Puma

Role of the administrative, management and supervisory bodies

Reference: page 74 (General information: Governance).

PUMA SE has a two-tier board: the Management Board (5 members) manages the company; the Supervisory Board (7 members, 2 of whom are employee representatives) monitors and advises it. Five members (71%) of the Supervisory Board are shareholder representatives and considered independent.

Diversity:

• Management Board: 1 woman, 4 men (20% gender diversity); 4 German nationals, 1 Chilean (20% nationality diversity); age range 42-59
• Supervisory Board: 3 women, 4 men (43% gender diversity); 2 French, 1 British, 1 British-Italian, 3 German nationals (57% nationality diversity); age range 47-62

Sustainability governance: A Sustainability Committee of 4 Supervisory Board members meets at least twice a year to oversee sustainability strategy, non-financial reporting and regulatory developments (CSRD, EUDR, ESPR). At Management Board level, the Chief Operating Officer (COO) is formally responsible for the sustainability and sourcing departments. An Executive Sustainability Committee (functional leads across P&O, Legal, Central Services, Logistics, IT, Design and Innovation) met once in 2025 to review programmes and approve bonus targets. PUMA's General Counsel also holds the role of Human Rights Officer.

Sustainability matters addressed by the management and supervisory bodies

Reference: page 75 (General information: Governance).

The Management Board and the Sustainability Committee of the Supervisory Board are updated at least twice a year on sustainability topics by the sustainability department, covering due diligence implementation, policy/action effectiveness, target achievement and legal updates on material IROs. A summary of PUMA's material IROs is shared with and approved by the Management Board and the Sustainability Committee.

Board members were included in the 2025 materiality assessment, stakeholder dialogue and development of PUMA's sustainability targets, which were approved by the Management Board. Progress is reported annually to the Management Board and Sustainability Committee, and publicly through the Sustainability Statement, which is signed off by the Supervisory Board and Management Board before publication. Oversight of PUMA's ERM system (into which material sustainability IROs are integrated) rests with the Management Board, which reports to the Supervisory Board on risk management effectiveness.

Integration of sustainability-related performance in incentive schemes

Reference: page 76 (General information: Governance).

For eligible employees in 2025, sustainability-related bonus targets covered climate change (3.33%), circularity (3.33%) and human rights (3.33%), across own operations and the supply chain. The Management Board's short-term incentive (STI) included circularity and human rights targets for own operations and supply chain (2.5% each); its long-term incentive (LTI) included climate change-related targets. Weightings were approved by the Supervisory Board.

Example ESG bonus targets (PUMA Group):

• Climate: reduce Scope 1 and 2 GHG emissions from own entities by 90% by 2030 vs. 2017
• Circularity: 9 out of 10 products made with recycled or certified materials by 2025 (PUMA S-Index)
• Human rights: all PUMA employees earning their income with PUMA continue to be paid against a living wage benchmark (Fair Wage Network)

PUMA Group Sourcing targets: Scope 3 Category 1 emissions -33% by 2030 vs. 2017 (interim -20% by 2025); 75% recycled polyester across all divisions by 2025; no child labour, forced labour, or other Zero Tolerance Issues.

"All ESG targets that were linked to variable remuneration were achieved."

Statement on due diligence

Reference: page 77 (General information: Governance).

PUMA's due diligence on human rights and environmental protection follows the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and national regulations including the German Supply Chain Act (LkSG). Since its first Code of Conduct in 1993, human rights have guided PUMA's business ethics; the Human Rights Officer monitors the risk management framework.

Scope of due diligence (T.12): Human rights and labour (child/forced labour, equal treatment, freedom of association, minimum wage, living wage, talent retention); Environmental (GHG emissions, substances of very high concern, water scarcity/pollution, microplastics, biodiversity loss, circular economy/waste); Integrity (bribery/corruption, supplier payment practices, corporate culture, consumer data privacy, consumer health/safety, whistleblower protection).

Prioritisation is based on severity (scale, scope, irremediability) and likelihood (operating environment, conflict zones, weak governance, mismatch between local practices and international standards). Measures include risk assessment, factory monitoring, grievance mechanisms, goal-setting and internal/external reporting.

Risk management and internal controls over sustainability reporting

Reference: page 78 (General information: Governance).

Sustainability reporting is fully integrated into PUMA's overarching Internal Control System (ICS) and ERM, based on the COSO framework, covering control environment, risk assessment, control activities, information/communication and monitoring.

Main sustainability reporting risks in the risk control matrix:

• Unclear, misaligned or unapplied procedures/standards
• Failure to comply with CSRD/ESRS
• Accuracy and timing of information availability
• Failure to report on all relevant material entities/elements
• Inadequate training and awareness among contributors
• Unrestricted access to reporting systems

Procedures are detailed in PUMA's Sustainability Reporting Manual. To address the risk of incomplete entity coverage, PUMA pre-aligns reporting scope with finance and auditors and validates data at entity/subsidiary and core-factory level. All assessed IROs are reviewed annually by relevant departments using a CSRD-aligned template; results are integrated into ERM by each risk owner and signed off by the Sustainability Committee. The Sustainability Statement is reviewed and signed off by the Management Board and the Sustainability Committee of the Supervisory Board.

Strategy, business model and value chain

Reference: page 63-65 (General information: Preamble/SBM-1).

PUMA SE is headquartered in Herzogenaurach, Germany, reporting across EMEA, Americas and Asia/Pacific. As of 31 December 2025 the PUMA Group comprised the parent and 93 subsidiaries. Products span three divisions: footwear, apparel and accessories, organised into seven Business Units (Sportstyle, Teamsport, Running and Training, Motorsport, Golf, Basketball, Accessories) plus stichd (socks/bodywear/licensed products).

Value chain: PUMA purchases finished products from outsourced, independent manufacturing partners based on PUMA's own designs; PUMA does not own or operate its production. Key material inputs: cotton, polyester, polyurethane, EVA, natural/synthetic rubber, leather; packaging is mainly cardboard and polyethylene.

Sourcing (2025): PUMA International Trading GmbH purchased from 141 independent suppliers (2024: 153) in 27 countries. Asia represented 95% of volume (2024: 94%): Vietnam 29%, China 23%, Cambodia 17%, Bangladesh 9%, Indonesia 9%, India 6%.

PUMA is not active in fossil fuel production, chemicals production, weapons production or tobacco.

Interests and views of stakeholders

Reference: page 69-71 (General information: Interests and views of stakeholders).

