportunities: the Management Board, the Sustainability Council, the Supervisory Board, its Audit Committee and Sustainability Committee, the Shareholders' Committee and the Compliance & Risk Committee (p.157). The Sustainability Council is chaired by the Management Board member responsible for Human Resources, Infrastructure and Sustainability (p.153). Henkel states that "The majority of the members of the Supervisory Board and the Shareholders' Committee possess expertise in the field of sustainability" (p.159).

Reference: page 159-160

Each year a schedule is prepared for meetings of all relevant bodies. The Management Board meets approximately every two weeks, the Sustainability Council approximately every two months with additional meetings as needed, the Shareholders' Committee approximately every two months, and the Supervisory Board, Audit Committee and Sustainability Committee quarterly (p.159). The number of meetings addressing sustainability matters in 2025 versus 2024 is disclosed for each body: the Management Board 11 (2024: 7), the Sustainability Council 6 (2024: 6 plus 5 special sessions related to the CSRD implementation programme), the Shareholders' Committee 2 (2024: 3), the Supervisory Board 3 (2024: 2), the Audit Committee 1 (2024: 2) and the Sustainability Committee 3 (2024: 4). (The report presents these counts in a two-column table; the pairing of individual figures to bodies is legible only in the printed layout, p.160.) The results of the materiality assessment, including the associated material impacts, risks and opportunities, were presented to and reviewed by the Sustainability Council, the Management Board and the Audit Committee of the Supervisory Board (p.160). These bodies also address trade-offs in decisions concerning significant transactions.

Reference: page 160-162

The Management Board remuneration system was adjusted and approved by the Annual General Meeting in 2023. The Short Term Incentive rests on financial targets achieved during the fiscal year (organic sales growth and adjusted earnings per preferred share, each weighted 50 percent) plus individual focus topics that include ESG aspects. The Long Term Incentive Plan, a virtual stock plan with a three-year measurement period and a subsequent one-year lock-up, combines financial goals (adjusted return on capital employed weighted 60 percent, relative total shareholder return weighted 20 percent) with ESG targets weighted 20 percent (p.160).

The 2025 LTI tranche carries three ESG targets: absolute reduction of Scope 1 and 2 CO2 emissions versus the 2021 base year (weighting 6 percent); increasing the share of recycled plastic for all packaging of consumer products (6 percent); and demonstrating commitment to belonging, inclusion and equal opportunities for all (8 percent) (p.161). The 2024 tranche used CO2 per metric ton of product (6 percent), recycled plastic (6 percent) and gender parity (8 percent); the 2023 tranche used CO2 intensity (10 percent) and gender parity (10 percent). Henkel states that the share of climate-related targets in the 2025 LTI tranche "remained unchanged at 12 percent" (p.161). Supervisory Board and Shareholders' Committee remuneration is fixed compensation only (p.162).

Reference: page 162

Henkel considers sustainability due diligence requirements when assessing material impacts and, for human rights, considers the risks to rights holders; this risk analysis is the basis for a human rights due diligence approach covering human rights and environmental risks. Implementation is guided by the UN Guiding Principles on Business and Human Rights, with the OECD Due Diligence Guidance for Responsible Business Conduct acting as a benchmark that Henkel "continuously review[s] and develop[s] as necessary". To identify, prevent or mitigate human rights and environmental risks the Company has established a company-wide risk management and due diligence process (p.162).

The statement carries the mandatory mapping table "Overview of the statement of due diligence", which links each of the five core elements of due diligence to paragraphs in the Sustainability Statement: embedding due diligence in governance, strategy and business model to ESRS 2 GOV-2, GOV-3 and SBM-3; engaging with affected stakeholders to ESRS 2 GOV-2, SBM-2, IRO-1 and MDR-P; identifying and assessing adverse impacts to ESRS 2 IRO-1 and SBM-3 plus the environmental and social topical chapters; taking action to the topical chapters and MDR-A; and tracking effectiveness and communication to ESRS 2 MDR-T and MDR-M in the topical chapters (p.162).

Reference: page 163-164

Coordinated risk management and internal control systems enable early identification and assessment of business-specific risks, and both incorporate sustainability matters. Henkel has reported annually on sustainability since its first Environmental Report in 1992. A significant portion of location-based data is systematically collected and verified, global data is collected through centrally controlled processes and checked for plausibility by experts, and selected location-based data is verified using the four-eyes principle (pp.163-164).

Three key risks in sustainability reporting are named: identifying report content through the materiality assessment; interpreting regulatory requirements for report content; and collecting and reporting report content (p.163). Mitigation rests on interdisciplinary collaboration between expert departments and a central reporting management function, and on close collaboration between the Sustainability and Finance departments. The risk situation is reported to the Compliance & Risk Committee, the Management Board and the oversight bodies, with unforeseen significant changes reported immediately to the CFO; Corporate Accounting coordinates risk reporting (p.164). The existing internal control system for financial reporting "is being constantly extended to include critical sustainability reporting processes" (p.164).

Reference: page 165-170

Sustainability, innovation and digitalization form Henkel's Purposeful Growth Agenda, complemented by the 2030+ Sustainability Ambition Framework (p.165). The business is organized in two units: Adhesive Technologies (adhesives, sealants and coatings across Mobility & Electronics, Packaging & Consumer Goods, and Craftsmen, Construction & Professional) and Consumer Brands (Laundry & Home Care, Hair, and Other Consumer Businesses). Consolidated sales in fiscal 2025 were 20.5 billion euros, with Europe, North America and Asia-Pacific accounting for 81.6 percent (p.165).

At the end of 2025 Henkel employed around 47,200 people: Europe 20,500 (43.5 percent), Asia-Pacific 8,650 (18.4), North America 7,250 (15.4), Latin America 5,450 (11.6) and IMEA 5,300 (11.2) (p.166). Products were manufactured in 53 countries at 165 sites (p.167). The value chain diagram splits activities into upstream (raw materials, packaging, contract manufacturing and traded goods, indirect materials, inbound transportation), own operations (production, R&D, marketing, sales, warehouse, own fleet) and downstream (outbound transportation, retail, end-users in craft and industry, consumers, disposal and recycling) (p.167). The five most important categories of direct materials are hotmelt adhesives, washing-active substances, polyurethanes, inorganic materials and surface treatment chemicals (p.167).

Reference: page 170-173

Henkel lists its key stakeholders and their expectations: customers and consumers (sustainable products and understanding of value chain impact); suppliers and business partners (a fair and reliable business relationship); employees (fair working conditions and opportunities to contribute); neighbours and local communities (general welfare, social development, environmental and climate protection); associations and NGOs; scientists; policymakers and authorities; and shareholders and investors, with ESG-focused investors holding "an identifiable interest in sustainability-related investments" (p.170).

Henkel holds memberships in industry associations and in the World Business Council for Sustainable Development and the World Economic Forum, and has been a UN Global Compact signatory since 2003 (p.170). Stakeholder opinion is monitored continuously through surveys, direct dialog, multi-stakeholder initiatives and dialog platforms (p.171). During the materiality assessment "stakeholder perspectives were represented by proxies to ensure diverse representation", and the administrative, management and supervisory bodies are informed of the results (p.171). Henkel states "There were no significant amendments to our strategy and/or business model during the 2025 fiscal year" (p.171). Separate subsections set out how the interests of the own workforce, value chain workers, affected communities and consumers are incorporated into the strategy (pp.171-173).

Reference: page 173, with the material IRO tables at pages 178-180

SBM-3 in the body is a cross-reference: "The material impacts, risks, and opportunities, as well as their interactions with Henkel's strategy and business model are outlined in the following chapter, 'Management of impacts, risks, and opportunities' (IRO-1, IRO-2)" (p.173). The materiality assessment result tables at pages 178-179 mark each ESRS 1 AR 16 sub-topic material or not material across four columns (positive impacts, negative impacts, risks, opportunities). All eleven topical standards are material at topic level.

Own activities, particularly production facilities, are linked to material impacts in climate change, water, biodiversity, circular economy, own workforce and business conduct; downstream relationships to climate change, water, biodiversity, circular economy, value chain workers and consumers; upstream relationships to climate change, water, circular economy, value chain workers and affected communities (p.180). On financial effects Henkel states that material risks and opportunities are primarily relevant over the medium to long term and that "the financial effects of each of those risks and opportunities are not considered material", with many current effects not reliably measurable, citing upstream carbon taxes embedded in purchase prices (p.180).

Reference: page 174-185

The materiality assessment follows a five-phase approach, updated in 2025 using the same method as the previous year: Phase 0 defines scope and organizational structure; Phase 1 creates a harmonized list of topics from the ESRS 1 list plus SASB, ISSB, GRI, the SDGs, EcoVadis, CDP and SFDR; Phase 2 compiles impacts, risks and opportunities along the value chain; Phase 3 assesses them; Phase 4 aggregates and validates (pp.174-175). "Compared to prior year, no entity-specific topics were added" (p.175).

Impacts are evaluated on a gross basis using a sector approach and scored on scale, scope, irremediability and likelihood; risks and opportunities on financial magnitude (annual impact on operating profit) and likelihood, each on a standardized 0 to 5 scale with written justifications (p.175). Thresholds are explicit: impacts scoring at least 3 on severity and at least 3 on likelihood are material, as are those scoring 4 or 5 on severity with likelihood 2, and 5 on severity with likelihood 1; the same pattern applies to risks and opportunities (p.176). Financial thresholds align with those used in enterprise risk management (p.176). Participants included Henkel Global Sustainability, Sustainability Finance, business unit and corporate function experts, the Sustainability Council, the Management Board and the Audit Committee (p.174).

