Rheinmetall

Reference: page 92. The Executive Board and the Supervisory Board, together with its committees, are Rheinmetall's central administrative, management and supervisory bodies (page 92). The Executive Board had four members at year-end 2025 (previous year: three): CEO Armin Papperger, CFO Klaus Neumann, CHRO Dr Vera Saal, and COO Rene Gansauge, a position created on 1 January 2025. Female representation on the Executive Board fell to 25.0% (previous year: 66.7%) (page 93).

The Supervisory Board has 16 members (five women, eleven men, a 31.3%/68.8% split, unchanged from the prior year), constituted under the 1976 Codetermination Act; all shareholder representatives are independent under the German Corporate Governance Code (page 93). Relevant committees include the Strategy, Technology and ESG Committee (met twice in 2025), the Personnel and Compensation Committee (five meetings, sets ESG remuneration criteria), and the Audit Committee (five meetings, covers sustainability data controls) (pages 93-94). The Executive Board approves the double materiality analysis annually, and it is presented to the Supervisory Board's Audit Committee (page 93).

Reference: page 93. Responsibility for sustainability sits with the Executive Board as a whole, which sets the strategic framework in consultation with the central Corporate Sustainability department. The Corporate Sustainability Board, meeting twice a year, brings together Executive Board members, the Chairmen of the Divisional Management Teams, and heads of Corporate Sustainability, Accounting, Controlling, Compliance, Strategy, Purchasing, Human Resources, Corporate Communications, Investor Relations and the Chief Technology Officer, to discuss material impacts, risks, opportunities and regulatory trends (page 93).

The Supervisory Board's Audit Committee, which met five times in 2025, addressed the scope and depth of current and future regulatory requirements, their implementation, and the processes and internal controls used to collect reporting data, alongside the risk management system and compliance (page 93). The Strategy, Technology and ESG Committee advises and monitors the Executive Board on sustainability-related business strategy (page 93), and the Personnel and Compensation Committee reviews ESG remuneration criteria annually (page 94).

Reference: page 133. Climate-related considerations were an integral part of Executive Board variable remuneration in 2025, accounting for 10% of both the Short-Term Incentive (STI) and Long-Term Incentive (LTI) programmes within the ESG targets, with climate-related targets making up 6.3% of recognised total remuneration. In STI 2025 the climate-related target concerned innovation and technology projects for CO2 avoidance and reduction; in LTI 2025 it concerned reducing CO2 emissions and contributing to carbon neutrality. The ESG targets in the variable remuneration framework provide for a CO2 reduction for the fiscal year, though the report notes these are not identical to the targets defined under the Climate change mitigation and energy chapter (page 133).

The Personnel and Compensation Committee defines the ESG criteria, target values and target-achievement ranges annually and assesses the degree of achievement of non-financial targets as part of Executive Board remuneration (page 94). Further detail on remuneration structure sits in the Remuneration report.

Reference: page 109. Rheinmetall presents its statement on due diligence as a table mapping the five core elements of due diligence under AR16 to the chapters and subchapters of the Sustainability Statement that address them (pages 109-110). (a) Embedding due diligence in governance, strategy and business model is addressed under General Disclosures - Governance/Strategy, and under Climate Change and Energy, Pollution, Own Workforce and Business Conduct. (b) Engaging with affected stakeholders sits under Business Conduct (Management of Relationships with Suppliers) and General Disclosures - Strategy. (c) Identifying and assessing adverse impacts is covered under Strategy/Management of Impacts, Risks and Opportunities, plus the Climate Change and Energy, Pollution, Own Workforce, Workers in the Value Chain and Business Conduct chapters. (d) Taking action to address adverse impacts and (e) tracking effectiveness of these efforts and communicating are each cross-referenced to the same topical chapters (pages 109-110). No separate narrative due diligence statement beyond this concordance table is provided.

Reference: page 94. Managing sustainability risks is described as an integral part of Rheinmetall's risk management system; the scope, features and risk-prioritisation approach for sustainability reporting are consistent with that system and are detailed in the Risks and opportunities chapter, which also covers how results of the risk assessment feed into internal functions and are communicated to the administrative, management and supervisory bodies (page 94). Internal controls for sustainability reporting are being continuously expanded and incorporated into the Group's internal control system; in fiscal year 2025, energy management and EU Taxonomy data were integrated into that system to mitigate data-quality risk (page 94). Annual checks on sustainability reporting are reviewed for adequacy and effectiveness as part of the internal control system, and the interaction between risk management, the double materiality analysis and internal controls is illustrated in a dedicated figure (page 94).

Reference: page 94. Rheinmetall's business model spans defence technology, civilian and dual-use products; the value chain runs from research and development through procurement of metals, electronic components and chemical substances, production and manufacturing (military vehicles, ammunition, protection systems; civilian engine parts, pumps, exhaust aftertreatment), logistics and distribution (subject to export controls in defence), marketing and after-sales, and finally recycling and service-life extension (pages 94-95). Employees totalled 33,217 at year-end 2025 (previous year: 29,322), with 17,232 in Germany, 9,251 in Other Europe, 2,735 in the Americas, 1,362 in Asia/Near East and 2,637 in other regions (page 95).