PUMA organises stakeholder dialogues covering its DMA, decision-making and sustainability strategy. External stakeholders include CSOs, NGOs, suppliers, topic experts, intergovernmental organisations, business partners, financial institutions, investors and ranking agencies; internal stakeholders span Sustainability, Product Compliance, Finance, Sourcing, Internal Audit, P&O, Investor Relations and Legal/Compliance (T.11 table maps stakeholder groups to interests and PUMA's response).

PUMA engages with materials-focused organisations (Better Cotton, Leather Working Group), manufacturing partners, workers' rights groups, trade unions and human rights experts.

"PUMA does not engage in direct lobbying or public policy advocacy, but relevant teams contribute to policy discussions through memberships and industry groups like FESI to provide PUMA's perspective in public policy discussions such as around climate change."

Feedback is summarised and reported to the Management Board and Supervisory Board via the Sustainability Committee. Voluntary disclosures beyond mandatory CSRD requirements are marked with a "»" icon.

Material impacts, risks and opportunities

Reference: page 68-69 (General information: Final list of IROs, IRO-2).

Material ESRS topics: E1 Climate change, E2 Pollution, E3 Water and marine resources, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users, G1 Business conduct.

Not material: S3 Affected communities. "Affected communities were not directly consulted" in the DMA process (confirmed across the E2, E3 and E4 IRO sections).

Report's own summary of material IROs (quoted):

• Climate change adaptation, mitigation and energy for own entities and in the value chain (E1)
• Pollution in the value chain, including substances of concern or high concern (E2)
• Water use in the upstream value chain including water scarcity (E3)
• Biodiversity, land use, and deforestation impacts in the upstream value chain (E4)
• Circularity including certified/recycled materials, environmental impact of inflow materials, extended product life (E5)
• Working conditions and equal treatment for own workforce (S1)
• Labour conditions and equal treatment for upstream value chain workers, incl. forced/child labour (S2)
• Ethical marketing, product safety and data safety for consumers (S4)
• Corporate culture, bribery/corruption, whistleblower system, responsible purchasing practices (G1)

For 2025, PUMA states it does not see any significant impacts of its material IROs on financial performance and cash flow.

Process to identify and assess material IROs

Reference: page 66-68 (General information: Impact, risk and opportunity management).

PUMA's DMA covers the Group's operations and value chain with a focus on Tier 1 (direct) and Tier 2 (strategic material/component) suppliers. A third-party consultancy conducted the DMA in 2023 with a stakeholder dialogue meeting in April 2024; it was reviewed again in 2025.

Impact materiality: scale x scope x irremediability, rated 0-15, multiplied by likelihood (0-1 unlikely to almost certain); impacts scoring ≥8 are material. Assessment covered core suppliers (~60-80% of business volume) and key sourcing countries (Bangladesh, Cambodia, China, Indonesia, Vietnam), with focus on wet-processing facilities and cotton farming.

Financial materiality: magnitude 0 (no effect) to 5 (very severe), multiplied by likelihood 0.65-1; risks/opportunities scoring ≥3 are material.

2025 review: in-person stakeholder dialogues in the top 5 sourcing countries (86% of 2025 sourcing volume), including GIZ's Our Rights, Our Voice pilot (Bangladesh, Cambodia) and the Fair Wear Foundation's Meaningful Stakeholder Engagement pilot (Indonesia). Input was collected from 40 organisations on human rights IROs and 20 on environmental IROs. The 2025 consultation added new material IROs to existing material topics.

Final list of IROs and disclosure requirements covered

Reference: page 68-69 (General information: Final list of IROs, IRO-2); ESRS INDEX (T.14).

The final list of IROs is approved by the Management Board and Supervisory Board and integrated into PUMA's ERM.

Topical standards reported: ESRS 2 (BP-1/BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), E1 (E1-1 to E1-8), E2 (E2-1 to E2-5), E3 (E3-1 to E3-4), E4 (E4-1 to E4-4), E5 (E5-1 to E5-5), S1 (S1-1 to S1-6, S1-9, S1-10, S1-12, S1-14, S1-16, S1-17), S2 (S2-1 to S2-5), S4 (S4-1 to S4-5), G1 (G1-1 to G1-4, G1-6).

Assessed as not material: ESRS S3 (Affected communities).

Phase-in provisions applied: "PUMA is applying quick fix phase-in relief to defer detailed disclosure on the anticipated financial effects, including disaggregation of monetary amounts by acute and chronic physical risk and location of significant assets at material physical risk, plus information on upstream value chain in E2-5. In addition, the relief is also applied to S1-13 and S1-15. For S1-8, the relief defers the reporting obligation for non-EEA countries" (no EEA country meets the 50-employee/10%-of-workforce threshold, so no S1-8 metrics are reported).

Transition plan for climate change mitigation

Reference: page 94-96 (E1 Climate change: Transition plan).

PUMA published its first Climate Transition Plan in 2023, aligned with SBTi-approved targets and the Fashion Industry Charter for Climate Action. "Only Scope 1 and Scope 2 emissions were formally aligned with the 1.5°C pathway in our published near-term target"; Scope 3 alignment is permitted under SBTi rules only when combined with a long-term/net-zero target. The transition plan itself does not require or undergo SBTi validation, though it is reviewed and approved by the Management Board and Supervisory Board.

Decarbonisation levers (quantified, by 2030 vs. current run-rate): Scope 1&2 own operations total 4,000 t CO2e/yr (airplane sale/lay-off 2,000t, low/zero-emission vehicles 1,000t, renewable fuel switch 500t, energy efficiency 500t). Upstream Scope 3 total 1,439,000 t CO2e/yr, led by new low-carbon technologies (345,000t), low-carbon materials (322,000t), offsite renewables (296,000t) and coal/biomass/electricity fuel switching (173,000t).

Net-zero: No SBTi-validated net-zero target yet; PUMA began shaping its net-zero strategy with the Management Board in 2024, targeting 90% emission reduction and 10% residual-emission neutralisation (reforestation, carbon credits) by 2050. Locked-in emissions (company cars, natural gas heating) are "only a small fraction" of the 2017 baseline and are not expected to jeopardise targets.

Policies related to climate change mitigation and adaptation

Reference: page 93 (E1 Climate change: Policies).

Key policies: PUMA's Environmental Policy, Environmental Handbook for Suppliers, and Environmental Handbook for Own Entities, all approved by the Management Board and publicly available. The policies endorse the UN Global Compact, the Paris Agreement, the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector, the Fashion Industry Charter for Climate Action, and the Fashion Pact.

The Environmental Policy sets out mitigation actions aligned with a maximum 1.5°C global warming pathway: renewable energy for PUMA entities, cutting GHG emissions in logistics and the upstream value chain, and increasing low-carbon materials. The Supplier and Own-Entity Handbooks recommend LED lighting, switching to renewable electricity, phasing out coal-fired boilers, and optimising heating/cooling. The next policy update will add climate adaptation measures.

