Hrvatski Telekom

Governance structure and sustainability oversight

Reference: pages 44-47.

HT has a two-tier board. The Management Board had 7 members on 31 December 2025 (CEO Nataša Rapaić as President). The Supervisory Board has 9 members: 8 elected by the Shareholders' Meeting and one appointed by the Workers' Council. Two members are independent, 22% (pages 44-45). Women hold 29% of Management Board seats and 44% of Supervisory Board seats, 38% overall against 31% a year earlier (page 45).

The Management Board adopts sustainability regulations and strategic guidelines, and the Group Policy on Corporate Responsibility gives it executive responsibility. A Sustainability Committee was set up in 2025 to advise it. A CR Manager coordinates the work and a CR Controller collects and consolidates KPIs (page 45). Audit Committee chair Marc Stehle also holds a Deutsche Telekom corporate responsibility finance role, which the report cites as sustainability expertise (page 47). Full board profiles are incorporated by reference from the Group Business section (page 43).

Information provided to the boards

Reference: pages 45-47.

The Management Board hears about sustainability at meetings with a broader management team, informed by the Sustainability Committee and department experts, and decides on current sustainability matters at its own meetings (page 47). The Supervisory Board is informed about the Sustainability Strategy, its implementation and KPIs at least quarterly as part of business reporting (page 46).

Before publication, the Audit Committee and a Workers' Council representative saw the sustainability information and the methods used to obtain and verify it. The Workers' Council was asked for a written opinion, passed to the Supervisory Board (page 47). The Management Board received the status of the double materiality assessment before finalizing it. In 2025 both boards addressed all material impacts, risks and opportunities, which are listed under SBM-3 of each topical standard (page 47).

Sustainability performance in incentive schemes

Reference: pages 47-48 (also cited for E1 in the index, page 47).

Management Board pay is a fixed salary plus a short-term incentive (STI) linked to financial and non-financial KPIs, under the Remuneration Policy adopted by the Shareholders' Meeting in 2023 (page 47). Two environmental KPIs, energy consumption and Scope 1 and 2 CO2 emissions, make up 20% of the target amount, each weighted 50%. The Supervisory Board sets target and border values from the corporate plan, and each goal can pay out between 0% and 150% (pages 47-48).

Customer satisfaction (measured with the TRI*M method) and employee satisfaction (regular surveys) together make up 25% of the strategic goals set for 2025, with the same 0% to 150% range (page 48). The report describes only the non-financial indicators of variable pay in this section.

Statement on due diligence

Reference: pages 48-49.

The statement is a mapping table showing where the report covers each core element of due diligence across ESRS 2, E1, E5, S1, S2, S4 and G1 (page 48).

• Embedding in governance, strategy and business model: GOV-2, GOV-3, SBM-3.
• Engaging affected stakeholders: GOV-2, SBM-2, IRO-1 and the policy DRs (E1-2, E5-1, S1-1, S2-1, S4-1, G1-1).
• Identifying and assessing adverse impacts: IRO-1 and SBM-3.
• Taking action: E1-3, E5-2, S1-4, S2-4, S4-4 and G1-3.
• Tracking effectiveness: the target DRs (E1-4, E5-3, S1-5, S2-5, S4-5) and the metric DRs (E1-5 to E1-7, E5-4, E5-5, S1-6 and S1-8 to S1-17) (pages 48-49).

Supply chain due diligence for human rights runs through Deutsche Telekom under the German Supply Chain Act (LkSG), described under S2 (pages 109-111).

Risk management and internal controls over sustainability reporting

Reference: pages 45-46, 49.

The report says risk management and internal control over sustainability reporting are part of the Group's general risk processes, described under GOV-1 (page 49). Risks tied to strategic goals are assessed quarterly and consolidated in a quarterly risk report built in a single Deutsche Telekom IT tool. It goes to the Management Board and the Audit Committee, and each material risk has an owner at top management level (page 46). Every risk in that report is also classed as environmental, social or governance (pages 46, 49). A Corporate Risk Committee supports the Management Board in overseeing the system (page 46).

Collection of sustainability data is documented and tested each year through the internal control system (ICS) under the DT ICS methodology, with management, internal audit and independent third parties involved (page 46). An independent third party tested the 2025 ICS for circularity and waste data (page 92).

