Nordex

(Section ESRS 2 GOV-1, p 95) Nordex SE, a listed onshore wind turbine manufacturer, describes its governing bodies. In the reporting period the Management Board had three executive members and the Supervisory Board had six non-executive members. Employees and other workers are not represented on either board. The Management Board comprised José Luis Blanco (CEO), Dr. Ilya Hartmann (CFO) and Patxi Landa (Chief Sales Officer), all with wind and renewable energy experience. All three are male, so the company does not yet meet its 25% female target for the Management Board set in 2024 for end of 2029. The board works on a principle of shared responsibility, which includes oversight of material sustainability matters, though actual implementation sits with the relevant departments, such as the HSE department for health and safety. The Supervisory Board has four men and two women, meeting its 33% female target for end of 2029, and all members are independent. In 2024 Nordex ran a mandatory CSRD and supply chain due diligence training at its General Management Meeting, attended by the three Management Board members. Patxi Landa resigned effective 22 January 2025, reducing the board to two members.

(Section ESRS 2 GOV-2, p 95) Nordex explains how its governing bodies are informed about sustainability matters. The Director Sustainability provides updates on sustainability-related activities to the Management Board quarterly and on an ad-hoc basis as needed. The Supervisory Board also receives quarterly presentations on sustainability topics from the Director Sustainability. These cover annual reporting, the impacts, risks and opportunities (IROs) identified in the double materiality assessment, and progress on the sustainability strategy. Information on IROs is one of several input sources used when the bodies develop, adjust and oversee the company strategy and decide on major transactions. Material risks from the DMA are integrated into the Enterprise Risk Management tool and become part of the quarterly risk assessment process. During the reporting period, the bodies did not explicitly address individual IROs identified in the DMA. Instead, material IROs were addressed implicitly through the strategies, policies and targets set for the company's functions, in alignment with the corporate strategy that was set and approved by the management and supervisory bodies.

(Section ESRS 2 GOV-3, p 96) Nordex describes how sustainability is built into Management Board pay. The Supervisory Board sets the remuneration system, supported by the Executive Committee acting as Personnel and Nominations Committee. The current system was approved with a 99.37% majority at the 2021 Annual General Meeting. Pay has fixed and variable components. Variable pay includes a short-term bonus and a long-term Performance Share Unit Plan (PSUP). The PSUP is 80% weighted to Nordex share performance against the capital market, with the remaining 20% tied to ESG targets: achieving 25% women at management levels M1 to M4 and reducing Scope 1 and Scope 2 GHG emissions, both derived from the sustainability strategy. In addition, a non-financial bonus criterion applies to CEO José Luis Blanco with a 5% weighting, linked to occupational safety, health and environmental protection, specifically lost-time incident frequency. The bonus depends on a financial corporate target (EBITDA, EBIT or EBT) and individual performance criteria, which can include occupational safety and health or other ESG targets. Further detail is in the Remuneration Report.

(Section ESRS 2 GOV-4, p 97) Nordex provides a statement on due diligence, saying it is committed to rigorous due diligence processes for responsible and ethical business practices. The disclosure consists mainly of a mapping table that shows where the core elements of due diligence set out in ESRS 1 Chapter 4 are addressed across the sustainability statement. The table links each element to the relevant sections. Embedding due diligence in governance, strategy and business model is covered in GOV-1 and 2 and SBM-1. Engaging with affected stakeholders is covered in SBM-2, S1-2, S1-3, S2-2, S2-3, S3 and G1. Identifying and assessing negative impacts on people and the environment is covered in IRO-1 and SBM-3. Taking action to address negative impacts maps to sections such as E1-3, E2-2, E3-2, E4-3, E5-2, S1-4, S2-4 and S3-4. Tracking the effectiveness of these efforts maps to numerous sections including the E1 to E5 metrics and targets, many S1 disclosures and G1-6. The purpose is to help stakeholders locate the due diligence information throughout the document.

(Section ESRS 2 GOV-5, p 98) Nordex describes risk management and internal controls over sustainability reporting. Reporting is overseen by the Sustainability Team, led by the Director Sustainability, who reports directly to the CFO. The team includes subject-matter experts in areas such as climate, human rights and technical sustainability, and works with departments including QHSE, Sourcing, Compliance, Product Strategy, Engineering and People & Culture. A cross-company Global Sustainability Network with members from 18 functions meets quarterly and helped validate the DMA outcome. Risks such as data inaccuracies, regulatory changes and resource constraints are identified through ongoing monitoring and prioritized by their impact on report reliability. Internal controls include standardized data validation processes, a disclosure management platform and an environmental data management system, integrated approver roles, the four-eyes principle and regular training. To manage regulatory change risk, Nordex participates in bodies like VDMA and WindEurope and stays close to its auditors. It faced severe resource constraints from CSRD demands and invested in additional staff. Because internal proxies were mainly used to represent external stakeholders in the DMA, there is a risk of misrepresentation, which the company considers limited. Findings are not reported to the boards regularly, but significant issues are escalated.

(Section ESRS 2 SBM-1, p 102) Nordex describes its strategy, business model and value chain. Its mission is to support the transition to renewable energy through efficient wind turbines, directly linked to its material positive impact of enabling low- or zero-carbon electricity. The sustainability strategy, developed in 2021 and approved by the Management Board, is built on the ESG framework with sustainable products at its core, covering sustainable products, environment, social matters and governance. The business model focuses on the development, production and installation of complete onshore wind turbine systems, globally excluding China and India, with the head office in Hamburg. Nacelles and hubs are assembled in-house; rotor blades are developed in-house and partly produced by contractors; components such as gearboxes, generators and inverters are procured from external suppliers; and towers are made as steel or steel-concrete hybrid constructions. The Delta4000 portfolio has eight product types in the 4 MW, 5 MW and 6 MW+ classes. Customers are mainly wind farm developers and operators, utilities, independent power producers and financial investors. The Group employs 10,405 employees. Total 2024 sales were EUR 7,298,825 thousand, split between the Projects segment (EUR 6,543,146 thousand) and Service segment (EUR 776,598 thousand). Nordex has also entered the green hydrogen market through two joint ventures.

(Section ESRS 2 SBM-2, p 105) Nordex explains how stakeholder interests and views inform its strategy and business model. It presents a table of key stakeholder groups and engagement channels. Shareholders, investors and analysts are engaged through conferences and calls; customers and suppliers through ongoing collaboration, fairs and calls; Nordex employees through the internal website, news and action days, e-onboarding and Welcome Days and the Global Sustainability Network; and Nordex management through monthly presentations and workshops. Regulatory bodies and media are covered through desktop analysis, science and research through studies and partnerships, and associations through working groups. The purpose of engagement is to keep communication open, identify risks and opportunities, and ensure stakeholder interests and views inform strategy and the business model, with feedback incorporated into strategic planning and operational decisions. Nordex notes that, as described in IRO-1, the interests of affected stakeholder groups were taken into account when assessing IROs in the double materiality assessment. The Management Board and the Supervisory Board were informed about the DMA results, which also include the perspective of affected stakeholders.