In the automotive supply chain, a distinction is made between OEMs, first-tier and second/third-tier suppliers; in defence, supplier-structure changes are constrained by qualification, regulatory and security requirements, so Rheinmetall diversifies suppliers to strengthen resilience, subject to laws including the War Weapons Control Act, the Foreign Trade Act and ITAR (page 95).

Reference: page 96. Rheinmetall's most important stakeholder groups are customers and business partners, shareholders/lenders/investors, employees, suppliers, the public, politicians and administrators, and nature as a "silent stakeholder" (page 95). Each group is engaged through employees in regular contact with them, and formats of dialogue are tabulated: customer events and surveys for customers and business partners; the AGM, roadshows and capital market days for shareholders and investors; the CEO letter, employee surveys (run twice yearly) and works council committees for employees; supplier conferences, development and audits for suppliers; multilingual public communication channels for the public; and parliamentary evenings and political talks for government and administration (page 95).

The results of stakeholder exchange feed into the double materiality analysis, and the outcomes are communicated to the administrative, management and supervisory bodies to keep them informed of stakeholder views and interests (page 96).

Reference: pages 96, 100. Significant impacts, risks and opportunities were identified as part of the double materiality analysis and are described per topic (page 96): climate change (Scope 1-3 emissions as a negative impact; energy efficiency gains and supplier-emissions software as a positive impact; physical and supply-chain climate risks); pollution (soil contamination risk from industrial processes and ammunition residues); own workforce (positive effects from social dialogue, health and safety, equal opportunity and data protection); workers in the value chain (potential human rights impacts in raw-material extraction); consumers and end-users (product safety benefits for soldiers and civilian users); and business conduct (resilience from governance/compliance structures, reputational risk from misconduct, and opportunity from rising defence budgets) (pages 96-98).

The double materiality assessment concluded that E1, E2, S1, S2, S4 and G1 are material, while E3, E4, E5 and S3 were assessed as non-material (page 100). Material impacts from Rheinmetall's strategy include gradual CO2 reduction, human resources strategy effects, human-rights protection and responsible management (page 96).

Reference: pages 97-99. Corporate Sustainability worked with divisional ESG managers and internal stakeholders to identify key topics (page 98). The 2025 double materiality analysis was carried out top-down at Group level based on the 2024 results, followed by a Divisional Review that replaced the prior mixed top-down/bottom-up approach; the report states "there has been no change in the materiality of the issues" (page 98). The process followed EFRAG's Implementation Guidance 1, starting with a context analysis (drawing on the value chain, corporate strategy, risk management system, legal and administrative provisions, media, benchmark reports, scientific articles, and a risk data provider for deeper-value-chain raw materials), then identification and assessment (page 98).

Impact severity was scored zero-to-five on magnitude, scope and (for negative impacts) irreversibility, plus probability of occurrence; a combined threshold of eight determines materiality for impacts, and 2.5 for risks and opportunities (page 99). Identified risks were reconciled against the existing risk management system on a gross basis. The next materiality update is planned for fiscal year 2026 (page 98).

Reference: page 101. Material sustainability aspects were identified from the significant impacts, risks and opportunities established by the thresholds described under IRO-1, and the resulting disclosure requirements were determined by comparing material impacts, risks and opportunities against the ESRS disclosure requirements at data-point level (page 101). The report states that disclosure requirements identified this way - including those arising from other EU legislation and those satisfied by reference to other chapters of the management report - are listed in a content index, with referenced items excluded from the Sustainability Statement itself and instead located in the combined management report using superscript notation (page 101).

The content index spans pages 102-108, tabulating each disclosure requirement or related datapoint against its specification (Disclosure or EU-legislation cross-reference), materiality outcome, and the chapter, subchapter and paragraph where it is addressed, covering ESRS 2, E1, E2, E3, E4, E5, S1, S2, S3, S4 and G1.

Reference: page 128. Rheinmetall's overarching climate protection goal, set by the Executive Board, is carbon neutrality by 2035 for Scope 1 and Scope 2 (market-based), targeting an average annual reduction of 4.2% overall in Scopes 1 and 2 relative to the 2022 base year, supported by a 1.7% annual reduction in energy consumption tied to recertifying energy management systems (page 128). No separate Scope 3 reduction target has been set, and external validation of the reduction targets has not been carried out; residual emissions after 2035 are intended to be offset, for instance through certified carbon sequestration projects (page 128).

A comprehensive CapEx plan has not yet been finalised, and a transition plan for achieving climate neutrality by 2050 "is currently being developed and is expected to be published when the European Corporate Sustainability Due Diligence Directive (CSDDD) comes into force" (page 129). Measures implemented in fiscal 2025 reduced GHG emissions by 1,563 tonnes of CO2 equivalents, with an expected future reduction of 2,439 tonnes (page 129).

Back-filled from ESRS 2 IRO-1 and the E1 climate-risk-analysis subsection, where this content is disclosed in the FY2025 report (pages 126-127). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against. Physical climate risks were assessed for Rheinmetall's production facilities in a 2024 site-specific external analysis, applying scenario analysis based on Shared Socioeconomic Pathways: the 2°C scenario (SSP1-2.6) and the 4°C scenario (SSP5-8.5), the latter identifying temperature, flooding, wildfire and tornado as the main risks. Geospatial granularity was 12 km in Europe and 25 km elsewhere; short-term was defined as up to 2040, medium-term 2041-2060, long-term 2081-2100, against a 1971-2000 reference period (page 127). Transitional risks were assessed internally using the 1.5°C scenario to 2050, over a short-to-medium-term horizon, via cross-divisional workshops, literature research and peer benchmarks (page 127). The report notes forecast reliability is rated low for short-term periods and that a detailed assessment of how identified transition risks affect assets and business activities "has not yet been carried out" (page 127). Climate-specific risk identification is also presented under E1-2 (2025 ESRS numbering).

