Hornbach

The General Partner of HORNBACH Holding AG & Co. KGaA is HORNBACH Management AG, represented by its Board of Management, which currently comprises two members (status: May 2025). The Board of Management of the General Partner manages the business of HORNBACH Holding AG & Co. KGaA and represents the company to third parties.

The Supervisory Board of HORNBACH Holding AG & Co. KGaA comprises six members. The Supervisory Board Chair coordinates the activities of the Supervisory Board and represents the interests of the Supervisory Board externally. The Supervisory Board of HORNBACH Holding AG & Co. KGaA is obliged to supervise the company's management.

Members of the Supervisory Board are bound to observe the company's best interests and, in discharging their duties, must be aware of the role played by the company within society and of its social responsibility. They are not dependent on any assignments or instructions.

Composition of Board of Management

Albrecht Hornbach - Chair, responsible for Builders' Merchants (HORNBACH Baustoff Union GmbH), Real Estate (HORNBACH Immobilien AG)

Karin Dohm - CFO (resigned March 31, 2025), responsible for Finance, Accounting, Tax, Group Controlling, Risk Management, Internal Audit, Legal, Compliance, Investor Relations

Erich Harsch - Member, responsible for DIY Stores and Garden Centers (HORNBACH Baumarkt AG), Public Relations

Supervisory Board Members

Dr. John Feldmann - Chair, Former Executive Board member of BASF SE

Martin Hornbach - Deputy Chair, Managing Partner of Corivus Gruppe GmbH

Simone Krah - (Managing) President of MMM-Club e.V.

Simona Scarpaleggia - Independent Management Consultant

Vanessa Stützle - Chief Executive Officer of LUQOM Group

Melanie Thomann-Bopp - Executive Board member at apetito AG responsible for Finance/Controlling/IT

The Supervisory Board has established three committees:

• Audit Committee (Chair: Melanie Thomann-Bopp)
• Nomination Committee (Chair: Dr. John Feldmann)
• Special Committee (Chair: Melanie Thomann-Bopp)

The General Partner (HORNBACH Management AG) and the Supervisory Board work together closely in the company's best interests. The Board of Management of HORNBACH Management AG is required to report regularly, promptly, and extensively on its intended business policy and other fundamental matter of corporate planning (in particular on its financial and investment planning, including sustainability-related targets), as well as on the company's current sales and earnings performance.

Its duties to provide information include reports on sustainability, on the company's profitability, planned transactions with a material influence on the company's asset, financial, and earnings position, reports on the company's risk management and risk situation, and compliance.

The Supervisory Board dealt closely with the development of management staff and succession planning at the company. One topic which we addressed in great depth in the past financial year was the implementation of the Corporate Sustainability Reporting Directive (CSRD). The topic of sustainability (ESG) played a central role in the activities of the board in the past financial year.

At the meetings held in May 2024 and May 2025 to approve the annual financial statements, the Supervisory Board examined the annual and consolidated financial statements for the past financial year in great detail. At the meeting held directly before the Annual General Meeting in July 2024, the Board of Management of the General Partner reported on the current situation of the Group.

In December 2024, the Board of Management and Supervisory Board discussed the Group's current business situation. At its final meeting in the past 2024/25 financial year, held in February 2025, the Supervisory Board addressed the Group's current business situation, as well as the budget for the financial years 2025/26 to 2029/30.

Since the 2023/24 financial year, 25% of the multiyear variable remuneration paid to the Board of Management of HORNBACH Management AG has been based on ESG (Environment, Social, Governance) key figures. These serve to guide the company's medium-term management and do not form part of its financial guidance.

Sales are a major key figure referred to when calculating the one-year variable remuneration for members of the Board of Management. EBT is a major key figure referred to when calculating the one-year variable remuneration for members of the Board of Management. The value spread is a major key figure referred to when calculating the multiyear variable remuneration for members of the Board of Management.

HORNBACH expects its direct business partners to communicate these requirements in the value chain and safeguard compliance with such. To underline this expectation, HORNBACH has made information materials on due diligence obligations in supply chains available to all business partners.

As well as the HORNBACH Values, the following requirements are therefore applied throughout the Group: HORNBACH's Corporate Social Responsibility (CSR) Policy, CSR Standards, and Policy Statement on Corporate Due Diligence Obligations and Human Rights. These documents have been published in the 'Responsibility' section of HORNBACH Holding's website.

The Audit Committee particularly prepares the deliberations and resolutions to be adopted by the Supervisory Board for all issues of accounting and specifically for the annual and interim financial statements and non-financial reporting. It also addresses matters of risk management, compliance, and the internal audit, including the reports submitted by the managers responsible for these areas.

HORNBACH Holding AG & Co. KGaA has a risk management system that is continually enhanced and updated to account for changes in conditions. The functionality of the early warning risk management system is checked by the auditors.

Moreover, Deloitte confirmed that the Board of Management of the General Partner had suitably implemented the measures required by § 91 (2) AktG, particularly those concerning the establishment of a monitoring system, and that this monitoring system was suitable for the early detection of any developments that could threaten the company's continued existence.

Group Business Model

Retail Activities

The main focus of business activities is on do-it-yourself (DIY) retail with DIY stores and garden centers, as well as online DIY retail, in Germany and eight other European countries. These retail activities are managed within the largest operating Subgroup, HORNBACH Baumarkt AG, and predominantly address private end customers. Furthermore, with its "ProfiService" and product range structure HORNBACH also targets trade firms and other commercial customers.

The product range encompasses an average of round 50,000 articles in stock at stationary stores and up to around 300,000 articles available online (excluding marketplace). The product range is structured in five divisions: (1) Hardware / Electrical, (2) Paint / Wallpaper / Flooring, (3) Construction Materials / Timber / Prefabricated Components, (4) Sanitary / Tiles, and (5) Garden. The product range includes 53 private labels from across all five divisions. In the 2024/25 financial year, these accounted for around 25% of total product range sales.

HORNBACH has an absolute focus on project customers. On the one hand, these are home improvement enthusiasts wishing to implement extensive renovation and construction projects under their own steam in their houses, apartments, or gardens (do-it-yourself). On the other hand, they are commercial customers and tradespeople.

The procurement organization of the HORNBACH Group safeguards broad access to global procurement markets and builds on strategic, long-term partnerships with suppliers. The HORNBACH Baumarkt AG Subgroup maintains a procurement office in Hong Kong to manage the import of goods from East Asia. In procuring its trading goods, the HORNBACH Group works with direct suppliers from around 40 countries. Around 70% of the trading goods purchased come from the European Union.

Real Estate Activities

The HORNBACH Group has an extensive real estate portfolio. This chiefly consists of retail properties at HORNBACH Baumarkt AG that are used as DIY stores with garden centers. The HORNBACH Group has an overriding strategy of ensuring that – measured in terms of sales areas and also accounting for potential sale and leasebacks – it owns at least half of the real estate used for operating purposes. This share amounted to 61.2% at the balance sheet date on February 28, 2025.

Group Structure

The partnership limited by shares (KGaA) is publicly listed on the Regulated Market at Frankfurt Stock Exchange and is a member of the SDAX. Its share capital is divided into 16 million no-par ordinary bearer shares with voting rights. Pursuant to the Articles of Association, the General Partner of HORNBACH Holding AG & Co. KGaA is HORNBACH Management AG, represented by its Board of Management. Hornbach Familien-Treuhandgesellschaft mit beschränkter Haftung owns all the shares in the General Partner of HORNBACH Holding AG & Co. KGaA.

Operating Segments

HORNBACH Baumarkt AG Subgroup: At the balance sheet date on February 28, 2025, operated 170 DIY megastores with garden centers and HORNBACH online shops in nine European countries. Generated sales of € 5,847 million (around 94% of consolidated sales) in the 2024/25 financial year and had 24,145 employees.

HORNBACH Baustoff Union GmbH Subgroup: Active in the regional builders' merchant business. Operated a total of 39 locations, of which 37 in south-western Germany and two close to the border in France. Generated sales of € 357 million (around 6% of consolidated sales) in the 2024/25 financial year and had 1,160 employees.

HORNBACH Immobilien AG Subgroup: Mainly owns retail properties for the operating companies in the Group. Of the rental income of € 89.6 million in the 2024/25 financial year, 98% resulted from the letting of properties within the overall Group.

Interests and views of stakeholders

The continuous exchange of information with stakeholders is decisive to the further development of the business model and strategy of the HORNBACH Group, particularly with regard to ESG topics. The views of stakeholders were accounted for in the materiality assessment (see "Materiality assessment" section).

Key stakeholder groups

For HORNBACH as a retail company, the most important stakeholder group involves its customers, to whom HORNBACH aligns its range of products and services. A further focus is on employees and their representatives, as well as applicants. Motivated and loyal employees form the basis for the company's success. Employees working in sales and service at the DIY stores and garden centers and at the builders' merchant outlets in particular have a material influence on customer satisfaction.

In addition, HORNBACH is reliant on good cooperation with:

• Suppliers, business partners, and service providers, and with their staff
• Representatives of the capital markets and banks
• Further cross-regional and local institutions and stakeholder groups

How views are integrated into strategy and business model

The Board of Management is regularly informed about:

• Results of customer surveys
• Exchanges information with employees and/or managers at internal events
• Participates in investor events
• On an occasional basis (e.g. in connection with compliance reports or expansion projects), the Board of Management is informed about the interests of local communities and workers in the value chain

Stakeholder engagement formats and outcomes

Distinction between affected stakeholders and users of sustainability information

The disclosure identifies affected stakeholders (those impacted by the business) including:

• Customers
• Own employees
• Suppliers and their workers
• Affected communities

Users of sustainability information are separately identified as:

• Investors, analysts, banks, credit and ESG rating agencies

Target setting

Stakeholders are not directly involved in setting the target values. The CSR department, the Board of Management, and Supervisory Board bodies were involved in defining the targets, as were further departments on a topic-specific basis. The interaction between the ESG targets formulated here and the respective ESG topics and underlying concepts is described in the E1 Climate change, S1 Own workforce, and S4 Consumers and end-users chapters.

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

Material topics

HORNBACH conducted a materiality assessment in accordance with ESRS requirements for the first time in the 2024/25 financial year. This comprised the identification and assessment of impacts, risks, and opportunities (IROs) resulting from the business activities of the HORNBACH Group. The assessment accounts both for those risks and opportunities which could impact on the company's profitability and for the impact of its business activities on stakeholders, the environment, and society (double materiality).

The double materiality assessment comprises the following steps:

1. Compiling a longlist of topics for HORNBACH
2. Identifying the relevant stakeholders
3. Identifying HORNBACH's impacts, risks, and opportunities along the value chain
4. Assessing the materiality of the impacts, risks, and opportunities
5. Validating the materiality assessment

Actual and potential impacts, risks and opportunities arising directly and indirectly, within and outside the HORNBACH Group and over the short-term, medium-term, and long-term time horizons were allocated to each of these topics.

List of material IROs by ESRS topic

E1 – Climate change

By using energy from non-renewable sources in its own operations, and above all via the upstream and downstream value chains, HORNBACH contributes to greenhouse gas emissions. In the DIY retail business, material volumes of energy consumption, and thus of associated emissions, result above all from the extraction of commodities and the manufacture of the products sold, the transport of products, and the use and disposal of the products by consumers and end-users. Efficiency measures and savings in own operations have a positive impact.

E2 – Pollution

The DIY and home improvement product range offered by HORNBACH includes numerous products whose manufacture in the upstream value chain may contribute to pollution of the soil, water, or air at the production sites or which contain raw materials whose extraction contributes to pollution, such as metals, oil, and gas.

E3 - Water and marine resources

As a retail company, HORNBACH does not operate any production locations. Water consumption is comparatively low at its retail and administration locations. The product range offered by HORNBACH includes numerous products whose production processes in the upstream value chain require the use of water and which may thus potentially contribute to water shortages.