Strategy, business model and value chain

Reference: pages 50-53.

HT supplies fixed and mobile telephony, internet, IPTV, data services and ICT solutions in Croatia and Montenegro, with four segments: fixed networks, mobile telephony, products and sales, and system solutions (pages 50, 52). Segment turnover was EUR 1,141,669 thousand in 2025 (2024: 1,101,579), of which mobile services were EUR 433,421 thousand and fixed services EUR 356,317 thousand. Head count was 5,733 (page 50). The Group states it has no activity in fossil fuels, chemical production, controversial weapons or tobacco (page 50).

Goals (page 50): 100% renewable electricity; net zero Scope 1 and 2 by 2025 and a 55% cut in Scope 1-3 by 2030 against 2020, both as part of Deutsche Telekom (SBTi); net zero across the value chain by 2040; recycle 100% of technological waste; keep women at 40% of management; rural 5G coverage targets; 95% 4G/5G population coverage in each of 20 defined areas. The strategy rests on climate, resource efficiency and digital inclusion (page 51). HT has no own manufacturing and relies on domestic and international suppliers (page 52); the value chain is mapped on page 53.

Interests and views of stakeholders

Reference: pages 42, 54.

The Group maps eight stakeholder groups: customers; employees and unions; suppliers, partners and the business community; owners, investors and financial institutions; regulators and state bodies; interest and expert associations; media, associations and educational and scientific institutions; and analysts, auditors and certification bodies (page 54).

Views are collected through customer satisfaction surveys, social dialogue with employee representatives, employee satisfaction surveys, and whistleblowing and feedback channels, and these feed the double materiality assessment (page 54). In 2025 HT built a Partner Assessment Survey on human rights and environmental protection in its value chain. Data collection began at the end of 2025; full analysis starts in 2026 (pages 42, 54). HT also interviews external experts each year; in 2025 the talks tested the resource savings and avoided GHG emissions from its circular business models (page 54). Customer and employee satisfaction feed Management Board pay (page 54).

Material impacts, risks and opportunities and their interaction with strategy

Reference: pages 55-58.

The general table covers E1, E5, S1, S2, S4, G1 and an entity-specific cyber security topic, giving each row a value chain position and, for impacts, an actual or potential label (pages 55-58). Counting the rows gives 36 items: 11 positive impacts, 16 negative impacts, 6 risks and 3 opportunities. The summary graphic on page 58 shows 14, 19 and 3 IROs, which match the environment (E1, E5), society (S1, S2, S4) and governance (G1, cyber) row counts.

The Group states that all material negative impacts are systemic and not tied to separate incidents or specific business relations. No identified IRO or measure changed strategy or business model in 2025, and no material financial impacts from the identified risks and opportunities were recorded in the period (page 58). No material own-workforce risks were identified (page 58). The report uses the phase-in for SBM-3 paragraph 48(e) for ESRS 2, E1, S4 and the cyber topic (page 44).

Processes to identify and assess material impacts, risks and opportunities

Reference: pages 59-61 (climate on page 77, business conduct on page 121).

The 2025 double materiality assessment was a re-evaluation of the full assessment done for the previous year (page 59). Inputs included competitor analysis, earlier independent materiality studies, the Deutsche Telekom assessment and DT-level value chain analyses, the ESRS and EFRAG guidance, GRI, the SASB telecom standards, TCFD and the SDGs (page 59).

Impacts are scored on scale, scope and, for negative impacts, irremediable character, each from 1 to 5. Potential impacts also get a likelihood score and a time interval: short term (1 year), mid term (2-5 years) or long term (over 5 years) (page 60). Financial materiality follows the Group's risk management method, with financial impact scored 1 to 4 in EUR million and likelihood 1 to 4 (pages 60-61). The reviews were done online, documented in Excel and confirmed by e-mail (page 60). The report says water and pollution impacts did not prove relevant and its activities do not harm biodiversity-sensitive areas (page 60). Page 59 lists the entity-specific indicators used.

Disclosure requirements covered by the sustainability statement

Reference: pages 39-40 (ESRS index), 44, 61-66.