Back-filled from the E1 climate-risk-analysis subsection, where this content is disclosed in the FY2025 report (pages 126-127). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against. Rheinmetall initiated a resilience analysis in 2024 that goes beyond the established risk management system and expanded it during fiscal 2025; it covers both physical and transitional risks along the entire value chain and derives possible measures to strengthen resilience, using scenario assumptions consistent with the Risks and Opportunities chapter (page 126).

During the fiscal year, the climate risk analysis was extended to production sites acquired in 2025, with a more detailed site-level investigation of physical risks (page 127). Based on its assessment of transitional and physical climate risks, Rheinmetall "currently assumes that the necessary adjustments can be made to business operations and that the financial impact can be mitigated by the Group", while stating that a detailed financial-effects assessment has not yet been carried out and that the company has not yet laid down a formal climate change adaptation policy (page 127). Resilience is also presented under E1-3 (2025 ESRS numbering).

Reference: page 128. Rheinmetall's climate change mitigation approach is governed by Executive Board-adopted energy management guidelines, which implement, monitor and further develop the Group's energy management system. Locations of fully consolidated companies with energy consumption above 3,500 MWh per year are required to implement an ISO 50001 energy management system; certified locations accounted for 74.2% of total energy consumption in the fiscal year (previous year: 45.9%) (page 128).

The strategy for sourcing renewable energy envisages gradually converting individual regions and business areas to renewable sources, through long-term energy supply contracts (including direct site connections) and expanding self-generation; purchased renewable electricity rose from 138,221 MWh in 2024 to 192,782 MWh in 2025 (page 128). Progress on renewable energy procurement is reported regularly to the Executive Board as part of reviewing compliance with the GHG reduction targets (page 128). The company states it has not yet laid down a climate change adaptation policy (page 127).

Reference: pages 127-129. Key decarbonisation levers are switching electricity procurement to renewable sources, substituting fossil fuels and reducing energy consumption; measures implemented in fiscal 2025 are expected to deliver 97,319 tonnes of CO2e reduction in Scope 1 and 2 (market-based) (previous year: 82,934 tonnes), split into 35,452 tonnes from energy-consumption reduction, 51,705 tonnes from switching to renewable electricity procurement, and 10,162 tonnes from fossil-fuel substitution (page 130). A 1,092 kWp photovoltaic system was installed at the Weeze site, with further facilities in planning or implementation, and a wood chipping plant at Unterlüß enables heating from the company's own forestry stock, replacing fossil-based heating (page 128).

On the value chain side, a software solution implemented in the fiscal year enables more detailed recording of suppliers' GHG emissions to support a future Scope 3 CO2 strategy, and Rheinmetall is developing power-to-liquid e-fuel solutions with strategic partners for decentralised, climate-neutral fuel production (page 129).

Reference: page 128. Rheinmetall's target is carbon neutrality by 2035 in Scope 1 and Scope 2 (market-based), set by the Executive Board, comprising an average annual reduction of 4.2% overall in Scopes 1 and 2 relative to the 2022 base year, plus recertification of energy management systems targeting a 1.7% annual reduction in energy consumption versus the 2022 base year (page 128). The targets cover greenhouse gases under the Kyoto Protocol, apply to all companies under Rheinmetall's operational control, and follow Science Based Targets initiative guidelines; with 2022 as base year the current target corresponds to 80.0% of the 1.5°C pathway (page 128). No separate Scope 3 target has been set and the targets have not been externally validated (page 128).

Considering the 2022 base year and the 4.2% annual reduction, emissions are expected to fall to 192,320 tonnes of CO2e by 2030 (page 131). The average reduction achieved in fiscal 2025 was 9.1% versus the base year, putting Rheinmetall "on track to achieve its targets" (page 131).

Reference: pages 129-130. Total energy consumption was 1,028,586 MWh in fiscal 2025 (previous year: 928,227 MWh). Fossil energy consumption totalled 639,980 MWh (62.2% of the total; previous year: 565,951 MWh, 61.0%), while total renewable energy consumption was 362,238 MWh (35.2% of the total; previous year: 328,181 MWh, 35.4%). Consumption from nuclear sources was 26,368 MWh (2.6%; previous year: 34,096 MWh, 3.7%) (page 130).

Energy intensity for activities in high-climate-impact sectors C, E, G and L was 99 MWh per €million (previous year: 108 MWh per €million), an 8.3% improvement, calculated against €10,283 million of net sales from those sectors (page 130). Data is collected centrally via energy management software covering all fully consolidated companies, with consumption estimated for a few smaller locations lacking meter data (less than 0.5% of total consumption); the fossil/renewable split uses supplier data, or the AIB residual mix and IEA databases where unavailable (page 130).