E4 – Biodiversity and ecosystems

HORNBACH's product range includes numerous products whose manufacture in the upstream value chain may potentially influence biodiversity at the production sites or which include commodities whose extraction may potentially contribute to a loss of biodiversity.

E5 – Circular economy

HORNBACH sells a broad range of home improvement products and construction materials, most of which are not yet recyclable and thus have negative environmental impacts due to the extraction of the required primary commodities.

S1 – Own workforce

Working conditions at the company and the treatment of employees significantly influence the level of employee satisfaction and thus indirectly also satisfaction levels among HORNBACH's customers.

S2 – Workers in the value chain

In purchasing and transporting its goods, HORNBACH works with large numbers of suppliers and service providers around the world who in turn procure upstream products and raw materials or commission service providers. Given inadequate transparency in the supply chain, potential negative impacts related to workers in the value chain as a result of poor working conditions, discrimination, or human rights violations cannot be excluded.

S3 – Affected communities

HORNBACH's business activities may impact on people or groups living in regions in which HORNBACH itself or its suppliers operate. While the retail locations have mainly positive impacts due to their social commitment on location, including donations of goods and trades training, the extraction of commodities and manufacture of products may result in negative impacts on local communities in the value chain.

S4 – Consumers and end-users

As a retail company, HORNBACH bears a significant responsibility towards consumers and end-users in terms of product safety, data protection, and the information provided on products and services.

G1 – Business conduct

For HORNBACH as a retail company with decentralized locations in various European countries and Hong Kong, the establishment of a Group-wide corporate culture that facilitates trusting and constructive cooperation between all operating units is essential and has positive impacts for the company's own workforce.

Interaction between IROs and strategy/business model

For HORNBACH as a retail company with no proprietary production activities, material environmental impacts result above all in the upstream and downstream value chains due to commodities extraction, production processes, logistics, and the use and disposal of non-recyclable products. Risks result above all from a potentially lower level of resource availability in the upstream value chain, rising procurement prices, and capital expenditure required for climate change adaptation.

HORNBACH is mainly addressing the short and medium-term risks and opportunities related to the company's own workforce, and in particular the challenges of recruiting new employees, by offering fair salaries and additional benefits, flexible working-hour models, and training and development programs.

HORNBACH counters potential negative impacts on workers in the value chain and local communities with its CSR Standards for business partners, regular audits of direct suppliers and production sites, and the establishment of reporting channels for internal and external whistleblowers.

As a retail company, HORNBACH has a particular focus on consumers and end-users. By systematically evaluating customer feedback, HORNBACH can achieve positive impacts and draw on opportunities resulting from the customer-focused further development of its retail concept and good communications with and information of its customers.

HORNBACH works to avert any risks resulting from infringements of the law and incidents of corruption by continually developing its compliance management system further in line with statutory and company-specific requirements.

Resilience to identified IROs

The process already initiated of investigating and labeling products with regard to their environmental impacts may make it possible to identify potential optimizations in the product range structure in the medium term. Moreover, in the medium to long term there is the possibility that increasing volumes of recycled or recyclable materials can be deployed in the upstream value chain. A reduction in product range-related emissions is to be achieved in the medium to long terms by working together with suppliers, not least within the sector initiative of the international DIY retail association EDRA/GHIN. In its own operations, the company has taken first steps to reduce CO2e emissions, energy consumption, and waste by implementing energy-saving measures and proprietary electricity production, as well as by converting to electric vehicles and working with company-internal resource management.

Overall, based on the qualitative assessment no impacts, risks, or opportunities are currently discernible which would require a fundamental change in the business model and strategy or which could materially impair or improve the company's earnings, financial, and asset position in the short term. In the long term, the transition to a climate-neutral, circular, and socially just economy nevertheless requires adaptations affecting the whole value chain and which can only be implemented together with business partners.

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

Overview

HORNBACH conducted a materiality assessment in accordance with ESRS requirements for the first time in the 2024/25 financial year. This comprised the identification and assessment of impacts, risks, and opportunities (IROs) resulting from the business activities of the HORNBACH Group. The assessment accounts both for those risks and opportunities which could impact on the company's profitability and for the impact of its business activities on stakeholders, the environment, and society (double materiality).

Step-by-step methodology

The double materiality assessment comprises the following steps:

1. Compiling a longlist of topics for HORNBACH
2. Identifying the relevant stakeholders
3. Identifying HORNBACH's impacts, risks, and opportunities along the value chain
4. Assessing the materiality of the impacts, risks, and opportunities
5. Validating the materiality assessment

Inputs to the assessment

Topic longlist: The topic longlist is based on the mandatory ESRS topics set out in ESRS 1, Annex 1, Appendix A, AR 16 and on the company-specific topics identified in previous years for ESG reporting pursuant to § 315b HGB which could not be allocated to any of the mandatory ESRS topics. Actual and potential impacts, risks and opportunities arising directly and indirectly, within and outside the HORNBACH Group and over the short-term, medium-term, and long-term time horizons were allocated to each of these topics.

Stakeholder engagement: The affectedness of stakeholders, including the environment and society, and the resultant impacts, were evaluated by assessing interactions between these stakeholders and the HORNBACH Group, as well as on the basis of studies and media reporting received from the departments responsible in each case.

Internal experts: The assessment of the impacts, risks, and opportunities was conducted by the HORNBACH departments responsible for the relevant products based on the EFRAG methodology "Double materiality conceptual guidelines for standard setting" (ESRG 1). Based on the dual control principle, the assessment of the IROs was conducted by a representative of the CSR department and by one or several representatives of the respective specialist departments.

External consultants: Not explicitly mentioned.

ESRS guidance: The methodology is based on EFRAG methodology "Double materiality conceptual guidelines for standard setting" (ESRG 1). The materiality thresholds are consistent with the EFRAG recommendation.

Value chain mapping

As called for by ESRS 1 Paragraphs 3.4 and 3.5, the identification of impacts, risks, and opportunities accounted where possible for the whole value chain. Among other aspects, this includes impacts due to products and services or business relationships, as well as risks and opportunities resulting from dependencies on natural, social, and personnel resources or impacts. These relate above all to reputational risks and risks resulting from compensation and penalty payments.

The impacts, risks, and opportunities were identified by way of aggregated consideration, as all fully consolidated subsidiaries of HORNBACH Holding AG & Co. KGaA have a uniform business model (retail with DIY and home improvement products). There are no individual activities or business relationships which fundamentally involve an increased risk of negative impacts.

Due to a lack of information about the upstream and downstream value chains, the impacts of business relationships can generally only be assessed on country or sector level or on the basis of the raw materials most commonly included in the product range or of higher-risk contents. As part of the value chain analysis, the product range was reviewed to identify the most common raw materials and their processing stages. Due to the size of the product range, the analysis was based on all article groups with sales of more than €10 million (basis: 2022/23 financial year) and which aggregately account for around one third of total sales.

Scoring criteria for impact materiality

The impacts were assessed by scale and scope (actual impacts) and, if applicable, additionally by remediability (negative impacts) and likelihood of occurrence (potential impacts). In the event of there being several impacts of the same kind, the impacts were assessed separately and included at the highest value thereby determined.

The following assessment categories apply:

Scoring criteria for financial materiality

Risks and opportunities were each assessed in terms of their likelihood of occurrence and level of financial effect (gross). In the event of there being several risks or opportunities of the same nature, the level of effects for the combination of the risks or opportunities stated was assessed.

The following assessment categories apply to assess the risks and opportunities. The thresholds for likelihood of occurrence and financial effects were based on the assessment scales used in risk management.

Threshold for materiality

The materiality thresholds are consistent with the EFRAG recommendation. Those ESG risks identified in the double materiality assessment which have a financial effect of €5 million or more excluding countermeasures (gross analysis) were reported to Group Risk Management and are to be integrated into the risk management process in future.

Validation

In a subsequent validation stage, the results of the materiality assessment were reviewed by the internal stakeholder representatives, risk management, and the Board of Management. The CSR additionally reviewed the completeness and consistency of the materiality assessment. All material decisions were documented.

Frequency and last review

The process used for the double materiality assessment in accordance with ESRS was introduced and implemented for the first time in the year under report (2024/25 financial year). This process will be reviewed in the course of preparing the materiality assessment in the coming year.

Supplementary information for climate change

To identify and assess the material impacts, risks, and opportunities (IROs) related to climate change adaptation, reference was made to the results of the physical and transitional climate risk assessment, as well as to studies and desktop research. The IROs on the topics of climate change and energy were identified and assessed by reference to the climate balance sheet and additional desktop research.

To ensure that the materiality assessment accounted for all activities and plans that make an actual or potential contribution to greenhouse gas emissions, an analysis of the value chain was performed in advance. This describes both the upstream and downstream value chains, as well as activities in own operations. The analysis was validated by the climate balance sheet, as this includes all greenhouse gas emissions in the upstream and downstream value chains, as well as in own operations.

Physical climate risk assessment: Reference was made to the scenarios published by the Intergovernmental Panel on Climate Change (IPCC). Consideration was given to the current status of risks, representative concentration pathway (RCP) 4.5 and RCP 8.5. The analysis covered all locations which, based on the definition of the operational control approach, form part of HORNBACH's own operations. In addition, HORNBACH's supply chains were also analyzed.

The physical climate risk assessment accounts for the climate risks stated in Regulation (EU) 2021/2139, focusing on: river flooding, coastal flooding, severe wind, heat stress, and strong rainfall. The assessment was performed for the short-term, medium-term, and long-term time horizons. The short-term time horizon refers to the status quo; the medium-term time horizon considers the period through to 2030; the long-term time horizon runs until 2050.

Transitional climate risk assessment: This investigated the influence of transition risks on HORNBACH's business activities and assets. The assessment was based on the Shared Socioeconomic Pathways (SSP) issued by the IPCC, and specifically on SSP1-1.9. This is based on the latest scientific findings of the IPCC and forecasts an increase in average global temperatures by up to 1.5° with limited excess of up to 1.8°.

Transition plan for climate change mitigation

Scope and target year

HORNBACH has set itself the target of reducing its direct emissions from own operations (Scopes 1 and 2) by 42% by 2030/31 compared with the 2021/22 base year, consistent with the targets of the Paris Climate Agreement and current scientific findings.

The target includes all Scope 1 and 2 emissions and considers these on a cumulative basis. The plan is currently being compiled in the short to medium term.

Alignment with Paris Agreement / SBTi validation status

In keeping with the approach promulgated by the Science Based Target initiative (SBTi), the calculation of the target has been based on current scientific insights. The SBTi's cross-sector reduction pathway was used to calculate HORNBACH's reduction pathway. Those CO2e emissions resulting from future organic growth are additionally reduced. The target thus corresponds to current scientific insights. Its calculation however, has not been validated by the SBTi or any other external review body.

This calculation resulted in a total reduction (Scopes 1 and 2) of 42% by 2030/31, corresponding to an annual reduction of 4.67%. That means a total reduction of 28,746 tonnes of CO2e. In the 2021/22 base year, 68,443 tonnes of CO2e were emitted in Scopes 1 and 2. By 2030/31, these emissions should be reduced to 39,697 tonnes of CO2e.

Scope 1 and 2 reduction milestones with baseline year

¹⁾ Cumulative reduction achieved since 2021/22 in %

The planned annual reduction of 4.67% was not achieved in the 2024/25 financial year.

To review the target achievement status, the reduction achieved each year compared with the previous year and the base year is calculated based on the latest figures in the climate balance sheet. Variances are analyzed, with the responsible departments assessing whether the actions, policies, or technologies used require adjustment or have to be newly compiled.