(Section ESRS 2 SBM-3, p 108) Based on its double materiality assessment, Nordex identified and assessed 166 material IROs across its own operations and upstream and downstream value chain. As a result, it assessed all ESRS topics except S4 Consumers and end-users as material and covers them in the statement. A table maps negative impacts, positive impacts, risks and opportunities for E1 Climate change, E2 Pollution, E3 Water and marine resources, E4 Biodiversity and ecosystems, E5 Circular economy, S1 Own workforce, S2 Workers in the value chain, S3 Affected communities and G1 Business conduct. Nordex identified no material risks or opportunities currently affecting its financial position, performance or cash flows, nor any posing a significant risk of material adjustment to assets and liabilities in the next annual period. It then describes implications for its business model and strategy across environmental, social and governance dimensions. On the environmental side it notes that in 2024 its installed total output of 57 GW worldwide avoided approximately 81.01 million tons of CO2e, its material positive impact, while it works to reduce material impacts and risks and capture opportunities in the green energy transition.

(Section ESRS 2 IRO-1, p 106) Nordex describes the process used to identify and assess material impacts, risks and opportunities. It conducted a double materiality assessment in 2024 covering IROs from its own operations and the upstream and downstream value chain, considering both the inside-out impact perspective and the outside-in financial perspective. A four-step approach was used. Step 1 scoping covered all Nordex subsidiaries, including those outside the consolidated financial statements, across short-, medium- and long-term horizons. Step 2 pre-assessment used a hybrid bottom-up and top-down method: the Sustainability team built a long list from prior reports, stakeholder requests, media, policy and scientific papers, mapped to ESRS 1 AR 16, and internal subject-matter experts and internal proxies for stakeholder groups pre-assessed it. Step 3 actual assessment used workshops and follow-up assessments. Impact materiality used a five-point scale for scale, scope and irremediability, with a threshold of 3.5. Financial materiality used a five-point scale with a threshold of 1 mEUR based on gross EBITDA impact, integrated into the ERM process. Step 4 consolidated and validated results through the Sustainability team, the Global Sustainability Network and internal proxies, with sign-off by the Management Board and the Supervisory Board's Audit Committee.

(Section ESRS 2 IRO-2, p 110) Nordex provides the list of disclosure requirements covered in its sustainability statement. This takes the form of a content index that lists each ESRS disclosure requirement addressed, with its description and page reference. The index covers the ESRS 2 General Disclosures, including BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1 and IRO-2, and then runs through the topical standards that were assessed as material. These include E1 Climate Change (with its own SBM-3 and IRO-1 entries and disclosures E1-1 to E1-8), E2 Pollution, E3 Water and Marine Resources, E4 Biodiversity and Ecosystems, E5 Circular Economy, the social standards S1 Own workforce, S2 Workers in the value chain and S3 Affected communities, and G1 Business conduct. Consistent with the materiality outcome, S4 Consumers and end-users is not included. The index is intended to give readers an overview of which disclosure requirements are covered and where to find them in the statement.

(Section ESRS E1-1, p 129-130) The Nordex Group does not yet have a finalized climate transition plan but states it is actively working towards developing one. In the meantime the Company pursues its sustainability strategy, which includes various climate-related targets under the focus topic "Climate Change & Decarbonization" and aims to align its business activities with the 1.5 degree Celsius target ambition by 2050 at the latest. Reporting voluntarily in line with the CSRD from 2024 onwards, the Group decided to first focus on implementing ESRS-compliant reporting and identifying remaining gaps that are elemental for finalizing the transition plan. Based on these findings, the GHG emission reduction targets defined in the reporting year, and the initiatives currently underway, the Group plans to complete the definition of the transition plan in 2025, with adoption expected in 2026. The Management Board and Supervisory Board will be consulted throughout development and will provide final approval of identified measures and milestones.

(Section ESRS E1-2, p 124-125) The Group's climate policies are derived from its globally applicable Sustainability Strategy. Its Green Electricity Policy, published in 2023, commits the Company to exclusively using green electricity for its operations, directly reducing Scope 2 emissions, and covers monitoring and reporting of energy consumption and emissions. It also commits to renewable energy deployment through solar and wind investments, encourages suppliers to use green electricity, and includes employee education. The Management Board is responsible for procuring 100% green electricity, with local plant management, Corporate Real Estate Management, and the Sourcing Board handling purchasing, and the global Sustainability department overseeing implementation. Car policies also apply: the German Company Car Guideline promotes hybrid and battery electric vehicles and sets a CO2 limit for conventional cars, and the French and Belgian Car Policy was adjusted in 2024 to exclude diesel cars and support wall box installation. The Group does not address climate change adaptation with a specific policy, focusing instead on areas of direct influence.

(Section ESRS E1-3, p 125-127) Nordex groups its climate actions by GHG emission category. For Scopes 1 and 2 it targets emissions from stationary equipment/heating and the corporate vehicle fleet through three focus areas: low-carbon energy consumption (green electricity contracts secured for three of four major offices in Spain, and in Q3 and Q4 2024 for blade, drive train, and nacelle facilities in India), energy efficiency in buildings (luminosity sensors, air curtains, LED outdoor lighting, and a preliminary photovoltaic study in Spain), and behavioral change (an energy management program and energy meters rolled out across production facilities in 2024). For Scope 3, a high-level action plan developed in 2022 was followed by 2024 workshops on blades and towers; measures include recycled PET foam in blades, project-specific green steel, SF6-free switchgear, higher-capacity commuter buses in India, and sustainable aviation fuel contracts. The Group states the action plans are in their initial stages, with no quantifiable emission reductions yet and no directly attributable CapEx or OpEx amounts.

(Section ESRS E1-4, p 128-129) Nordex set SBTi-validated GHG reduction targets using a 2022 base year, submitted at the end of 2023 and officially validated by the SBTi in July 2024, following a cross-sector absolute contraction approach. The near-term target commits to reducing absolute Scope 1 and 2 GHG emissions by 42% by 2030 (Scopes 1 and 2 combined, market-based approach) and reducing absolute Scope 3 emissions by 25% by 2030. According to the SBTi, the near-term Scope 1 and 2 target follows the 1.5 degree Celsius ambition while the near-term Scope 3 target follows the well-below 2 degrees ambition. The long-term target is to reduce absolute Scope 1, 2, and 3 emissions by 90% by 2050 from the 2022 base year, aligned with 1.5 degrees. The Group also commits to net-zero GHG emissions across the value chain by 2050. Targets exclude carbon credits and avoided emissions. A supplier engagement target to encourage suppliers to set their own science-based targets is planned to be finalized in the first half of 2025. Targets were validated by the SBTi but not externally assured.

(Section ESRS E1-5, p 130-131) In 2024 the Nordex Group's total energy consumption was 272,395 MWh. Fossil energy consumption totaled 219,194 MWh, or 80.47% of the total, comprising fuel from crude oil and petroleum products (193,647 MWh), natural gas (22,504 MWh), and purchased electricity, heat, steam, and cooling from fossil sources (3,043 MWh); consumption from coal and other fossil sources was zero. Consumption from nuclear sources was zero. Total renewable energy consumption was 53,201 MWh, or 19.53% of the total, made up of renewable fuel including biomass (154 MWh) and purchased renewable electricity, heat, steam, and cooling (53,047 MWh). Because the Group's activities fall within high climate impact sectors under NACE Section C (38.13), it reports an energy intensity of 37 MWh per EUR million of net revenue from activities in high climate impact sectors for 2024.