Reference: page 185, with the index at pages 328-330

IRO-2 in the body is short: "A list of disclosure requirements followed in the preparation of the Sustainability Statement, is included in the Annex. Likewise, the Annex also contains a list of datapoints in cross-cutting and topical standards that derived from other EU legislation" (p.185).

Appendix 2, "List of disclosure requirements followed in the preparation of the Sustainability Report based on the results of the materiality assessment" (pp.328-330), is the content index. It lists, with section titles and page ranges: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1 and IRO-2; E1 SBM-3 and E1-1 to E1-8; E2 SBM-3 and E2-1 to E2-3; E3 SBM-3 and E3-1 to E3-4; E4 SBM-3 and E4-1 to E4-5; E5 SBM-3 and E5-1 to E5-5; S1 SBM-3, S1-1 to S1-6, S1-8, S1-9, S1-10, S1-14, S1-16 and S1-17; S2 SBM-3 and S2-1 to S2-5; S3 SBM-3 and S3-1 to S3-5; S4 SBM-3 and S4-1 to S4-5; and G1 SBM-3, G1-1 and an MDR-T row headed "Targets related to corporate culture and whistleblowers" (p.317). Disclosure requirements not listed are E1-9, E2-4 to E2-6, E3-5, E4-6, E5-6, S1-7, S1-11, S1-12, S1-13, S1-15 and G1-2 to G1-6. Appendix 3 (pp.331-337) is the separate list of datapoints deriving from other EU legislation, each marked material or not material with a page reference.

Reference: page 191

Henkel developed and published its Climate Transition Plan in 2024; it "outlines how its business model and climate related strategic priorities will align with the goal of limiting global warming to 1.5 degrees Celsius" and "serves as a roadmap for responsible growth and climate resilience", setting the path to net-zero emissions by 2045 (p.191). The plan's actions are set out under E1-3 and its targets under E1-4.

"The Climate Transition Plan and corresponding actions were approved by the Sustainability Council" (p.191). The plan is described as a key component of the climate strategy, which "strives for an end-to-end organizational and cultural shift toward net zero", with energy use, energy efficiency, renewable energies, eco-design of products and packaging, use of low-carbon materials and low-carbon logistics at the forefront of the actions adopted (p.189). Henkel states the plan "is in line with our general business strategy and resilience analysis", is "incorporated into our financial planning through corresponding operating and capital expenditure plans for key actions to achieve our net-zero targets", and that "Henkel is excluded from the EU Paris-aligned benchmarks" (p.199). During the reporting period no material capital expenditure was invested in coal-, oil- and gas-related economic activities (p.199).

Back-filled from the "Climate-related resilience analysis" subsection of the E1 chapter, disclosed under ESRS 2.19 and E1.19-21 in the FY2025 report (pages 189-191). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Henkel "continued and further developed our climate scenario analysis in 2025 based on the analysis conducted in 2024" (p.189). Risks are classified physical or transition. The physical assessment is "guided by the EU Taxonomy for sustainable activities, which defines 28 climate-related hazards as potential risk drivers including e.g. wildfires, storms and heatwaves". Exposure and sensitivity were assessed qualitatively and separately for the upstream chain (key feedstocks, supplier networks, logistical services), own operations (production sites, business continuity) and downstream (customer and consumer behaviour, market dynamics, logistics); own operations used geographic coordinates, other segments a regional level (pp.189-190).

Three IPCC Shared Socioeconomic Pathway scenarios were used with stated temperature ranges: SSP5-8.5 (3.2-5.4 degrees C), SSP2-4.5 (1.7-3.2) and SSP1-2.6 (0.9-2.3). SSP5-8.5 served "as the basis for modeling highest possible physical risks", and "the IPCC Scenario SSP1-2.6 was used as the basis for modeling the highest possible transition risks" (pp.189-190).

Back-filled from ESRS 2 SBM-3 "Resilience of the strategy and business model" (page 180) and the "Results and limitations" subsection of the E1 climate resilience analysis (page 191). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The analysis is qualitative: "To support a qualitative analysis of the resilience of the Company's strategy and business model, long-term risks over a period of ten years are identified annually, subjected to qualitative assessment and reviewed by selected in-house experts. This risk assessment also covers social and environmental risks. The risks are analyzed as a whole and assessed against our long-term risk-bearing capacity" (p.180).

The E1 chapter states that the material risks and opportunities relate to the transition to a low-carbon economy in the upstream and downstream value chain; that legal changes will have a financial impact through carbon taxes or market changes; and that these also create opportunities from demand for low-carbon and climate-neutral products (p.191). The response is the Climate Transition Plan, which "serves as a strategic element" mitigating the identified gross risks. Uncertainty is stated: "future results depend on a number of uncertainties and may therefore differ substantially from the results of the forward-looking materiality assessment".

Reference: page 192-193

Henkel "aligns its climate strategy with the 1.5-degree target of the Paris Climate Agreement" and pursues net-zero GHG emissions across the value chain by 2045, neutralizing residual emissions released after 2045. This includes a stepwise reduction of absolute direct and indirect emissions, including biogenic emissions from land-use changes and the extraction of biological raw materials for bioenergy, followed by counterbalancing remaining emissions in line with the SBTi Corporate Net Zero Standard. One commitment is stated: "We commit to reducing the carbon intensity of our business" (p.192).

Henkel "plans to continuously increase its energy efficiency over time and to transition to renewable energies while avoiding investing in the expansion of fossil fuel usage where possible", and aims for its products to reduce or avoid GHG emissions in use, naming detergents, shower gels and hotmelt adhesives as products associated with use-phase energy consumption (p.192). The Code of Sustainability covers the sub-topics climate change mitigation and energy, while energy efficiency, renewable energy and other mitigation levers "are primarily addressed in our Climate Transition Plan" (p.192). Henkel supports the IPCC Special Report on Global Warming of 1.5 degrees, the Kyoto Protocol and the Paris Agreement, aims to contribute to the nationally determined contributions of the countries in which it operates, and recognizes SDGs 7, 11 and 13.

Reference: page 193-199

The Climate Transition Plan is Henkel's long-term action plan and groups actions under four headings: energy use (energy efficiency, renewable energy deployment, renewable energy and fuel sourcing); eco-design (format design, packaging design); low-emission materials (supplier engagement, packaging, raw materials); and carbon-efficient logistics (logistics optimization, low-carbon transportation) (p.193). Scopes 1 and 2 account for "only a low percentage of total GHG emissions" (p.193).

Named 2025 progress includes a closed-loop cooling system at Maribor, Slovenia, in operation from 2025; on-site solar including "the biggest solar installation at Henkel in Kruševac (Serbia)"; confirmed Power Purchase Agreements, eco tariffs, I-RECs, power-to-heat projects and a biomethane Guarantee of Origin; liquid laundry reformulation phasing out non-biodegradable ingredients; a recyclable paper box replacing a plastic-paper blister for Blue Star toilet rimblocks in Austria; continuation of the "Henkel Climate Connect" supplier programme; hotmelt raw material partnerships with Dow and Synthomer; and relocation of several products from Europe to Los Angeles with a switch from air to sea freight (pp.193-197).

Lever contributions to 2030 are quantified. Scope 1 and 2 fall from an indexed 100 in 2021 to 58.0, with renewable energy and fuel sourcing -32.2, energy efficiency -9.1 and renewable energy deployment -0.6 (p.197).

Reference: page 199-203

Three absolute targets, all in percent against a 2021 base year: reduce absolute Scope 1 and 2 GHG emissions by 42 percent by 2030; reduce absolute Scope 3 GHG emissions by 30 percent by 2030; and reduce absolute Scope 1, 2 and 3 emissions by 90 percent by 2045 (net zero) (p.200). They apply to all geographies and the full inventory except category 3.11; categories 3.8, 3.10, 3.13 and 3.14 "are not relevant to Henkel's business model and are therefore not reported". Residual emissions of at most 10 percent are to be neutralized with permanent carbon removal and storage. "Since Henkel follows the SBTi Corporate Net Zero Standard, the removal of greenhouse gases, CO2 certificates or the avoidance of emissions will not be considered as ways of achieving the GHG emission reduction targets" (p.200).

Progress: "-49.5 percent for 2025 in respect of Scope 1 and Scope 2, and -28.0 percent in respect of Scope 3" (p.201). The Scope 3 reduction is "led by reductions in purchased volumes due to business transformation, portfolio projects and market effects" as well as supplier engagement.

The targets "have been independently validated and meet all relevant criteria of the SBTi Corporate Net Zero Standard version 1.2"; Scope 1 and 2 are aligned with a 1.5 degree decarbonization rate, while Scope 3 is "consistent with the well-below 2 degree goal for its near-term targets and consistent with the 1.5 degree goal for its long-term targets" (p.202).

Reference: page 203-204

Total energy consumption in 2025 was 2,076,464 MWh (2024: 2,114,259 MWh): 955,140 MWh fossil (46.0 percent; 2024: 1,115,803 MWh and 52.8 percent) and 1,121,323 MWh renewable (54.0 percent; 2024: 998,456 MWh and 47.2 percent). Consumption from nuclear sources was zero in both years (p.203).