Scope 3 targets and commitments

HORNBACH's Scope 3 greenhouse gas emissions were fully recorded for the first time in the 2024/25 financial year. Within the "Make it Zero" initiative of the European DIY Retail Association and the Global Home Improvement Network (EDRA/Ghin), HORNBACH has committed itself to developing a Scope 3 emissions reduction target that is compatible with the Paris Climate Agreement within the next two years.

HORNBACH has committed itself within the initiative to actively work towards ensuring that its relevant business partners set Scope 1 and 2 targets that are compatible with the Paris Climate Agreement within the next five years.

Key decarbonization levers and approach

The transition plan is being based on the approach towards reducing emissions laid down in the CSR Guidelines, namely "avoid, reduce, self-produce".

The most important measures to reduce Scope 1 and 2 emissions involve:

• Proprietary generation of electricity
• Efficiency measures at the retail locations
• Electrification of the vehicle fleet

The estimated savings already achieved with these actions amount to 22,600 tCO2e, while the savings currently expected from the measures for 2025/26 amount to 27,000 tCO2e.

As outlined in the "Policies related to climate change" section, the CSR Standards also contain requirements relating to environmental standards and call on business partners to reduce their resource input as far as possible. This means that the CSR Standards represent an initial approach to request business partners to reduce their greenhouse gas emissions at their own initiative.

CapEx / investment commitments

The company did not yet implement any transition plan related to the topics of climate change adaptation, climate change, and energy and involving significant operational expenditure (OPEX) or capital expenditure (CAPEX) in the year under report, as this plan is still being compiled.

Locked-in emissions and stranded assets

Not disclosed.

Use of carbon credits / removals

Not disclosed in the transition plan. (Note: ESRS E1-7 reporting indicates that GHG removals and carbon credits are assessed as "not material" - see separate disclosure requirement E1-7.)

Transition plan development and governance

To meet the 42% reduction target by 2030/31, the company is currently compiling a transition plan that lays down the decarbonization levers and their contribution towards achievement of this target. The plan is to be compiled in the short to medium term.

The transition plan is being based on the approach towards reducing emissions laid down in the CSR Guidelines. Building on the Scope 3 findings, it will be possible to extend the transition plan accordingly once Scope 3 targets are set.

The Board of Management of HORNBACH Management AG was kept informed at regular update meetings of the implementation status and potential process risks. At its meetings, the Supervisory Board Audit Committee also addressed the CSRD implementation.

Contribution to SDGs and policy alignment

With the stipulated reduction in greenhouse gas emissions in its own operations, HORNBACH is making a contribution to the politically agreed climate targets, assuming responsibility for its directly caused emissions, and reducing its impacts. Furthermore, the target is consistent with the Sustainable Development Goals (SDGs) of the United Nations (UN), and in particular with Goal 13 "Climate action" and Goal 15 "Life on land".

Policies related to climate change mitigation and adaptation

Hornbach does not disclose a specific named policy dedicated to climate change mitigation and adaptation under ESRS E1-2. However, the company references policy elements embedded in other governance documents:

CSR Guidelines / CSR Standards

• Scope: The CSR Guidelines contain requirements relating to environmental standards and apply to business partners in the value chain. They call on business partners to reduce their resource input as far as possible and to reduce their greenhouse gas emissions at their own initiative.

• Key content: The guidelines establish an approach towards reducing emissions based on the principle "avoid, reduce, self-produce." They also contain environmental standards requirements for suppliers.

• Monitoring: As outlined in the disclosure, the CSR Standards represent "an initial approach to request business partners to reduce their greenhouse gas emissions at their own initiative."

Policy gap and planned development

The company explicitly states: "Managing risks and opportunities related to climate change adaptation with suitable policies requires a robust basis of data and well-considered planning that accounts for numerous factors and uncertainties. To enable it to compile meaningful policies, HORNBACH is currently analyzing those topics identified as material in connection with HORNBACH IRO E1.1.a, E1.1.c, and E1.1.d which present a risk or an opportunity in the transition to a low-carbon economy."

The company is in the process of compiling a transition plan for climate change mitigation that will lay down decarbonization levers. The plan is being based on the approach towards reducing emissions laid down in the CSR Guidelines ("avoid, reduce, self-produce"). The transition plan is to be compiled in the short to medium term.

Hornbach has set a science-based target to reduce Scope 1 and 2 emissions by 42% by 2030/31 compared with 2021/22, consistent with the 1.5° target and aligned with the Science Based Target initiative (SBTi) methodology, though not externally validated.

Actions and resources in relation to climate change policies

Location insurance as action related to climate change adaptation

IRO: E1.1.a
Scope: Own operations
Description: Physical climate risk assessment identified locations that may be affected by flooding in the medium and long-term time horizons due to overflowing rivers, storm tides, or severe rain. To mitigate the financial effects, locations are insured with policies covering interruptions to operations, goods and contents at the stores.
Time horizon: Medium and long-term
Resources allocated: Not quantified

Preparations upon weather alerts as action related to climate change adaptation

IRO: E1.1.a
Scope: Own operations (all HORNBACH locations)
Description: Work Safety function provides employees on location with a list of actions to be performed in the event of weather risks, wind risks, or severe rain. Actions include preparations in the event of weather alerts, such as checking the wind resistance of goods in outdoor sections, the functionality of rainwater runoffs, and measures to secure doors and gateways if applicable.
Resources allocated: Not quantified

Exchanging heating systems as action related to climate change adaptation, climate change, and energy

IROs: E1.1.b, E1.1.e, E1.2.a, E1.2.e, and E1.3.c
Scope: Own operations
Description: One of the most important levers to reduce greenhouse gas emissions in own operations involves exchanging heating systems for heat carriers powered by renewable energies. This action additionally contributes to reducing enclosed GHG emissions and reduces CO2e emissions at locations during the utilization stage by using renewable energies.
Time horizon: Planning compiled for implementation by 2030
Link to target: Contributes towards achievement of HORNBACH's Scope 1 and 2 target
Planning factors: Operating lifecycle of a store, lifecycle and condition of existing heating system, renewable energy sources available at respective location
Status: In 2024/25, the HORNBACH Baumarkt AG Subgroup compiled plans for exchanging heating systems due to be implemented by 2030
Resources allocated: Not quantified

Construction of photovoltaics systems as action related to climate change adaptation, climate change, and energy

IROs: E1.1.b, E1.1.e, E1.2.a, E1.2.e, and E1.3.c
Scope: Own operations (retail locations and logistics centers)
Description: Expansion of photovoltaics systems to reduce greenhouse gas emissions while simultaneously cutting operating costs at operating locations. Promoted in all countries in which HORNBACH Baumarkt AG Subgroup operates and at HORNBACH Baustoff Union GmbH Subgroup.
Link to target: Contributes towards achievement of HORNBACH's Scope 1 and 2 target by 2030/31
Current status (end of 2024/25): 21 photovoltaics systems with capacity of 11,891 kWp installed
Planned (by 2025/26): Construct 26 additional photovoltaics systems with 14,217 kWp
Resources allocated: Not quantified

Conversion to LED and optimization of building control technology

IRO: Related to climate change
Description: Action mentioned but details cut off in excerpt
Resources allocated: Not disclosed in excerpt

Scope 3 emissions reduction commitment

IROs: E1.2.b, E1.2.c, E1.2.d, E1.3.a, and E1.3.b
Scope: Value chain (Scope 3)
Description: Within the "Make it Zero" initiative of the European DIY Retail Association and the Global Home Improvement Network (EDRA/Ghin), HORNBACH has committed to:

• Developing a Scope 3 emissions reduction target compatible with the Paris Climate Agreement within the next two years
• Actively working towards ensuring relevant business partners set Scope 1 and 2 targets compatible with the Paris Climate Agreement within the next five years
  Time horizon: Short to medium-term (within 2-5 years)
  Status: Scope 3 data measured for the first time in 2024/25 financial year; no processes currently in place to measure effectiveness of current actions and policies
  Resources allocated: Not quantified

Targets related to climate change mitigation and adaptation

Scope 1 and 2 GHG Emissions Reduction Target

Target metric: Reduction in Scope 1 and 2 greenhouse gas emissions (CO₂e)

Target value: 42% reduction (corresponding to 28,746 tonnes CO₂e reduction)

Target year: 2030/31

Baseline year and value: 2021/22 baseline year; 68,443 tonnes CO₂e (Scopes 1 and 2 combined)

Absolute target value for 2030/31: 39,697 tonnes CO₂e

Scope: Own operations (Scopes 1 and 2). The target includes all Scope 1 and 2 emissions considered on a cumulative basis, covering the HORNBACH Baumarkt AG Subgroup operations.

Type: Absolute target

Science-based validation: The target is calculated based on the Science Based Target initiative (SBTi) methodology and current scientific insights, using the SBTi's cross-sector reduction pathway aligned with the 1.5°C target of the Paris Climate Agreement. However, the calculation has not been validated by the SBTi or any other external review body.

Annual reduction rate: 4.67% per year

Progress to date: As of 2024/25, cumulative reduction achieved since 2021/22 is 5.87%. The planned annual reduction of 4.67% was not achieved in the 2024/25 financial year.

Scope 3 GHG Emissions Reduction Target

Status: Target under development

Commitment: Within the "Make it Zero" initiative of the European DIY Retail Association and the Global Home Improvement Network (EDRA/Ghin), HORNBACH has committed to developing a Scope 3 emissions reduction target compatible with the Paris Climate Agreement within the next two years (from 2024/25).

Baseline: Scope 3 greenhouse gas emissions were fully recorded for the first time in the 2024/25 financial year.

Scope: Upstream and downstream value chain (Scope 3)

Additional commitment: HORNBACH has committed within the initiative to actively work towards ensuring that its relevant business partners set Scope 1 and 2 targets compatible with the Paris Climate Agreement within the next five years.

Executive Remuneration Link

25% of multiyear variable remuneration (MVR) for the Board of Management is dependent on achievement of sustainability targets, including the CO₂e reduction target (5% weighting within the 25%). The remuneration system applies for the performance period 2023/24 to 2026/27, with first payment in 2027.

Target Tables from Remuneration System

ESG targets for MVR 2023/24 – 2026/27:

ESG targets for MVR 2024/25 – 2027/28:

Note: The MVR targets use different baseline years (2020/21 and 2021/22) and different metrics (intensity per m² vs absolute tonnes) than the main science-based target disclosed in E1-4.

Energy consumption and mix

HORNBACH is classified as a high climate impact sector (Section G – Retail) under Regulation (EU) 2022/1288. Energy consumption data covers all locations under HORNBACH's operational control. Electricity and heat consumption at HORNBACH Baumarkt AG Subgroup is recorded on an ongoing basis; for several small locations at HORNBACH Baumarkt AG and HORNBACH Baustoff Union GmbH Subgroups, consumption is manually recorded annually. Data gaps are filled with time series predictions or degree day figures. Energy mix is evaluated by reference to supplier invoices. Fuel consumption is determined partly via fuel cards (liter consumption) and partly on a cost basis. Data collection is not validated by external third parties.

Energy intensity

Net revenues used to calculate energy intensity are based on Consolidated Financial Statements (Income Statement of HORNBACH Holding AG & Co. KGaA Group).

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 GHG emissions

Scope 1 breakdown by source: Not disclosed.

Scope 2 GHG emissions

Scope 3 GHG emissions

¹ Only part of category 1 was calculated in 2023/24; in 2024/25 the category was calculated in full.
² Adjustment to 2023/24 figures due to use of improved emission factors.

Total GHG emissions

GHG intensity per net revenue

Biogenic CO2 emissions

Not separately disclosed. The report states: "For Scope 2 greenhouse gas emissions it is not possible to report the share of biomass or the share of biogenic CO2 emissions, as these do not form part of the information made available by providers. The same applies to the emission factors used for location-based emissions. Based on the data currently available, it is not possible to state biogenic CO2 emissions from incineration or from the biodegradation of biomass arising in the upstream and downstream value chains separately from Scope 3 gross GHG emissions."