(Section ESRS E1-6, p 131-134) In 2024 the Group's total GHG emissions across Scopes 1, 2, and 3 were 4,732,673 t CO2e (location-based) and 4,704,408 t CO2e (market-based), a decrease of 7.36% from 2023 (5,078,054 t CO2e market-based). Scope 3 accounted for about 99% of the total. Gross Scope 1 emissions were 53,007 t CO2e (2023: 66,433), of which 13.01% (6,895 t CO2) were regulated under the EU ETS from maritime activities. Scope 2 emissions were 28,670 t CO2e location-based and 405 t CO2e market-based (2023: 27,267 and 584), a 30.65% market-based reduction driven by lower purchased heating. Total Scope 1 and 2 emissions were 53,412 t CO2e, a 20.30% decrease from the base year. Gross Scope 3 emissions totaled 4,650,996 t CO2e, down 7.24% from 2023 (5,011,037), with purchased goods and services the largest category at 75.47%. GHG intensity was 645 t CO2e per EUR million (market-based) on net revenue of EUR 7,299 million. Emissions were calculated per the GHG Protocol covering 13 of 15 Scope 3 categories. 2023 data was not part of the KPMG audit.

(Section ESRS E1-7, p 137) Within its "Climate Change and Decarbonization" focus topic the Group set a goal of achieving climate neutrality for Scopes 1 and 2 emissions by 2023, compensating for GHG emissions from its direct business activities through the purchase of voluntary carbon credits. The Group is in the process of purchasing verified carbon credits to compensate for its 2024 Scope 1 and 2 emissions, sourced from accredited projects certified under recognized standards. Carbon credits retired in the reporting year for 2023 Scope 1 and 2 emissions totaled 66,675 t CO2e, all from reduction projects (100%) and none from removal projects (0%), all certified to the VERRA quality standard, with none within the EU and none considered corresponding adjustments. Credits planned to be cancelled by 2025 for 2024 emissions total 53,412 t CO2e. The Group states this compensation is voluntary, is not a dependency or requirement for its reduction targets and is not an offset for disclosed emissions, and that it prioritizes direct emission reductions. The Group also reports an entity-specific Scope 4 metric of approximately 81 Mt CO2e emissions avoided in 2024 through its wind turbines.

(Section ESRS E1-8, p 137) The Nordex Group states that it does not apply internal carbon pricing schemes so far.

(Section ESRS E2-1, p 140) The Nordex Group integrates its commitment to pollution prevention into its Quality, Health, Safety and Environmental Protection (QHSE) policy, which applies globally across the development, sales, production, supply, installation and service of wind turbines and wind farms. The CEO holds the highest level of accountability for implementing the QHSE policy, which is publicly available. This policy addresses pollution to air and pollution to water. A global Hazardous Materials Corporate Guideline governs the responsible use of substances and ensures compliance with international and national regulations while minimizing risks to the workforce and environment. It includes a "Black and Grey List" to identify substances of concern and substances of very high concern based on their potentially harmful properties. Nordex assesses each chemical in use, drawing on Safety Data Sheets to flag hazardous materials on the list and puts action plans in place based on a hierarchy. Local organizations adapt the guidelines to national regulations, conducting risk assessments for handling, storage, use and disposal. As an EU-headquartered company, Nordex must comply with the EU Taxonomy Regulation on the global use of chemicals and demonstrate that operations meet Do No Serious Harm criteria.

(Section ESRS E2-2, p 141) The Nordex Group's actions aim to reduce air pollutants and the use of substances of concern (SoC) and substances of very high concern (SVHC) and to find better substitutions. During the reporting year the Group implemented formal company-wide processes for evaluating and implementing hazardous materials. It successfully substituted one of the most prevalent blacklist materials used in Project Management and Service, updated its bill of materials, and removed these materials from operations, addressing substances of concern. Working with suppliers, it re-classified one material so that it is no longer considered blacklisted. The Engineering and Industrialization teams continue to substitute other blacklist materials, with monthly progress tracking reviews in place, relevant to both SoC and SVHC. To improve air quality, the Group developed and implemented product-specific, global, cross-site and local action plans to reduce volatile organic compound (VOC) emissions in blade production. This action addresses pollution to air and is of special relevance in Lumbier because of local regulations.

(Section ESRS E2-3, p 142) The Nordex Group has set pollution-related targets to guide its environmental performance. The first target is to reduce hazardous materials and minimize their hazard potential; the Group continuously seeks to eliminate hazardous materials and reduce both their total number and their hazard levels. A working group with representatives from all divisions and production areas meets at least monthly to steer the project, and the reduction in blacklisted materials is a KPI for all areas, though it does not depend on defined, quantified goals. This target addresses substances of concern and substances of very high concern. The second target is air quality improvement: developing and implementing product-specific, global, cross-site and local action plans to reduce VOC emissions in blade production by 5% per produced MW. The Spanish blade factory has completed all planned adjustments in line with local legal limits, while the Indian blade factory plans to analyze how to implement such ambitions in coming years. The targets align with the QHSE policy and the Hazardous Materials Corporate Guideline. Progress will be monitored annually and disclosed per ESRS 2 MDR-T.

(Section ESRS E2-4, p 142) The Nordex Group analyzed the amounts of pollutants listed in Annex II of the E-PRTR Regulation (Regulation (EC) No 166/2006) emitted to air, water and soil, excluding GHG emissions reported under ESRS E1. For products, Nordex followed a systematic approach covering material selection, bill of materials analysis, substance assessment, usage and risk assessment, and volume comparison against E-PRTR thresholds, conservatively using the highest estimates from Safety Data Sheets. The product-based analysis found that potential emissions did not exceed the thresholds for air, water and soil, so no reporting requirement was triggered. A third party then assessed pollution from own operations, including production sites, offices and logistics. Most pollutants posed no risk of exceeding limits, except nitrogen oxides (NOx/NO2) and particulate matter (PM10) from fossil fuel use. Own transportation via vessel generated 906.3 tonnes of NOx/NO2 and 64.5 tonnes of PM10, which exceeds the thresholds; this data was provided by the ship owner(s). No spills have been reported from the vessel. VOC emissions in blade production were quantified at 154.9 tonnes in 2024. An initial analysis revealed no effects on water pollution; the potential impact of ship paint on water is to be investigated in 2025.

(Section ESRS E2-5, p 144) The Hazardous Materials Corporate Guideline sets out Nordex's approach to using substances responsibly so as not to endanger employees, other stakeholders or the environment. The company created an internal "Black and Grey list" based on criteria defined in various regulations, including REACH and RoHS. Nordex prioritizes the substitution and minimization of substances of concern (SoC) and actively phases out those classified as substances of very high concern (SVHC), particularly in non-essential societal applications and consumer products. New hazardous materials are evaluated before being incorporated into product design, and suppliers based outside the EU are asked to provide information consistent with EU Safety Data Sheets. Nordex reports on its global operations under EU Taxonomy rules and sets KPIs focused on eliminating risk from items on the Black and Grey lists. The classification of SoC was based on analysis of safety data sheets and screening of all substances against the ECHA Candidate List of substances of very high concern. In 2024, SoC amounted to 2603.1 tonnes; the SVHC figure is reported as N/A.

(Section ESRS E3-1, p 146) The Nordex Group has policies addressing the identified material risk of operational disruptions due to water scarcity, tackling the issue by reducing corporate water use in affected regions and by lowering reliance on water availability for production, sanitary and irrigation purposes. The QHSE Policy underscores the sustainable use of natural resources such as fresh water and applies globally; it is publicly available on the Group's website. As the QHSE Policy is a foundational document, it does not address specific matters such as water management. The HSE Corporate Manual sets global minimum HSE requirements, ensuring activities do not negatively impact community livelihoods, particularly in areas of high or extremely high water stress; the CEO holds highest accountability for its implementation. For all wind farm project sites, Project Health, Safety and Environment Plans require environmental management plans, with a globally applicable mandatory instruction introduced in late 2024, covering water management and protection of surface and underground water. During the reporting year, 158 Group locations were in regions of very high water stress, mostly small offices and service points; among production sites and larger offices, only those in India were in such areas, and these do not consume water as all withdrawn water is treated on-site and returned to the water cycle for irrigation. The material impact of high water consumption for materials in the value chain is not yet covered by policies.

