Salzgitter

Reference: page 103

Two-tier board under the German Stock Corporation Act. The Supervisory Board "is made up equally of ten representatives each of the shareholders and the employees, supplemented by one further, neutral member"; the Executive Board "as a general rule ... is made up of three members: the CEO, the CFO and the CPO" (page 103).

Diversity is quantified: the Supervisory Board "had seven female members in the reporting year. This corresponds to a gender diversity on the Board of 7 : 14 or 50 %", and the Executive Board "consisted of two women and one man" (page 104). Sixteen Supervisory Board members were still in working life and five over 65. After the December 4, 2025 resolution of the shareholder representatives, "66.66 % of the members of the Supervisory Board are to be classed as independent" (page 103).

Conflicts of interest are disclosed: none new in 2025, but two members had flagged in December 2024 a possible conflict over the takeover offer by GP Guenter Papenburg AG and TSR Recycling (page 103).

The ESG structure is set out on pages 108-109: a CSRD Steering Committee chaired by the CFO for reporting compliance, an ESG Steering Committee led by the CEO for prioritisation, an ESG working group, and an ESG roundtable across Group companies.

Reference: page 109

Environmental matters reach the Executive Board and Group Management Board on a needs-driven basis, supplemented by strategy workshops "conducted with the Executive Board four times a year", and "The status of the SALCOS(R) program features on the agenda at every joint meeting of the Executive Board and Group Management Board" (page 109).

The disclosure then names the individual IROs discussed in the year rather than describing the process in the abstract. Sixteen environmental IROs are listed by name and type, from "Pioneering role in the decarbonization of industry (actual, positive impact)" and "Imponderables surrounding the transformation of primary steel production (climate-related transition risk)" through to "High volumes of waste in steel production (actual, negative impact)" (page 109).

It also records how sustainability entered specific decisions: climate protection and energy fed into the decision to raise the budget for the first SALCOS(R) stage at Salzgitter Flachstahl GmbH; working conditions fed into the assessment of the Executive Board's 2024 variable remuneration and the setting of the 2026 targets. "No compromises had to be made in connection with these sustainability aspects in the reporting year" (pages 111-112).

Reference: page 112

Thirty per cent of the Executive Board's annual bonus and 30 % of its performance cash award "depends on non-financial targets besides financial targets" (page 112). The Supervisory Board sets these taking account of "occupational health and safety, improving ESG ratings, implementation of the SALCOS(R) transformation program ... or the sustainable expansion of scrap recycling".

The targets agreed in 2024 for 2025 "can be predominantly assigned to the sphere of sustainability", and those agreed in 2025 for 2026 "can be exclusively assigned to this sphere" (page 112). They cover demographic change, accident reduction, securing green electricity, the proportion of women in managerial positions, structured employee interviews and an ideas management system, measured through named parameters including the percentage reduction in Lost Time Injury Frequency and "the proportion of green electricity volumes secured measured against the Group's total electricity requirement".

On climate specifically: "In the reporting year, no climate-related considerations associated with the emission reduction targets announced were incorporated into the remuneration of Supervisory Board members." They entered Executive Board pay only through the Performance Cash Award 2021-2024, paid out in 2025, which weighted decarbonisation milestones at 30 % (page 112).

Reference: page 113

GOV-4 is answered with a mapping table rather than narrative: "Below we list the information provided in this report on the procedure for meeting due diligence obligations" (page 113). Each of the five core elements is cross-referenced to the paragraphs that carry it.

The table maps embedding due diligence in governance, strategy and business model to ESRS 2 GOV-2, GOV-3 and SBM-1 plus the topic-level GOV-3 and SBM-3 sections for G1, E1, S1 and S2; engaging affected stakeholders to GOV-2, SBM-2, IRO-1 and the S1 and S2 SBM-2 sections; identifying and assessing negative impacts to IRO-1, SBM-3 and the topic-level IRO-1 sections; actions to the MDR-A content across E1 to E5, S1, S2 and G1; and tracking effectiveness and communication to the MDR-T and MDR-M content across the same standards (page 113).