Reference: pages 130-132. Gross Scope 1 GHG emissions were 146,119 tonnes CO2e in fiscal 2025 (2024: 139,801; base year 2022: 141,395), a 4.5% year-on-year increase. Gross market-based Scope 2 emissions were 64,728 tonnes CO2e (2024: 69,897), down 7.4%. Total gross indirect Scope 3 emissions were 6,886,097 tonnes CO2e (2024: 5,838,481), up 17.9%, of which Category 1 (purchased goods and services) was 2,762,396 tonnes and Category 11 (use of sold products) was 4,123,701 tonnes - together over 80% of Scope 3 and the two categories identified as material (page 132). Total GHG emissions (market-based) were 7,096,944 tonnes CO2e, up 17.3% on 2024 (page 132).

Market-based GHG intensity was 599 tonnes CO2e per €million revenue (2024: 620), down 3.4% (page 131). Scope 1 emissions used IPCC emission factors; Scope 2 location-based used IEA factors and market-based used supplier-specific factors where available; Scope 3 Category 1 used EXIOBASE (v3.8.2) expenditure-based factors and Category 11 used DEFRA/AIB factors (pages 130-131).

Reference: page 133. Rheinmetall assessed material pollution-related impacts, risks and opportunities via a double materiality analysis covering air, soil and water pollution, pollution of living organisms and food resources, microplastics, and substances of concern and substances of very high concern, with site-level assessments carried out by each production site's environmental management officer (page 133). Three policy pillars address pollution reduction and prevention: updating the Supplier Code of Conduct (SCoC), extending ISO 14001 certification to smaller production plants (including emergency preparedness and hazard prevention), and reducing and eliminating soil contamination, the last of which is carried out in accordance with legal regulations rather than a separate internal concept (pages 133-134).

The SCoC was updated with effect from 1 January 2025 and forms part of subsequently agreed supply contracts, extending Rheinmetall's own environmental protection standards to the upstream value chain (page 133). Consultations with affected communities on pollution assessments were not carried out, as deemed disproportionate (page 133).

Reference: pages 133-134. Rheinmetall's larger production sites have held ISO 14001 certification for several years; in 2022 the Executive Board decided to extend certification to all existing production plants with more than 400 employees, now fully implemented, with new locations above that threshold given a three-year implementation deadline (page 134). Given the already extensive certification scope, fiscal 2025 measures were mainly organisational improvements: operating instructions were optimised at numerous sites, including documentation for systems handling substances hazardous to water (AwSV), reducing the risk of leaks and accidents involving oils, lubricants and solvents (page 134).

A new standard process for recording potential environmental pollution data was developed in the fiscal year, based on the European Pollutant Release and Transfer Register (E-PRTR) methodology for EU sites and an equivalent company-wide process for non-EU sites, coordinated by divisional ESG managers and audited by Corporate Sustainability, with Switzerland using the SwissPRTR (page 134).

Reference: page 134. Rheinmetall's stated objective is to expand ISO 14001 certification within the company and, in connection with this, to implement preventive measures for potential leaks and accidents; the report notes Rheinmetall "has voluntarily established this objective" (page 134). By 2028, certification is to be extended to all production sites with more than 100 employees, having already reached full coverage for sites with more than 400 employees (page 134). No quantified numeric pollution-reduction target (such as a percentage reduction in emissions to air, water or soil) is disclosed; the target is expressed as a certification-coverage milestone tied to the ISO 14001 environmental management system, through which the efficacy of operational pollution-related measures continues to be assessed (page 134).

Reference: page 134. A large share of Rheinmetall-owned land has been subject to industrial use for decades, so previously unknown contamination from production processes cannot be ruled out, and process-related emissions into the soil remain a potential risk (page 134). The procedure for a leak is documented in workplace-specific operating instructions identifying reporting centres and immediate measures; if soil contamination cannot be ruled out, an external expert takes soil samples to assess the extent of contamination, with remediation measures taken as needed (page 134). Soil remediation was carried out at Rheinmetall production sites during the fiscal year in connection with construction and acquisition activities (page 134).

Data collection follows the E-PRTR methodology (and SwissPRTR for Switzerland). During the fiscal year, no pollutant emissions into the soil exceeded the E-PRTR thresholds at Rheinmetall's production sites, so the result for all pollutant loads in the soil is reported as zero (previous year: zero), and a tabular presentation of soil pollutant load is therefore not provided (page 134).

Reference: page 134. Rheinmetall's human resources strategy rests on a stated set of principles and international guidelines: a Code of Conduct with binding rules on human rights, anti-corruption, compliance and competition law; the global framework agreement on principles of social responsibility (FAIR2ALL), signed in 2018 with the European Works Council and IndustriAll Global Union; the 2025 Declaration of Principle on human rights and environmental due diligence under Section 6(2) of the German Supply Chain Due Diligence Act (LkSG), version 3.0; the Position Paper on Transformation and Internationalisation; the ten principles of the UN Global Compact; the Diversity Charta; the Framework Agreement on Health Management; and the Luxembourg Declaration on occupational health promotion (page 135).

FAIR2ALL covers human rights, equal opportunities, anti-discrimination, violence and harassment, remuneration, working hours, sustainable employment, occupational health and safety, training and environmental protection, and explicitly rejects child labour, forced labour and human trafficking (page 135).