Actions and resources for climate change

Reference: page 97-99 (E1 Climate change: Actions related to climate change).

Own operations: PUMA allocates operating and capital expenditure "in the low-single-digit million-euro range" annually for climate mitigation in own operations, with no significant capex for coal/oil/gas activities.

Suppliers: Of 24 key suppliers on the SBTi track, 12 had SBTi-approved targets by end 2025, 11 had submitted commitment letters, 1 pending. Of 35 core suppliers on the science-aligned track, 1 has WRI-approved targets, 7 via Cascale's Manufacturer Climate Action Program, 6 still developing (remaining 21 expected by 2027).

Training: Climate Action Training reached 69 participants from 45 factories in 2025; renewable-energy networking sessions had 97.7% participation; climate risk-assessment training for high-physical-risk factories had 93.3% participation.

Cleaner production (2019-2025 cumulative, with IFC, Aii, ENERTEAM, GIZ, WWF): 103,867 t CO2e/yr GHG reduction; 216,935.8 MWh/yr energy savings.

Renewable energy programmes covered 71.4% of Tier 1 and 53.1% of Tier 2 factories in 2025; PUMA and stichd factories had installed 191.7 MWp of solar PV capacity by year-end.

Targets related to climate change mitigation and adaptation

Reference: page 99-102 (E1 Climate change: Metrics and targets); T.23 SBTi targets.

SBTi-approved targets (T.23):

10FOR25 targets (T.21), all achieved: climate target approved by SBTi (aligned 1.5°C); 100% renewable electricity at own operations; 25% renewable energy at core factories (achieved 33.4%).

Targets cover all regions where PUMA operates and are unchanged for 2025; 2017 was chosen as baseline for representativeness (no temperature anomalies). PUMA currently focuses on mitigation without using GHG removals or carbon credits toward these targets.

Energy consumption and mix

Reference: page 102-105 (E1 Climate change: Energy consumption and mix); T.24, T.26.

Own operations (T.24): Total energy consumption 125,319 MWh (2025) vs. 123,923 MWh (2024); renewable share rose to 79% (2024: 76%); fossil share 21%. PUMA has sourced 100% renewable electricity since 2020. Energy intensity in high-climate-impact-sector activities: 16.9 MWh/€m (2025) vs. 14.1 MWh/€m (2024).

Upstream value chain (T.26, Tier 1 and 2 core factories): Total energy consumption 955,332.3 MWh; renewable share 32.3% (2024 target of 25% exceeded); fossil share 67.7% (mainly natural gas 167,815.7 MWh and coal 160,880.0 MWh). Renewable electricity at Tier 1/2 factories reached 28.0% (14.6% via EACs); Tier 2 saw a 1.1-point drop in renewable electricity due to a shift toward biomass (+16.3%). stichd reached 21.4% renewable energy at core factories.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: page 106-109 (E1 Climate change: Gross Scopes 1,2,3 and total GHG emissions); T.27.

GHG intensity (market-based): 208.4 t CO2e/€m revenue (2025) vs. 407.6 (2017). Reporting follows the GHG Protocol Corporate Standard, covering ~96% of Scope 1/2/3; Scope 1 decrease driven mainly by the 2025 sale of PUMA's company airplane. Tier 2 textile production is the largest emissions source within Scope 3 Category 1 (materials 39.4%, Tier 1&2 factories 35.9%, Tier 3 24.7%). FLAG emissions are 9.6% of total (below the 20% SBTi threshold), so no separate FLAG target is required.

GHG removals and carbon credits

Reference: page 110 (E1 Climate change: GHG removals and mitigation financed through carbon credits).

"We plan to use GHG offsets and removals to neutralise 5-10% of residual emissions towards achieving our net-zero target in 2050. We do not currently use any GHG removal or storage methods in our value chain, nor do we finance any reductions or removals from climate change mitigation projects outside our value chain through carbon credits. As a result, these requirements are not material to PUMA" for the current reporting year.

Internal carbon pricing

Reference: page 110 (E1 Climate change).

"PUMA currently does not have internal carbon pricing." No shadow price or internal levy is applied to investment or product decisions; decarbonisation is instead driven through the SBTi-approved absolute reduction targets and named decarbonisation levers described in the Transition plan (E1-1) and Actions (E1-3) sections.

Policies related to pollution

Reference: page 113-114 (E2 Pollution: Policies).

PUMA's Environmental Policy, approved by the Management Board, manages water pollution IROs in the upstream value chain: guidelines for product testing to AFIRM RSL, monthly chemical-concentration tracking for ZDHC MRSL compliance, and bi-annual wastewater testing against ZDHC Wastewater Guidelines.

"Our Environmental Policy does not currently include a standalone substitution or phase-out commitment. However, it does outline a targeted reduction strategy for VOCs in footwear... The current policy does not include procedures for managing pollution-related emergencies, which will be addressed in the future revision." Pollution of soil and air were not identified as material topics compared with water pollution.

Actions related to pollution

Reference: page 114-116 (E2 Pollution: Actions).

Own operations (offices, stores, warehouses, one footwear factory in Argentina) are not material for pollution given minimal chemical/water use. Upstream: PUMA tracks ZDHC MRSL conformance monthly across core Tier 1/2 factories via the ZDHC Gateway. In 2025, 100% of scoped factories (106) submitted data, achieving 86.6% MRSL conformance (77.9% including DMFa in polyurethane factories); 60 factories met the 90% target. ZDHC InCheck Verification completed by 75 of 90 factories with reports (83.3%), 100% pass rate. AFIRM RSL compliance reached 98.2% (Jan-Oct 2025).

Training: 5 chemical-training sessions reached 484 factories/780 participants; 76 core factories completed the ZDHC Supplier to Zero programme. "PUMA had no major incidents or pollution deposits in the reporting year," with no related operating/capital expenditures or provisions.

Targets related to pollution

Reference: page 116 (E2 Pollution: Metrics and targets).

PUMA has not set contextual pollution targets; its overall target is to improve wastewater quality and eliminate hazardous chemicals upstream and downstream, referencing the ZDHC Wastewater Guidelines and ZDHC MRSL. MRSL conformance is reported as the percentage (by weight) of chemicals used in manufacturing that conform to the ZDHC MRSL; final-product substances are tracked via RSL testing, reporting concentration rather than total amount. Targets are voluntary and may exceed local regulatory standards, developed through the DMA and stakeholder consultation.