Fossil consumption comprised natural gas 685,372 MWh (33.0 percent), crude oil and petroleum products 179,415 MWh (8.6 percent), purchased electricity, heat, steam and cooling from fossil sources 90,353 MWh (4.4 percent) and coal nil, against 10,078 MWh (0.5 percent) in 2024, consistent with the statement that coal use was completely discontinued in 2024 at the Düsseldorf-Holthausen power plant (pp.203, 203). Renewable consumption comprised purchased electricity, heat, steam and cooling 728,710 MWh (35.1 percent), fuel from renewable sources including biomass 356,570 MWh (17.2 percent) and self-generated non-fuel renewable energy 36,043 MWh (1.7 percent). "Henkel uses a market-based approach based on the GHG Protocol to balance its energy mix" (p.203).

Own energy generation was 930,585 MWh (2024: 935,711), of which 137,122 MWh renewable (2024: 99,107) and 793,463 MWh fossil (p.204).

Reference: page 205-215

Gross Scope 1 emissions excluding biogenic CO2 were 357,850 t CO2e (2024: 405,621; 2021 base: 618,089), of which 188,994 t CO2e related to energy used by Henkel and 168,856 t CO2e to steam, heat and electricity supplied to third parties. 59 percent of Scope 1 came from regulated emission trading schemes (2024: 56 percent). Gross location-based Scope 2 was 320,779 t CO2e (2024: 320,897) and gross market-based Scope 2 34,824 t CO2e (2024: 55,988; base 160,242). Scope 1 and 2 in the SBTi target scope fell to 392,674 t CO2e from a 2021 base of 778,331, a 49.5 percent reduction (p.205).

Total gross Scope 3 was 33,455,268 t CO2e (2024: 35,002,308), and Scope 3 in the SBTi target scope 12,959,361 t CO2e against a 2021 base of 17,990,115, a 28.0 percent reduction (p.205). Total GHG emissions were 34,133,897 t CO2e location-based and 33,847,942 t CO2e market-based (2024: 35,728,826 and 35,463,917), giving intensities of 1,666 and 1,652 t CO2e per million euros of net revenue (2024: 1,655 and 1,643) (p.214). Categories 3.8, 3.10, 3.13 and 3.14 are excluded "because they are insignificant for our business model" (p.207).

Methodology follows the GHG Protocol, with UK DESNZ factors for energy-related Scope 1, the Scope 2 hierarchical approach, and Scope 3 calculated predominantly by the average-data method using Ecoinvent 3.11, CarbonMinds 2024, Exiobase and supplier-specific factors; GWPs come from the IPCC Sixth Assessment Report (pp.207-211).

Reference: page 215

Henkel discloses a nil return. "According to Henkel's current net-zero strategy and Climate Transition Plan, the removal and storage of GHG are not part of Henkel's emissions reduction in the reporting year and are excluded from the target calculation under the application of the SBTi Corporate Net Zero Standard, on which our targets are based" (p.215). GHG removal and storage are noted as possible either via nature-based or technical solutions.

Because the net-zero target is set in conjunction with the SBTi Corporate Net Zero Standard, "actions to neutralize remaining emissions can be considered with an emission reduction of 90 percent in the Scopes 1, 2 and 3. Acceptable measures are high-quality CO2 compensation for the long-lasting removal and storage of CO2, as described in the SBTi Corporate Net Zero Standard" (p.215). On carbon credits and neutrality claims the statement is unambiguous: "Henkel has not made any public claims regarding the Company's GHG-neutrality and GHG-neutrality related to the use of CO2 certificates" (p.215). No removals, no credits purchased or retired and no neutrality claims are therefore reported for 2025.

Reference: page 215-216

Henkel uses carbon price forecasts, not internal carbon fees. "Internal carbon prices can be an effective instrument to link investments to sustainable solutions. Henkel uses carbon price forecasts for relevant business decisions in order to anticipate and mitigate risks from an increasing carbon price... The Company does not use any internal carbon fees" (p.215). Forecasts are applied to strategic questions such as investment projects, R&D investments, corporate planning and risk management.

Different prices are applied per country and region. Current prices come from the latest World Bank data and are extrapolated using the World Energy Outlook: "Conservative use cases such as risk management are aligned with the 'Net Zero Emissions by 2050' scenario, whereas more probable or operational use cases follow the 'Stated Policies Scenario'." The Stated Policies Scenario underpins corporate planning and, because asset impairment testing rests on those assumptions, is applied there too. "The resulting carbon prices per country vary between 0 and 250 USD per metric ton of CO2" (p.216).

On coverage: "The volume potentially relevant for investment and R&D projects comprises Henkel's GHG emissions in Scope 1 and 2 (392,674 metric tons) and 3.1 (10,332,003 metric tons). The actual share of Scope 1, 2 and 3 GHG emissions covered by carbon prices depends on the number of use cases for which carbon prices are considered financially relevant" (p.216).

Reference: page 218-220

Henkel's pollution policy covers one material sub-topic, substances of very high concern (SVHC), managed "in line with its Responsible Chemistry approach and internal standards such as our globally applicable SHE standards. In addition to following the SVHC definition of the ESRS, we also take local definitions into account" (p.218).

The Responsible Chemistry approach rests on a four-fold commitment: comply with statutory requirements on hazardous substances; ensure safe handling throughout the upstream value chain and own operations; provide solutions safe for consumers, end-users and the environment; and continuously innovate to develop products with lower hazard (p.218). The SVHC minimization policy has four elements: comply with local laws restricting these substances; where elimination is not yet possible, ensure safe use by providing instructions; anticipate future regulations and work with stakeholders on alternatives; and engage the value chain to switch to available SVHC-free alternatives (p.219).

"The policy is in line with the 'zero pollution hierarchy' of the EU action plan to prevent pollution of air, water and soil" (p.220). Henkel implements lower-hazard products before they are regulated and applies this globally rather than only where a substance is regulated (p.219).

Reference: page 220-221

Henkel implements its policy through active portfolio management in both business units and defines two actions as the most important for reducing the risk from products containing SVHC (p.220).

Driving the Responsible Chemistry approach of Adhesive Technologies: "we are phasing out certain products as planned and continuing to work on the replacement projects that were launched in 2025 or earlier... These actions are implemented globally." In 2025 Henkel "installed a holistic and proactive approach to managing SVHC across the Adhesive Technologies portfolio", identified all products containing SVHC in the existing portfolio, "defined maximum allowable sales volumes of SVHC-containing products by 2030", and "amended the governance of the development of new products with a new rule that requires management approval for any new product containing SVHC" (p.220).

Reducing and replacing SVHC in Consumer Brands' products targets an already defined list of SVHC globally: "In 2025, for example, we reduced the use of the cyclosiloxanes in the products of our hair care portfolio throughout all our markets" (p.221). The Consumer Brands initiative is to complete in the mid-term, the Adhesive Technologies initiative is long-term. Because the actions "do not represent an action plan as defined in the European Sustainability Reporting Standards... Henkel does not report on allocated financial resources" (p.221).

Reference: page 221

Henkel discloses that it has set no aggregate pollution target: "The sub-topic SVHC is managed through our policies and actions rather than an aggregate target. Our monitoring processes track the effectiveness of our policies and the progress of our actions in relation to the material sustainability impacts, risks and opportunities" (p.221).

This is the MDR-T alternative limb rather than a stated target. The effectiveness tracking referred to is described in the actions section: "Through portfolio management we monitor the progress of specific initiatives to reduce products containing SVHC in the two business units and report these to the Consumer Brands and Adhesive Technologies Executive Committees" (p.220). One quantified internal ceiling is disclosed within the Adhesive Technologies action rather than as a target: Henkel has "defined maximum allowable sales volumes of SVHC-containing products by 2030" (p.220), though the level is not given. Henkel's group-level target review, described under MDR-T, states that new targets applying from 2026 will be published during 2026 (p.185); pollution is not among the topics for which the Company says it has set time-bound outcome-oriented targets (p.184).

Reference: page 224-225

Henkel "aims for holistic water stewardship that enables responsible water management across the value chain based on collective action. This includes reduction of water consumption, circular water use and engagement in water-replenishment projects" (p.224). In its own operations the Company reduces withdrawal and consumption, applies efficiency measures and reuses wastewater wherever possible, treats and regularly monitors wastewater quality "to avoid water pollution resulting from our operational activities as well as to enable water recycling", and pre-treats where pollutants must be removed first.

On sourcing, "sustainability and environmental compatibility are our top priorities. We place particular emphasis on the use of renewable and responsibly managed water sources. We strive to avoid over-extraction from vulnerable ecosystems and prefer sources that have a minimal impact on local communities and wildlife" (p.224). Product design is a stated lever, aimed at optimizing water use in production, reducing use-phase water consumption and preventing downstream water pollution. Upstream, Henkel encourages suppliers "to improve their practices in the areas of water conservation, quality monitoring, wastewater treatment and recycling".

Responsible and circular water stewardship became a central pillar of the Nature Policy in 2024 (p.223).

Reference: page 225-226

Henkel implements water efficiency and circular water usage actions in its own operations and relies on consumer collaboration downstream; "Actions to address material impacts in the upstream value chain are being considered" (p.225).

Water efficiency actions "help to prevent water loss and reduce the total amount of water used in operations. For example, we optimize the changeover sequence to minimize cleaning water. We have also introduced efficient cleaning systems and closed-loop cooling systems in several locations to reduce the amount of cooling water required." Circular water usage actions "enable us to recycle and reuse water within the operational boundary", including reusing cleaning water in production, recycling water in sanitation processes and collecting rainwater from production facility roofs (p.225). Both "apply globally to all Henkel production sites and throughout our own operations and were further advanced in 2025", including at locations in areas of high water risk and water stress.