The report prints an "ESRS index according to ESRS 2 IRO-2" with a page reference for each disclosure requirement (pages 39-40). It covers ESRS 2, E1, E5, S1, S2, S4, G1 and an entity-specific cyber security topic (page 39). E1 lists E1-1 to E1-7. E5 lists E5-1 to E5-5. S1 lists S1-1 to S1-6, S1-8, S1-9, S1-13, S1-14, S1-16 and S1-17. S2 and S4 list all five DRs. G1 lists G1-1, G1-3 and G1-4 (pages 39-40).

Page 61 states that E2, E3, E4 and S3 "were not material" after the double materiality analysis. The phase-in table on page 44 covers SBM-3 (paragraph 48(e)) for ESRS 2, E1, S4 and the cyber topic, and E1-9. Pages 62-66 list datapoints that derive from other EU legislation, with a materiality column.

Transition plan for climate change mitigation

Reference: page 76.

The Group has no standalone transition plan. It points to the climate transition plan Deutsche Telekom (DT) published in 2024, which is to be implemented with the Group taking part (page 76). The report says that, after the EU change to the CSDDD, the Group no longer has to prepare and publish its own plan. It will keep carrying out actions that feed DT's plan and says it plans to compile a standalone plan voluntarily (page 76).

Climate targets sit at DT Group level, were approved by SBTi, and the report says this confirms alignment with Paris Agreement goals (pages 76, 82). The content a plan would hold (targets, levers, planned investment) is in E1-3 and E1-4 (pages 79-82).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 E1, where this content is disclosed in the FY2025 report (page 77). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The Group ran a physical climate risk assessment with the Munich Re Location Risk Intelligence Software, covering 2,400 sites (data centers and mobile and fixed infrastructure in Croatia). It covers floods, temperature stress, precipitation, fires, droughts, cold waves, cyclones and sea-level rise, with projections for 2030, 2050 and 2100 (sea-level rise for 2100 only) (page 77).

Three scenarios are described: SSP1 / RCP 2.6 (below 2°C), SSP2 / RCP 4.5 (2.2-2.6°C) and SSP5 / RCP 8.5 (above 4°C). The analysis itself used RCP 8.5 for 2050, citing a UNEP trajectory of 2.8°C by 2100 (page 77). The SBM-3 table classes extreme weather as a long-term physical risk, electricity price volatility as a mid-term transition risk and ICT solutions as a mid-term transition opportunity (pages 76-77). No transition scenario analysis is described, and no date for the assessment is given.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 E1 and IRO-1 E1, where this content is disclosed in the FY2025 report (pages 76-77). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The report describes no formal resilience analysis in the ESRS sense. It says only a small part of the Group's infrastructure is currently exposed to climate hazards, and that RCP 8.5 projections to 2050 suggest the share of assets at heightened risk from some hazards could grow if global mitigation falls short (page 77).

Resilience measures named: ring topologies and redundancy of network elements, uninterruptible power supply systems with batteries and diesel generators at the most critical sites, and crisis management and operational preparedness processes (page 77). The business continuity system follows ISO 22301:2019 (pages 58-59). The analysis is meant to guide site-level adaptation planning (page 77). The climate chapter does not discuss uncertainty or financial capacity to adapt.

Policies related to climate change mitigation and adaptation

Reference: page 78.

Climate neutrality is an umbrella goal of the Sustainability Strategy. The climate strategy has four pillars: value chain emissions, renewable energy, energy efficiency, and enabling customers' own climate action (page 78). The policies named are the Environmental, Health and Safety at Work Management Policy (ISO 14001 and ISO 45001 system), the Group Policy on Corporate Responsibility (mitigation, adaptation and an enabling solution portfolio), the Energy Policy (efficiency and the transition risk from electricity price volatility), the Supplier Code of Conduct and the Code of Human Rights (page 78).

The page also describes ICT solutions sold to cut customers' emissions: more than 540 EV charging connection points (35,000 app users, 2,339,547 kWh delivered in 2025), cloud fleet management, smart factory, smart metering, smart parking and the ComEnergy energy monitoring tool (pages 78-79).

Actions and resources in relation to climate change policies

Reference: pages 79-81.

Scope 1 and 2 measures: buy only renewable electricity, raise energy efficiency and phase out legacy systems, shrink and modernize office space, electrify and reduce the vehicle fleet, and install heat pumps (page 79). In Croatia renewable power comes from a ten-year virtual power purchase agreement, "ZelEn" green supply from HEP Opskrba and guarantees of origin; Montenegro uses a green tariff and guarantees of origin (page 79). The report counts 25,024 t CO2e of avoided Scope 1 and 2 emissions in 2025 (page 79).