Methodology and scope notes

• Reporting standard: GHG Protocol corporate standard.
• Consolidation approach: Operational control.
• Base year: 2021/22 for Scope 1 and 2 target setting. Scope 3 base year not established.
• Scope 1: Covers fuel consumption from crude oil and petroleum products (47,091 MWh) and natural gas (89,723 MWh). No coal or other fossil sources. Emission factors from DBEIS.
• Scope 2: Location-based uses IEA emission factors. Market-based uses supplier-specific factors where available.
• Scope 3 coverage: First full calculation in 2024/25. Categories 8, 10, 14, 15 deemed not applicable (NA). Category 1 was only partially calculated in 2023/24. Around 86% of Scope 3 data provided by business partners. Category 1 (purchased goods and services) accounts for the largest share (2.84 million tCO2e) and is calculated activity-based for HORNBACH Baumarkt AG trading goods (by weight); cost-based for HORNBACH Baustoff Union. Categories 4, 9, 11, 12 newly added in full in 2024/25. Category 11 (use of sold products) is 3.15 million tCO2e.
• Data quality: Activity-based method used where possible. Distance-based for transport where distances unavailable. Cost-based for non-trading goods and some categories. Some data projected or estimated. Internal data collection not externally reviewed. Projections based on sales, expert assumptions, and time series where actual data gaps exist.
• Exclusions: No GHG removals or carbon credits offset applied. No internal carbon pricing disclosed.
• Regulated emissions: Percentage of Scope 1 from EU ETS not disclosed (field left blank).
• Scope changes: Scope 3 significantly expanded in 2024/25 (full category 1 and addition of categories 4, 9, 11, 12), leading to large year-on-year increase.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

According to the disclosure table on page 105, ESRS E1-9 is referenced on pages 120 ff (120 and following pages).

However, the specific content for E1-9 is not included in the provided excerpts. The excerpts show:

• Page 105: Index table listing various ESRS E1-9 data points (66, 66a, 66c, 67c, 69) marked as "n.m." (not material)
• Page 107: Reference that E1-9 "Anticipated financial effects from material physical and transition risks and potential climate-related opportunities" is disclosed on pages 120 ff

The actual substantive disclosure content from pages 120 ff is not provided in the excerpts.

Data points marked as not material:

From the index table, the following specific E1-9 data points are assessed as not material:

• ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks (data point 66)
• ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk (data point 66a)
• ESRS E1-9 Location of significant assets at material physical risk (data point 66c)
• ESRS E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes (data point 67c)
• ESRS E1-9 Degree of exposure of the portfolio to climate-related opportunities (data point 69)

Targets related to pollution

The document references ESRS E2-3 (Targets related to pollution) on page 126, but the actual content of this disclosure requirement is not included in the provided excerpts. The excerpts contain:

• A table of contents indicating E2-3 is on page 126
• General context that pollution arises from product manufacturing, raw material extraction, and transportation in the upstream and downstream value chain
• Statement that these impacts "are therefore connected to the business model, but can only be influenced by HORNBACH to a limited extent"
• A cross-reference table showing ESRS E2-4 requirement on pollutant emissions is "not material" (n.m.)

No specific pollution-related targets are disclosed in the provided excerpts.

Pollution of air, water and soil

Disclosure Status

ESRS E2-4 (Pollution of air, water, and soil) is disclosed as not material by Hornbach.

As stated in the ESRS E2 index on page 126:

• E2-4 Pollution of air, water, and soil: not material
• E2-5 Substances of concern and substances of very high concern: not material

Context

While quantified emissions to air, water, and soil are not disclosed, Hornbach identifies the following material impacts in the upstream value chain:

Pollution (E2.1):

• E2.1a: Pollution due to extraction of commodities and production processes in the value chain (negative, actual)
• E2.1b: Transport relating to combustion processes (e.g. NOx for diesel engines) (negative, actual)
• E2.1c: Pollution in the event of environmental contamination from inappropriate handling of wastewater and chemicals/accidents (negative, actual)

Substances of concern (E2.2):

• E2.2a: Environmental contamination and/or health impacts due to inappropriate storage or handling of substances of concern in the supply chain (negative, actual)

Microplastics (E2.3):

• E2.3a: Release of microplastics into the environment with potentially severe consequences for biodiversity and natural resources (e.g. tire abrasion, microplastics in materials and clothing, work materials) (negative, actual)

E-PRTR Reference

The index table on page 106 notes:

• ESRS E2-4 Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water, and soil - Data point 28 (SFDR): n.m. (not material)

Management Actions

While no quantified emissions are reported, Hornbach describes qualitative actions:

• Manufacturer audits check compliance with environmental standards relating to water, air, and soil pollution
• CSR Standards forwarded to business partners include environmental requirements
• Quality management performs pollutant audits on imported and private label products
• Full truck load principle to reduce transport-related pollution

No quantified metrics for emissions to air (NOx, SOx, PM, VOC), water (heavy metals, nutrients, BOD/COD), or soil are disclosed.

Substances of concern and substances of very high concern

Disclosure status: E2-5 is marked as not material in Hornbach's CSRD reporting index (page 107).

Materiality context

Hornbach identified substances of concern as a material negative impact in its double materiality assessment:

• E2.2: Substances of concern – Environmental contamination and/or health impacts due to inappropriate storage or handling of substances of concern in the supply chain (Actual negative impact, upstream value chain)

The company states: "For the topic of substances of concern, the materiality results from the potentially inappropriate storage and handling of substances of concern and the associated potential contaminations in production activities in which large volumes of the substances of concern are used (HORNBACH IRO E2.2.a)." However, material impacts are located in the upstream value chain with limited direct influence by Hornbach.

Policy

CSR Guidelines set the objective of replacing controversial or environmentally harmful substances with effective, ecological alternatives through merchandising guidelines. The policy does not list any specific controversial or environmentally harmful substances.

Actions

Audits on substances of concern for imported and private label products: Hornbach's Quality Management department performs pollutant audits on products with the assistance of independent, accredited, and certified audit institutes. These audits monitor compliance with environmental legislation and threshold values. The Quality Management department also "monitors compliance with European standards and directives governing the threshold values for chemicals and specific hazardous substances and substances of concern."

In the event of pollutant audits not being passed, corrective measures range from product improvements to sales stops and product recalls. These audits are performed on an ongoing basis within continuous quality assurance measures.

Compliance

Hornbach states it complies with all applicable legal requirements relating to pollution, substances of concern, and microplastics, including:

• REACH (Registration, Evaluation, Authorisation of Chemicals) Directive
• RoHS (Restriction of Hazardous Substances) Directive
• Stockholm Convention on Persistent Organic Pollutants (POPs Convention)
• Minamata Convention and EU's Mercury Regulation (EU) 2017/852
• Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal

Quantitative disclosure

No quantitative data on total amounts of substances of concern (SoC) or substances of very high concern (SVHC) generated, used, or procured is disclosed. No breakdown by hazard class is provided.

Targets and outlook

Hornbach notes: "As HORNBACH only has limited influence on this area [upstream value chain], setting meaningful targets is a complex task. Accordingly, establishing effective targets will require further research and analysis of the value chain, scale, and possible actions."

Policies related to water and marine resources

Hornbach references ESRS E3-1 on page 129 of its CSRD sustainability statement. However, the excerpts provided do not contain the actual policy disclosure content from page 129.

The index indicates that:

• ESRS E3-1 Water and marine resources is addressed on page 128
• ESRS E3-1 Dedicated policy is marked as "n.m." (not material)
• ESRS E3-1 Sustainable oceans and seas is addressed on pages 128 ff

Based on the index entries, Hornbach has indicated that a "dedicated policy" for water and marine resources is not material. The company appears to address water and marine resources topics more broadly on pages 128-130, but the specific policy content is not included in the excerpts provided.

Without access to the actual content from pages 128-130, it cannot be determined whether Hornbach has adopted any policies related to water and marine resources or whether they rely on other existing policies to address these topics.

Actions and resources related to water

Forwarding of CSR Standards as action related to water consumption and marine resources

Scope: Upstream and downstream value chains

Description: The CSR Standards are forwarded to existing and new business partners for them to sign and return. The CSR Standards call on business partners to deal with water responsibly in their production.

Resources allocated: No action plan involving significant operational expenditure (OPEX) or capital expenditure (CAPEX) was implemented for the topic of water and marine resources in the year under report.

Links to IROs: This action addresses HORNBACH IROs E3.1.a and E3.2b

Limitations:

• No actions and resources are specified in relation to areas at water risk, including areas of high-water stress
• Due to the complexity of the value chains and HORNBACH's indirect possibilities of exerting influence, the establishment of meaningful actions will require further research to be performed on the scale and possible actions
• The general approach is described in the "Strategy, business model, and value chain" section of the "General disclosures" chapter

Water consumption

Disclosure approach

Hornbach states in its materiality assessment that ESRS E3-4 Water consumption is classified as not material. The company explicitly notes on page 128 that E3-4 is "not material".

Context

As a retail company, Hornbach does not operate production locations. Water consumption is comparatively low at its retail and administration locations. The company acknowledges that products in its range may require significant water use in upstream production processes, potentially contributing to water shortages, but states it has limited influence over these upstream impacts.

Material impacts identified

• E3.1a: Contribution to water shortage by using water in production processes in the upstream value chain, especially in regions already suffering from water shortages (actual negative impact)
• E3.2a: Burden on marine resources due to transport by ship (actual negative impact)
• E3.2b: Damage to or endangering of marine resources due to underwater extraction of commodities (potential negative impact)

Water consumption metrics

No quantitative water consumption data is disclosed. The document confirms that:

• Total water consumption in m³ per net revenue in own operations (ESRS E3-4, data point 29) is referenced on page 129 but marked as "n.m." (not material)
• Total water recycled and reused (ESRS E3-4, data point 28c) is referenced but marked as "n.m." (not material)

Methodology note

The excerpts indicate that water consumption is included in Scope 3 Category 1 calculations:

"This category includes the trading goods, non-trading goods, packaging, and water consumption at the HORNBACH Baumarkt AG and HORNBACH Baustoff Union GmbH Subgroups... Emissions from water consumption are calculated based on actual water consumption figures. Where these are not available, estimates are compiled for the locations."

However, the actual water consumption volumes (in m³ or megalitres) are not disclosed in the provided excerpts.

Conclusion

Hornbach has assessed E3-4 as not material and does not report water consumption, withdrawal, discharge, recycling, or intensity metrics for the reporting period.

Anticipated financial effects from material water and marine resources-related impacts, risks and opportunities

According to the index on page 108, ESRS E3-5 is referenced on page 130. However, the provided excerpts do not contain the actual content from page 130 where this disclosure requirement would be detailed.

The index indicates that E3-4 Water consumption is "not material" but E3-5 is listed with a specific page reference (130), suggesting it may have been assessed as material and should contain substantive disclosures.

Resource outflows

Products made of recycling materials

To reduce waste volumes at the HORNBACH Group, there are initial approaches for recyclable products that arise from the waste and recyclable resources collected in own operations. The rigid plastics or foils collected are processed into recyclate and then turned into water butts or construction foil. Furthermore, fragments of articles such as tiles, bricks, or concrete blocks are collected at the operating locations and processed into recycled gravel. These products are then offered in the product range at HORNBACH Baumarkt AG.

Alongside products from its own recyclable materials, the product range at HORNBACH Baumarkt AG also includes products made of recycled materials, such as plant pots or glass wool. These articles are available on a permanent basis until they are delisted.