Reference: pages 139-140. Co-determination is a long-standing tradition at Rheinmetall, based on local and general works councils, a Group Works Council, and a European Works Council that safeguards information, consultation and participation rights on cross-border issues, meeting annually for a five-day session and via a Presidium that meets three times a year (page 139). Rheinmetall respects freedom of association and collective bargaining under ILO Convention 98 (page 139).

The anonymous "YOUR VOICE" survey, run twice yearly, gathers direct employee feedback on job satisfaction, working conditions and corporate culture, with results communicated to employees and workers' representatives (page 140). The Chief Human Resources Officer and Labour Director are operationally responsible for ensuring dialogue results and survey findings reach the Executive Board and are incorporated into HR strategy; CHROs are appointed per division and report through this structure (page 139).

Reference: page 145. The Rheinmetall Whistleblower System Manual and the Misconduct Response Policy define binding procedures through which workers can raise concerns; several communication channels exist, including centralised and decentralised reporting offices and ombudspersons, contactable in person, by phone, post, email or web application, optionally anonymously (page 145). A complaints procedure under the German Whistleblower Protection Act and the LkSG covers reporting to local or central compliance or the Group-wide electronic Whistleblower System; data-protection concerns can be raised with the Data Privacy Organisation (page 145).

External independent ombudspersons - lawyers specialising in reporting procedures, subject to confidentiality obligations - can forward reports anonymously to Compliance (page 146). Reprisals against good-faith whistleblowers are not tolerated under the Whistleblower Protection Act and the Rheinmetall Whistleblower System Manual (page 146). Preventive and remedial measures follow the existing risk management system and are reviewed annually as part of human-rights due diligence (page 146).

Reference: pages 135-142. Areas of action for the workforce are reviewed and updated on an ongoing basis with input from workers' representatives, central and specialist departments, and survey results, without fixed reference periods (page 136). Concrete measures span sustainable employment (structured dialogue on transformation and internationalisation, socially responsible handling of restructuring), competitive remuneration (base salary aligned to market benchmarks, profit-sharing and occupational pension for collectively-agreed employees, share purchase programmes now extended to Australia, parts of Spain, the UK and Italian civil-business companies) (pages 136-137), skill development (the Rheinmetall Academy, tailored management/project/expert career paths) (pages 138-139), and health and safety, including Global Operational Safety, established in January 2025 as a Group-wide occupational-safety organisation (pages 141-142).

The report states that "no material negative impacts, risks or opportunities were identified" for the workforce compared with fiscal 2024 (page 136).

Reference: page 136. Rheinmetall states plainly that "with regard to the Group's workforce, no material negative impacts, risks or opportunities were identified in the double materiality analysis compared to fiscal year 2024. For this reason, no separate targets have been defined for the Group's workforce in accordance with the European standards for sustainability reporting" (page 136). Instead, existing areas of action for the workforce are reviewed and updated on an ongoing basis, drawing on the views of workers' representatives, central and specialist departments, and survey results, to assess qualitatively whether measures and concepts continue to support positive effects on the workforce; the report notes "there are no specific targets or fixed reference periods" and that findings are continuously incorporated into further development of the areas of action (page 136).

Reference: pages 135-138, 143-144. Total headcount was 33,217 at 31 December 2025 (previous year: 29,322), comprising 26,066 male, 7,150 female and 1 diverse employee (page 135). Germany accounted for 17,232 employees, with no other single country exceeding 10% of the workforce (page 136). By contract type, 31,923 employees held permanent contracts and 1,294 temporary contracts, with no non-guaranteed-hours employees reported (page 137). Total departures during the year were 3,486 (10.5% turnover rate; previous year: 3,571, 13.5%) (page 137).

By age, 14.8% of employees were under 30, 57.1% were 30-50, and 28.1% were over 50 (page 144). Headcount data is based on active employment relationships as at the reporting date, including temporary and exempt staff but excluding external workers, trainees, dual students and interns (page 135).

Reference: page 141. The percentage of employees covered by tariff or collective agreements was 57.2% Group-wide (previous year: 58.4%); Germany is the only country with a significant number of employees covered by multiple collective bargaining agreements, where coverage was 75.6% (previous year: 75.5%) (page 141). Non-tariff employees and higher-hierarchy-level employees are not included in collective bargaining coverage and instead receive variable remuneration tied to defined targets (page 141). 100% of employees in Germany (unchanged from the previous year) are represented by workers' representatives (page 141).

Co-determination structures include local and general works councils, a Group Works Council, and a European Works Council (page 139); social dialogue channels are described under Engaging with own workers, including the twice-yearly "YOUR VOICE" employee survey (page 140).

Reference: pages 142-143. At the top management level (management levels one to four, covering executives and top management), male representation was 87.6% (106 employees) and female representation 12.4% (15 employees) at 31 December 2025, versus 88.0%/12.0% (103/14) a year earlier (page 143). At Board level, the Executive Board comprised three men and one woman (25.0% female, down from 66.7%), while the Supervisory Board comprised eleven men and five women (31.3% female, unchanged) (page 93). The Corporate Social Integrity (CSI) department coordinates anti-discrimination initiatives and, together with divisional CSI contacts, forms a network intended to build a common understanding of a fair, non-discriminatory working environment, supported by training for future managers and seminars on intergenerational and intercultural cooperation (page 142). Further gender-distribution detail for the highest management level is cross-referenced to the Corporate governance statement (page 143).