Pollution of water

Reference: page 117 (E2 Pollution: Pollution of water).

In 2025, 153 supplier factories conducted wastewater testing per the ZDHC Wastewater Guidelines (99.4% completion, 294 test reports); 130 factories achieved 100% compliance, all achieved at least 90%. Overall compliance was 99.2%: conventional wastewater parameters 99.4% (applies to 66 factories discharging directly into natural water bodies), heavy metals 99.4%, restricted chemicals (MRSL) 99.0%.

On microplastics, PUMA has conducted 61 microfibre shedding tests since 2021 using The Microfibre Consortium (TMC) method. In 2025, average shedding was 0.70 g/kg vs. the TMC database average of 0.76 g/kg, though two fabric types shed above average and require further testing. Aggregate pollutant volume data is not available since wastewater tests are point-in-time snapshots.

Substances of concern and very high concern

Reference: page 117-118 (E2 Pollution: Substances of concern and very high concern).

Factories are prohibited from using ZDHC MRSL-listed substances, but impurities/contamination may still result in substances of very high concern (SVHC) in wastewater or final products; the Product Compliance mechanism keeps SVHC within legal limits. "Currently, we have data on chemical substances level for 77.4% of our factories (82 out of 106)... However, data completeness is not sufficiently consistent to allow for accurate reporting of the volume of substance of concern and very high concern used."

Air pollution is not a material topic vs. water pollution, but ZDHC Air Emission Guidelines were implemented at 62 factories in 2025; only 35 were compliant (Foundational level+), 27 (mostly Tier 1 footwear/Tier 2 textile) were not. Average VOCs in footwear manufacturing fell to 11.3 g/pair (2025) from a 2020 baseline of 14.7 g/pair.

Policies related to water and marine resources

Reference: page 120 (E3 Water and marine resources: Policies).

PUMA's Environmental Policy, approved by the Management Board, covers industrial water consumption at Tier 1/2 wet-processing factories (dyeing, washing, finishing, leather tanning), including measures for conserving, reusing and recycling water. It underpins the goal of a 15% reduction in water use per pair/piece by 2025 (2020 baseline). Marine resources are explicitly stated as not material: "its core business of designing, manufacturing, and selling apparel and footwear does not rely on or significantly impact marine ecosystems."

Actions related to water and marine resources

Reference: page 120-121 (E3 Water and marine resources: Actions).

Own operations: rainwater is collected at PUMA's headquarters to cut freshwater use. Upstream: PUMA partners with WWF on a water stewardship project in Vietnam and the IFC on a water-efficiency project in Bangladesh; 62 factories joined the WWF/GIZ Water Stewardship Training (To the Finish Line programme). Cleaner-production programmes (2019-2025, 46 Tier 1 + 45 Tier 2 factories) delivered expected water savings of 2,689,649.8 m3/year. In May 2025 PUMA joined the Bangladesh Alliance for Water Reuse and Recycle (A4R), a public-private initiative. Actions to date address avoid/reduce/transform in the mitigation hierarchy; restoration will be considered as part of the future SBTN nature target.

Targets related to water and marine resources

Reference: page 121-122 (E3 Water and marine resources: Metrics and targets).

The 2025 goal (15% reduction in water use per pair/piece vs. 2020 baseline) was set in 2019; the 2030 goal (50% recycled industrial wastewater at core Tier 2 factories) was set in 2024 following a DMA and stakeholder consultation including suppliers. PUMA has not set contextual location-based water targets; suppliers' environmental KPIs track progress. Targets are voluntary, not based on conclusive scientific evidence, and driven by sustainability strategy rather than specific regulatory requirements.

Water consumption

Reference: page 122-125 (E3 Water and marine resources: Water consumption); T.35-T.39.

2025 performance vs. 15% reduction target (2020 baseline): Footwear -58.4% (0.1 l/pair) - achieved; Apparel +220.6% (1.2 l/piece) - missed, due to a newly captured washing process; Leather +43.5% (94.4 l/m2) - missed, due to product-style changes requiring more water; Textile -9.4% (91.4 m3/ton) - missed, target of 15%, due to reduced production volume and more complex products.

Own operations use no industrial water; wastewater goes to public sewers. Using the WRI Aqueduct Tool, PUMA identified 10 PUMA Tier 2 factories (Bangladesh, Cambodia, China, Vietnam) and 1 stichd Tier 2 factory (Pakistan) subject to high baseline water stress. Vision 2030 target: 50% recycled industrial wastewater at core Tier 2 factories (2025 baseline 16.5%).

Transition plan and consideration of biodiversity in strategy

Reference: page 128-130 (E4 Biodiversity and ecosystems: Transition plan).

PUMA's value chain depends on healthy ecosystems for cotton and leather; strategy prioritises certified/recycled materials and a commitment to source all bovine leather from a deforestation-free upstream value chain by 2030 (via the LWG/Textile Exchange call to action, supporting cattle farms in Mato Grosso, Brazil - 5 farms working toward animal-welfare certification by 2027).

Own-operations risk screening (IBAT tool): 9 locations within 1km of a Natura 2000 site or Key Biodiversity Area (KBA), but no identified impact; WWF Biodiversity Risk Filter scores 2.5-4.0 (none classified "very high risk" ≥4.2).

Upstream risk assessment (third-party consultant, 2025): 473 PUMA and 85 stichd Tier 1/2 factories across 35 countries; 62 PUMA + 18 stichd factories identified as highly sensitive by proximity to protected areas/KBAs/IUCN Red List species; 27 PUMA + 11 stichd factories prioritised for action after applying the WWF BRF tool. No full SBTN-approved nature target yet; development is scheduled to begin in 2026.

Policies related to biodiversity and ecosystems

Reference: page 130 (E4 Biodiversity and ecosystems: Policies).

The Management Board approves PUMA's Biodiversity and Forest Protection Policy, Environmental Policy and Animal Welfare Policy, covering mainly the upstream value chain and embedded in the Code of Conduct and Sustainability Handbooks (contractually binding for suppliers).

Disclosed gaps: "Our current policies do not address traceability for products, components, and raw materials with significant biodiversity and ecosystem impacts... The policies also do not address sourcing from ecosystems managed to maintain or enhance biodiversity, consider the social impacts of our biodiversity-related activities, or cover sustainable land, ocean, or sea practices." These will be folded into an updated Environmental Policy in 2026.

Actions related to biodiversity and ecosystems

Reference: page 130-131 (E4 Biodiversity and ecosystems: Actions).