Spare parts management

The HORNBACH Baumarkt AG Subgroup supports its customers with suitable spare parts and accessory items from the respective manufacturers to enable them to use the articles they have bought for as long as possible. To this end, the Subgroup offers spare part procurement services from manufacturers for the machines and garden machinery in its product range. This enables the machines to be optimized and wear parts to be replaced. The accessory items are always aligned to the respective machines, with stocks being retained once the machines have been delisted to enable customers to continue purchasing spare parts. Furthermore, HORNBACH also offers its customers traditionally recyclable articles, such as rechargeable batteries or battery-powered torches. These product ranges are offered on a permanent basis.

Product quality and durability

HORNBACH has set itself the standard that all of the products it sells should be of flawless quality. The operating units perform trial samples themselves or have such tests performed by external service providers. These checks on goods are performed both in production and prior to shipment of the goods, as well as following their arrival at the logistics locations. HORNBACH Baumarkt AG has high quality standards, particularly for its private label products, which are regularly audited. Products which meet the quality standards contribute to the durability of the private label products, meaning that a corresponding guarantee can be issued for such products.

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

According to the index on page 108, E5-6 is disclosed on page 138. However, the page content for page 138 was not included in the provided excerpts. The index indicates that this disclosure requirement is applicable (not marked as 'not material' or 'Phase-in').

Waste

Waste management approach

The HORNBACH Group works with a holistic waste concept. For the Germany region, there is the HORNBACH Waste Primer, which lays down the principles underlying the treatment of waste at HORNBACH. The priorities are on reducing waste and on recording single-origin waste. Furthermore, correct waste separation is explained and illustrated with examples.

The CSR Guidelines call for separating recyclable materials and waste and promoting the re-use of recyclable materials as secondary raw materials.

The packaging pyramid describes the hierarchy applied to packaging: avoid – prepare for re-use – recycle – put to other use (especially energy-related) – remove.

Waste categories

The waste categories relevant to HORNBACH's activities comprise:

• Waste for recycling: Packaging material, plastic plant pots, carpet waste, garden umbrellas, etc.
• Old paint and old varnish: Old paints and old varnishes, including containers
• Waste metal: Shelf parts, metal bars, metal straps
• Rubble: Masonry, bricks, stones, concrete, tiles, glazed tiles, mortars, waste plaster, clay plant pots
• Electrical waste: Large household appliances, small household appliances, tools, printers, fax machines, televisions, fluorescent tubes, energy-saving lights
• Foil 80/20: PE plastic foils; transparent/colored
• Gypsum-based waste: Aerated concrete stones, plasterboard panels
• Timber (A1 – A3): Packaging timber, pallets, clipping residues from cutting, chips, furniture
• Compost material / green waste: Flowers, plants, tree and shrub cuttings, bark cork / mulch, plant soil
• Plastics (various): Plant bowls, plastic straps, rigid plastics, polystyrene, PET bottles
• Paper, paperboard, cardboard: Cardboard, repackaging/transport packaging, catalogs

Quantitative data (2024/25)

The disposal volumes are exported from HORNBACH's recycling portal and are based on volume feedback for the orders. For those disposal volumes arising outside the portal, the volume statistics have been compiled based on the disposal documents or volume statistics provided by service providers. Due to a lack of data, the volumes for Romania, Czechia, and Slovakia regions have been projected based on their sales.

Deployment of Resource Liners

Recyclable resources incurred at the operating locations are forwarded for recycling. To reduce the number of journeys traveled, high-volume materials such as paper and plastics are compressed into balls at the location where they arise. The "HORNBACH Resource Liners" are in operation in large areas of the countries in which HORNBACH operates. They transport recyclable resources from the stores and logistics centers directly to the recycling location, such as paper factories. This avoids empty runs and stores that are in any case located on the disposal route of the truck can be supplied with the necessary goods.

Online recycling portal

To simplify disposal and gain a precise overview of all material flows, HORNBACH operates a proprietary online recycling portal that is used by HORNBACH Baumarkt AG in seven regions and by HORNBACH Baustoff Union in Germany. Each location connected to the portal has an overview of all waste classes and can order punctual and suitable disposal.

Policies related to own workforce

Hornbach has disclosed multiple policies related to its own workforce under ESRS S1-1.

HORNBACH Foundation

• Content: Formulates ten principles describing HORNBACH's characteristics as a company, applicable on a Group-wide basis. Examples include understanding itself as the top address for projects, focus on customers, honesty and team spirit in internal dealings, and commitment to social responsibility.
• Development: Internally developed principles; no external stakeholders were involved in development.
• Scope: Applicable on a Group-wide basis.
• Availability: Available to all employees on the intranet; published in German and English on the website of HORNBACH Holding AG & Co. KGaA; appended to employment contracts with new employees.

HORNBACH Values

• Content: Address meeting responsibility to society (affected communities), respectful dealings with one another (own workforce), fair competition, acting with integrity, data protection, and transparent external reporting. Explicitly oppose conflicts of interest and corruption.
• Target groups: Managers and employees, customers, suppliers and competitors, providers of equity and debt capital, government and society.
• Development: No external stakeholders were involved; no external standards or initiatives were referred to.
• Scope: Applicable Group-wide to all employees.
• Governance: The Compliance Group function is responsible for updating and further developing the HORNBACH Values.
• Availability: Available to all employees on the intranet; published in German and English on the website of HORNBACH Holding AG & Co. KGaA; appended to employment contracts with new employees.
• Monitoring: The Internal Audit department regularly reviews compliance with internal policies and procedures and with external requirements.

HORNBACH Code of Conduct – Acceptance and Granting of Gratuities

• Content: Specifies HORNBACH's expectations in its employees regarding accepting and granting gratuities in day-to-day business operations. Sets clear limits on impermissible gratuities, underlines the role model function of managers, and emphasizes principles of professionalism, transparency, and appropriateness. Sets out the company's approach to conflicts of interest and corruption in greater detail.
• Scope: Applicable Group-wide.
• Governance: The Board of Management of the General Partner bears overall responsibility for compliance. The Compliance Group function is responsible for updating and further developing the Code of Conduct.
• Availability: Available to all employees on the intranet.
• Monitoring: The Internal Audit department regularly reviews compliance with internal policies and procedures.

Corporate Social Responsibility (CSR) Policy

• Content: Applied throughout the Group as a requirement for responsible activity.
• Scope: Applied throughout the Group.
• Availability: Published in the "Responsibility" section of HORNBACH Holding's website.

CSR Standards

• Content: Applied throughout the Group as a requirement for responsible activity.
• Scope: Applied throughout the Group.
• Availability: Published in the "Responsibility" section of HORNBACH Holding's website.

Policy Statement on Corporate Due Diligence Obligations and Human Rights

• Content: Explains the approach taken by the HORNBACH Group with regard to respect for human rights and workers' rights and to compliance with environmental-related obligations and the measures implemented in this respect in its own operations and supply chains. Meets the due diligence obligation to submit a policy statement pursuant to § 3 (1) No. 4 in conjunction with § 6 (2) of the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG).
• International standards: Committed to internationally valid standards and policies.
• Scope: Applicable to all companies within the HORNBACH Group.
• Governance: Responsibility for the policy is incumbent on the CSR department and the Human Rights Officer of the HORNBACH Group.
• Availability: Available within the company in German on the intranet; published in German and English on the website of HORNBACH Holding AG & Co. KGaA.

Whistleblower Policy

• Content: Summarizes the general functionality of HORNBACH's whistleblower system as required by the German Whistleblower Protection Act. Provides clear, easily understandable, and publicly accessible information about the accessibility, responsibilities, and implementation of procedures adopted to handle complaints concerning human rights and environmental-related risks and infringements in supply chains as required by the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG). Addresses all material impacts on workers in the value chain and associated risks. Infringements of national and international laws, or of internal regulations and policies, explicitly regarding topics including human trafficking, forced labor, and child labor, can be reported.
• Scope: Available to employees, service providers, and suppliers worldwide.
• Implementation: Employees can communicate directly, confidentially and, if preferred, anonymously with the compliance department, as well as with an internet-based external service provider.
• Monitoring: The Compliance Committee acts as the topmost advisory body for compliance organization. The compliance department led by the Head of Compliance coordinates and optimizes Group-wide compliance activities and reports to the Chief Compliance Officer, who reports to the Board of Management.

Additional workplace safety requirements

• Content: Workers of service providers who predominantly work directly on location at the stores are subject to HORNBACH's work safety requirements.
• Coverage: 100% of employees in the company's own workforce are covered by health and safety policies based on legal requirements and HORNBACH's policies.

Compliance management system

• Governance: The Board of Management of the General Partner bears overall responsibility for compliance. The Compliance Committee acts as the topmost advisory body for compliance organization. The compliance department led by the Head of Compliance coordinates and optimizes Group-wide compliance activities and reports to the Chief Compliance Officer, who reports to the Board of Management. Compliance officers operate on a decentralized basis in all of HORNBACH's regions and departments.
• Focus: Compliance activities have a particular focus on the risks of "improper conduct / corruption" and "cartel law violations".
• Monitoring: Development in risks which are already known and potential emergence of new risks are surveyed in the compliance survey, conducted once a year and regularly updated. Auditing adherence to compliance regulations is incumbent on Internal Audit.

Targets related to own workforce

The excerpts reference S1-5 on page 159-160 but the actual target details are not provided in the extracted text. The document mentions:

Diversity Target

• Target metric: Number of women in the two management levels below the Board of Management at HORNBACH Baumarkt AG
• Target type: Percentage of total number of managers on these levels
• Measurement approach: Determined as of the balance sheet date
• Target achievement: Starting in 2025/26 financial year, the figure at the end of the performance period will be relevant for determining target achievement
• Performance period: Four-year performance period mentioned
• Specific target value: Not disclosed in excerpt
• Baseline year: Not disclosed in excerpt
• Target year: Not disclosed in excerpt

Personnel Turnover Target

• Target metric: Personnel turnover (number of terminations as percentage of average number of employees in permanent employment)
• Target achievement: Determined by comparing the average figure for each of the financial years in the four-year performance period with the target value
• Performance period: Four-year performance period mentioned
• Specific target value: Not disclosed in excerpt
• Baseline year: Not disclosed in excerpt
• Target year: Not disclosed in excerpt

Employee Satisfaction

• Mentioned: Key figures on employee satisfaction are determined by reference to available personnel data
• Specific targets: Not disclosed in excerpt

The excerpts indicate that detailed S1-5 disclosures should be found on pages 159-160, but those specific pages are not included in the provided text.

Characteristics of the undertaking's employees

Total headcount and FTE

Current period (as of February 28, 2025):

• Total employees (head count): 25,359
• Total employees (FTE): Not disclosed for total
• Permanent employees (head count): 19,916
• Temporary employees (head count): 5,443
• Non-guaranteed hours employees (head count): 361

Prior year (as of February 29, 2024):

• Total employees (annual average, FTE): 20,750

Headcount by gender (as of February 28, 2025)

Headcount by employment contract type (as of February 28, 2025)

Headcount by country/region (as of February 28, 2025)

Detailed breakdown for countries with >10% of total workforce:

Germany detail:

• Permanent employees (head count/FTE): 11,950
• Temporary employees (head count/FTE): 1,638
• Non-guaranteed hours employees (head count/FTE): 256

Netherlands detail:

• Permanent employees (head count/FTE): 1,176
• Temporary employees (head count/FTE): 2,798
• Non-guaranteed hours employees (head count/FTE): 0

Employee turnover

Turnover rate (2024/25): 19.1%

Calculation methodology: Employee departures (including employee resignations, employer terminations, and departures due to retirement or death) aggregated over the financial year, stated as a proportion of the average number of employees (head count) in the financial year. Average number of employees corresponds to the average of all 12 end-of-month figures.

Note: The definition of permanent and temporary employment and of non-guaranteed working hours is based on national legal requirements in the countries in which the employees work. The data on country level is then aggregated to calculate the totals, with no account then being taken of national legal definitions.