Reference: page 137. Rheinmetall states that all employees receive "appropriate remuneration in line with the applicable reference benchmarks" through a regular base salary determined in line with market standards, taking into account qualifications, experience and scope of responsibility, and supplemented where applicable by additional components under the relevant employment-relationship regulations (page 137). Where no statutory or collective bargaining regulations apply, remuneration is based on market conditions; salaries are paid in recognised currencies and may only be withheld with sufficient legal or contractual basis reflected in payroll documentation (page 137). Employees generally receive a written or digital payslip setting out all salary components, additional benefits and deductions, or receive one on request where not regionally customary (page 137). The Executive Board, senior managers and non-tariff employees are additionally eligible for variable performance- and success-related remuneration tied to financial and ESG goals (pages 137-138).

Reference: page 144. Rheinmetall's commitment to inclusion of people with disabilities dates to a 2002 framework integration agreement developed with the Executive Board, the Group's representative body for severely handicapped employees, and the Group Works Council, and was formalised further in a 2018 inclusion agreement, most recently revised during fiscal 2025 (page 144). The inclusion agreement specifies that each company should strive for a minimum 5% employment quota for people with disabilities, with special measures considered if the rate falls below 3%; an inclusion team advises on appropriate measures (page 144).

In Germany, representatives for severely handicapped persons, together with the Group's central representative body, ensure interests of people with disabilities and persons of equal status are represented across German Group companies and businesses, supported by a central office promoting inclusion through awareness-raising, initiatives and reporting (page 144).

Reference: pages 141-142. The percentage of employees covered by the company's health and safety management system, established under legal requirements or recognised standards, was 97.0% in fiscal 2025 (previous year: 97.7%) (page 142). There was one employee fatality, at a site in Spain, with the legal assessment still ongoing at publication (previous year: no fatalities among employees) (page 142). The number of reportable work-related accidents among employees was 454 (previous year: 386, restated), and the rate of recordable work-related accidents was 9.1 (previous year: an uncorrected 6.8, restated to 8.7 for comparability after adjusting planned working hours for vacation, sick leave and public holidays) (page 142).

Occupational safety is organised on three levels - local, divisional and corporate - under the Global Operational Safety (GOS) organisation established in January 2025, and one component is ISO 45001 (or equivalent) certification at operational locations (pages 141-142). The Lost Time Incident Rate (LTIR) has been part of Executive Board and senior management compensation plans since 2022 (page 142).

Reference: pages 137-138. The unadjusted gender pay gap, measured on gross hourly earnings, was 9.9% in fiscal 2025 (previous year: 11.4% on a comparable, country-weighted basis; the uncorrected prior-year figure was 17.0%) (page 137). The calculation subtracts average male gross hourly earnings from female gross hourly earnings and divides by the male average, per the ESRS definition, with the fiscal 2025 methodology applying country-level weighting by employee numbers, restated back to 2024 for comparability (page 138).

The annual total remuneration ratio of the highest-paid individual to the median of total annual compensation of all other employees was 144.5 (previous year: 59.8), based on a weighted contribution value by country/division; the increase mainly reflects payout of the 2022 LTI tranche after its four-year performance period, and excluding that tranche the ratio is 73.5 (page 138).

Reference: pages 145-146. The number of complaints from workers received through the Rheinmetall Whistleblower System in fiscal 2025 was 202 (previous year: 146). A total of 10 confirmed cases of discrimination, including harassment, were recorded (previous year: 12, though this figure rose by three cases after publication of the 2024 annual report due to review processing time, and the 2025 figure may likewise still increase) (page 146). There were no complaints submitted to the OECD National Contact Points for Multinational Enterprises, and no significant fines, penalties or claims for damages connected to the incidents and complaints mentioned (page 146).

There were no serious incidents regarding human rights related to workers within Rheinmetall's business operations, no complaints regarding violations of the UN Guiding Principles on Business and Human Rights or the OECD Guidelines for Multinational Enterprises, and no related fines, sanctions or compensation payments (page 146).

Reference: pages 146-147. The Supplier Code of Conduct (SCoC) defines requirements for suppliers on human rights, working conditions, environmental protection and ethical business conduct, covering Tier 1 to Tier N suppliers and their workers, and referencing the OECD Guidelines for Multinational Enterprises, ILO Core Conventions, the UN Sustainable Development Goals, the UN Global Compact and the Diversity Charter; it was updated to version 3.0 on 1 January 2025, streamlined and made more user-friendly, with suppliers no longer required to formally countersign but obliged to consent during onboarding (page 147). The Instruction for Supplier Assessment under the German Supply Chain Due Diligence Act (LkSG), an internal guideline, was revised in fiscal 2025 and takes effect in 2026 as version 2.0 (page 147).

Rheinmetall's 2022 Responsible Minerals Sourcing Policy aims to ensure raw materials are not sourced from conflict regions, and the 2018 FAIR2ALL global framework agreement extends due-diligence expectations to business partners and suppliers (page 147).