Own operations: no material actions, given minimal footprint of offices/stores/warehouses. Upstream: PUMA supports Better Cotton's Soil Management Plan and works with the Leather Working Group and Canopy; the deforestation-free bovine leather commitment purchases Textile Exchange Impact Partnership Incentives for Brazilian cattle farms. Land-use impact by raw material (PUMA): cotton 61.5%, leather 30.7%, polyester 4% (stichd: cotton 88.2%, polyester 10.3%, paper packaging 1%). Biodiversity training reached 245 participants from high/medium-risk suppliers. "Local and indigenous knowledge and nature-based solutions have not been part of PUMA's actions related to biodiversity and ecosystems to date."

Targets related to biodiversity and ecosystems

Reference: page 131-133 (E4 Biodiversity and ecosystems: Metrics and targets).

PUMA discloses significant gaps rather than overstating maturity: "Current 2025 and 2030 biodiversity targets are not based on conclusive scientific evidence or location-specific ecological thresholds... were not made in consideration of planetary boundaries, nor in consultation with indigenous communities... were not developed in alignment with the Kunming-Montreal Global Biodiversity Framework (GBF)." On the mitigation hierarchy, only avoidance is addressed today (the deforestation-free leather commitment); minimisation, restoration and rehabilitation are deferred to the SBTN-approved nature target process (targeted completion by 2030). No biodiversity offsets are currently used.

Policies related to resource use and circular economy

Reference: page 135 (E5 Resource use and circular economy: Policies).

The Circularity Policy, approved by the Management Board and reviewed by an external circularity organisation, aligns with the waste hierarchy (prevention, preparing for re-use, recycling, other recovery, disposal): circular design for durability/repairability, increased recycled-material use, take-back schemes, water recycling in the upstream value chain, and a commitment to eliminate landfill waste. "However, the policy does not include detailed quantitative targets and specific procedures for each stage of the waste hierarchy, particularly regarding the management of residual waste for disposal."

Actions related to resource use and circular economy

Reference: page 135-137 (E5 Resource use and circular economy: Actions).

RE:FIBRE textile-to-textile recycling programme (chemical/mechanical recycling of polyester) expanded in 2025 to cover jerseys of all major football clubs and federations, scaling to over 9 million items; a new multi-year partnership with RE&UP will recycle complex textile blends into recycled cotton fibres and polyester chips. PUMA contributed to EPR schemes in Germany and the Netherlands and joined the Circular Fashion Partnership in Vietnam and Cambodia (with GFA/GIZ).

Country of origin (PUMA only): ~28.7 thousand tonnes of cotton sourced, 77.4% from the USA, Brazil and India (all certified or recycled); ~7.5 thousand tonnes of leather, 91.5% from the USA and Argentina. Take-back schemes operate in the US, UK, China, India, France, Germany, Switzerland and Australia. The PUMA S-Index defines compliance as ≥50% certified/recycled material by weight for apparel/accessories, or one or more main components for footwear.

Targets related to resource use and circular economy

Reference: page 137-139 (E5 Resource use and circular economy: Metrics and targets); T.44.

10FOR25 results (2020 baseline → 2025):

• Recycled polyester (apparel/accessories): 16.7% → 89.0% (target 75%, achieved)
• All product divisions recycled polyester: → 82.0%
• Certified/recycled material (≥50% weight): apparel 81%→90.6% (achieved); accessories 47%→58.5% (target 90%, missed); footwear 24%→96.1% (achieved)
• Production waste to landfill: apparel -98.7%, footwear -90.7% (both beat the 50% reduction target)
• Plastic bags eliminated from PUMA stores since 1 January 2023
• Recycled content developed: cotton 21.8%, rubber 4.2%, leather 0.7%, polyurethane 4.0%

Vision 2030 (2025 baseline, targets set 2024): circular design criteria and recycled-material targets for 2026-2030, including 100% recycled polyester and 100% unavoidable plastic packaging from recycled content.

Resource inflows

Reference: page 140-141 (E5 Resource use and circular economy: Resource inflows); T.46.

How PUMA reports inflows despite fully outsourced manufacturing: all data is collected via a material-consumption questionnaire sent to Tier 1 and Tier 2 supplier factories (712 core and non-core factories for PUMA, Cobra and stichd in 2025), covering the types of materials used and certifications held; suppliers upload data for consolidation, and PUMA's material team validates it against development-stage usage records. Primary data covers January-September/October; the remaining months are extrapolated from confirmed shipment orders.

T.46 resource inflows by weight (2025): Biological materials 91,007t (paper/cardboard 45,413t 49.9%, cotton 35,490t 39.0%, leather 7,510t 8.3%, natural rubber 1,769t 1.9%) - 95.3% sustainably sourced. Technical materials 143,210t (polyester 53,875t 37.6%, synthetic rubber 45,069t 31.5%, polyurethane 18,122t 12.7%, EVA 16,693t 11.7%). Secondary/recycled materials totalled 97,593t (41.7% of total weight): recycled polyester 78.8%, recycled cardboard 94.9%, recycled cotton 18.3%. 99.5% of cotton was certified or recycled; 99.3% of leather came from gold-rated LWG-certified tanneries. Material categories with material assumptions and data-quality caveats are disclosed in full in the E5-4 footnotes (e.g. no cascading-principle adjustment for biological materials).

Resource outflows

Reference: page 141-142 (E5 Resource use and circular economy: Resource outflows).

"In the absence of a clear definition or industry standard on the basis of which materials or components can be considered recyclable, we are unable to report a precise figure for the recyclable content of footwear and accessories products," and products are "currently not recycled at scale after their use." No universal durability standard exists for footwear/apparel; PUMA awaits ESPR finalisation before updating its own standards. No formal repairability service is offered, though products are designed to be repairable in normal tailor shops, and RE:HACKS provides consumer care/washing guidance.

Primary packaging (cardboard shoe boxes, polyethylene bags for apparel/accessories, excluding stichd) uses over 90% recycled input material and is recyclable, except for printed surface colours.

Waste

Reference: page 142-144 (E5 Resource use and circular economy: Waste); T.47, T.48.

Own operations (T.47): total waste 5,502.2t (2025) vs. 6,767.2t (2024); 73% diverted from disposal (up from 66%), mainly non-hazardous recycling (4,022t). Hazardous waste diverted: 3.3t of 60.4t total hazardous waste.

Upstream value chain (T.48): total waste 35,666.5t; 82.6% diverted from disposal. In 2025, PUMA expanded waste data collection to rubber, EVA, leather and PU (previously only fabric): of 16,051.1 tonnes of this material waste, 76.8% (12,323.3t) was diverted (2.7% reused, 74.1% recycled), 12.1% (1,943.0t) incinerated, 10.1% (1,617.5t) had an undefined disposal pathway, and 1.0% (167.2t) went to landfill due to local waste-infrastructure limits. Hazardous upstream waste (57.8% sent to disposal, mostly incineration) is harder to divert than non-hazardous waste (84.9% diverted, primarily boiler ash, fabric waste, paper/cardboard).