(Section ESRS E3-2, p 147) Dedicated to increasing water efficiency, especially in high-water-stress areas, the Nordex Group has focused on initiatives at its Indian production sites, where most water is used for irrigation as required by local law or for sanitary purposes. All Indian sites have on-site sewage treatment plants allowing used water to be treated and reused for irrigation, reducing freshwater demand. In the reporting year this was complemented by installing sprinkler systems at the Indian nacelle production site to further reduce freshwater use for irrigation by up to 30%. Measures to reduce sanitary water use are continually implemented, such as modifications to flushing systems at the blade production plant in 2024 and spray nozzles on hand wash basins in 2025. The rotor blades factory in India hired a hydrologist to identify rainwater use initiatives while minimizing groundwater use. The concrete tower factory in Brazil, the only production area with material water consumption, installed a concrete vibrator system that separates aggregates, sand and stones from water so the water can be repurposed for cleaning, laboratory tasks and wetting the external field to prevent dust. Actions addressing the material impact of high water consumption for materials in the value chain have not been developed so far.

(Section ESRS E3-3, p 148) Within its sustainability strategy, the focus topic "Environmental Protection" includes a voluntary target to increase water efficiency, defined as water withdrawal relative to installed capacity (MW), aligned with Sustainable Development Goal 6 "Clean Water and Sanitation". This target and related measures were developed with internal and external experts via interviews, stakeholder roundtables, an online employee survey and two management workshops. The target addresses water withdrawals at production sites and main offices relative to installed capacity, aiming for a significantly reduced group-wide water intake per installed MW by 2025 compared to the 2021 base year; it does not set a defined target level beyond the aim of a significant reduction. In the reporting year, more water per installed capacity was withdrawn at the locations in scope (22.2 m3/MW) than in the base year 2021 (14.8 m3/MW). A further target aims to expand rainwater collection globally by adopting cisterns or rainwater harvesting pits by 2025, based on 1% in 2021; in the reporting year the share of rainwater, reported as surface water, remained unchanged at around 1% of water demand. Neither target includes a defined target level beyond the aim of significant improvement. Targets addressing the material impact of high water consumption for materials in the value chain have not been developed so far.

(Section ESRS E3-4, p 149) The Nordex Group reports its water consumption and withdrawal for 2024. Total water consumption was 4,026 m3, with 0 m3 consumed in areas at water risk including areas of high-water stress. Total water withdrawals were 165,265 m3 and total water discharges were 143,594 m3. Total water recycled and reused was 28,600 m3, and total water stored was 808 m3, while total surface water usage was 1,252 m3. The Group's water withdrawal consists entirely of freshwater regardless of the initial source. A site-specific approach is used for data collection, with primary data gathered at least quarterly from production sites and main offices through direct measurements, meter readings and invoices reported by local HSE or facility managers via a global environmental reporting platform; for smaller locations water use is extrapolated based on staff numbers. Water is stored only at the Indian production sites (waste water held for on-site treatment) and at the German headquarters (rainwater collected for toilet flushing). On water intensity, total water consumption per net revenue was 0.55 m3/EUR million, total water withdrawal per net revenue was 22.64 m3/EUR million, total water withdrawal per installed capacity was 24.89 m3/MW, and total water withdrawal within the sustainability strategy scope per installed capacity was 22.20 m3/MW.

(Section ESRS E4-1, p 151) The Nordex Group states that its onshore wind solutions can help mitigate climate change, one of the main drivers of biodiversity loss, by enabling low- or zero-carbon electricity. It cites the Kunming-Montreal Global Biodiversity Framework and the Paris Agreement as orientation for future resilience analysis and a related transition plan. As an original equipment manufacturer, its operations do not heavily rely on biodiversity services such as those needed in agriculture or forestry, so the immediate impact of biodiversity and ecosystem change on core business is described as relatively limited. Given this, the Group has not yet performed a detailed resilience analysis on biodiversity and ecosystems, but says it remains committed to monitoring its environmental impact and is considering conducting such an analysis as part of ongoing sustainability efforts. It notes that biodiversity became a material topic only during this reporting year.

(Section ESRS E4-2, p 152) Because biodiversity became a material topic only during the course of this reporting year, the Nordex Group states that it does not yet have any policies related to the material sustainability matters identified for biodiversity and ecosystems.

(Section ESRS E4-3, p 152) The Nordex Group differentiates between biodiversity actions taken from a product portfolio (downstream) perspective and actions in its own operations, all addressing the direct impact drivers of biodiversity loss; actions relating to impacts and dependencies on ecosystem services are not yet developed. On the product side it is developing bird-friendly turbine technologies, including a universal communication interface that processes signals from third-party bird detection systems and slows the rotor when a protected species is detected, with sales release and global roll-out planned for 2025. In operations, colleagues at the rotor blade production facility in India planted 1,000 tree saplings for World Environment Day 2024 (donated by the Tamilnadu Forest Department). The Group is developing a climate transition plan by 2026, expected to influence biodiversity performance. It reports no significant directly attributable CapEx or OpEx for these initiatives and has not used biodiversity offsets or incorporated local and indigenous knowledge.

(Section ESRS E4-4, p 153) The Nordex Group states that it has yet to define specific targets related to biodiversity and ecosystems. As it continues to advance its understanding of biodiversity and ecosystems, it is considering setting specific targets in the future to ensure its operations contribute positively to the environment.

(Section ESRS E4-5, p 153) The Nordex Group analyzed its more than 500 operational sites (production sites, offices, and service points) plus all project sites active in the reporting year. It found 87 operational sites and 83 project sites (wind farms under construction) located near protected areas defined by the World Database of Protected Areas (WDPA) or Key Biodiversity Areas. The affected operational sites account for 3.53 hectares and the project sites cover 1,037.84 hectares. Vicinity follows Integrated Biodiversity Assessment Tool (IBAT) criteria, using 0.5km for offices, warehouses and production sites and 1.0km for onshore wind project sites. The IBAT analysis showed no own-operations production sites within the 0.5km buffer of a key biodiversity or protected area. The Group identified no material negative impacts on land degradation, desertification or soil sealing, and is not aware of negative impacts on species from its production sites. It aims to carry out a more detailed analysis of potential negative impacts on biodiversity-sensitive areas in 2025.

(Section ESRS E5-1, p 155) The Nordex Group states that most identified resource-use and circular-economy IROs relate to the materials used in its products, with positive impacts from transitioning to recycled or bio-based materials and negative impacts mainly upstream, particularly environmental damage from producing and mining key materials such as steel. The sustainability department has allocated dedicated resources, and Nordex uses life cycle assessments per ISO 14040/44 to evaluate turbine environmental performance and as a basis for resource inflow calculations. The Group has not yet formalized a specific circularity policy, but its sustainability strategy underscores commitment to sustainable resource management, waste reduction, and circular economy principles. For the upstream negative impact tied to critical raw materials and related hazardous waste, there are no specific policies, metrics, or targets yet, as the strategy focused on own operations. The Code of Conduct for contractors and suppliers sets values based on compliance, integrity, and ethical behavior and covers conflict minerals.