Downstream, consumer engagement informs users about sustainable water use: "One example is our 'It Starts with Us' program, that started in 2023, which provides consumers with practical tips for the sustainable and water-saving use of our products." In 2025 Henkel "continued this consumer education program and enhanced it with further sustainability tips for additional product categories" (pp.225-226).

Reference: page 226-227

Henkel has one water target: "Henkel's target is to reduce water withdrawal by 35 percent in m3 per metric ton of product by 2025 compared to 2010." It applies to all Henkel production sites worldwide, including those in areas affected by water risks or high water stress, and covers surface water, groundwater and third-party sources (p.226). It is relative, measured against a 2010 baseline of 1.23 m3 per metric ton of product (p.227). "Targets to address material impacts on the upstream and downstream value chain are being considered" (p.226).

The target was missed. "By the end of 2025, water withdrawal per metric ton of product had decreased by 22 percent compared to the 2010 baseline. Thus, the target level of -35 percent has not been achieved in the target year, which is attributable to changes in the product portfolio. For example, in several core markets, a shift from powder to liquid detergents can be observed" (p.226). Each site reports the metric monthly through a centralized tool; supplier-operated facilities are excluded.

The target is grounded in the UN Environment Programme finding "that water demand is projected to exceed supply by up to 40 percent by 2030" and in the freshwater planetary boundary, which "was already exceeded in 2023" (p.227).

Reference: page 227-229

Total water consumption in 2025 was 3,721,666 m3 (2024: 3,858,063) and total withdrawal 6,568,000 m3 (2024: 6,727,625). Withdrawal intensity was 0.96 m3 per metric ton of product, unchanged, and consumption intensity 182 m3 per million euros of net revenue (2024: 179). Water recycled and reused was 606,818 m3 (2024, restated: 736,380) and total water stored 63,929 m3 (2024: 131,779). Total wastewater, newly disclosed for fiscal 2025, was 2,846,334 m3 (2024: 2,869,562) (p.227).

Water consumption in areas of water stress was 1,682,870 m3 (2024: 1,762,678) and in areas at water risk 1,736,099 m3 (2024: 1,810,369), split into 947,352 m3 in areas with both increased general water risk and increased water stress, 788,747 m3 in areas of increased general water risk, and 735,518 m3 in areas of water stress but no increased overall risk (p.227).

"Our operational sites are located in 112 different river basins, as identified through the World Wildlife Fund (WWF) Water Risk Filter analysis" (p.228). Areas of water stress are those where withdrawal from surface water and groundwater is high (40-80 percent) or extremely high (over 80 percent) relative to available renewable water, identified with the WWF "Baseline Water Stress" indicator drawing on the PCR-GLOBWB 2 model at HydroBASINS levels 6 and 7. Consumption is defined as withdrawal less discharge and includes water contained in product formulations.

Reference: page 240

Henkel discloses no biodiversity transition plan and explains why. "The materiality analysis performed by Henkel included a risk assessment regarding financial effects. No material transition, physical or systemic risks related to biodiversity and ecosystems were identified. It was concluded on this basis that Henkel's business model overall is resilient to risks related to biodiversity because no biodiversity-related risks are material for Henkel" (p.240).

The risks assessed and rejected are named. Upstream: rising costs and unavailability of certain bio-based raw materials, arising from new legal requirements such as anti-deforestation regulations reducing arable land availability, decreased pollination from insect species extinction, and droughts or floods. "These risks were not classified as material because Henkel's portfolio is not reliant on a single raw material, and the Company has a resilient business model through diversification." For own operations: fines or penalties for non-compliance with environmental contamination regulations, transition risks from modifying packaging formats, and physical risks from insufficient water supply in water-scarce regions, all not material (p.240).

"As part of the materiality analysis, no material risks were identified in Henkel's own operations or its upstream and downstream value chain. As a result, no resilience analysis was conducted for the upstream and downstream value chain" (p.240).

Reference: page 240-242

Henkel "is committed to protecting and restoring biodiversity with a focus on forests, land and water", and the policy "sets the guiding principles for our biodiversity targets, as well as general principles for the selection of actions and the transition strategy toward our targets and ambitions" (p.240). Protection of global biodiversity was strengthened as a central pillar of the Nature Policy in 2024 (p.232).

Henkel supports the global "Nature Positive" goal, "strives to avoid negative impacts on threatened and protected species, especially impacts of own operations located in or near sensitive ecosystems", does not trade in CITES-listed species and respects legally designated protected areas (p.240). "Henkel is also committed to zero net deforestation and has an ambition of deforestation- and conversion-free sourcing of high-volume commodities with a high risk for deforestation, conversion of forests and natural ecosystems, or human rights violations. This particularly applies to timber, pulp and paper, palm oil, palm kernel oil and their derivatives" (p.241).

The ambition rests on named principles: transparency along the value chain; no conversion of natural ecosystems; no burning or use of fire for land clearing or replanting; and a zero net deforestation, DCF or NDPE commitment from suppliers, going beyond the EU Deforestation Regulation because of the concept's global scope (p.241).

Reference: page 242-243

"Our primary action in the area of biodiversity and ecosystems is the procurement of sustainable, certified raw materials, particularly palm oil, palm kernel oil, and their derivatives, as well as paper, pulp and other wood-based packaging products. This measure addresses material impacts on land use changes and land degradation in the upstream value chain" (p.242).

Recognized certifications are named: RSPO mass-balanced or segregated for palm oil, palm kernel oil and their derivatives; FSC, PEFC, SFI, CSA, AFS or equivalent for wood-based packaging (p.242). "The aim of this action is to prevent land-use changes and land degradation caused by deforestation in the procurement of relevant raw materials, while also promoting social sustainability. Within the mitigation hierarchy, this relates to the aspect of avoidance and reduction. This action is also contributing to our commitment of zero net deforestation."

The scope is the global upstream value chain, and the stakeholders involved are "suppliers, smallholder farmers, small-scale entrepreneurs along the value chain, affected communities and indigenous peoples in the relevant sourcing regions" (p.243). "In 2025, we continued the procurement of sustainable, certified raw materials", monitored by the Global Procurement Sustainability team.

Limits are disclosed: "No biodiversity offsets or other compensation was undertaken for the described actions.

Reference: page 243-247

Three targets, all absolute, measured in percent, aimed at 100 percent of the raw materials in scope, with no base year, no reference value and no interim milestones, running to 2025 and applying to the global upstream value chain (pp.243, 246).

Target 1, 100 percent palm and palm kernel oil responsibly sourced and certified or externally verified by 2025: achievement 98 percent in 2025 (2024: 97 percent), on 79,435 tonnes purchased of which 78,812 tonnes certified (2024: 79,002 and 78,143). Volumes covered by RSPO mass-balance certificates were 77,362 tonnes and by RSPO segregated certificates 36 tonnes. "The remaining difference towards 100-percent certified palm oil is mainly caused by limited availability of certified material in some markets" and by suppliers declining RSPO membership (pp.244-245).

Target 2, 100 percent transparency and traceability by 2025: traceability to mill 93 percent (2024: 94), to refinery 95 percent (95) and to plantation 79 percent (65), assessed by Action for Sustainable Derivatives on an agreed baseline of 99 percent of procurement volume (p.245).

Target 3, 100 percent paper and cardboard recycled or sourced from sustainable origins by 2025: achievement 68 percent (2024: 64), on 197 kt purchased (2024: 222 kt), with a 30 percent recycled share (34) and 98 percent certified non-recycled share (98).

Reference: page 233-239 and 247

"In 2025, 15 sites relevant to biodiversity have been identified, meaning locations among Henkel's own operations that contribute to the identified material drivers of biodiversity loss within its own operations (climate change and/or freshwater-use change). The identified sites relevant to biodiversity encompass an area of 14,247 hectares" (p.247). The 2024 figures were 18 sites and 15,857 hectares as originally reported, restated to 15 sites and 14,467 hectares after a methodological change.

The change is explained: the priority water site definition was aligned with the water stress and water risk indicators used in the E3 chapter, and from 2025 the 10 percent of sites with the highest water withdrawal are considered rather than those above average withdrawal. "The implication of this methodological change... applied for 2024 data, that 3 out of 18 sites are no longer classified as sites relevant to biodiversity (17 percent change, production sites in Drogenbos (Belgium), Maribor (Slovenia) and Raciborz (Poland)" (p.239).

Each site is listed with its impact driver, on-site activity, dependencies, ecological status and potentially affected key biodiversity and protected areas, from Bridgewater, Cannon Falls, Elgin, Enoree, Rocky Hill and St. Louis in the USA to Dammam, Düsseldorf-Holthausen, Jundiaí, Montornès, Reghaia, Toluca, two Zapopan sites and Umm Al Quwain (pp.234-235).

Reference: page 251-253

Henkel "is working on the transition to a circular economy, aiming to align resource inflows and outflows with circular principles", and states two commitments: "We commit to increasing the renewable share of ingredients and packaging materials" and "We commit to prioritizing sustainable packaging designs that minimize the use of packaging material and support reuse" (p.251).

On inflows, activities focus on increasing renewable and recycled raw materials in formulations, reducing raw material use by reformulation, increasing recycled content in packaging, and "Reducing the amount of packaging materials to a minimum, without compromising the quality, performance or safety of products" (p.251). On outflows, the packaging portfolio is being designed for recycling or reuse, Consumer Brands is increasing biodegradable ingredients, and Adhesive Technologies solutions extend product service life. "Henkel is also dedicated to supporting Extended Producer Responsibility (EPR) systems for packaging" and finances waste collection and recycling through EPR fees (p.252).