Planned cuts for 2026-2029: 1,606 t CO2e of Scope 1 with EUR 15 million of investment, and 3,681 t CO2e of downstream Scope 3 with EUR 15 million, so EUR 30 million in all. The report says these investments cannot be classed as a Taxonomy-aligned CapEx plan (pages 79-80). Upstream actions run at DT Group level and need no significant spend from HT (page 80). An AI-based cooling tool went live in 2025 at the Utrine data center (page 80). Electricity price risk is managed with hedging derivatives and the vPPA (page 80).

Targets related to climate change mitigation and adaptation

Reference: pages 81-82.

The targets are set at DT Group level, approved by SBTi, and the Group contributes to them (page 81): source 100% of electricity from renewables (a continuous goal, met since 2021); net zero Scope 1 and 2 by 2025; cut Scope 1-3 emissions 55% by 2030 against 2020; net zero across the value chain by 2040 at the latest, which needs a 90% absolute cut against 2020 with up to 10% compensation (pages 81-82).

The report says the Scope 1 and 2 goal was reached at DT Group level by the end of 2025. DT cut Scope 1 and 2 by 94% against 2017 and neutralized the remaining 6% with carbon removals (pages 81-82). Progress is tracked through the fall in GHG emissions, using the market-based method for Scope 2 (page 82). SBTi confirmed the targets align with the Paris Agreement under its stricter guidelines. Setting the targets took account of market development, technical development and the expansion of renewable energy (page 82).

Energy consumption and mix

Reference: pages 82-83.

Total energy consumption was 169,613 MWh in 2025 (2024: 167,428), up 1%, mainly from a 2% rise in electricity use as the network grew (page 82). Fossil sources were 34,832 MWh, 21% of the total (2024: 35,559 MWh, 21%), down 2% after two heat pumps replaced oil heating. Renewable sources were 134,781 MWh, 79% (unchanged), all of it purchased green electricity. Nuclear was zero (page 82). The Group says it does not operate in high climate impact sectors (page 82).

A Group-specific KPI, energy intensity, improved 15% to 17 kWh per terabyte of data transported (2024: 20 kWh/TB) (page 83). Data comes from segment reporting and energy provider data, with extrapolation when data is late, and is covered by the internal control system. Certification bodies validate green energy certificates (page 83).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 83-85 (restatement note on page 43).

Scope 1 was 8,555 t CO2e in 2025 (2024: 8,728) and Scope 2 market-based 394 t (384), so Scope 1 and 2 market-based totaled 8,949 t (9,112). Scope 2 location-based was 25,168 t (30,139) (page 84). Scope 3 was 150,155 t (2024 restated: 161,733): 84,616 t upstream and 65,539 t downstream. The largest categories are use of leased products (51,611 t), purchased goods and services (35,611 t) and capital goods (29,139 t) (page 84).

Total emissions were 159,104 t market-based and 183,878 t location-based (page 84). Intensity was 0.14 t CO2e per EUR thousand of net revenue market-based, 0.16 location-based (page 85). The 2024 Scope 3 figures were adjusted for new emission factors and method changes (page 43). Scope 3 is extrapolated from direct and indirect statistical data; categories 8, 10 and 14 are excluded as not significant (pages 83, 85).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 85.

HT cancelled carbon credits of 8,949 t CO2e in 2025, the same figure as its Scope 1 and 2 market-based total. All came from removal projects (6,712 t from biogenic sinks, 2,237 t from technological sinks) and none from reduction projects (page 85). Standards used: Verra 5%, Climate Action Reserve 70%, Puro.earth 8% and Carbon Standards International 17%. 1% of projects are in the EU and none carry corresponding adjustments (page 85).

A further 25,040 t CO2e is contractually planned for cancellation in 2026-2028 (18,029 t biogenic, 7,011 t technological) (page 85). The Group limits purchases to Oxford categories IV and V, projects that remove carbon through short- and long-lived storage (pages 81-82, 85). The credits come from projects outside the Group's value chain (page 85).

Policies related to resource use and circular economy

Reference: page 87.