(Section ESRS E5-2, p 155) During turbine design, the Nordex Group prioritizes modular components where feasible and economically viable to ease material handling, maintenance, and end-of-life disassembly, reducing virgin material use and greenhouse gas emissions. It began analyzing the use of secondary materials in turbines in 2024 as a starting point for improvement, and focuses on extending the lifetime of turbines and components through repair and refurbishment in Service. It has developed measures to increase reuse and recycling of waste during production and at end of life, with a key focus on fully recyclable rotor blades to avoid landfill and close material loops, and participates in projects such as RenerCycle and RE SORT to develop sustainable rotor-blade recycling technologies by providing blade material for testing and expert knowledge. Local action plans are being developed to eliminate landfill waste at production sites, and an SVHC substitution plan will be implemented next year. The Group reports no directly attributable CapEx or OpEx for these action plans.

(Section ESRS E5-3, p 156) The Nordex Group's circular-economy targets were developed through a materiality assessment with input from a stakeholder roundtable, and its main targets are valid globally and voluntary. Its targets are: fully recyclable rotor blades by 2032 (pursued through R&D and recycling partnerships, with no linear path so the status quo cannot yet be measured); reducing hazardous materials and minimizing their hazard potential throughout production (achievement not yet measurable); zero production waste to landfill by 2025 via local action plans (not achieved in the reporting year); decreasing the carbon footprint of turbines by 25% by 2025 to below 4.9g CO2e/kWh from a 6.5g CO2e/kWh baseline (accomplished, and extending an N163/5.X turbine from 25 to 35 years can cut the specific footprint by 28%); and increasing the waste recovery rate by five percentage points by 2025 from 55% (2021 baseline) to 60%, which reached only 41% and was not achieved. The Group applies the waste hierarchy, prioritizing prevention.

(Section ESRS E5-4, p 158) The Nordex Group reports total resource inflows of 1,367,695 tonnes for 2024, covering wind turbines and the service segment. By material (in tonnes): steel and iron 715,481; concrete 451,624; glass and carbon fiber composites 124,605; plastics 22,230; inbound packaging 22,589; service materials 11,683; other materials 9,205; copper 4,562; aluminium 3,895; operating fluids 1,822. Turbine production covers blades, nacelles (including hubs and drivetrains) and towers, broken down to material level, and only Nordex-installed foundations are included. The only bio-based material is balsa wood used in some rotor blades; 100% is sustainably sourced with FSC certification, though Nordex is working to phase out balsa wood over deforestation concerns. In 2024, sustainably sourced biological materials were 0.28% of all resource inflows. Using industry-average datasets from the LCA software "LCA for experts" by Sphera and assuming 0% recycled content for other material groups, the Group used 121,411 tonnes of recycled content, or 8.88% of total materials used.

(Section ESRS E5-5, p 159) The Nordex Group defines its resource outflows across nacelles, hubs, drivetrains, blades, towers, foundations, outbound packaging, and service materials, with component net weights taken from LCAs and multiplied by 2024 production output; waste is not counted separately. Service materials use the same amounts as resource inflows, and outbound packaging uses multi-way steel frames as load carriers. Because inbound and outbound packaging differ, the resource balance is not fully closed, but excluding packaging would make resource inflows equal resource outflows. Product durability is assessed at the wind-farm level, with an industry-average life of 20 years extendable by 10 or 15 years to a total of 30 or up to 35. Based on an assessment by recycling company Neowa applying DIN SPEC 4866, overall turbine recyclability is around 97%, with main waste streams being GFRP, CFRP, concrete and steel recycled via state-of-the-art routes (thermal recovery not counted as recycling). Service materials were assumed 0% recyclable due to lack of data. Overall outbound packaging recyclability is 0% (multi-way steel frames are 100% reused and about 58.78% of wooden packaging is reusable, but neither counts as recyclable under the standard), while the multi-way share of outbound packaging is around 71%.

(Section ESRS E5-5 Waste, p 161) The Nordex Group generated 21,578 tonnes of total waste from own operations in 2024, of which 8,073 tonnes were hazardous and 0 tonnes radioactive; the share of non-recycled waste was 59%. Of waste diverted from disposal, hazardous waste totaled 547 tonnes (441 preparation for reuse, 106 recycling) and non-hazardous 8,215 tonnes (2,142 reuse, 5,669 recycling, 404 other recovery). Of waste directed to disposal, hazardous waste totaled 7,525 tonnes (7,198 incineration, 327 landfill) and non-hazardous 5,291 tonnes (2,125 incineration, 3,147 landfill, 19 other), for 12,816 tonnes disposed overall. Primary waste streams are composite waste from rotor blade production, wooden packaging waste from nacelle assembly, and concrete waste from tower production, managed under standards including ISO 14001:2015, the WEEE Directive (2012/19/EU) and the Batteries Directive (2006/66/EC). By mass, waste composition is roughly 27.26% composite materials, 24.14% industrial waste, 17.85% wood, 8.78% concrete, 5.91% contaminated materials, 5.81% paper, 4.19% metals, 1.61% fat, 1.51% plastics, 1.38% dust and small particles, 1.33% bulky waste, 0.21% mixed packaging, and 0.03% glass, covering 99% of production waste. Rotor-blade recycling is pursued through the RenerCycle and RE SORT projects. Waste data is drawn from environmental management software using site-specific quarterly primary data from weighing notes and treatment invoices.

(Section ESRS S1-1, p 181) Nordex reports policies addressing material impacts, risks and opportunities related to its own workforce. The Human Rights Policy applies to the whole workforce and is publicly available, covering modern slavery, forced labor, child labor, discrimination, fair wages, working conditions, health and safety, and freedom of association, with due diligence and grievance mechanisms for monitoring. It applies across the Nordex Group and value chain in all geographies, covering employees, customers, suppliers, shareholders and communities with no exclusions. The Board is accountable for implementation, and the policy commits to the UN Guiding Principles on Business and Human Rights, the UN Universal Declaration of Human Rights, the ILO core labor standards, the OECD Guidelines and the UN Global Compact. Additional policies include a German Supply Chain Act (GSCA) Policy Statement, a global accident management system, a Diversity and Inclusion Policy (with a D&I Council overseen by the CEO and Chief People Officer) covering discrimination on grounds such as gender, age, ethnicity, disability and religion, and a Compensation and Benefits Policy.

(Section ESRS S1-2, p 183) Nordex describes its processes for engaging with its own workforce and workers' representatives about actual and potential material impacts. Engagement occurs at multiple stages through regular consultations, feedback sessions, surveys, direct dialogues and participation in Safety Committees, with some engagement quarterly (such as the Compass development process) and other engagement ongoing (such as safety inspections). Operational responsibility lies with the People and Culture department led by the Chief People Officer, the most senior position responsible for engagement. In Germany employee interests are protected by collective bargaining agreements and works agreements, and works councils hold information, consultation and co-determination rights. The European Works Council (the SE Forum) represents employees across Europe and meets senior management at least twice a year, and local works council committees exist in countries such as France, Sweden and Finland. Nordex reports no known cases of employees' rights of association or collective bargaining being breached during the reporting period. To understand vulnerable and marginalized groups, Nordex uses targeted D&I programs, specific training and mentoring schemes and regular feedback mechanisms.