Reference: page 148. Rheinmetall states directly that "the double materiality analysis did not reveal any significant impacts, risks or opportunities in relation to exchanges with workers in the value chain or remedial measures. There is no general approach to exchange with workers in the value chain" (page 148). Engagement instead operates indirectly through supplier-facing mechanisms: the Supplier Code of Conduct and systematic risk analyses (page 147), and external multi-stakeholder channels such as the Automotive Sector Dialogue (member since 2021, self-financed from July 2025 under the UN Global Compact umbrella, including a project group on "Collective Measures in India" focused on working conditions), the UN Global Compact, the "Helpdesk for Business and Human Rights", and the German Institute for Compliance (DICO) working groups on ESG, human rights and investigations (page 149).

Reference: pages 147-149. Risk analyses under the LkSG are integral to the purchasing process, run through a two-stage system: an abstract country- and industry-risk assessment (covering environment, ethics, labour and human rights via indices including the Environmental Performance Index, Human Development Index and Corruption Perception Index), followed by a supplier-specific evaluation generating a scorecard; high-risk suppliers trigger Operational RGP Council review, potentially including audits (pages 147-148). Audits require three calendar days' notice, supplier document/premises access, and confidentiality safeguards; a three-step escalation process applies to LkSG-relevant incidents, from direct-supplier correction, to ESG Supply Chain Officer follow-up and possible audit, to Operational RGP Council involvement and potential blacklisting after six months without evidenced remedy (pages 148-149).

Workers in the value chain, like other third parties, can report anonymously via the Integrity Line whistleblower platform (page 149).

Reference: page 149. No reports of actual negative impacts on workers in the value chain were received via the Rheinmetall whistleblower system in fiscal 2025; however, Rheinmetall became aware of four incidents in the deeper upstream value chain through supplementary evaluation of media reports and information from the downstream value chain (page 149). The company states it "investigated the reports with due diligence and supported its direct suppliers in planning and implementing the necessary remedial measures along the value chain", and that "a system for reviewing the effectiveness of the measures is currently being set up" (page 149).

The 'Supply Chain Transparency and Risk Management' project, using a geolocation tool and further tools to trace raw materials in intermediate products, aims to build transparency and resilience in the deeper upstream value chain within the purchasing department (page 147).

Reference: page 147. Rheinmetall states that "with regard to the workforce in the lower upstream value chain, no actual material negative impacts, risks or opportunities were identified in the double materiality analysis. For this reason, no separate targets have been defined for the workforce in the lower upstream value chain in accordance with the European Standards for Sustainability Reporting" (page 147). In place of formal targets, the company describes forward-looking indicators and initiatives intended to identify and minimise potential risk in this area, including the "Supply Chain Transparency and Risk Management" project within the purchasing department, which uses a geolocation tool and additional tools to build transparency on raw-material origin in intermediate products (page 147).

Reference: page 150. Rheinmetall operates a B2B automotive-component business and a B2G defence-technology business; end users are private and commercial vehicle users in the civilian division and, in defence, soldiers and government-customer personnel such as police officers (page 150). Product safety is governed by the Product Safety Policy, managed by Rheinmetall AG's central Research, Technology, Development and Innovation (RTI) division, and incorporates the OECD Guidelines for Multinational Enterprises, ILO Core Labour Standards, the UN Sustainable Development Goals and the UN Global Compact principles (page 150).

The policy sets out a consistent process for systematic handling of risks and hazards, Group-wide exchange of information between technical experts, and independent product safety management validated by each Management Board; product safety engineering is embedded from the design phase, and required resources are considered from the quotation phase onward (page 150). Quantitative product-safety objectives are not pursued (page 150).

Reference: pages 150-151. Customer representatives - such as procurement authorities or delegated users - are directly involved in product development through fixed technical milestone reviews and continuous system safety working groups (page 150). In the defence sector, customers typically commission studies before tendering to investigate how to close an identified capability gap, sometimes covering risk-mitigating measures such as laser-reflection eye-safety risk during operation and maintenance; results feed into subsequent procurement specifications, and a human factors analysis considers influencing factors such as stress, ergonomics and usability (page 151).

Additional field testing with government customers incorporates their requirements and change requests, accompanied by internal and external audits for compliance with quality specifications and product safety policies; regular milestone communication and working-group exchanges with government system experts continue through the development process (page 151).

Reference: page 151. Direct contact persons are designated for Rheinmetall's B2B and B2G customers to report product safety incidents after delivery, supplemented by market and field observation drawing on public sources such as specialist articles and subject-specific databases (page 151). Reported or otherwise known safety-related incidents are analysed by product safety staff at the relevant Rheinmetall companies so that countermeasures can be taken, which may include releasing further safety information, temporarily restricting product use pending revisions, or recall campaigns (page 151). User surveys and experience exchanges with users are also conducted (page 151). The Group's publicly accessible whistleblower system is available to end users or their representatives for security-related incidents, though the report notes it made no determination of whether consumers or end users are aware of, or trust, that system (page 151).

Reference: page 150. Rheinmetall took measures during fiscal 2025 to maintain product safety, including periodic evaluations of Product Safety Policy implementation at existing and new companies, and initial training and onboarding of new product-safety workers, for example on product liability, risk tracking and risk minimisation (page 150). Evaluations of Product Safety Policy implementation were carried out in 2025 at Rheinmetall Denel Munition, Rheinmetall Laingsdale and Rheinmetall Resonant, and new product safety experts were trained (page 150).