Policies related to own workforce

Reference: page 155-156 (S1 Own workforce: Policies).

Key policies, all Management-Board approved and reviewed annually: Code of Ethics (2006), Human Rights Policy (revised and made public in 2025 to align with the German Supply Chain Due Diligence Act), Occupational Health and Safety Policy (in place 10+ years), and Human Rights Guideline (published 2024, implemented globally in 2025).

PUMA states a zero-tolerance policy for violations of fundamental human rights and labour rights: adequate wage, freedom of association, safe working environment, and zero tolerance of discrimination, forced/child labour, modern slavery or human trafficking. In 2025 the Code of Ethics was made publicly available in 12 additional languages used in major subsidiaries. PUMA also prohibits discrimination on an extensive list of grounds including race, gender, age, disability, religion, and sexual orientation.

Engagement with own workforce about impacts

Reference: page 156-158 (S1 Own workforce: Engagement).

Engagement channels include annual global employee opinion surveys (via Workday since 2024/2025), focus groups, interviews, sentiment analysis, global townhall meetings, and roundtables with C-level management. The European Works Council of PUMA SE has 17 members from 13 countries (meets annually in person, 2-3 times online); the German Works Council also has 17 members (full council meets fortnightly).

Employee engagement score (2025): 8 out of 10, calculated via a new Workday-based methodology, 0.2 points above the consumer-retailing industry benchmark and in the top quartile. Findings are communicated globally by the CEO and/or VP P&O, with breakdowns by gender and demographics feeding into action plans.

Remediation of negative impacts and channels for concerns

Reference: page 157-158 (S1 Own workforce: Remediation).

Employees can raise concerns via supervisors, staff representatives, Works Councils, the P&O Business Partner, the Compliance Officer, or the external SpeakUp whistleblowing platform (anonymous option available, data encrypted via a secure third-party server). Investigations are impartial; PUMA states it protects complainants from retaliation, with disciplinary action against retaliators.

A 2022 global risk assessment found 99% of participants viewed the compliance culture positively and 92% were aware of SpeakUp. Complaint procedures are reviewed at least annually or on an ad hoc basis after significant risk changes. Two mandatory Code of Ethics training sessions were delivered to all employees in 2025.

Actions on material impacts on own workforce

Reference: page 158-161 (S1 Own workforce: Actions).

Working conditions: regular working week ≤48 hours; living wage for all employees since 2021 (benchmarked via the Fair Wage Network); freedom of association respected, though PUMA applies the phase-in relief for S1-8 as no EEA country meets the reporting threshold (50 employees, 10% of workforce); hybrid working available globally; "audit berufundfamilie" certification since 2015 for working-parent support.

Health and safety: a central Health and Safety Committee at Herzogenaurach (quarterly meetings, incl. labour physician); ISO 45001-certified headquarters; "we have recorded no work-related fatal accidents in more than 10 years."

Diversity target: at least 45% of leadership roles (teamhead+) held by women and men by 2030. PUMA employs people from 143 countries; average employee age is 33 (29 retail, 38 non-retail). Community engagement: over 300,000 volunteering hours recorded since 2016 (Charity Cat, founded 2004).

Targets related to own workforce

Reference: page 162-164 (S1 Own workforce: Metrics and targets); T.55, T.56.

Targets were jointly approved by the Management Board, Supervisory Board and employee representatives.

Vision 2030 baselines (2025): adequate wage 100%; leadership gender balance 43% (target ≥45% women and men by 2030); Diversity & Inclusion score 8.5/10; engagement score 8/10; training 8.6 hours/FTE (target ≥8); gender pay gap below 5% in 97% of countries (target: closed in all countries); Lost Time Injury Rate 3.10 (target <2); 305,502 cumulative community-engagement hours (target 500,000 by 2030).

10FOR25 cycle closed in 2025: met all targets except "reduce accident rate to 0.5" was achieved (0.2) while "zero fatal accidents" recorded 2 fatal accidents at core Tier 1 factories (partially achieved) - see S2-5 for value-chain-worker detail.

Characteristics of the undertaking's employees

Reference: page 164-165 (S1 Own workforce: Characteristics of workforce); T.57, T.58.

Total employees (year-end headcount, directly employed, interns excluded): 21,194 (2025) vs. 22,214 (2024). By gender: Male 10,640 (2025) / 11,188 (2024); Female 10,537 / 11,006; Other 17 / 20.

By country (only countries ≥10% of global workforce, plus Germany disclosed voluntarily as HQ location): Germany 1,982 (2025) vs. 2,154 (2024); United States 2,895 vs. 3,307.

Diversity metrics

Reference: page 165-166 (S1 Own workforce: Diversity metrics); T.61, T.62.

Top management gender (2025): Women 205 (34%), Men 401 (66%) vs. 2024: Women 223 (36%), Men 404 (64%) - a slight decline in the proportion of women in top management.

Age groups (2025, all employees): under 30: 44%; 30-50: 50%; over 50: 6%.

PUMA employs people from 143 countries; its German home base employs people from over 91 nations. Long-term target: 97.5% of the global workforce employed in countries where the adjusted gender pay gap is ≤2.5% by 2030 (interim: below 5% in all countries with ≥50 employees by 2027; 97% achieved in 2025). D&I score from the employee voice survey: 8.5/10.

Adequate wage metrics

Reference: page 166 (S1 Own workforce: Adequate wage metrics); T.63.

"Employees getting an adequate wage (%)": 100 (2025 and 2024); "Employees paid below the applicable adequate wage (%)": 0; "Countries where employees are paid below the applicable adequate wage": 0. All employees worldwide earn at least the nationally defined minimum wage or, where none exists, the Fair Wage Network living-wage benchmark (per ESRS S1-10). All assessments were performed internally.

Persons with disabilities

Reference: page 161-162 (S1 Own workforce: Actions - Equal treatment and opportunities for all/Diversity).

"We prioritise an inclusive workplace for people with disabilities, adapting workplaces and training to meet their needs. In Germany, an elected Works Council member represents the interests of employees with disabilities. In some countries, legal issues prevent our companies from asking questions about and recording people's disability status and severity. Around 1% of our employees have told us that they have a severe disability, but the true number is probably higher." No formal percentage-of-workforce disclosure per ESRS S1-12 is given beyond this self-reported estimate.