(Section ESRS S1-3, p 184) Nordex describes processes to remediate negative impacts and channels for its own workforce to raise concerns. The company states it does not tolerate abuse of human rights and is committed to effective remedies through company-based grievance mechanisms. When it identifies that it has caused or contributed to a material negative impact, it runs a due diligence process involving assessing the impact, engaging with affected individuals and implementing remedial actions, with follow-up evaluations and feedback from impacted individuals to assess effectiveness. The main channel is the 'notify!' whistleblower system, through which grievances and complaints from the own workforce and externals are handled, communicated via physical and online campaigns and e-learnings. Internal controls and due diligence use Human Rights questionnaires and GSCA questionnaires reaffirmed annually by local People and Culture managers. Further detail on tracking, monitoring, effectiveness and protection from retaliation is provided in the G1-1 business conduct section.

(Section ESRS S1-4, p 185) Nordex describes actions on material negative and positive impacts, risks and opportunities, structured by the sub-topics working conditions, equal treatment and opportunities for all, and other work-related rights. On working conditions it covers employee representation and social dialogue, work-life balance (flexible working time and remote working options), and health and safety, where identified actions include a monthly HSE newsletter, Safety Stand Downs and Lessons Learned, a three-level Safety Notifications Process, Safety Walk and Talks with mandatory Safety First Leadership Training, near-miss reporting, supplier and subcontractor audits, Occupational Safety Committees in each country, and GWO-based training programs. Nordex targets an LTIF below 1.5 by 2025 and holds ISO 45001:2018 certification and RoSPA recognition. On equal treatment it describes the Trust.Listen.Lead. leadership development programs, the annual Compass performance dialogue process, the Upwind management talent program, D&I actions including an inclusion agreement for employees with disabilities since 2022, and an employer branding campaign. Nordex notes it has not yet implemented actions on overwork-related well-being or on potential privacy impacts.

(Section ESRS S1-5, p 192) Nordex reports targets to manage material negative impacts, advance positive impacts and manage risks and opportunities, described as specific, time-bound and outcome-oriented and, unless stated otherwise, relating to employees globally. Key targets include reducing the voluntary turnover rate to below 5 percentage points of the market average by 2025 (current rate 6.4% globally, mid-term rate 3.2%, against a market average of 5.1% per Mercer); optimizing talent programs through the Learning Management System and the Trust.Listen.Lead. Advanced Program; achieving a minimum of 25% female representation in management positions by 2025 and maintaining 40% female representation in the strategic talent development program; promoting sustainable commuting and business travel; reducing accidents to a Lost Time Injury Frequency below 1.5 per one million working hours by 2025; developing a mental health strategy; and reducing supply chain accidents through contractor evaluation. Nordex states the workforce was consulted through an employee survey during strategy development but is not directly involved in tracking performance against targets or identifying lessons learned.

(Section ESRS S1-6, p 192) Nordex reports the characteristics of its employees. At the end of 2024 the total global number of employees was 10,405 reported as headcount, comprising 1,782 female and 8,623 male (0 other, 0 not disclosed). Of these, 10,006 were permanent (1,675 female, 8,331 male) and 399 temporary (107 female, 292 male), with no non-guaranteed-hours employees. Employees are broken down by location, with primary areas of operation being Germany (2,801), India (1,302), Spain (2,015), Brazil (644) and the United States (606), among others. During the reporting period 1,587 employees left the company, giving an overall turnover rate of 15.37% and a voluntary turnover rate of 6.43% globally, with a mid-term rate of 3.20%. Data is compiled from a global cloud-based human capital management (HCM) suite. Headcount is reported at the end of the reporting period, and the turnover rate is calculated as terminations divided by the average headcount over the period, differentiating total and voluntary turnover by categorized termination reasons.

(Section ESRS S1-7, p 194) Nordex reports the characteristics of non-employees in its own workforce. Non-employees are defined as individuals working for a Nordex entity without a formal employment contract, such as independent contractors, freelancers and workers provided by third-party agencies. In the reporting year the total number of non-employees in the Nordex own workforce was 2,658. Because there is no central tracking system for non-employees, Nordex gathered the data using two sources: manual collection for production site information and data maintained in its HCM system. Each non-employee is counted as headcount without adjustment for hours worked, and the figure is reported at the end of the reporting period.

(Section ESRS S1-8, p 194) Nordex reports on collective bargaining coverage and social dialogue. Because this information is not held in the HCM system, it was requested manually from the responsible People and Culture departments in each country, covering EEA and non-EEA locations. The percentage of Nordex employees covered by collective bargaining agreements is 83%. Coverage is presented in bands by country for the EEA and by region outside the EEA, alongside workplace representation for EEA countries. Countries in the 80 to 100% coverage band include Austria, Belgium, Denmark, Finland, France, Germany, Italy, Netherlands, Norway, Spain and Sweden within the EEA, and Argentina, Brazil, Chile, China, India, Mexico, Peru, Serbia, Turkiye and Uruguay outside the EEA. Employee representation is framed by the SE Forum (SEF), the equivalent of a European Works Council, which holds extensive information rights exercised through biannual meetings and in response to transnational changes, escalates issues to corporate management including the CEO, CFO, COO and CSO, and whose representatives enjoy special protection against dismissal.

(Section ESRS S1-9, p 195) Nordex reports diversity metrics for gender at top management level and the distribution of employees by age group and gender. At top management level (internal graded Management Levels III and IV) there were 90 employees in 2024, of whom 9 were female (10%) and 81 male (90%), with none recorded as other or not reported. By age group and gender, employees under 30 numbered 282 female and 2,020 male; employees between 30 and 50 numbered 1,287 female and 5,670 male; and employees over 50 numbered 213 female and 933 male, all reported in headcount at the end of 2024. The gender distribution is calculated by dividing the aggregated female or male headcount by total headcount, and the age distribution divides the headcount in each age band (under 30, 30 to 49, and 50 or above) by total headcount.

(Section ESRS S1-10, p 196) Nordex reports on adequate wages. All employees are compensated with wages in accordance with the adequate wage standards set by Directive (EU) 2022/2041 within the EEA. Outside the EEA, adequate wages are based on existing legislation or benchmarks from recognized sources. The directive references values such as 60% of the gross median wage and 50% of the gross average wage, using data from the European Labor Force Survey. Nordex defines the lowest wage as the basic wage plus fixed additional payments, calculated separately for each country, except outside the EEA where it is defined at a sub-national level.

(Section ESRS S1-11, p 196) Nordex reports on social protection coverage against loss of income from major life events. All Nordex Group employees are covered, through public programs or benefits offered by the company, against loss of income due to sickness and retirement. Coverage gaps are disclosed for the remaining events: for unemployment, employees in India, Croatia, Mexico and Pakistan lack social protection (Pakistan 38, India 1,302, Mexico 74, Croatia 12); for employment injury and acquired disability, Australia provides no coverage (42 employees); and for parental leave, Turkiye is the only country without provision for male employees (387 employees). The data on social protection coverage was requested manually from the responsible Human Resources departments in each EEA and non-EEA country.

(Section ESRS S1-12, p 197) Nordex reports on persons with disabilities. It states that 0.74% of its employees are persons with disabilities. The number of employees with disabilities was extracted from the central HCM system and divided by the total number of employees, with figures as of 31 December 2024 and reported in headcount. Nordex notes this disclosure is made while adhering to legal restrictions on data collection, and states its commitment to fostering an inclusive environment and providing equal opportunities for all employees.