Age structure (as of February 28, 2025)

Collective bargaining coverage

Overall: 74.6% of employees covered by collective bargaining agreements

By country:

• Germany: 90% covered
• Netherlands: 100% covered
• Countries outside EEA (Switzerland, Hong Kong): 0% covered

Worker representation coverage: 67.5% overall (Germany: 88.2%, Netherlands: 100%)

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

Scope and Definitions

HORNBACH includes the following categories in its own workforce:

• Permanent employees (employees in full-time or part-time positions, including temporary staff)
• Employees in training (trainees, students, interns, working students)
• Third-party staff
• Mediated or transferred employees (e.g. cleaning staff, assembly and stocking assistants at the stores, seasonal staff, IT specialists)
• Self-employed staff (e.g. advisors, IT specialists)

Non-Employee Workers Metrics

The disclosure indicates that HORNBACH employs third-party staff, mediated/transferred employees, and self-employed staff as part of its own workforce. However, specific quantitative metrics for non-employee workers are not separately reported in the excerpts provided.

The company notes that workers in the value chain who work on site at HORNBACH's locations are considered third-party individuals, but detailed headcount or FTE figures for non-employees are not disclosed.

Phase-in Status

According to the sustainability statement index, ESRS S1-7 (Characteristics of non-employee workers in the undertaking's own workforce) is subject to phase-in provisions and detailed metrics are not yet reported for the current reporting period.

Collective bargaining coverage and social dialogue

Coverage metrics

As of February 28, 2025:

Regional scope of collective bargaining agreements: Germany, Netherlands, Sweden, and Austria regions have collective bargaining agreements. No collective agreements exist for workers outside the European Economic Area (Hornbach Switzerland and Hong Kong) (0%).

Social dialogue structures

No European-level representation: The workforce is not represented in social dialog on European level. There is no agreement concerning employee representation by a European Works Council, a Societas Europaea Works Council, or a Societas Cooperativa Europaea Works Council.

Country and local level representation:

• Germany: General Works Council, works councils at almost all German locations, and employee representatives in the Supervisory Board of HORNBACH Baumarkt AG (equal numbers of employee and shareholder representatives)
• Luxembourg, Netherlands, Sweden: Employee representation on country level and in some cases at individual locations
• Netherlands: Works council meets with country Managing Director and HR Director quarterly; staff councils at DIY stores and garden centers

Social dialogue processes

Workers' representatives regularly exchange information with the Board of Management, enabling workforce concerns to be factored into decisions. Implementation of national collective agreements is managed on a decentralized basis. Each workers' representation body determines its own meeting frequency. Both full-time workers' representatives and employees with reduced hours for representation tasks are supported with resources from HORNBACH.

No global framework agreement has been signed with workers' representatives concerning respect for human rights in the company's own workforce.

Methodology

The number of employees as of the balance sheet date (head count) forms the population for these metrics, stated in proportion to employees covered by collective bargaining agreements or workers' representatives. The degree of coverage varies between countries in line with respective legal frameworks. Calculation is based on figures as of the reporting date; intra-year fluctuations are not presented. Data collection has not been validated by external third parties.

Diversity metrics

Gender diversity in top management

In the first two levels beneath the Board of Management, women managers accounted for 21.5% of the first management level and 24.7% of the second management level at the balance sheet date on February 28, 2025.

Overall, this corresponds to:

• 14 women in the first management level (out of 65 managers in total)
• 57 women in the second level (out of 231 managers in total)

On the first two levels beneath the Board of Management, the share of women managers totals 24.0%; 71 of the 296 managers are women.

Methodology note: Managers are employees who manage other employees in disciplinary terms. The figures for all managers include female, male, and diverse people, as well as people whose gender is unknown. This metric is based on figures at the balance sheet date. Intra-year fluctuations are not presented.

Age band distribution of workforce

The workforce had the following age structure at the balance sheet date on February 28, 2025:

Methodology note: The number of persons per age group are stated as a proportion of the population (number of people at balance sheet date) and present the figures as of the balance sheet date in number of people. The ages are calculated as of the reporting date at the end of the financial year. The collection of this data has not been validated by external third parties.

Adequate wages

Benchmark Used

Hornbach uses a mixed benchmark approach depending on the country:

• Statutory or collectively agreed minimum wage in countries where applicable
• Wage Indicator Foundation portal for countries without statutory/collectively agreed minimum wages

The company states: "Depending on the country, the benchmark wage is a statutory or collectively agreed minimum wage or comparable figure from the portal of the Wage Indicator Foundation."

Coverage

100% of employees were paid at or above the benchmark wages in the 2024/25 financial year.

• 0% of employees received wages lower than the benchmark wages in the respective country
• Trainees, dual work-study program students, and interns are excluded from these figures (pursuant to ESRS S1-10)

Geographic Scope

All nine countries in which Hornbach operates are covered.

Specific collective bargaining coverage:

• ~75% of employees are paid at or above collectively agreed rates (in Germany, Austria, the Netherlands, and Sweden)
• ~25% of employees work in countries where no collectively agreed pay rates apply for the retail sector and are paid "on the basis of agreements customary to the market and as a minimum in accordance with the statutory minimum wage"

Methodology Details

Calculation approach:

• Pay is calculated on an hourly basis (gross) and compared with the benchmark wage on an hourly basis
• Gross hourly pay = total monthly basic income + fixed additional benefits ÷ gross number of hours worked
• Calculation performed in national currency

Basic income components:

• Monthly basic salary paid to individual
• Fixed additional benefits: guaranteed payments to all employees in a given region

Exclusions:

• Unpaid absences not included
• Figures based on remuneration actually paid and hours actually worked
• Intra-year entrants accounted for in line with length of company affiliation

Process:

• Basic income, fixed additional benefits, and gross hours calculated based on local pay circumstances for each country
• Data made available to Group HR department for aggregation
• Uniform definitions of remuneration components communicated in advance

Additional Context

Annual review process:

• Annual salary reviews performed in all regions to ensure fair relationship between performance and pay
• Gender pay gap analyses performed in Austria and Sweden regions

Gender pay gap (2024/25): 6.6%

Targets / Commitments

No specific forward-looking targets disclosed for adequate wages or living wage implementation.

Social protection

Disclosure status

ESRS S1-11 is listed as Phase-in in Hornbach's sustainability statement index, indicating that quantitative metrics on the percentage of employees covered by social protection against loss of income from major life events are not yet disclosed.

Qualitative information on social protection benefits

Hornbach provides information on social protection policies and benefits across its operations:

Coverage across countries:

• Company pension scheme or contribution to pension insurance (group-wide)
• Employee shares in HORNBACH Holding AG & Co. KGaA (group-wide)
• Maternity protection and parental leave in accordance with statutory requirements in all countries; in Switzerland, benefits exceed legal requirements

Country-specific additional benefits:

• Occupational disability insurance
• Healthcare promotion (e.g. company physician, mental health support services, physiotherapy, fitness)
• Advice on nursing care
• Job bike
• Anniversary payments
• Private additional insurance

Germany-specific benefits:

• HORNBACH Mastercard (tax-free credit for regional retail shopping)
• HORNBACH Voucher Card (tax-free credit for purchases at HORNBACH)
• HORNBACH Advertising Partner (financial incentive for wearing HORNBACH work clothes)
• JobBike (bicycle leasing)
• Occupational disability insurance

Pension schemes by country:

Switzerland:

• Defined benefit pension plan managed through external pension provider
• Required by Swiss Occupational Pensions Act (BVG)
• Covers old-age, invalidity and fatality pensions
• 1,098 beneficiaries
• Employee covers ~35% of premiums; employer covers remainder
• Benefits exceed statutory minimum requirements

Germany:

• Securities-financed pension plans for Board of Management/managing directors (HORNBACH Baumarkt AG, HORNBACH Immobilien AG, HORNBACH Baustoff Union GmbH)
• Working time account model allowing salary conversion to value credits for early retirement
• Company guarantees 2% p.a. minimum return during vesting period

Company integration management:

• Applies to employees in Germany who were unable to work for more than six weeks in a twelve-month period
• Governed by central company agreement
• Country-specific agreements on company health management in Austria, Switzerland, the Netherlands, Sweden, and at HORNBACH Baustoff Union Subgroup

Scheme types

Benefits are provided through a combination of:

• Public statutory schemes (maternity, parental leave)
• Private company-sponsored schemes (pension plans, disability insurance, health benefits)
• Voluntary employee contribution schemes (working time accounts, securities-financed pensions)

Health and safety metrics

Coverage of health and safety management system

100% of employees in the company's own workforce are covered by health and safety policies based on legal requirements and HORNBACH's policies.

Fatalities

There were no fatalities within the company's own workforce as a result of work-related injuries in the 2024/25 financial year.

Recordable work-related accidents

Methodology note:

The rate of recordable work accidents (from the 1st day of absence) is calculated based on the total number of recordable work accidents per 1,000,000 working hours. No assumptions were used. The collection of this data has not been validated by external third parties.

Days lost

Not disclosed. ESRS S1-14 days lost metric is noted as "Phase-in" in the disclosure requirements table (page 109).

Work-life balance metrics

Not disclosed.

The company has applied the phase-in provision for ESRS S1-15 (as indicated on page 109 of the report). While the excerpts describe various work-life balance policies and practices, including:

• Maternity protection and parental leave granted in accordance with statutory requirements in all countries
• In Switzerland, the company goes beyond legal requirements for parental leave
• Flexi-time and mobile work available at all administration locations
• Part-time models implemented on a Group-wide basis
• Digital time recording systems for flexible working hour management

No quantitative metrics are disclosed for:

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

Compensation metrics

Pay gap

The pay gap between female and male employees (gender pay gap) amounted to 6.6% in the 2024/25 financial year.

Methodology: The population for this calculation is formed by all employees in a valid employment relationship with a HORNBACH Group company as of February 28, 2025. Remuneration is calculated on an hourly basis. The difference between the average gross hourly wage paid to male and female employees is stated as a proportion of the average gross hourly wage paid to male employees. The average gross hourly wage paid corresponds to the total of the actual monthly basic income plus other remuneration components divided by the gross hours actually worked by the employee. Basic income is taken as the monthly basic salary paid to a given individual. Other remuneration components comprise payments that are neither the basic salary nor fixed additional benefits that are guaranteed for all employees. The figures for both remuneration and working hours are based on the remuneration actually paid and the number of hours actually worked. Unpaid absences are not included. Intra-year entrants are accounted for in line with the length of their company affiliation. The basic income, other remuneration, and gross hours per employee are calculated on the basis of local pay circumstances for each region and then made available to the Group HR department for aggregation. A uniform understanding of the various remuneration components was ensured by determining and communicating definitions in advance. Employees of neither male nor female gender are not included in this calculation. The gender pay gap is calculated in euros. Foreign currencies are translated into euros using a rolling exchange rate. It should be noted that HORNBACH operates in different countries with different levels of remuneration. These are aggregated in the overall calculation. The figures are not adjusted to account for disparities in purchasing power. All activities, and thus all associated differences in remuneration, are aggregated. No data is collected on the basis of comparable activities.

Remuneration ratio

In the 2024/25 financial year, the annual total remuneration of the highest-paid individual at the Group was 50.9 times higher than the median annual total remuneration of all employees.