The base document is the Group's Environmental, Health and Safety at Work Policy, described as the way the Group manages its overall environmental footprint (page 87). It commits the Group to continuous improvement of environmental protection and to responsible management of resources, packaging and waste. Waste at all locations is sorted and disposed of under applicable law, with a focus on cutting volumes, recycling and reuse (page 87).

The policy also sets strategic projects, internal programs and communication to build a culture of environmental responsibility among customers, employees and business partners (page 87). The Management Board is directly responsible for setting up and carrying out the policy, which follows the ISO 14001 and ISO 45001 management system requirements (page 87).

Actions and resources related to resource use and circular economy

Reference: pages 87-90.

The Group applies a "Prevent - Reduce - Reuse - Recycle" approach. Most waste comes from network modernization, office buildings and data centers, and all waste types are collected separately and handled with authorized processors under ISO 14001 (page 88). Circular business models are the main action: Trade In (launched 2024), Forward TradeIN (launched May 2024, over 41,000 devices sold by end of 2025, returns expected in 2026) and Devices as a Service for business customers (since 2024, 12 to 36 months) (page 88).

The "Call You Have to Take" platform (launched 2023) and a Take Back & Recycle scheme collect old devices (page 89). In 2025 the Group collected 39,494 mobile devices (2024: 40,201); 34,745 smartphones and mobile phones came through circular models (2024: 30,890), up 12% (page 89). It collected 280,477 pieces of fixed equipment (2024: 213,808), of which 194,180 went to refurbishment and reuse (page 90).

Targets related to resource use and circular economy

Reference: page 90.

The one target is continuous: recycle 100% of technological waste. The report says the Group has met it every year since 2021 (page 90). It rests on a renewed Management Board commitment confirmed when the Sustainability Strategy was adopted in 2023, and means proper disposal or recycling of technological waste under Croatian and Montenegrin waste law, so no waste to landfill. It applies to the Group's own waste and to electronic waste collected from customers (page 90).

The Group says it has set no other measurable objectives tied to the material E5 impacts (page 90). The printed heading on page 90 reads "Policies related to resource use and circular economy", but the content is the targets disclosure and the ESRS index lists it as E5-3 targets (page 40).

Resource inflows

Reference: pages 42, 91.

Inflows are reported for the two main materials in network build-out: fiber optic cables and mobile telephony antennas. Total weight used was 156 t in 2025 (2024: 221 t), made up of 65 t of fiber optic cables (54 t) and 91 t of antennas (167 t) (page 91).

Weights are estimated: cable length bought times average weight per unit of length, and antenna counts times average weight per piece, in two weight categories (pages 42, 91). Biological materials are mainly paper packaging, roughly estimated because manufacturers give no data, and the report says they are an insignificant share of total weight (pages 42, 91). The Group did not disclose the weight or share of unprocessed, reused or recycled materials, saying it was not practical to assess them (page 91).

Resource outflows

Reference: pages 91-92.

The report treats outflows mainly as waste. It tracks hazardous waste (batteries, accumulators, lighting, electrical and electronic equipment) and non-hazardous waste (paper, wood, construction and bulky waste) (page 91). Most waste that could pose an environmental risk is technological waste, and the Group says it recycles all of it (page 91).

Waste rose in 2025 in all three monitored categories: electronic waste from network modernization and decommissioning of old equipment, municipal waste from site clearing, and other waste from renovation and network construction (page 91). Network and device waste contains metals, rare earths, non-metallic minerals and plastics (page 92). Device take-back volumes are reported under E5-2 (pages 89-90). No expected durability or recyclable-content rates are given for the Group's own outflows.

Waste

Reference: page 92 (narrative on page 91).

Total waste was 943 t in 2025 (2024: 742 t): hazardous 457 t (408 t) and non-hazardous 486 t (334 t) (page 92). All of it, 100%, was diverted from disposal by recycling. Waste directed to disposal and non-recycled waste were both 0 t, in both years (page 92).

Waste is reported by generation location to the Croatian Register of Polluters and verified by the competent bodies; the Montenegrin subsidiary reports to its Environmental Protection Agency. The 2025 filings were still in preparation when the report was written (page 92). An independent third party tested the internal controls over the waste data for 2025 (page 92).

Policies related to own workforce

Reference: pages 95-97.