(Section ESRS S1-13, p 197) Nordex reports training and skills development metrics, drawn from training records and performance review results (the Compass dialogue) stored centrally in the HCM system. The percentage of employees who participated in performance and career development reviews in 2024 was 68.39% for male and 73.63% for female employees, with figures for other and not reported not disclosed. The average number of training hours per employee in 2024 was 61 for male and 12 for female employees, with figures for other and not reported not disclosed. Training hours are defined as time spent on training and skills development through methods such as on-site training, online courses, workshops, certification programs and educational opportunities, and exclude trainee programs, course development and instructor teaching time. Training hours per employee by gender are calculated by dividing total recorded training hours by the average number of employees in headcount for each gender across 2024.

(Section ESRS S1-14, p 197) Nordex reports health and safety metrics. In 2024, 100% of both employees and non-employees in the own workforce were covered by the health and safety management system based on legal requirements, and 91.71% of the workforce was covered by the audited ISO 45001 management system. Work-related fatalities were 0 for both employees and non-employees. Recordable work-related accidents totalled 132 for employees and 49 for non-employees, giving a total recordable incident rate (TRIR) of 4.18 per million working hours. Recordable work-related ill health cases were 3 for employees and 0 for non-employees. Days lost to work-related injuries and fatalities were 813 for employees and 814 for non-employees. The work-related injury rate (lost time injury frequency, LTIF) per one million hours worked was 1.53 for employees, 1.37 for non-employees and 1.45 in total. All incidents, occupational illnesses, near misses and unsafe conditions are registered in Nordex's incident management system.

(Section ESRS S1-15, p 199) Nordex reports work-life balance metrics on entitlement to and use of family-related leave in a gender-equitable manner. In the reporting year, 96.28% of employees were entitled to take family-related leave, comprising 95.51% of male and 100.00% of female employees. Of entitled employees, the share that actually took family-related leave was 4.17% in total, made up of 4.20% of male and 4.04% of female entitled employees. The information on which employees are entitled to parental leave and the number who actually took it was requested from People and Culture in each country and analyzed by headcount and gender across the full 2024 reporting period. The ratio was calculated by dividing the number of employees who took parental leave by the total number entitled to it.

(Section ESRS S1-16, p 200) Nordex reports remuneration metrics covering the gender pay gap and total remuneration. The unadjusted gender pay gap, expressed as a percentage of male employees' average pay, was 9.73% for white collar, 13.20% for blue collar, 21.96% for managers, and -9.26% for all employees. Without considering grades or job types, female employees earn 9.26% more than male employees overall, but at management level male employees earn 21.96% more than female employees, 9.73% more in white-collar and 13.20% more in blue-collar categories. Nordex explains the negative all-employee figure arises because it has a comparatively small proportion of female employees, predominantly in higher wage groups, while a much higher proportion of male employees are in blue-collar positions in lower wage groups or lower-salary countries. The annual total remuneration ratio of the highest-paid individual to the median for all employees (excluding the highest-paid) is 36.97. All remuneration data was recalculated to Euros and adjusted to a 100% full-time-equivalent basis.

(Section ESRS S1-17, p 200) Nordex reports on incidents, complaints and severe human rights impacts within its workforce, along with related fines, sanctions or compensation. During the reporting period there were 28 cases of discrimination, including harassment, reported, and 118 complaints filed through the company's channels for workforce members. There were no fines, penalties or compensation resulting from the reported incidents and complaints. Complaints were filed through the 'notify!' whistleblower system, which allows employees to safely report suspected misconduct or maladministration. There were no severe human rights incidents connected to the Nordex Group's workforce, and consequently no fines, penalties or compensation for such incidents. Nordex states that all discrimination incidents and complaints are handled through formal channels, in particular the Notify! system, with reports treated confidentially so that employees can report any incident confidentially and safely.

(Section ESRS S2-1, p 204) Nordex reports it has no dedicated formal policy specifically for engaging with value chain workers or providing remedies for human rights impacts, but several existing policies cover human and labor rights that also include value chain workers. These incorporate processes to ensure compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. All listed documents are publicly available on the Nordex website and, where applicable, included in supplier contracts applying to all suppliers globally. They comprise the Code of Conduct for Contractors and Suppliers, the Human Rights Policy, the QHSE Policy (CEO accountable, supported by ISO 14001 certification), the Diversity and Inclusion Policy, and the German Supply Chain Act (GSCA) Policy Statement covering due diligence based human rights and environmental risk management for tier-1 and tier-2 suppliers. Nordex reports no cases of non-respect of these international instruments involving value chain workers came to its knowledge.

(Section ESRS S2-2, p 205) Nordex reports it does not have a dedicated process for engaging with value chain workers about actual and potential impacts on them. However, there is regular exchange with key suppliers via the annual Supplier Conference. Regular checks of worker-related risks and public information regarding relevant supply chains are performed as part of the GSCA risk assessments, as defined in the GSCA Policy Statement. In addition, the Nordex Group engages with its stakeholders, including employees, suppliers, customers, and communities, to understand their concerns and expectations through direct contact by relevant staff such as Sourcing Managers, and uses this feedback to inform its policies and decision-making processes. During the double materiality assessment, the views and interests of supply chain workers were considered by proxies rather than through direct interaction; further identification, categorization and interaction with value chain workers did not take place.

(Section ESRS S2-3, p 205) Remediation of actual violations against the human rights of value chain workers follows the GSCA implementation processes described in the GSCA Policy Statement. If a violation at a tier-1 supplier cannot be ended in the foreseeable future, Nordex will develop and implement a plan to end or minimize it; for tier-n suppliers, it conducts a risk analysis and develops a risk minimization concept upon substantiated knowledge of actual violations. The GSCA implementation follows the OECD due diligence methodology and includes a multi-step risk analysis with prevention measures such as training, measuring effectiveness through subsequent risk assessments. Nordex reports its whistleblower system "notify!" provides a specific channel for value chain workers to raise concerns, open to any compliance violation. Reports are validated and investigated by Corporate Compliance or the Business Ethics Committee, handled confidentially, with whistleblowers protected against retaliation. Nordex does not assess how aware of or how much value chain workers trust these structures.

(Section ESRS S2-4, p 206) Nordex reports it addresses impacts on value chain workers by applying the due diligence and risk management approach outlined in the OECD Guidelines on Responsible Business Conduct, implemented through the GSCA. This includes analyzing human rights and environmental risks related to value chain workers and considering the potential contribution to these risks by high-risk suppliers. Prevention measures include mandatory e-learning trainings on human rights and environmental positions for high-risk suppliers, addressing all material negative impacts related to working conditions. Nordex states it has not taken action to provide remedies for actual material impacts, as none were detected, and has no initiatives aimed at delivering positive impacts for value chain workers. It tracks and assesses the effectiveness of actions such as training through process-inherent risk assessments. No dedicated actions are planned to address material risks and opportunities. No severe human rights issues or incidents connected to its value chain have been reported. Resources to manage impacts include those in the Sourcing Department and the Human Rights and Environmental Officer overseeing GSCA-related risk assessments.

(Section ESRS S2-5, p 207) Nordex reports it has not yet set targets related to managing material negative impacts, advancing positive impacts, or managing material risks and opportunities related to workers in the value chain. The Nordex Group does not track the effectiveness of its policies and actions in relation to the specific material impacts, risks and opportunities related to workers in the supply chain. Evaluation of the value chain worker-related processes is done via the GSCA risk assessment, and training for high-risk suppliers is carried out as part of that inherent process. Nordex further states it has not established a process to set targets, including direct engagement with workers in the value chain, their legitimate representatives, or credible proxies with insight into their situation.