Methodology: The population for the median figure is formed by all employees in a valid employment relationship with a HORNBACH Group company as of February 28, 2025. Annual total remuneration comprises all remuneration components (basic salary, fixed additional benefits, and other remuneration). The figures for both remuneration and working hours are based on the remuneration actually paid and the number of hours actually worked. This means that both full-time and part-time employees are included in the calculation. Unpaid absences are not included. Intra-year entrants are accounted for in line with the length of their company affiliation. The pay gap is calculated by stating the total annual remuneration paid to the highest-paid individual at the company as a proportion of the median annual total remuneration of all employees (excluding the highest-paid individual). The highest-paid individual is a member of the Board of Management. The salaries of members of the Board of Management are only determined once the annual financial statements have been completed and approved, adopted by the Supervisory Board, and published in the Remuneration Report. To calculate the pay gap, reference therefore has to be made to the Remuneration Report for the previous year (FY 2023/24). Pursuant to the definition provided in ESRS S1.6, members of the Board of Management do not count as employees. The salaries paid to other members of the Board of Management are therefore not included in the median figure for all other employees. The pay gap is calculated in euros. Foreign currencies are translated into euros using a rolling exchange rate. It should be noted that HORNBACH operates in different countries with different levels of remuneration. The figures are not adjusted to account for disparities in purchasing power. The calculation of basic income, fixed additional benefits, and other remuneration per person is performed for each country based on the respective remuneration circumstances and then made available to the Group HR department for aggregation and calculation of the KPIs. A uniform understanding of the various remuneration components was ensured by determining and communicating definitions in advance.

Note: The collection of this data has not been validated by external third parties. The Supervisory Board members do not receive any variable remuneration components and therefore also do not receive any remuneration linked to climate-related considerations (0%).

Incidents, complaints and severe human rights impacts

Incidents of discrimination and harassment

In the 2024/25 financial year, 11 cases of discrimination, including harassment, were reported in the workforce.

Complaints filed through grievance mechanisms

The number of complaints filed by employees through the reporting channels communicated at HORNBACH amounted to 11 in the 2024/25 financial year.

None of the complaints filed was submitted to the OECD national contact point.

Severe human rights impacts

Due to the company's business activities and the associated legislation and enforcement, severe incidents of human rights violations in the company's own operations (e.g. forced labor, human trafficking, or child labor) are unlikely; no such incidents were identified in the 2024/25 financial year.

Fines, penalties and compensation

No fines, penalties, or compensation for damages were paid in the period under report for discrimination and harassment incidents.

No fines, penalties, or compensation for damages were paid for severe human rights violations.

Status of complaints

Not disclosed.

Methodology

Incidents and complaints are collected by the Group's HR managers and forwarded to the Group Legal department. The collection of this data has not been validated by external third parties.

Policies related to value chain workers

Hornbach has disclosed four main policies that relate to value chain workers, addressing working conditions, equal treatment and opportunities, and other work-related rights.

CSR Standards for the Business Partners of the HORNBACH Group

Scope: Direct suppliers of the HORNBACH Group

Key content:

• Social and environmental standards applicable to direct suppliers
• Addresses all material impacts on workers in the value chain and associated risks
• Explicitly covers human trafficking, forced labor, and child labor
• Acts as the Supplier Code of Conduct for the HORNBACH Group
• Takes due account of § 6 (4) No. 2 and 4 of the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG)

Links to international standards:

• Aligns with the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG)

Coverage: HORNBACH IROs S2.1a, S2.1b, S2.1c, S2.1d, S2.1e, S2.1f, S.2.2a, S.2.2b, S2.3a, S2.3b, S2.3c, and S2.3d

Whistleblower Policy

Scope: Workers in both the upstream and the downstream value chains

Key content:

• Summarizes the general functionality of HORNBACH's whistleblower system as required by the German Whistleblower Protection Act
• Provides information about accessibility, responsibilities, and implementation of procedures to handle complaints concerning human rights and environmental-related risks and infringements in supply chains
• Addresses all material impacts on workers in the value chain and associated risks
• Enables reporting of infringements of national and international laws, or of internal regulations and policies, including human trafficking, forced labor, and child labor

Links to international standards:

• Required by the German Whistleblower Protection Act
• Aligns with the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG)

Coverage: HORNBACH IROs S2.1a, S2.1b, S2.1c, S2.1d, S2.1e, S2.1f, S.2.2a, S.2.2b, S2.3a, S2.3b, S2.3c, and S2.3d

CSR Guidelines

Key content:

• Records the overriding sustainability topics and presents the CSR strategy of the HORNBACH Group
• On a peripheral basis, if not explicitly, addresses all material impacts on workers in the value chain and associated risks

Coverage: HORNBACH IROs S2.1a, S2.1b, S2.1c, S2.1d, S2.1e, S2.1f, S.2.2a, S.2.2b, S2.3a, S2.3b, S2.3c, and S2.3d

Policy Statement on Company Due Diligence Obligations and Human Rights in Supply Chains of the HORNBACH Group

Scope: All companies within the HORNBACH Group, covering own operations and supply chains

Governance:

• Responsibility is incumbent on the CSR department and the Human Rights Officer of the HORNBACH Group

Key content:

• Meets due diligence obligation pursuant to § 3 (1) No. 4 in conjunction with § 6 (2) of the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG)
• Explains the approach taken by the HORNBACH Group with regard to respect for human rights and workers' rights and to compliance with environmental-related obligations
• Describes measures implemented in own operations and supply chains
• On a peripheral basis, if not explicitly, addresses all material impacts on workers in the value chain and associated risks
• HORNBACH commits to respecting and protecting human rights, not violating such rights or contributing to violations
• Aims to avert potential violations at an early stage and to end or minimize such violations

Public availability: Published in German and English on the website of HORNBACH Holding AG & Co. KGaA; available within the company in German on the intranet

Links to international standards:

• Based on internationally valid standards and policies
• Aligns with the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG)

Coverage: HORNBACH IROs S2.1a, S2.1b, S2.1c, S2.1d, S2.1e, S2.1f, S.2.2a, S.2.2b, S2.3a, S2.3b, S2.3c, and S2.3d

Additional measures

Workers of service providers who work directly on location at the stores are also subject to HORNBACH's work safety requirements.

Policies related to affected communities

The excerpts provided reference ESRS S3-1 disclosures on pages 182-183, indicating that Hornbach addresses:

• Human rights policy commitments (page 184)
• Non-respect of UNGPs on Business and Human Rights, ILO principles, or OECD guidelines (page 184)

However, the actual policy content for affected communities as required under ESRS S3-1 is not included in the provided excerpts. The excerpts primarily contain:

• An index/table of contents showing where S3-1 disclosures appear in the full report
• Detailed content for climate change (E1) topics
• Brief references to other social topics (S2, S4) and governance (G1)

The substantive S3-1 policy disclosures that are referenced as being on pages 182-184 are not reproduced in the excerpts provided.

Unable to extract specific policy details from the provided excerpts.

Policies related to consumers and end-users

Hornbach has disclosed several policies related to consumers and end-users, covering information rights, customer safety, customer satisfaction, and complaint handling.

CSR Guidelines

Key content: The CSR Guidelines include commitments to consumers and end-users. The guidelines refer to the United Nations Guiding Principles on Business and Human Rights, the United Nations Universal Declaration of Human Rights dated December 10, 1948, and the Conventions, Protocols, and Recommendations of the International Labour Organization (ILO) on labor and social standards.

Link to international standards:

• UN Guiding Principles on Business and Human Rights
• UN Universal Declaration of Human Rights (December 10, 1948)
• ILO Conventions, Protocols, and Recommendations on labor and social standards

Scope: Covers consumers and end-users related to Hornbach's business activities.

Monitoring: In the year under report, Hornbach did not become aware of any incidents of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises. No severe human rights-related incidents were identified in connection with consumers and end-users.

Group Data Protection Policy

Relevant to: Information rights (HORNBACH IROs S4.1a and S4.1c)

Key content: Lays down the minimum organizational standards and a uniform framework for using and protecting personal data at the HORNBACH Group. It particularly relates to the data of employees, applicants, visitors, customers, and business partners. The policy describes the objectives and principles of data protection for the whole of the HORNBACH Group and lays down responsibilities and accountabilities for data protection.

The most important principles include lawfulness, transparency, specification of purpose of data processing, data minimization, accuracy, storage limits, integrity, and confidentiality. The legislation provides data subjects with various rights, including the right to information, rectification, erasure, restriction in processing, data portability, and objection.

Scope: All employees of the HORNBACH Group.

Governance: The Board of Management of HORNBACH Management AG is responsible for monitoring compliance with data protection in all parts of the Group. Within the Board of Management, responsibility is allocated to the CFO's division. The Board of Management has appointed a Group Data Protection Manager, who reports to the relevant member of the Board of Management and the Chief Compliance Officer.

Link to international standards:

• European General Data Protection Regulation (GDPR)
• National data protection laws in countries of operation
• Swiss Data Protection Act

Public availability: Available on the intranet in all Group languages. Data protection information (privacy notice) is deposited on the websites of the online shops and in the HORNBACH apps, and is integrated into social media channels via links.

Monitoring: The Group Data Protection Manager is entitled to regularly review compliance with the policy and with applicable data protection laws at all HORNBACH companies, or to have such compliance reviewed. The operative HORNBACH companies report on a regular basis, and at least once a year, to the Group Data Protection Manager on data protection at their respective companies.

Safety Handbook

Relevant to: Customer safety (HORNBACH IRO S4.2b)

Key content: Summarizes the basic principles of safe conduct and work. Serves as a source of information and defines general safety standards at the retail outlets.

Scope: Applicable at retail outlets.

HORNBACH Customer Service Center Guidelines

Relevant to: Information rights and customer satisfaction (HORNBACH IROs S4.1b, S4.1d, and S4.3a-c)

Key content: Outline the role played by the CSC within the HORNBACH Baumarkt AG Subgroup and focus on the core topics of "Enable customers to implement their projects" and "Listen to the customer", i.e. offering competent advice about products and projects and evaluating customer interactions.

Scope: Applicable for the HORNBACH Baumarkt AG Subgroup. Implemented by employees at the stationary retail locations and in the Customer Service Center.

Governance: The responsibility is incumbent on the CSC management, which reports directly to the Subgroup's CEO.

Link to international standards: The CSC Guidelines are tailored to HORNBACH's requirements and are not based on external standards.

Public availability: Available to employees in all Group languages on the intranet.

Monitoring: The underlying processes and systems are continually improved in line with customers' need for advice and information.

Customer Claims Process

Relevant to: Information rights and customer satisfaction (HORNBACH IROs S4.1d and S4.3b,c)

Key content: Outline the approach taken to customer complaints and claims at the HORNBACH Baumarkt AG Subgroup and are intended to increase customer satisfaction. The guidelines include advice on how to assess and review complaints or claims, as well as on rights of return and guarantee conditions. Supplementary guidelines are in place for the claims process relating to the Trade Service.

Scope: Applicable for the HORNBACH Baumarkt AG Subgroup. Implemented by employees at the stationary retail locations and in the Customer Service Center.

Governance: Responsibility for the claims process is incumbent on the Store Processes department, whose director reports directly to the Board of Management of the HORNBACH Baumarkt AG Subgroup.

Link to international standards: The customer claims process is tailored to HORNBACH's requirements and is not based on external standards.

Public availability: Available to employees in all Group languages on the intranet.

Monitoring: The underlying processes are continually improved based on customer feedback.

Policy Statement on Company Due Diligence Obligations and Human Rights in Supply Chains

Key content: Consistent with internationally valid standards and policies. Does not explicitly focus on the protection of consumers and end-users, but does address compliance with legal requirements relating to merchantability and threshold values. The Human Rights Officer appointed by HORNBACH is also available as a contact partner for consumers and end-users.

Link to international standards: Consistent with internationally valid standards and policies.

Note on policy coverage: The policies referred to above cover consumers and end-users who are customers of HORNBACH or use HORNBACH products. The Customer Service Center Guidelines and the Customer Claims Process Guidelines only refer to direct customers of the HORNBACH Baumarkt Subgroup.