Policies cover collective bargaining and social dialogue, health and safety, equal treatment (gender equality and equal pay, measures against violence and harassment, diversity) and training. They rest on the Code of Human Rights, the Code of Conduct, the Diversity, Equity and Inclusion (DE&I) Policy, the Social Charter, the Collective Agreements and the Quality, Health, Safety and Environment Management System (page 96).

The Code of Human Rights commits the Group to the International Bill of Human Rights, the ILO fundamental principles, the OECD guidelines, the UN Global Compact and the UN Guiding Principles, and lists principles including a ban on child and forced labor, an adequate living wage and zero tolerance of violence and harassment (pages 95-96). The Management Board answers for adherence; a Human Rights Officer and a DE&I Officer support it (pages 96-97). The report says no policy explicitly addresses burnout and stress, though several address it indirectly (page 96). HT and its Montenegrin subsidiary hold ISO 45001:2018 certification (page 97).

Taking action on material impacts on own workforce

Reference: pages 99-102.

Collective bargaining: the Collective Agreement raised minimum wages by a total of 37%, set a minimum salary of EUR 1,150 and led to pay rises for over 3,900 employees (page 99). Health and safety: HT tracks injuries, occupational disease, audit findings and complaints. From 1 January 2025 employees get supplementary health insurance with free preventive check-ups through Croatia osiguranje (page 100). Actions include workplace risk assessments, safety training, medical check-ups, drills and an annual action plan; well@work addresses stress and burnout (pages 99-101).

Equal treatment: DE&I education, the "Everyone Can Be Themselves Here" series, equal pay by job grade and the Equal Pay Champion certificate from SELECTIO Group, one of 16 Croatian companies to receive it (page 101). Training: development programs reached over 80% of employees in 2025 and more than 2,000 took short-term courses (pages 101-102). HT earned the Employer Partner certificate and the Above and Beyond recognition (page 102).

Targets related to own workforce

Reference: page 102.

There is one target: keep women at 40% of management positions, a continuous goal resting on a renewed Management Board commitment confirmed with the 2023 Sustainability Strategy (page 102). It was first set for HT only, and acquisitions in recent years lowered the Group ratio (page 102). In 2025 women held 38% of management positions at HT and 35% at Group level (Group 2024: 34%) (page 102). The Group says it has set no other measurable, outcome-oriented targets for its material own-workforce impacts (page 102).

Characteristics of the undertaking's employees

Reference: pages 102-103.

Head count was 5,733 at 31 December 2025 (2024: 5,751): 3,717 men and 2,016 women (page 102). By country, 5,229 were in Croatia (5,271) and 451 in Montenegro (447) (page 102); the SBM-1 table shows a further 53 in other countries (page 50). By contract, 5,340 were permanent (2024: 5,429) and 393 temporary (322), and none were on non-guaranteed hours (page 103).

535 employees left in 2025, a turnover rate of 9% (2024: 8%) (page 103). The unit is the number of individuals employed at year end (page 102). The report leaves self-employed people and third-party agency workers out of the impact review because they are under 5% of workforce cost (page 94).

Collective bargaining coverage and social dialogue

Reference: pages 99-100, 103.

90% of employees were covered by collective agreements in 2025 (2024: 92%) (pages 99, 103). In Croatia, HT's Collective Agreement applies to its employees but not to managers or to other Group companies, whose staff fall under the Labour Act and each company's own rules (page 103). The Montenegrin subsidiary's Collective Agreement covers all Group employees in Montenegro (pages 100, 103). HT's agreement runs to 31 December 2026 (page 99).

On social dialogue, the workers' representative on the Supervisory Board, Viktor Vanek, sits on the Presidium of the European Works Council of Deutsche Telekom (page 103).

Diversity metrics

Reference: pages 102-104 (also page 45).

Women held 35% of leading management positions, excluding the Management Board, in 2025: 68 women and 128 men, 196 in total (2024: 74 women and 144 men, 218 in total, 34%) (page 103). At HT alone the share is 38%, against a Group goal of 40% (page 102).

By age, 829 employees were under 30 (14%), 3,312 were 30 to 50 (58%) and 1,592 were over 50 (28%); in 2024 the counts were 778, 3,396 and 1,577 (page 104). Women are 2,016 of 5,733 employees (page 102), 29% of the Management Board and 44% of the Supervisory Board (page 45).