(Section ESRS S3-1, p 209) Nordex reports it has not set or implemented dedicated policies, processes and measures to manage material impacts on affected communities and associated material risks and opportunities. However, the Nordex Group's Human Rights Policy (see section S1-1) adheres to the United Nations Guiding Principles on Business and Human Rights, the United Nations Universal Declaration of Human Rights, the International Labour Organisation's core labor standards, the ILO Declaration on the Fundamental Principles and Rights at Work, and the principles outlined in the UN Global Compact. That is, Nordex has no dedicated policy relating to affected communities but references external documents which have affected communities in scope. The relevant sustainability matter is communities' economic, social and cultural rights. Nordex reports no cases of non-respect of the UN Guiding Principles on Business and Human Rights, the ILO Declaration, or the OECD Guidelines for Multinational Enterprises involving affected communities in its own operations or in its upstream and downstream value chain.

(Section ESRS S3-2, p 210) Nordex reports it has not yet adopted a general process to engage with affected communities. It explains this is because it is usually not the land owner for the wind farms it installs, and stakeholder engagement, including Free, Prior and Informed Consent (FPIC), is typically conducted by its customers. Related context in the general disclosures notes that the views, interests, and rights of affected communities, along with relevant activities and procedures, are considered and implemented at the level of the specific projects, and that this project-level approach is part of the Nordex Group's business model.

(Section ESRS S3-3, p 210) Nordex reports it does not yet have a general approach or dedicated processes for remediating negative impacts on affected communities or providing remedies for material negative impacts, as no actual negative impacts have been identified. It states that if such impacts linked with affected communities occur, remediation would follow the relevant GSCA processes described in section S2 Workers in the value chain. The Nordex Group has an online portal, part of the whistleblower system "notify!", for affected communities to raise concerns directly; this channel allows affected communities to raise concerns and have them addressed to remediate negative impacts. Nordex does not assess whether affected communities are aware of or trust these structures or processes. The whistleblowing policy (see ESRS G1-1) protects individuals using the system against retaliation.

(Section ESRS S3-4, p 210) Nordex reports it currently does not have specific policies, actions, or targets for managing material risks or opportunities related to affected communities, as no actual material impacts have been identified. Consequently, it has not implemented dedicated processes or procedures for mitigation, remediation, or tracking the effectiveness of such actions. Nordex states that no severe human rights issues or incidents connected to affected communities have been reported, and the Nordex Group has no dedicated resources allocated at the group level for managing material impacts on affected communities.

(Section ESRS S3-5, p 210) Nordex reports it has not set targets for reducing negative impacts, advancing positive impacts, or managing material risks and opportunities related to affected communities. Consequently, it states it has not implemented relevant processes for setting these targets, tracking performance against them, or identifying lessons and improvements based on its performance.

(Section ESRS G1-1, p 213) Nordex describes its business conduct policies and corporate culture, built on integrity, transparency and accountability. Core policies include the Code of Conduct for Employees (aligned with the UN Global Compact), a Global Policy on Risk Management, a Human Rights Policy, a Whistleblower System Policy, GSCA-related complaints rules, a Donations Guideline, a Code of Conduct for Contractors and Suppliers, a Conflict of Interest Standard and a Crime Prevention and Anti-Fraud Policy. The Management Board holds overall responsibility, with named accountable officers for individual policies. Corporate values are introduced during e-onboarding and reinforced through leadership training, surveys and feedback. The whistleblower system Notify! offers 24/7 anonymous reporting via an online portal, a Help Desk and email, operated by Corporate Compliance and protecting whistleblowers from retaliation. Nordex notes it does not yet have anti-corruption and anti-bribery policies consistent with the UN Convention against Corruption but plans to implement them by the first trimester of 2025.

(Section ESRS G1-2, p 217) Nordex explains its approach to managing supplier relationships, focused on long-term partnerships based on mutual trust, respect and shared values. The company works with suppliers to promote sustainable practices across the supply chain and to reduce their environmental and social impact. Negative impacts and supply chain risks are managed through the Policy Statement Pursuant to the German Supply Chain Due Diligence Act (GSCA). Nordex aims to implement a supplier management system in 2025 covering supplier assessments, audits and ongoing monitoring. Social and environmental criteria form part of the Request for Information (RFI) process but are not decisive in final supplier selection, though the company says it is working to integrate these criteria more comprehensively into sourcing. Nordex states it does not have a policy that specifically covers the prevention of late payments to suppliers.

(Section ESRS G1-3, p 218) Nordex describes procedures to investigate business conduct incidents, including corruption and bribery, promptly, independently and objectively, under a zero-tolerance policy for all forms of corruption. Any active or passive bribery, illegal contributions to public officials or political parties, and facilitation payments are prohibited, except where there is an imminent risk to personal freedoms, health or life, in which case the incident must be reported and documented. Corruption risks are reviewed across all company activities and supported by general and specific risk-based training. Investigations are led by defined investigators and a steering committee; the Chief Compliance Officer reports regularly to the Business Ethics Committee, Management Board, Supervisory Board and German Workers Council on reports received and their resolution, with information anonymized. Donations and sponsorships are assessed, and the whistleblower system Notify! is open to reports of bribery and corruption. Training details are covered under business conduct training.

(Section ESRS G1-4, p 219) Nordex reports on incidents of corruption or bribery during the reporting period. The company recorded no convictions and no fines imposed for violations of anti-corruption and anti-bribery laws, which it states underscores its adherence to legal and regulatory standards. Regarding actions taken to address breaches in anti-corruption procedures and standards, Nordex notes that the presumption of innocence applies, meaning no negative consequences are imposed without sufficient evidence and the opportunity to clarify facts and mount a defense. Any action taken is within an appropriate professional framework, in accordance with relevant legislation and internal works council agreements where applicable. Detailed information on incidents involving actors in the value chain, where Nordex or its employees are directly involved, is covered by the Notify! whistleblower system introduced earlier in the G1 section.

(Section ESRS G1-5, p 219) Nordex describes its political influence and lobbying activities. As a wind turbine manufacturer affected by political and regulatory decisions, the company advocates for its interests directly and through sector-specific trade associations, focusing on the expansion of renewables with an emphasis on onshore wind, an ambitious climate and renewable policy, and pragmatic regulation. Lobbying is managed at a regional level with global coordination at head office; corporate, international and supranational activities are handled by a Global Public Affairs senior staff function reporting directly to the CEO. The Management is informed regularly and the Supervisory Board is informed on relevant topics. A Group-wide Donations Policy prohibits political donations and financial assistance to political parties or candidates. Nordex is registered in the EU Transparency Register (No. 284199650786-87) and the German Transparency Register (No. R004917). In 2024 no board members were appointed who had held a comparable public administration position in the preceding two years.

(Section ESRS G1-6, p 220) Nordex reports on its contractual payment terms and payment performance. On average, the Nordex Group takes 65.32 days to pay an invoice, calculated from recording the invoice to actual payment and weighted by the individual paid amount. Payment terms generally range from 0 to 180 days, with the most common being 30EOM5, 45EOM5 and 60EOM5 (for example, 30EOM5 means payment 30 days out, due on the 5th of the following month), depending on individual negotiations. In 2024, 80.41 percent of payments were made early or on time considering the weekly payment cycle, while the remaining share was paid later than agreed, for reasons such as ongoing quality checks. Overall, Nordex paid on a weighted average of one day late, without differentiating by supplier location or size. There are no legal proceedings for late payment outstanding. Data is drawn from ERP invoice data; India Q4 figures were extrapolated and Brazil was omitted due to a new ERP integration, with no significant impact expected.