Taking action on material impacts on consumers

Overview

HORNBACH implements a variety of actions with regard to the topics identified as material, namely information rights, safety, customer satisfaction, and sustainability labeling in the product range. No action plans involving significant operational expenditure (OPEX) or capital expenditure (CAPEX) were implemented for these topics in the year under report. The actions implemented are based on legal requirements (data protection, product safety) or are the result of a strategic objective (product and project information, customer satisfaction, sustainability labeling).

Actions by material topic

1. Product and project information related to information rights (HORNBACH IRO S4.1b)

Description: At the DIY stores and garden centers, in the online shops, and at the builders' merchant outlets, HORNBACH's customers receive information about products and projects, as well as well-informed advice concerning product qualities and suitability for implementing construction and renovation projects.

Activities:

• Digital product information and video tutorials in online shops and on social media explaining product applications
• Step-by-step home improvement project guides
• Event formats at DIY stores and garden centers (some target-group specific, e.g. project evenings for women or formats for tradespeople)
• Evaluation of customer interactions and customer surveys to update product quality and project information

Scope: Own operations and downstream (customers)

Resources: Not quantified

2. Customer dialog and evaluation of customer satisfaction (HORNBACH IRO S4.1d, S.4.3a-c)

Description: The Customer Service Center (CSC) serves as a central point of contact for customers of the HORNBACH Baumarkt AG Subgroup, available at several locations and in all countries.

Activities:

• Information and advice on products
• Order acceptance by telephone
• Processing claims and customer orders
• Consignment tracking, hire transporter bookings, customer notifications
• Customer satisfaction surveys for the Trade Service
• Systematic evaluation of customer feedback and forwarding to relevant departments
• External customer surveys conducted several times a year in all countries (except Luxembourg)

Outcomes: Customer feedback impacts the further development of product range, services, information and advice offerings. Enables the company to counter potential undesirable developments and risks due to falling customer satisfaction.

Scope: Own operations and downstream (customers)

Resources: Not quantified

3. Data protection measures related to information rights (HORNBACH IRO S4.1a and S4.1c)

Description: All HORNBACH Group companies are obliged to observe and adhere to data protection laws in the respective countries and comply with the Group Data Protection Policy.

Activities:

• Implementation of Group Data Protection Policy across all Group companies
• Appointment of data protection officers at Group companies
• Data protection information (privacy notice) on websites, online shops, apps and social media channels

Scope: Group-wide (own operations)

Resources: Not quantified

Basis: Legal requirements

4. Quality assurance and product safety related to safety (HORNBACH IRO S4.2a)

Description: Measures to ensure products meet safety and quality standards, particularly for private label products.

Activities:

• Quality tests and article acceptance checks commissioned to independent, accredited, and certified audit institutes
• Monitoring compliance with European standards and directives governing threshold values for chemicals and hazardous substances
• Quality assurance employees check products at logistics centers and retail outlets
• Product crisis management procedure established
• Sales halts or product recalls implemented when defects identified
• Audits at production sites (see Workers in value chain chapter)
• Continuous evaluation of customer interactions and surveys for product quality feedback

Scope: Own operations and upstream (production sites)

Resources: Not quantified

Basis: Legal requirements and company quality standards

5. Safety at stores related to safety (HORNBACH IRO S4.2b)

Description: Actions relating to safety in own operations (see "Actions and resources" section of the "Own workforce" chapter).

Activities:

• Implementation of Safety Handbook defining general safety standards at retail outlets
• Systematic recording of accidents suffered by customers and employees
• Remedial action taken where necessary

Scope: Own operations (stationary stores)

Resources: Not quantified

Basis: Largely derived from work safety requirements

6. Labeling related to sustainability benefits in product range (HORNBACH IRO S4.4a-c)

Description: Investigation and labeling of products with sustainability benefits in the listed stock range.

Activities:

• Review of products to identify sustainability benefits compared with alternative products
• Assessment criteria include: manufacture and transport (ecological requirements, human rights, ILO standards, energy/waste/water approach); product characteristics (lifetime, reparability, recyclability, recycled material content, regional origins); suitable sustainability seals
• Products identified receive labeling in internal article master data
• Future development of actions to communicate sustainability benefits to consumers and end-users

Timeline: As of February 28, 2025: 26.4% of listed stock range labeled. Target: 85% by 2028/29

Scope: Own operations (product range) and upstream (product manufacture)

Resources: Not quantified

Link to target: Forms part of multi-year variable remuneration (MVR) for Board of Management

Remedial actions and grievance handling

Channels available:

• Customer Service Center (telephone, contact form, e-mail, letter) with ticket system
• Project and Service Center at stationary stores
• Fixed contact partners for commercial customers (Baustoff Union)
• Article review functions in online shops
• Social media channels
• External evaluation platforms
• Internet-based whistleblower system (available on all HORNBACH websites)

Processes:

• Customer inquiries recorded and monitored by processing status with reminder functions
• Store evaluations answered by local employees
• Social media channels centrally managed per country
• Sales halts and product recalls communicated immediately to stores and online shops
• Warning signs displayed at stores and published online
• Purchasers notified by Customer Service where contact data available

Statement on absence of significant investments

No action plans involving significant operational expenditure (OPEX) or capital expenditure (CAPEX) were implemented for consumer-related topics in the year under report.

Our System of Values: the HORNBACH Foundation

HORNBACH is a forward-looking, family-managed company and is characterized by a clear system of values. The values on which this system is based are honesty, credibility, reliability, clarity, and trust in people. This system of values, which had already been actively lived for many decades, was summarized in the so-called "HORNBACH Foundation" in 2004. This model forms the cornerstone for our Group strategy, everyday behavior, and corporate social responsibility. It lays down the basic values governing how we behave towards our customers, as well how our employees behave towards each other.

Compliance

In a competitive climate, only those companies which manage to convince their customers with their innovation, quality, reliability, dependability, and fairness on an ongoing basis will succeed in the long term. Here, compliance with legal requirements, internal company guidelines and ethical principles (compliance) is absolutely crucial. HORNBACH's corporate culture is built on these principles.

HORNBACH has a value-based compliance system which pursues the primary objective of preventing compliance infringements, if possible before they arise. The "HORNBACH Foundation" forms the basis for HORNBACH's system of values. The principles included in the "HORNBACH Foundation" are fleshed out in the "HORNBACH Values", which have been translated into all relevant languages across the Group and are available to all employees. These formulate the standards of conduct expected of managers and employees with regard to the target groups of government and society, managers and employees, customers, suppliers and competitors, and providers of equity and debt capital.

In connection with the safeguards governing integrity, HORNBACH's "Accepting and Granting Gratuities" code of conduct specifies HORNBACH's expectations in its employees with regard to accepting and granting gratuities in day-to-day business operations. This code sets clear limits in respect of impermissible gratuities and, as well as underlining role model function of managers, emphasizes the principles of professionalism, transparency, and appropriateness.

The Board of Management of the General Partner bears overall responsibility for compliance. One core component of HORNBACH's compliance system is the Compliance Committee, which acts as the topmost advisory body for compliance organization. The compliance department led by the Head of Compliance is responsible for coordinating and optimizing Group-wide compliance activities. This department reports to the Chief Compliance Officer. He or she reports in turn to the Board of Management and is responsible for permanently optimizing and further developing the Group's compliance organization and structures.

The procurement organization of the HORNBACH Group safeguards broad access to global procurement markets and builds on strategic, long-term partnerships with suppliers. The HORNBACH Baumarkt AG Subgroup maintains a procurement office in Hong Kong to manage the import of goods from East Asia. In procuring its trading goods, the HORNBACH Group works with direct suppliers from around 40 countries. Around 70% of the trading goods purchased come from the European Union.

Among others, direct suppliers of trading goods include manufacturers of metal products, plastic goods, glass, ceramics, timber goods, chemical products and textiles, stone and soil processors, and agricultural firms and market gardens. Furthermore, HORNBACH works together with service providers offering services in, among other areas, transport, logistics, construction, energy supply, and IT and software. It also procures furnishings and vehicles for its stores and administration locations.

Moreover, HORNBACH expects its direct business partners to communicate these requirements in the value chain and safeguard compliance with such. To underline this expectation, HORNBACH has made information materials on due diligence obligations in supply chains available to all business partners.

As well as promoting an effective compliance culture, compliance activities have a particular focus on the risks of "improper conduct / corruption" and "cartel law violations". The development in risks which are already known and the potential emergence of new risks are surveyed in the compliance survey, which is conducted once a year and regularly updated.

The compliance system is supplemented by a whistleblower system. This provides employees, service providers, and suppliers worldwide with a further possibility of communicating directly, confidentially and, if preferred, anonymously with the compliance department, as well as with an internet-based external service provider. This way, potential infringements of compliance requirements, and in particular infringements relating to antitrust law and corruption, as well as offenses against property and assets, can be reported.

Incidents of corruption or bribery

Confirmed incidents

No confirmed incidents of corruption or bribery were reported for the 2024/25 financial year.

Convictions and fines

There were no convictions or fines in connection with corruption and bribery/corruptibility in the 2024/25 financial year.

Investigation procedures and speak-up mechanisms

Combating corruption and bribery/corruptibility is one of the focus topics for compliance and, like all compliance infringements, is pursued at HORNBACH with a zero-tolerance policy. HORNBACH adheres to all laws aimed at combating bribery and corruption in all countries in which it operates.

The actions taken to prevent corruption include:

• Risk analyses
• Internal control mechanisms
• Signing and approval regulations
• Due diligence procedures towards business partners
• Reporting channels for internal and external whistleblowers

Suspected cases reported by direct channels or via the whistleblower system are reviewed and evaluated by the Compliance department. Based on this assessment, an investigation of the incident is initiated. The Board of Management is involved in the process if such measure is deemed relevant given the potential scale of the incident.

Auditing adherence to the compliance regulations (including anti-corruption) is incumbent on Internal Audit. This department performs independent and objective audit and advisory services in all Group departments and subsidiaries. The Internal Audit and Compliance functions are independent of the operating business and have extensive powers and unrestricted access to information.

Training on the topic of anti-corruption forms part of basic compliance training and is available to all Group employees on the intranet. Furthermore, anti-corruption training can be provided by the Compliance department upon request for individual departments.

Whistleblower system

In the year under report, there was a low double-digit number of notifications received through the whistleblower system, of which a quarter were not directly within the objective scope of the whistleblower system. The whistleblower system provides employees, service providers, and suppliers worldwide with the possibility of communicating directly, confidentially and, if preferred, anonymously with the compliance department, as well as with an internet-based external service provider.

Not disclosed.

Payment practices

Payment terms and practices

The payment of suppliers is based on contractually agreed terms. Unless otherwise agreed, payments at the HORNBACH Baumarkt AG Subgroup are made on a net basis within 30 days following receipt of the return service and at the earliest 30 days after receipt of the invoice. At the HORNBACH Baustoff Union GmbH Subgroup, the payment terms are generally agreed on an individual basis.

Due to the variety of the product range and variances in international business practices, both Subgroups have a variety of payment agreements, some of which provide for early payment discounts.

Average payment time

Reporting period: 2024/25 financial year

Legal proceedings for late payment

There were no legal proceedings outstanding for late payments in the period under report.

Methodology

To calculate the average time (in days) which HORNBACH takes to pay an invoice from the date when the contractual term of payment starts, a representative sample of clearing documents was collected in the period under report. The base date of the maximum maturity agreed with the supplier was compared with date of actual payment, with the average then being calculated for all documents.

Additional context

In structuring its payment agreements, HORNBACH does not differentiate by company size. Supplier characteristics of this nature are not determined or collected by HORNBACH when structuring its payment practices and are not known to the company.

The company does not have any policies, targets, and actions, or other key performance indicators concerning supplier relationships or payment practices. HORNBACH considers its existing payment targets and practices to be appropriate.