Suppliers are expected to "drive progress toward a circular economy by applying the 5Rs of the circular economy: Reduce, Reuse, Repair, Recycle, Recover" (p.252). On waste, "Our goal is to reduce waste at the source by making production processes more efficient."

Reference: page 253-254

Increasing recycled content in packaging: "In our Consumer Brands business unit in Europe we increased the share of recycled plastics in almost all of our liquid laundry bottle bodies from 50 percent in 2024 to 65 percent in 2025, while in Australia and New Zealand we increased this share from 50 percent in 2024 to 75 percent in 2025. As of 2025, almost all of our liquid laundry bottle bodies in North America have incorporated a minimum of 50 percent post-consumer recycled plastics. In our business unit Adhesive Technologies, all plungers for cartridges in North America that were entirely based on virgin plastic materials until 2024 are now made of 97 percent recycled content" (p.253).

Enhancing design for recycling: polystyrene was excluded from Adhesive Technologies aerospace shipping packaging; in the EU the toilet rim block pack moved from a non-recyclable plastic blister card to recyclable cardboard; and in North America a Got2b Curled line launched with mono-material HDPE bottles and PE labels (p.254).

Waste reduction in production: "In the year 2025, for example, we increased the share of high-quality outbound recycled cardboard at a global level. This led to a waste reduction from around 5,900 metric tons of waste in 2024 to around 3,700 metric tons in 2025. Moreover, in Brazil our Pallet Reconditioning Program led to the reduction of 450 metric tons of wasted raw materials compared to 2024" (p.254).

All actions apply globally.

Reference: page 255-257

Three circular economy targets within the scope of own operations, all due in 2025 (p.255).

Target 1, 100 percent of packaging designed for recycling or reusability: absolute, measured as a percentage, not based on a reference year, covering all packaging materials for finished goods placed on the market but excluding products whose ingredients or residue may affect recyclability. Achievement was 88 percent in 2025 (2024: 89 percent). Each plastic packaging component is tested against ten criteria including colour, label properties, material composition and avoidance of substances that disrupt recycling such as PETG (pp.255-256).

Target 2, more than 30 percent recycled plastic for all consumer product packaging: achievement 28.3 percent (2024: 25 percent).

Target 3, minus 50 percent production waste per metric ton of product versus 2010: relative, against a 2010 reference of 20.3 kilograms per metric ton, excluding construction waste and high-quality outbound recycling. Achievement minus 41 percent (2024: minus 39 percent) (pp.255-256).

All three targets were missed. On design for recycling, "complex technical hurdles and the absence of viable recycling solutions for certain formats - such as small-sized and flexible packaging - require extended development timelines"; on recycled content, "Technical, availability, quality and economic challenges, along with portfolio shifts and volume effects have contributed to the result" (p.255).

Reference: page 257-260

The material resource inflows are "raw and packaging materials, goods obtained from contract manufacturers, merchandise, goods for logistics (pallets), energy and water for operational processes" (p.257).

Total weight of products and technical and biological materials used in 2025 was 12,080,358 tonnes (2024: 12,700,562). The share of biological materials and biofuels used to manufacture products and packaging was 3 percent, unchanged. The total weight of secondary reused or recycled components, secondary intermediary products and secondary materials was 221,294 tonnes (2024: 226,179), a share of 2 percent in both years (p.257).

A packaging material mix is newly disclosed for fiscal 2025: plastic 255,977 tonnes (45.8 percent; 2024: 267,272), paper 215,891 tonnes (38.7 percent; 2024: 227,598), metal 75,894 tonnes (13.6 percent; 2024: 79,076), glass 4,101 tonnes (0.7 percent) and other 6,505 tonnes (1.2 percent) (p.258).

Limits are disclosed. "Around 8 percent of packaging and 2 percent of raw materials tonnage is estimated" (p.259). Recycled materials are evaluated only in the packaging category, and packaging from contract manufacturing, traded goods and indirect materials is excluded "since no sufficient documentation and information can be provided".

Reference: page 260

"Henkel is striving for a packaging portfolio that is designed for recycling or reuse. In the area of formulation ingredients, Consumer Brands business unit is working on increasing the share of biodegradable ingredients in product formulations. Biodegradability facilitates reintegration into the biological cycle and minimizes environmental impacts. Solutions from Adhesive Technologies reduce resource consumption during the use phase, enable reparability and support an extended lifespan of products and technologies" (p.260).

On durability and reparability Henkel gives a reasoned nil return for its own outflows: "The products that Henkel sells are intended to be used by consumers and end-users. Hence, the aspect of product durability plays a minor role. Reparability is not relevant for products placed on the market by Henkel" (p.260).

For recyclable content the chapter cross-refers to the target rather than reporting a separate rate: "The rates of recyclable content are captured with our target achievement for target 1: 100 percent of packaging are to be designed for recycling or reusability" (p.260), which stood at 88 percent in 2025 against 89 percent in 2024 (p.255). Recycled content of packaging placed on the market is reported through target 2, at 28.3 percent of plastic packaging for consumer products (2024: 25 percent). No separate rate of recycled content in resource outflows by material stream is given.

Reference: page 260-263

Total waste generated in 2025 was 123,054 tonnes (2024: 131,708), of which construction and demolition waste 29,545 tonnes (2024: 30,274) and high-quality outbound recycling waste 9,475 tonnes (2024: 5,219), both newly disclosed for fiscal 2025 (p.260).

Non-hazardous waste totalled 97,501 tonnes (2024: 100,932), of which 44,418 tonnes were diverted from disposal (2024: 50,406) and 53,083 tonnes directed for disposal (2024: 50,526). Hazardous waste totalled 25,553 tonnes (2024: 30,776), of which 5,568 tonnes diverted (2024: 7,987) and 19,984 tonnes directed for disposal (2024: 22,789). Total non-recycled waste was 77,985 tonnes, 63.4 percent of total waste (2024: 85,177 tonnes and 64.7 percent). "Henkel does not produce radioactive waste" (pp.260-261). Data on preparation for reuse is not recorded (p.262).

Waste is defined as "any material, substance or object that leaves a Henkel site for disposal or treatment" and divided into six streams: production waste; obsolete product waste; waste from wastewater systems; municipal waste; construction waste; and high-quality outbound recycling, "waste where the quality of the material is maintained or completely restored" and which replaces raw materials. Disposal routes reported are landfill, incineration with and without energy recovery, recycling, other disposal and other recovery methods (p.261).

Reference: page 273-276

Henkel states three commitments: "We commit to continuously ensuring that our employees earn a living wage or higher"; "We commit to building a proactive SHE culture, reduce recordable incidents and eliminate serious harm potential"; and "We commit to respecting human rights across our own operations and supply chain" (p.273).

Policies are set by sub-topic. Working time: "The maximum work time of a normal work week must usually not exceed 48 hours, unless otherwise permissible by law"; "All overtime work undertaken must not exceed 12 hours per week. At least one day off must be granted per seven-day working period" (p.273). Adequate wages: compensation reviewed regularly and non-discriminatorily, paid as agreed and without undue delay. Collective bargaining: "The right to collective bargaining must be respected and exercise of that right must not result in any sanctioning of employees." Work-life balance: flexible arrangements and parental leave, which "should apply based on the caregiver role and not based on gender or biological parent status". Health and safety: corporate SHE standards apply globally, each affiliated company implementing them through a management system (p.274).

On equal treatment, salary bands and grading systems support "equal pay for work of equal value", and the DEI approach covers gender, internationality and ethnicity, LGBTQ+, people with disabilities and cross-generation representation.

Reference: page 276-277

"Trust-based collaboration with employee representative bodies is an important part of our corporate culture. Extensive dialog and consultations with the management take place both at the operational level - for example with local works councils - and at the higher corporate level with the General Works Council and the trade union. Members of the German Works Council and representatives of IG BCE (Industrial Union for Mining, Chemicals and Energy in Germany) are part of Henkel's Supervisory Board" (p.276).

"To promote collaboration between management and workers' representatives at a European level, Henkel has voluntarily established a European Works Council. The EWC meets approximately five times a year" and is informed about the economic situation, restructuring or reorganization programmes, safety, health and the environment, and training and development. "A framework agreement served as the basis to establish the European Works Council that has 25 members from 18 European Union countries" (p.276). Where representation is not established, "Alternative mechanisms are in place... Examples include employee assemblies or employee committees."

To reach workers who may be vulnerable or marginalized, Henkel operates nine global employee resource groups working with the DEI and HR teams, and "a monthly pulse-check survey is sent to 5,000 randomly selected Henkel employees, which includes questions on aspects of diversity, equity and inclusion" (p.277).

Reference: page 277

"All Henkel employees and the stakeholders (for example customers, suppliers and service providers), as well as anyone else affected by Henkel's business activities, can report potential misconduct via the whistleblowing system. We have clear processes in place for due diligence and compliance to identify and assess potential negative impacts of our business activities. Where necessary, we also ensure access to remedial actions. A case-by-case assessment is conducted. This includes investigations, reviews of remedial actions and documentation of cases. Possible remedies are classified based on the severity of the violation and the outcomes of any prior corrective actions" (p.277).

The channel's detail is carried in the business conduct chapter, to which S1-3 cross-refers. Reports may be made by email to compliance.office@henkel.com, via a web form, or by name or anonymously through the compliance hotline, with procedural guidelines published on the website "in more than 40 languages" (p.318). Henkel commits to strict compliance with whistleblower laws globally including EU Directive 2019/1937, states that "Those who report suspected violations in good faith are protected and any kind of retaliation against them will not be tolerated", and confirms that "The effectiveness of the whistleblower process as a grievance mechanism is reviewed annually and on an ad hoc basis" (p.318). Employees may also raise concerns through supervisors or HR (p.280).