Occupational health and safety

Reference: page 166 (S1 Own workforce: Occupational health and safety); T.64.

Injury counts and rates both rose year over year despite zero fatalities. Fatalities are defined as resulting from occupational accidents and ill health; injuries as accidents at the workplace or during work-related movement resulting in at least one day's work stoppage.

Compensation metrics

Reference: page 166-167 (S1 Own workforce: Compensation metrics); T.65.

Gender pay gap (ESRS methodology, gross hourly pay): 10.7% (2025) vs. 9.5% (2024, restated with the same methodology) - the gap widened year over year, "mainly influenced by gender representation across functions." Calculated via PayAnalytics regression using target total direct compensation as of 31 December 2025.

CEO pay ratio: annual total remuneration ratio of the highest-paid individual to the median employee's total remuneration was 198 (2025) vs. 168 (2024); the ratio versus the German employee average (per the Compensation Report) is 68. In 2025 the PUMA Group was certified a Fair Pay Developer by the Fair Pay Innovation Lab, having closed the adjusted (like-for-like) gender pay gap to below 1%.

Incidents, complaints and severe human rights impacts

Reference: page 167-168 (S1 Own workforce: Incidents, complaints and severe human rights impacts).

84 work-related complaints were submitted via SpeakUp in 2025 (2024: 109), covering discrimination, harassment (incl. sexual harassment/bullying) and other workplace grievances. Of these, 5 were confirmed: 1 discriminatory-remarks harassment, 1 bullying, and 3 sexual harassment cases (2024: 4 confirmed harassment cases). "For the year 2025, the company recorded no severe human rights impacts. PUMA also incurred no fines, penalties, or compensation payments related to human rights violations or other work-related incidents during the reporting period."

Policies related to value chain workers

Reference: page 172-174 (S2 Workers in the value chain: Policies).

Key policies: Human Rights Policy (updated 2025 for German Supply Chain Due Diligence Act alignment); Code of Conduct (updated 2025, binding on all supplier contracts, adding provisions on child labour, slavery, traceability, security forces, chemical management and land rights); Social Standards Handbook (foreign migrant worker recruitment, vulnerable-worker support); and a Civil Society Organisation Engagement Policy approved by the Fair Labor Association (FLA), prioritising engagement by country risk, production volume, and severity/likelihood of violations. All suppliers must display the Code of Conduct with hotline contact details.

Engagement with value chain workers about impacts

Reference: page 174-175 (S2 Workers in the value chain: Engagement); T.67.

PUMA evaluates value chain worker conditions every 6-24 months (risk-based) and organised 2025 stakeholder engagements with legitimate worker representatives/credible proxies in its top 5 sourcing countries (Bangladesh, Cambodia, China, Indonesia, Vietnam).

Worker survey on grievance-mechanism trust (2025): 9,537 workers surveyed (71.7% women) at 26 core Tier 1 factories (China, Cambodia, Indonesia). Results: legitimacy (trust the hotline) 92.7%; accessibility (know where to find it) 81.6%; predictability (understand the procedure) 81.6%; transparency (grievance resolved) 97.1%. The 2024 workplace-satisfaction survey (57 factories, 20,119 workers) scored 4.1 satisfaction.

Remediation and grievance channels for value chain workers

Reference: page 175-177 (S2 Workers in the value chain: Remediation); T.68.

Third-party grievance platforms (MicroBenefits, WOVO, Amader Kotha, Hamari Awaz, RSC, MUDEM) cover 91 factories and over 234,000 workers (77.8% of Tier 1 production); more than half a million workers are covered by voice channels overall; the Better Cotton Grievance procedure covers farm-level complaints.

2025 (T.68): 4,227 total complaints received (2024: 2,607); of the 161 cases received via the PUMA Hotline/escalation route, 95.0% were resolved (2024: 90.1%), 5.2% of complainants were dissatisfied with the resolution (2024: 2.5%). Third-party complaints: 9 outstanding from 2024 plus 16 new in 2025 (mainly recruitment fees, freedom of association, resignation payments); 13 resolved, 12 under active follow-up.

Actions on material impacts on value chain workers

Reference: page 177-179 (S2 Workers in the value chain: Actions); T.69, T.70.

PUMA's FLA-accredited social monitoring programme audits Tier 1, core Tier 2 factories and selected warehouses (500-600 audits/year), with frequency by rating: A every 24 months, B+ 18 months, B- 12 months, C 6 months, D must resolve zero-tolerance issues within 2-6 months.

2025 results (T.69): 600 factories audited; 23 failed (17 Tier 1, 2 subcontractors, 4 Tier 2), 6 deactivated. New-factory pass rate improved to 94.6% (2024: 81.9%). Shared assessments (reducing audit duplication via SLCP) rose to 82.1% (2024: 70.9%).

Forced labour/recruitment fees: since 2020, 18 factories reimbursed ~USD 590,000 to 755 workers in Taiwan, Japan, South Korea, Thailand and Mauritius; a 3-year IOM partnership began in 2025 to eliminate recruitment fees.

Targets related to value chain workers

Reference: page 186-187 (S2 Workers in the value chain: Metrics and targets); T.72.

10FOR25 results (2020 baseline → 2025): "Zero fatal accidents" - 2 fatal accidents recorded (partially achieved); reduce accident rate to 0.5 - achieved at 0.2; 100% of core Tier 1 factories with elected worker representation (2020: 33%) - reached 95% (partially achieved); pay via bank transfer (2020: 90%) - reached 100% (achieved); building-safety assessments - ACCORD Bangladesh at 91% progress (achieved); train 100,000 staff on women's empowerment - 358,128 factory workers trained (achieved).

Fair Compensation example: a Bangladesh factory Returns programme trained 10 female workers, of whom 7 were promoted to supervisor (31% wage increase, 12% efficiency gain). Gender pay gap methodology was updated in 2025 to focus on the top 4 departments (~70% of core-factory workforce), aligned with the FLA Fair Compensation dashboard.

Policies related to consumers and end-users

Reference: page 190-191 (S4 Consumers and end-users: Policies).

Key policies: Human Rights Policy (extended to consumers); Ethical Marketing Policy (avoids exploitation, appropriation, stereotyping; advertising is directed at carers, not vulnerable groups like children); Product Safety Policy and RSL Implementation Manual (Management Board oversight); Information Security Policy and Privacy Policy; an AI Framework prohibiting sensitive consumer data being fed into AI systems without security safeguards. An Information Security Committee (Legal, Sourcing, P&O, Finance, Product, Brand & Marketing, IT) meets quarterly. In a data breach, the Data Protection Officer must notify the relevant authority within 72 hours.