Training and skills development metrics

Reference: pages 101-102, 104.

100% of employees, men and women, took part in regular performance and career development reviews in both 2025 and 2024 (page 104). The report also gives average training hours per employee by gender, split between management and other employees, for both years (page 104).

Development programs in 2025 reached over 80% of employees. More than 2,000 employees joined individual short-term internal or external courses, and access to online learning tools rose 20% (pages 101-102). The Percipio learning platform is open to all employees, and an internal AI portal brings together awareness and skills activities (page 102). More than 800 employees took part in the national "You Can Do AI Too" program (page 102).

Health and safety metrics

Reference: page 104.

All Group employees (100%) are covered by an occupational safety system based on ISO 45001:2018 (page 104). There were 23 recorded accidents in 2025 (2024: 33), 16 in the working process and 7 outside it. The accident rate was 2.18 (2024: 3.37) and 905.6 days were lost to injuries (2024: 1,347.5). The table splits the Lost Time Injury Rate into 1.52 in the working process and 0.66 outside it (page 104).

There were no fatalities from work injuries or work-related illness (2024: 0), and no work-related illnesses that needed a record (page 104). The report credits the fall to prevention work: revised risk assessments, improved work processes and more training (page 104).

Compensation metrics (pay gap and total compensation)

Reference: page 105.

The unadjusted gender pay gap was 4% in 2025 (2024: 3%). The adjusted gap, which weights each Group company by its share of employees, was 3% (2024: 4%) (page 105). The ratio of the highest-paid individual's total annual remuneration to the median for all other employees was 28:1 (2024: 32:1) (page 105).

Remuneration counts basic and variable pay, bonuses, fixed supplements, reimbursements, vacation and Christmas bonuses, and similar payments for staff employed on 31 December 2025, shown on a full-time equivalent basis for the ratio. Benefits in kind and support not tied to work, such as childbirth or long-term sick leave payments, are left out (page 105). HT also received the Equal Pay Champion certificate (page 101).

Incidents, complaints and severe human rights impacts

Reference: page 105.

Seven reports of discrimination and harassment reached the Group in 2025 through the "Tell Me!" website, the Ethics Line and the persons authorized to handle dignity complaints (2024: 5, of which one was confirmed). All seven came from Group employees (page 105). There were no fines, penalties or compensation for damages (2024: none).

No severe human rights incidents, such as forced labor, human trafficking or child labor, were recorded in the workforce in 2025 (2024: 0), and fines, penalties and compensation for such incidents were EUR 0 (page 105).

Policies related to value chain workers

Reference: pages 108-109.

The Group, as part of Deutsche Telekom (DT), manages human rights impacts on value chain workers through centralized procurement. Suppliers must follow the Supplier Code of Conduct, part of DT's General Procurement Terms and Conditions, and carry it down their own chains (page 108). The Code covers a ban on child labor, forced labor and slavery, freedom of association and collective bargaining, fair wages and working hours, occupational health and safety, and non-discrimination (page 108). It refers to the International Bill of Human Rights, ILO fundamental principles, OECD guidelines, UN Global Compact and UN Guiding Principles (page 108).

Breaches trigger a central risk incident analysis under the German Supply Chain Act (LkSG). DT created an LkSG Officer role reporting to its CEO and an LkSG Risk Board (page 109). Public e-learning for suppliers is on HT's website (page 108).

Taking action on material impacts on value chain workers

Reference: pages 110-111.

Actions are taken centrally at DT Group level. DT runs an annual LkSG risk analysis of direct suppliers and extra audits when it hears of irregularities. In 2025 it contacted all priority direct suppliers about its expectations on human rights and the environment (pages 110-111). It reviews own-brand products (T Phone, T Tablet) each year for raw materials from conflict-affected areas, and requires the Conflict Minerals Reporting Template from suppliers where conflict minerals cannot be avoided (page 111). From early 2025, LkSG aspects were added to regular quality audits at production sites, and JAC audits continue, mostly in Asia (page 111).

DT reviews effectiveness once a year against set indicators. At DT Group level there were no cases of potential high-priority human rights violations in 2025. The report says the identified potential impacts do not include HT's own direct and indirect suppliers in Croatia and Montenegro (page 111).

Targets related to value chain workers

Reference: page 111.