Reference: page 277-281

Actions on working conditions are named individually. Standardized time and attendance tracking: "In 2025, we broadened the scope of our global time and attendance tracking system, which now covers 31 countries" (p.277). Adequate living wage reviews: "In 2025, we continued our annual reviews based on external benchmarks to assess an adequate living wage. These analyses are regularly carried out across all regions and business areas at Henkel. They include all employees" (p.278). Membership of employer associations, including a board seat at the German Chemical Industry Employers' Association. Flexible working arrangements: "Our flexible options allow employees to spend up to 40 percent of their working hours outside the office." Global parental leave: "Henkel offers all employees who become parents a minimum of eight weeks of paid parental leave" in all roles and all countries (p.278).

On safety, Henkel "launched the first company-wide World Safety Day under the theme 'Unite in Safety - Inspire with Action'" and further developed the Sphera HSM incident management system. Health promotion in 2025 included the global campaign "My Rhythm of Life" (p.278).

Reference: page 281-282

Henkel has one own-workforce target: "+60 percent safer per million hours worked (2025 vs. 2010)". It is relative, measured as a percentage, and "The scope of this target refers to work-related accidents involving Henkel employees that result in lost-time cases." The baseline is a lost-time incident rate of 1.17 in 2010, calculated as lost time cases multiplied by 1,000,000 divided by total employee working hours, covering only work-related injuries to the own workforce and excluding non-employees, value chain workers, illnesses, occupational diseases and commuting incidents (pp.281-282). No milestones or interim targets were established.

The target was missed: "The achievement of our target to be 60 percent safer per million hours worked vs 2010 stands at 59.2 percent in 2025. As a result, the target of 60 percent was narrowly missed." Henkel names the residual risk areas: "there were still a number of accidents in key risk areas, such as ergonomic risks, slips, trips and falls, risks related to equipment and maintenance, and working at height" (p.282).

A limitation on worker involvement is disclosed: "However, employees or workers' representatives were not directly involved in the target-setting process, performance monitoring or in identifying insights and areas for improvement" (p.281). A target review was conducted in 2025 and new targets will be introduced in 2026.

Reference: page 282-283

At the end of 2025 Henkel had 47,200 employees by headcount (2024: 47,150), comprising 28,600 male (2024: 28,850) and 18,550 female (2024: 18,300). None are recorded as other or not reported: "Employees identifying as non-binary are reported under 'Other'... Currently, no cases have been reported" (p.283).

By country, only Germany and the USA meet the reporting threshold of at least 50 employees representing at least ten percent of the workforce: Germany 8,100 (2024: 8,050) and the USA 6,700 (2024: 7,200). By level, newly disclosed for fiscal 2025, there were 33,350 non-managerial employees (2024: 33,700), 13,100 managers in Management Circles III and IIb (2024: 12,650) and 700 top managers (2024: 700) (p.282).

By contract type there were 42,200 permanent employees (2024: 42,300) and 5,000 temporary employees (2024: 4,850), of whom 16,400 permanent and 2,150 temporary were female and 25,800 permanent and 2,800 temporary were male. No zero-hours employees are reported. Turnover: 5,350 employees left the Company in 2025, a rate of 11.3 percent, against 6,250 and 13.1 percent in 2024 (p.283). All figures cover permanent employees excluding apprentices at period end; headcount is captured through the Human Capital Management Core System, and "In some countries, we interpret the mandatory field for 'title' in SAP as an indication of gender".

Reference: page 283-284

Collective bargaining coverage at the end of 2025 was 49.4 percent globally (2024: 48.1 percent) and 83.1 percent in Germany (2024: 83.3 percent) (p.283). The coverage-rate table places Germany, the only EEA country meeting the reporting threshold, in the 80-100 percent band for both years (p.284).

"The percentage of employees covered by collective bargaining agreements is collected at the country level by HR teams in the respective regions. In accordance with ESRS, we report the percentage of employees covered by collective bargaining agreements, broken down by country only for countries where the proportion of employees accounts for at least 10 percent of Henkel's total workforce. All figures cover permanent employees excluding apprentices and apply to the end of the reporting period" (p.284).

The social dialogue context is set out under S1-2: a European Works Council with 25 members from 18 EU countries meeting approximately five times a year, local works councils, the General Works Council, and IG BCE representation on the Supervisory Board (p.276). Henkel notes in its S1 strategy that "legal restrictions on collective bargaining and union participation may prevent the negotiation of collective bargaining agreements" in some countries where it operates (p.271). Coverage of workplace representation in the EEA is not separately tabulated.

Reference: page 284-285

Top management is defined as Corporate Senior Vice Presidents and Management Circles I, Ia and IIa, consistent with Henkel's previous sustainability reports. At that level there were 700 employees at the end of 2025, comprising 450 male (63.5 percent) and 250 female (36.5 percent), against 450 male (65.5 percent) and 250 female (34.5 percent) in 2024. No employees are recorded as other or not disclosed. Henkel notes that "Headcount figures are rounded by 50, while % are based on the exact numbers", which is why the rounded headcounts are identical while the percentages move (p.284).

Beyond the top management level, Henkel states its wider ambition and its 2025 result: "Henkel also pursues a clear ambition in terms of gender diversity. We aim to achieve a balanced gender distribution across all leadership levels, in line with local laws. The ambition encompasses both top management and middle management. In 2025, the proportion of women across all management levels increased to 43.2 percent" (p.284).

Age distribution of the total workforce at the end of 2025: under 30 years 6,650 (14.0 percent, unchanged in share from 2024), 30 to 50 years 29,650 (62.8 percent; 2024: 29,400 and 62.4 percent) and over 50 years 10,950 (23.2 percent; 2024: 11,150 and 23.6 percent), on a total of 47,200 (p.285). All figures cover permanent employees excluding apprentices at the end of the reporting period and are captured globally through the HCM Core System.

Reference: page 285

Henkel discloses a positive assurance on adequate wages: "All our employees receive an adequate wage in accordance with applicable standards at the end of the reporting period" (p.285). The benchmark is named and dated: "Adequate wage levels for all employees are calculated using the reference values provided by the 'Fair Wage Network' (as of October 2025) to assess the appropriateness of our employees' remuneration levels" (p.285). No country or region is identified as falling below the benchmark, so no breakdown of non-compliant countries is given.

The supporting policy commitment appears under S1-1: "Henkel is committed to ensuring that our employees earn a living wage or higher. Compensation shall be reviewed on a regular basis and considering job performance in a non-discriminatory manner. Furthermore, remuneration must be paid as agreed and without undue delay. Deductions from remuneration must be clearly stated" (p.273). The related action is the annual living wage review, which in 2025 continued "based on external benchmarks... regularly carried out across all regions and business areas at Henkel. They include all employees" (p.278). Henkel notes that employees in countries without statutory minimum wage regulations "are at greater risk of low wages that fail to meet basic needs" (p.272).

Reference: page 285-286

"100 percent of the Company's workforce is covered by our health and safety management system, which is based on legal requirements and recognized standards. We achieve this coverage by establishing it as a minimum requirement for all our locations through globally applicable SHE standards" (p.285).

Fatalities from work-related injuries in 2025 were zero among employees, unchanged from 2024, and one among value chain workers, also unchanged. Recordable work-related accidents among employees fell to 186 from 215, a rate of 2.1 per million hours worked (2024: 2.3) (p.285). The lost time incident rate, newly disclosed for fiscal 2025, was 0.48 per million hours worked for employees (2024: 0.6) and 0.6 for non-employees (2024: 0.2) (p.286). The employee figure is consistent with the S1-5 target achievement of 59.2 percent against a 2010 baseline LTIR of 1.17.

"This KPI includes only work-related injuries involving our own workforce - both on-site and off-site and excludes non-employees, workers along the value chain, illnesses, occupational diseases and commuting incidents" (p.286). Fatalities and notifiable accidents are recorded in Sphera HSM, which calculates the rate automatically. Cases of recordable work-related ill health and days lost to injuries and ill health are not separately quantified.

Reference: page 286-287

The unadjusted gender pay gap fell to 0.7 percent in 2025 from 1.8 percent in 2024. The ratio of the annual total remuneration of the highest-paid individual to the median annual total remuneration for all employees rose to 142 from 137 in 2024 (p.286).

Both formulas are disclosed. The gender pay gap is calculated as "Average gross hourly rate male employees - Average gross hourly rate female employees / Average gross hourly rate male employees" (p.286). The remuneration ratio is calculated as "Annual total remuneration for the Company's highest paid individual/Median employee annual total remuneration (excluding the highest-paid individual)" (p.287).

Exclusions are stated: "The analysis considered all relevant compensation elements for the year 2025. Insignificant compensation elements in terms of their amount, which have no material impact on the overall analysis, were excluded. For the calculation of the unadjusted gender pay gap, the Management Board is excluded from this calculation as it does not constitute employees. Including the Management Board remuneration would distort the depiction of the Company remuneration policy. Also, interns, apprentices and student assistants are not included in the analysis" (p.286). Both datapoints are flagged in Appendix 3 as deriving from other EU legislation, mapped to SFDR Annex I indicators and, for the gender pay gap, to Delegated Regulation (EU) 2020/1816 Annex II (page 335).