Engagement with consumers and end-users on impacts

Reference: page 191 (S4 Consumers and end-users: Engagement).

PUMA tracks brand and sustainability perception via quarterly brand-tracker surveys and consults its athletic ambassadors for product feedback. "Voices of a RE:GENERATION" empowers Gen Z advocates to influence PUMA's sustainability strategy and communications; podcast series FOREVER.BETTER., GREEN FLAGS and (new in 2025) Who Gives a Shirt engage younger audiences on sustainability topics. "No further engagements with consumers have taken place to influence the management of potential impacts."

Remediation of negative impacts for consumers who raise concerns

Reference: page 191-192 (S4 Consumers and end-users: Remediation).

Consumers contact PUMA via website, phone, email or social media; product-safety issues are routed to the Product Compliance team, which arranges root-cause analysis and a corrective action plan with suppliers. "In 2025, no product safety recalls have been received during the reporting period." Three data privacy complaints were received in 2025, all resolved. Phone contact allows anonymity; email and chat do not. "For other topics, there are not yet any specific policies in place to protect individuals from retaliation when using channels to raise concerns" beyond SpeakUp for confidential-information misuse.

Actions on material impacts on consumers

Reference: page 192-193 (S4 Consumers and end-users: Actions).

Annual review of product safety/RSL policies (AFIRM RSL standard); children's products undergo mechanical safety testing at nominated third-party labs; personal protective equipment (shin guards, goalkeeper gloves) is third-party certified to EU PPE regulations; non-compliant products/materials must be remediated pre-shipment with a verified corrective action plan.

Information security (2025): 24/7 Security Operations Centre; e-commerce private Bug Bounty programme; rollout of third-party cyber-risk assessment in progress; Cloud Native Application Protection Platform prepared; regular zero-trust reviews implemented. Product Compliance, Legal, Global Information & Cyber Security, and Brand & Marketing/Consumer Insights teams are dedicated to these actions, targeted for completion by 2030.

Targets related to consumers and end-users

Reference: page 193-194 (S4 Consumers and end-users: Metrics and targets); T.75.

Only one target is set, on product safety; "consumers have not been engaged to set up, identify opportunities, or track performance against this target," and it was developed internally. "No targets or metrics have been set for the other material IROs" (data privacy, responsible marketing) - an explicit gap disclosure.

10FOR25 results: "100% of PUMA products are safe to use" - achieved, no product recalls (2020 baseline: 0.59% RSL test failure rate). "Maintain RSL compliance rate above 90%" - achieved at 98.2% (2020 baseline: 98.8%). "In 2025, as we closed out the 10FOR25 cycle, we met the targets."

Corporate culture and business conduct

Reference: page 195-200 (G1 Business conduct: Corporate culture; Role of administrative bodies; Mechanisms to identify unlawful behaviour).

PUMA's Code of Ethics (guiding since 2006) covers human rights, safe workplaces, IP, asset use, sustainability, business-partner selection, conflicts of interest, insider trading, anti-money-laundering, trade/sanctions compliance, antitrust, anti-corruption, confidentiality, and speaking up.

The Management Board holds overall responsibility for the Compliance Management System (CMS), supported by a Chief Compliance Officer reporting to the CEO and quarterly to the Audit Committee. The CMS has three pillars: Prevent (risk assessments, policies, training, "Tone from the Top"), Detect (SpeakUp and third-party mechanisms), Respond (proportionate disciplinary/remediation measures). SpeakUp complies with the German Whistleblower Protection Act (Directive (EU) 2019/1937); a 2025 upgrade added voice-recording/transcription for accessibility. Nine named policies (Code of Ethics, Human Rights Policy/Guideline, Code of Conduct, Anti-Corruption and Anti-Bribery Policy, Anti-Money Laundering Policy, Business Partner Due Diligence Policy, Conflicts of Interest Policy, Rules for the Complaint Procedure, Whistleblowing Policy, Animal Welfare Policy) are each CEO-released, Management-Board-approved, and mandatory group-wide.

Management of relationships with suppliers

Reference: page 204 (G1 Business conduct: Management of relationships with suppliers).

The Vendor Financing Programme (since 2016, with BNP Paribas, Standard Chartered Bank, HSBC) offers suppliers liquidity during disruptions. The Responsible Purchasing Practice Policy (since 2019) guides sourcing-team and supplier training on the link between purchasing practices and human rights risk; since 2023, a responsible disengagement clause commits PUMA to at least six months' notice before significantly downscaling orders or ending a supplier relationship (per FLA guidelines).

Suppliers sign a legally binding Declaration of Principles (anti-corruption, building safety, animal protection, sustainability audits, RSL, cotton-sourcing annexes). The Better Buying survey, gathering anonymous supplier feedback on PUMA's purchasing practices, was paused in 2025. PUMA extends local supply-chain sourcing initiatives in China, India, Latin America and Türkiye.

Prevention and detection of corruption and bribery

Reference: page 202-203 (G1 Business conduct: Prevention and detection of corruption and bribery); T.77.

The Anti-Corruption and Anti-Bribery Policy underpins a systematic CMS approach to prevention, detection and response; anti-corruption/anti-bribery training is mandatory in-person and e-learning for all employees, plus supplier training and onboarding. The Supervisory Board receives anti-bribery/anti-corruption updates and training quarterly. Investigations are handled independently by Group Compliance, with investigators chosen to avoid conflicts of interest.

Anti-bribery/anti-corruption e-learning completion (T.77, 2025): Germany 99.1%, EEMEA 98%, APAC 96.5%, LATAM 95.8%, North America 94%, Group total 96.9%. Business Partner Due Diligence Policy e-learning: Group total 99%.

Incidents of corruption or bribery

Reference: page 203 (G1 Business conduct: Prevention and detection of corruption and bribery).

"In 2025, PUMA had zero convictions or fines for violations of anti-bribery and anti-corruption laws." PUMA enforces a zero-tolerance policy on corruption and bribery, with mandatory disciplinary consequences and remediation plans for any confirmed case; investigation outcomes are reported to the Management and Supervisory Boards by the Chief Compliance Officer in quarterly updates.

Payment practices

Reference: page 204-205 (G1 Business conduct: Payment practices).

Standard contract payment terms are 90 days after invoice receipt; supplier payments are automated and paper-free. The Vendor Financing Programme gives suppliers access to reduced payment terms via banking partners. "In 2025, approximately 99% of annual invoices were paid according to these standard terms, with payments being made on average within 95 days." The remainder followed locally agreed terms between the sales subsidiary and supplier. "In 2025, there were no outstanding legal proceedings for late payments, as this process is automated."