The report states that no measurable, outcome-oriented targets related to the significant impacts under S2 have been set, either at DT Group level or at Group level (page 111). Effectiveness of measures is reviewed once a year in the LkSG risk analysis against predefined indicators (page 111).

Policies related to consumers and end-users

Reference: pages 114-115.

The Code of Human Rights commits HT to protect customer data and digital autonomy, freedom of expression and information, children and young people, and digital inclusion. The Code of Conduct, Guiding Principles and Digital Ethics Guidelines on Artificial Intelligence also apply (page 114). On 28 September 2025 HT signed the Code of Conduct on Children's Rights in the Digital Environment, developed with UNICEF Croatia (page 114).

Privacy follows the GDPR and the HT Customer Privacy Policy: data is collected from customers with consent, stored for set periods and not sold (page 114). Digital inclusion sits in the Sustainability Strategy, the DE&I Policy and the Group Policy on Corporate Responsibility (page 115). Advertising follows the Croatian communications agencies' code, and the Group holds ISO 9001:2015 and ISO 27001:2017 certificates (page 115).

Taking action on material impacts on consumers and end-users

Reference: pages 116-119.

Customer experience: the Customer Centricity program, NPS analysis, training for all employees and workshops on survey results (page 116). Privacy: system checks, a full audit of sales partners against GDPR, ISO/IEC 27001 and ISO 22301 recertification, and a privacy and security assessment for every new system or project, with privacy and data protection impact assessments for high-risk cases (pages 116-117).

Children: the "Tools for Modern Times" program has reached 219 primary schools, with 60 new schools in 2025 (page 117). HT also launched the "Bye-Bye Hate Speech" and "OwnYourWorld" campaigns, and the Moj Telekom app lets parents restrict children's internet access (pages 117-118). Access: 99% of the inhabited territory has 4G coverage (2024: 99%) and 5G reaches 85% of the population (2024: 69%). Seven grant-backed projects cover 54 thousand customer units (page 118). The "You Can Do AI Too" program trained more than 120,000 people (page 119).

Targets related to consumers and end-users

Reference: page 119.

The targets concern network build-out in rural areas: 25% 5G coverage of the total rural area of Croatia by the end of 2025, and 50% by the end of 2027. The Group reached 50% in 2025, meeting the 2027 goal early (page 119). A further target is 95% population coverage with an appropriate 4G or 5G signal in each of 20 defined areas by the end of 2026; 14 areas are done and the other 6 depend on construction permits (page 119). The Group says it has set no other measurable targets tied to its material S4 impacts (page 119). The coverage figures are also reported as Group-specific indicators (page 59).

Business conduct policies and corporate culture

Reference: pages 121-123.

The Code of Conduct sets rules of lawful, ethical behavior, backed by the Supplier Code of Conduct and policies on avoiding corruption and conflicts of interest, benefits and events, engaging consultants and lobbyists, competition, anti-money laundering, supply chain management and digital ethics (page 121). The Group states zero tolerance of bribery and corruption (page 121). Corporate culture rests on six Guiding Principles, used in performance reviews, recruitment and training, with an annual "Living Culture Day" (page 122).

Concerns can go to the Ethics Line, the Compliance Officer, the anonymous SAD! and BKMS systems, or a whistleblower e-mail address (page 122). All employees take online compliance training including anti-corruption; new managers take an in-person workshop and the Management Board repeats it every three years. The Group does not train Supervisory Board members (pages 122-124).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are not a numbered disclosure. G1-3 became a standalone DR only in the 2025/2026 ESRS; this report was prepared under the 2023 ESRS (page 39).

The G1 chapter has no targets section and states no measurable business conduct target (pages 120-124). Effectiveness is tracked in other ways. Independent auditors confirmed in 2025 that the compliance management system prevents and detects corruption-related risks (page 123). A Compliance Risk Assessment is repeated each year and sets the next year's compliance program (page 123). Training coverage is set at 100% for business areas at increased risk (page 124). Every whistleblowing report is reviewed and investigated (page 124).

Incidents of corruption or bribery

Reference: page 124.

No corruption or bribery incidents were recorded in 2025, and there were no convictions or fines for breaching anti-corruption and anti-bribery law (2024: 0 corruption cases recorded) (page 124). The index lists this disclosure as confirmed incidents of corruption or bribery (page 40).