Reference: page 287

Reported and addressed incidents of discrimination including harassment rose to 15 in 2025 from 12 in 2024. Warnings related to compliance violations fell to 9 from 18, while terminations related to compliance violations rose to 31 from 23. Complaints reported through the whistleblowing system rose to 259 from 208. The total amount of fines, penalties and compensation for damages as a result of incidents and complaints was zero in both years (p.287).

"We react forcefully to violations of laws, codes and standards. Where necessary, we initiate appropriate disciplinary actions." On the recording basis, "We record all cases of discrimination, including harassment, that have been reported and addressed. The number of complaints submitted through whistleblower hotlines is reported by the respective hotline operators. Fines, sanctions and compensation payments related to human rights incidents and complaints are reported to our central Compliance Department" (p.287).

A limitation on attribution is disclosed: "The preceding information on complaints via our whistleblower system includes all reports, as the possibility of anonymization means that no distinction can be made between employees and other stakeholders" (p.287). No severe human rights incidents involving the own workforce are reported for the period.

Reference: page 291-293

"Henkel is committed to respecting internationally acknowledged human rights for the workers in its value chain and therefore requires suppliers to ensure fair working conditions and respect for human rights." Three commitments guide the effort: "We commit to respect human rights across our own operations and supply chain"; "We commit to improve livelihoods of vulnerable workers within our value chain"; and "We commit to develop our 'Established Suppliers' toward a solid sustainability maturity" (p.291).

Suppliers worldwide must comply with the cross-industry Code of Conduct of the German Association for Supply Chain Management, Procurement, and Logistics (BME), "which is grounded in the principles of the United Nations Global Compact", linked to contracts with strategic suppliers alongside the Responsible Sourcing Policy (pp.291-292).

Three expectations are explicit: "Suppliers must have management systems in place to identify, assess and mitigate risks to ensure the health and safety of people affected by their operations. Suppliers do not tolerate child labor (according to the International Labor Organization - ILO). All work is voluntary, and suppliers do not permit or cause forced, bonded or indentured labor, slavery or human trafficking. As such, the policy explicitly addresses the issues of human trafficking, forced labor and child labor" (p.292).

Reference: page 293-294

Henkel engages with value chain workers indirectly, through its Responsible Sourcing Process and through partners. "The Responsible Sourcing Process is an integral part of our procurement activities. This process is initiated before any new collaboration begins. It involves a recurring cycle of review, analysis and continuous improvement with existing suppliers" (p.293).

"A central element is an assessment or audit at the start of a new business relationship. Authorized supplier representatives are asked to either disclose existing sustainability performance results or to complete a questionnaire that provides transparency regarding their sustainability performance, including labor and human rights issues. We do this for a significant portion of our external purchasing volume using an assessment methodology developed by EcoVadis", which "builds on 21 indicators across four main categories: Environment, Labor and human rights, Ethics, and Sustainable procurement". Since 2021 IntegrityNext has served suppliers with lower purchasing volumes (p.293).

"Henkel works with specialized independent auditors to monitor supplier compliance with the defined standards. Our audits consist of on-site inspections (for example at production sites) and include factory inspections and discussions with employees at all levels of the hierarchy. At a successful audit that meets Henkel's requirements, the audit validity is set for three years.

Reference: page 294

"We have established clear due diligence and compliance processes to identify and assess the potential adverse impacts of our business activities. We also ensure that access to remedy is established and accessible, where necessary. Workers and stakeholders of Henkel, as well as all other people affected by Henkel's business activities (for example value chain workers), can report potential misconduct through the whistleblower system" (p.294). The section cross-refers to the business conduct chapter for the remedy process and whistleblower protection.

The supplier-facing route is set out under S2-1: "Henkel has a clearly regulated complaints procedure: Possible compliance infringements or human rights violations in terms of actual or suspected breaches must be reported as soon as possible to Henkel's Compliance Department" (p.293). Requirements toward suppliers "are also made available on our Supplier Portal. They are also part of the supplier onboarding process and are integrated in related contracts as applicable" (p.293).

The channel is described under G1-1: email, web form, or by name or anonymously via the compliance hotline, with procedural guidelines published in more than 40 languages (p.318). Henkel reports that "During the reporting period, no confirmed severe human rights issues or incidents related to the upstream or downstream value chain were reported" (p.298). No figures on use of the channel by value chain workers are given.

Reference: page 294-298

Four actions address potential material impacts on health and safety, child labour and forced labour in the value chain (p.294).

The Responsible Sourcing Framework rests on a six-step process applying globally to all suppliers and all value chain workers: pre-check and risk assessment at regional, country and value chain level; onboarding, with suppliers expected to agree to the Supplier Code of Conduct and Responsible Sourcing Policy; initial assessment or audit using EcoVadis or IntegrityNext; analysis of performance assessments, where "Serious non-compliance trigger an escalation process, which may result in contract termination"; corrective action and continuous improvement; and re-assessment or re-audit (pp.294-295). Feedstocks are mapped beyond tier 1, with palm oil traceability evaluated with Action for Sustainable Derivatives, and conflict-minerals due diligence follows the OECD Guidance, the EU Regulation and the Dodd-Frank Act (pp.295-296).

Engagement in initiatives centres on Together for Sustainability, where member suppliers assess their own suppliers so that "we achieve a more in-depth (tier n) approach", plus founding membership of ASD and membership of AIM-Progress (pp.296-297). Competence building runs through the TfS Academy, which "offers over 390 courses in eleven languages" (p.297).

Reference: page 299

Henkel discloses that it has no target for value chain workers and explains the basis: "The sub-topics 'Working Conditions' and 'Other Labor Rights' are managed through our policies and actions. Our monitoring processes track the effectiveness of our policies and the progress of our actions in relation to the main sustainability impacts, risks and opportunities. As part of our target review process conducted in 2025, a new target will be introduced as of 2026" (p.299).

This is the MDR-T alternative limb, effectiveness tracking in the absence of a target, together with a stated intention to set one. The mechanisms are described in the actions section: annual and, where needed, ad hoc reviews with processes adjusted accordingly; metrics developed by Together for Sustainability for assessments and audits, whose shared results "create transparency and foster positive impacts"; and the observation that "Many suppliers have demonstrated sustainability improvements, reflected in better assessment or audit results, after implementing corrective actions identified during the TfS program evaluations" (p.298).

At group level, MDR-T records that Henkel sets time-bound outcome-oriented targets for climate change, water and marine resources, biodiversity and ecosystems, circular economy and resource use, and own workforce (p.184). Workers in the value chain is not among them.

Reference: page 302-303

"Henkel is committed to doing business in an ethical and legal manner. This is inseparably linked with our commitment to respecting internationally acknowledged human rights. Henkel respects local, national and international land, water and resource rights, including those of indigenous communities" (p.302).

Supplier requirements are stated directly: "Suppliers must respect land rights including collective and traditional rights of women, indigenous peoples and local communities and other vulnerable groups that may be affected by their operations and sourcing practices. Suppliers must not engage in any form of land-grabbing. If legally permitted land-use changes are made, suppliers are required to obtain the free, prior and informed consent (FPIC) of affected indigenous communities, as well as any other forms of participation that are required by local law. This applies in particular if a local community's access to water or other resources is affected. Unlawful forced evictions are not permitted" (p.302).

Henkel publishes a policy statement on the German Supply Chain Due Diligence Act which "prohibits the illegal acquisition of land, forests and waters", and its grievance mechanism "allows all individuals affected by our business activities, including affected communities, to report potential misconduct" (p.303).

Reference: page 303-304

Henkel discloses that it has no direct engagement process and says so plainly: "Given the indirect nature of our relationship with affected communities and despite the identified potential negative impacts, we currently do not have formalized and specific processes for direct engagement with affected communities, particularly indigenous peoples" (p.303).

What it does instead is described: "However, we actively strive to better understand the concerns of affected communities in relevant value chains, such as palm (kernel) oil, by participating in multiple initiatives and collaborating closely with stakeholders along the value chain. These include our suppliers, the Roundtable on Sustainable Palm Oil (RSPO) and NGOs" (p.303). "Depending on the topic, participation in these strategic partnerships involves multiple functions and business units... Together with our partners, we regularly assess the effectiveness of the partnerships in achieving their objectives" (p.304).

Henkel states an intention to develop the process: "We are currently considering further developments of our engagement with affected communities and/or their representatives regarding potential impacts" (p.304). A related limitation is recorded in the strategy section: "At present, our ability to formally describe the characteristics or contexts related to potentially affected communities... is limited", with a project underway and results expected in 2026 (p.302).

Reference: page 304

"We have established clear due diligence and compliance processes to identify and assess potential negative impacts of our business activities. We also ensure that access to legal remedy is established when necessary. Henkel employees, stakeholders and all other individuals affected by our business activities (for example, affected communities) can report potential misconduct through our whistleblower system" (p.304). The section cross-refers to the business conduct chapter for the remedy process and whistleblower protection.

That channel is open to anyone affected by Henkel's business activities, including risks to human rights and the environment arising from Henkel's activities or its suppliers, and may be used by email, web form, or by name or anonymously via the compliance hotline, with procedural guidelines published in more than 40 languages (p.318). Reports are handled "with the highest level of care, promptness and confidentiality, in full compliance with relevant data protection laws", access is limited to the necessary members of the local and global Compliance Group, and "The effectiveness of the whistleblower process as a grievance mechanism is reviewed annually and on an ad hoc basis" (p.318).

Henkel reports that "During the reporting period, no serious human rights issues or incidents connected to affected communities were reported" (p.305). No data on communities' awareness of or trust in the channel is disclosed.