Deviations from the Product Safety Policy are recorded in reports and tracked, and training-course participation is documented via certificates of attendance (page 150). Compliance and process effectiveness are ensured through audits by each organisation's product safety management, the central Product Safety & Cybersecurity Management (PSCM) function, and independent safety assessors (page 151). In fiscal 2025, there were no known cases of non-compliance with the OECD Guidelines, ILO Core Conventions, the UN SDGs, the UN Global Compact or the Diversity Charter relating to end users (page 151).

Reference: page 150. Rheinmetall states plainly that "no separate target definitions have been defined for consumers and end users in accordance with European standards for sustainability reporting", adding that the company "strives to identify and minimize potential risks in this area using the following indicators" (page 150). In place of formal ESRS-aligned targets, product safety performance is tracked through the audit concept laid down in the Product Safety Policy, periodic evaluations of policy implementation at Group companies (with 2025 evaluations at Rheinmetall Denel Munition, Rheinmetall Laingsdale and Rheinmetall Resonant), tracked deviation reports, and training-participation records, overseen by the central Product Safety & Cybersecurity Management function (page 150).

Reference: pages 151-152. Rheinmetall's corporate values are respect, trust and openness, with a mission statement of "taking responsibility in a changing world"; the Executive Board communicates through CEO letters, video messages, location newsletters, notices and the Rheinmetall app, and engages directly with workers during factory visits (page 151). A biennial global soccer tournament, sports and cultural sponsorships, and support for veterans (including hosting the first National Veterans Day and sponsoring the 2025 National Veterans Congress in Berlin) reinforce corporate culture, alongside a twice-yearly anonymous morale survey with results published and discussed internally (page 152).

Business conduct governance centres on export control (a dedicated organisation ensuring compliance with German/European Foreign Trade Law, the War Weapons Control Act and international sanctions), corporate security (led by a function reporting to the CEO), and cybersecurity (a multi-year strategy under the Chief Information Security Officer, supported by a Security Operations Centre and CIRT) (page 152).

Reference: page 157. Rheinmetall Group Purchasing manages supplier relationships with the objective of building resilient, efficient, cost-effective and sustainable supply chains while avoiding excessive dependence on individual suppliers or countries of origin; the Strategic Group Purchasing Council sets targets and strategic decisions, while the Operative Rheinmetall Group Purchasing Council handles ESG-related tasks and acts as the highest escalation authority for critical-supplier decisions (page 157).

ESG criteria are an integral part of supplier award decisions: the Supplier Code of Conduct sets safe-working-conditions and ethical-practice standards, creditworthiness and anti-money-laundering compliance are checked at onboarding, and suppliers undergo an abstract sustainability risk analysis followed by a supplier-specific evaluation for those flagged high-risk, with connection contingent on a positive result (page 157). New contracts require manufacturers to have, or commit to developing, a decarbonisation roadmap, and suppliers may be required to disclose product carbon footprints (page 157).

Reference: pages 153-154. Rheinmetall's anti-corruption strategy aligns with the UN Convention against Corruption, embedded within a central compliance management system covering corruption, data protection and fraud risk, overseen by the Chief Compliance Officer, who reports regularly to the Executive Board and Audit Committee (page 153). A compliance risk assessment regulation ensures systematic risk prevention, supported by a reporting tool tracking training, audits, risk analyses and compliance-project status across the organisation (page 154).

Mandatory training on corruption and bribery prevention, conflicts of interest, money laundering and fraud is delivered every three years (60 days for new workers) via web-based and face-to-face sessions; 100% of high-risk functions are covered by the training programme, and 35.9% of workers in high-risk roles participated during the fiscal year (previous year: 38.0%) (page 154). Central Investigations, supported by independent Ombuds officers, handles reports via the "Integrity Line" whistleblower platform and speakup@rheinmetall.com (page 155).

Back-filled per the MDR-T "effectiveness tracked in the absence of a target" limb, drawing on the Business Conduct / Compliance chapter of the FY2025 report (pages 153-155). This disclosure requirement is renumbered from the 2023 ESRS MDR-T rather than newly introduced, and the report was prepared under the 2023 ESRS, so no standalone G1-3-Targets section exists. No explicit numeric business-conduct target (such as a target training-completion rate) is stated; instead, effectiveness is tracked through a dedicated reporting tool that "offers a wide range of options for tracking, evaluating and controlling the status of a large number of compliance-related processes and projects", covering training-course status, audits, risk analyses and guideline roll-out levels, feeding compliance reporting to the Executive Board and Supervisory Board "focus[ed] on identified compliance risk areas and the mitigation measures established, as well as the related KPIs" (page 154). Concrete tracked indicators include the 100% coverage of high-risk functions by anti-corruption training and the 35.9% fiscal-2025 participation rate among high-risk-role workers (page 154), and the year-on-year comparison of confirmed corruption/bribery convictions and excluded business partners under G1-4 (page 156).

Reference: page 156. In fiscal 2025, there were no convictions or fines for violations of corruption and bribery regulations (previous year: none) (page 156). Where internal investigations lead to confirmed cases, labour-law measures are taken against the employees concerned irrespective of any court decisions or official investigations; business partners found in violation of corruption or bribery regulations are excluded from all business relationships with Rheinmetall Group companies (page 156). No business partner was affected by this exclusion measure in fiscal 2025 (previous year: one) (page 156).