Reference: page 304-305

Two actions address the material potential impacts on indigenous peoples, FPIC-related rights and cultural rights in the value chain (p.304).

The Responsible Sourcing Process "is a central element of our risk management and compliance strategy, designed to identify risks and establish appropriate mitigation actions in relation to potential negative impacts. This process has a global scope and applies to all suppliers worldwide... With regard to affected communities, particularly indigenous peoples and potential impacts related to violations of their FPIC-related and cultural rights, these aspects are assessed within our human rights due diligence processes as part of our Responsible Sourcing Process. For example, the risk of upstream actors engaging in unlawful land appropriation is part of our risk assessment process" (p.304).

The Solidaridad partnership is the second action: "Since 2013, Henkel has partnered with the civil society organization Solidaridad in Colombia, Ghana, Honduras, Indonesia, Mexico, Nicaragua and Nigeria... The focus is on training in best practice approaches, including climate-friendly agriculture... We work with smallholders to increase their production of sustainable, deforestation-free palm (kernel) oil and support them with the transition to agroforestry models" (p.305). "During the reporting period, no serious human rights issues or incidents connected to affected communities were reported" (p.305).

Reference: page 305

Henkel discloses that it has set no target for affected communities and gives the basis: "The sub-topic 'Rights of indigenous peoples' is managed through our policies and actions rather than an aggregated target. Our monitoring processes track the effectiveness of our policies and the progress of our actions in relation to the main sustainability impacts, risks and opportunities" (p.305).

This is the MDR-T alternative limb. The monitoring relied on is described in the actions section: "To assess the effectiveness of our actions, we conduct regular reviews. Processes are continuously adjusted to achieve improvements. Regarding our human rights due diligence processes, the members of the Human Rights Office and the Human Rights Coordination Panel continuously review and evaluate whether the implemented risk management system needs to be adapted to enhance its effectiveness. Additionally, we participate in regular meetings as part of our industry collaborations and with other industry partners - for example, within the frameworks of ASD and AIM-Progress" (p.305).

The group MDR-T section confirms that affected communities is not among the topics for which Henkel has set time-bound outcome-oriented targets (p.184). Two potential downstream S3 impacts were reassessed as non-material in the 2025 update, though the topic remains material in the aggregated view (p.181).

Reference: page 309-310

Henkel's policy covers access to quality information and health and safety, and states one commitment: "We commit to provide to our customers and consumers sustainability-related information about our products and solutions" (p.309).

On information, "we are guided by international standards, clear principles and rules for responsible consumer communication based on compliance, honesty and transparency, and social responsibility and ethics in advertising... which ensures that consumers and end-users receive accurate, complete and easily understandable information about our products - in full compliance with applicable local and global regulations, labelling requirements in our countries of operation, and our internal standards." Henkel is "committed to disclosing potential negative consequences related to product use when relevant and to ensuring that all environmental, health or performance claims are substantiated by robust scientific evidence. We avoid greenwashing, ensure all materials respect human dignity, and avoid derogatory and discriminatory content" (p.309).

On health and safety, "we ensure that products are safe for their intended use in terms of human health and the environment... Our product safety or product stewardship concepts cover the safe transport, handling and disposal of products in addition to their end-use" (p.310).

Reference: page 310-311

"We maintain direct dialog with consumers and end-users (for example, through our customer and consumer service teams, customer relationship management teams, websites, marketing and social media campaigns, social media interactions, and product labels). The insights gathered from these interactions help us to improve our products and enhance the transparency of our information. We also involve retailers and distributors as additional communication channels... For example, we regularly train our distributors to ensure they have the most up-to-date information about our products" (p.311).

"Engagement with our consumers and end-users is an ongoing process. We manage it throughout the entire product lifecycle: from the beginning of the innovation development process to communication with consumers and end-users during the product launch" (p.311).

"We assess the effectiveness of our engagement through our service channels for consumers and end-users. This allows us to gather feedback and evaluate satisfaction so as to identify areas for improvement" (p.311). For vulnerable groups, "we follow best practices and legal requirements. We also conduct targeted studies where appropriate and relevant".

Reference: page 311

"We have established clear compliance processes to identify and assess potential negative impacts of our business activities. We also ensure that access to remedy is established and available where necessary. Henkel's consumers and end-users, as well as all other people affected by Henkel's business activities, can report potential misconduct through the whistleblower system" (p.311).

Alongside the whistleblower route, Henkel describes the routine service channels: "In addition to market observations and research (such as purchase reports and data), ongoing dialog through surveys, marketing campaigns, events and social media activities play a central role in understanding consumer and end-user expectations. We also collect valuable insights through consumer and customer service channels, which contribute to product improvements and reinforce our commitment to transparency" (p.311). The policy section adds that "Consumers and end-users can rely on our Customer and Consumer Service channels, which can be accessed through a dedicated hotline and/or email address... The respective contacts are displayed on the labels of our products and can be found on the websites" (p.310).

Named accountability is disclosed for both business units, from the Corporate Senior Vice Presidents for Hair and Laundry & Home Care to the Head of Product Safety & Regulatory Affairs in Adhesive Technologies (p.311). No figures on the use of these channels by consumers are disclosed.

Reference: page 312-315

Four actions are described, all implemented globally (p.312).

Accuracy of product information rests on the Product Information Management System built on SAP Hybris, "a central repository for collecting, managing, enriching and distributing all product-related information, including logistics, safety and R&D data". Technical, safety and regulatory data sheets are available, and in B2B "a complete safety data sheet (SDS) is provided when a new product is introduced, with all changes proactively communicated". "In 2025, we initiated further improvements to the PIM based on sales data and customer feedback" (p.312).

Socially and environmentally responsible communication: environmental benefits are communicated on-pack, for example through responsible use instructions such as "wash cold", and through the "It Starts with Us" campaign launched in 2023. "In 2025, for example, we expanded the use of NaviLens technology and Braille on product packaging to help visually impaired consumers access product information" (p.312).

Transparency of portfolio sustainability performance: Consumer Brands supported the Cosmile app by haut.de, and Henkel is a founding partner of the Eco Beauty Score Consortium, now joined by more than 70 companies and associations; in 2025 Henkel "launched the next phase of the EBS activities by publishing available scores for our brands on our websites" (p.313).

Reference: page 315

Henkel discloses that it has set no target for consumers and end-users and gives the basis: "The sub-topics 'Information-related impacts for consumers and/or end-users' and 'Personal safety of consumers and/or end-users' are managed through our policies and actions, rather than through aggregated targets. Our monitoring processes track the effectiveness of our policies and the progress of actions in relation to the main sustainability-related impacts" (p.315).

This is the MDR-T alternative limb. The tracking relied on is described immediately before: "We track and assess the effectiveness of our actions and initiatives using a variety of measures. We integrate data-driven knowledge, inquiries and concerns from our consumers and end-users, along with safety standards. This ensures that the actions defined by Henkel achieve their objectives for consumers and end-users. To support this commitment, we allocate the necessary resources, including advanced technologies such as SAP, PowerBI and other Henkel IT tools. We also rely on specialized teams" (p.315). Under S4-2, effectiveness of engagement is assessed through the consumer and end-user service channels (p.311).

The group MDR-T section confirms that consumers and end-users is not among the topics for which Henkel has set time-bound outcome-oriented targets (p.184).

Reference: page 317-319

The business conduct chapter covers two material sub-topics, corporate culture and protection of whistleblowers. "The basic principles of compliant behavior are spelled-out in Henkel's Code of Conduct. This is backed by the fundamental understanding that compliance always takes priority over business goals if there is a conflict" (p.317). On culture, "The Company promotes a culture of trust, teamwork, and respect with zero tolerance for harassment, bullying or discrimination... Aspects of corporate culture are addressed and discussed at the meetings of the Management Board and Supervisory Board at least once a year and on an ad-hoc basis" (p.317).

On whistleblowers, possible violations "including breaches of applicable laws" may be reported by employees, stakeholders and all others affected by Henkel's activities, covering "risks to human rights and the environment, as well as violations of human rights or environmental obligations that arise from Henkel's business activities or suppliers". Henkel commits to "strict compliance with whistleblower laws globally, including the EU Directive (EU) 2019/1937"; those reporting in good faith are protected and retaliation "will not be tolerated". Channels are email, a web form and the compliance hotline, by name or anonymously, with guidelines published in more than 40 languages (p.318).

Reference: page 319

The ESRS content index lists an MDR-T row for ESRS G1 headed "Targets related to corporate culture and whistleblowers" at page 317 (index at page 330). The disclosure it points to is a reasoned nil target with effectiveness tracking in its place: "The topics 'Corporate Culture' and 'Whistleblowers' are managed through guidelines and our policies rather than aggregated targets. Our monitoring processes track the effectiveness of our policies and the progress of actions in relation to the main sustainability-related impacts, risks and opportunities" (p.319).

The tracking mechanisms are named elsewhere in the chapter: corporate culture "addressed and discussed at the meetings of the Management Board and Supervisory Board at least once a year and on an ad-hoc basis" (p.317); compliance issues "regularly reported to the Management Board, the Audit Committee of the Supervisory Board, the Shareholders' Committee and other local committees" under the principle of "prevention, detection, response"; and "The effectiveness of the whistleblower process as a grievance mechanism is reviewed annually and on an ad hoc basis" (p.318). Quantified outcomes appear under S1-17: 259 whistleblowing complaints in 2025 (2024: 208) and 15 reported and addressed incidents of discrimination including harassment (2024: 12) (p.287).