It is a signposting disclosure only. The digits identifying individual disclosure requirements in this table did not survive text extraction from the PDF, so the cross-references above are read from the table structure and surrounding headings; a reader checking a specific one should consult page 113 of the report.

Reference: page 113

"The Executive Board of Salzgitter AG bears Overall responsibility for the sustainability reporting and for the accuracy of the information reported. The Supervisory Board verifies the contents of the sustainability reporting as part of its monitoring role" (page 113). Process ownership sits with the ESG team in Strategy and Corporate Development, coordinating content from Legal, Compliance & Insurance, Personnel and Social Policy, Purchasing, Central Occupational Safety and Group Controlling.

The sustainability-related internal control system (sICS) "is an integral part of the Group's existing internal control system" and "is based on a risk-oriented scoping approach and pursues the goal of preventing erroneous or improper disclosures in the sustainability statement". Technical departments "define control activities for critical data points with a risk exposure of 'medium' or 'high'" (page 113).

The risks are named: "The most pertinent risks relate to quantitative data points from the ESRS E1 report standard in conjunction with the 'Corporate Carbon Footprint' sub-process, ESRS S1 in conjunction with the 'Data collection for key indicators for occupational health and safety' and the reporting of EU taxonomy-compliant KPIs" (page 114). A standardised sICS questionnaire documents local controls, and internal audit reports ICS effectiveness to the Executive Board regularly and to the Audit Committee annually.

Reference: page 114

"Our vision is to establish Salzgitter AG as a leading company in the circular economy world" (page 114). The "Salzgitter AG 2030" strategy carries the sustainability strategy, grouped into six focus areas, two each under Environmental, Social and Governance: Climate, Transformation, Employees, Value chain and Integrity, plus supplier relationships (pages 114-116).

"The most important product groups in the Salzgitter Group are our steel products and the packaging and filling systems and special machinery that we manufacture" (page 116). External sales fell to EUR 8,981 million from EUR 10,012 million, "mainly due to lower selling prices for steel products and the deconsolidation of the stainless steel tubes group", with exchange rates costing EUR 58 million and deconsolidations EUR 315 million (page 62, incorporated into SBM-1 paragraph 40 b by reference per the table on page 103). Seventy-six per cent of external sales were generated in Europe (page 18, incorporated by reference).

Page 116 carries the Group's sustainability targets by focus area, each tagged quantitative or qualitative with a target year: 20 % lower emissions per tonne of hot-rolled steel by 2028, 100 % renewable purchased electricity by 2030, scrap recycling to 3 million tonnes a year by 2030, and a 50 % cut in accidents by 2030 against 2021.

The core workforce numbered 22,014 employees at December 31, 2025 (page 25).

Reference: page 120

SBM-2 is a stakeholder table naming each group, the channels used and the subjects discussed (pages 120-122). Customers are engaged through visits, conferences, customer events and trade fairs on strategy, "Strengthening customer relationships, setting up strategic partnerships with regard to closed loops" and "SALCOS(R): sustainable, low carbon steel production".

Employees are engaged through "Co-determination bodies at Group and company level", manager and employee events, workforce meetings and ideas management, on company development, occupational health and safety, training, employer attractiveness and investments.

Political circles are engaged on green lead markets, "Transformative regulatory policy: Subsidies and regulatory systems", export policy, "Design of EU ETS and CBAMs", the circular economy and named current risk issues: "Russia sanctions, energy security, hydrogen ramp-up, foreign trade protection". Regional communities, NGOs and research partners are engaged through regional networks, associations, universities, facility visits and research projects.

The route into the DMA is indirect and the company says so: stakeholder groups were assigned to internal experts who "are familiar with the views of the relevant stakeholder groups"; workforce topics were discussed with employee representatives in a joint workshop; and "No external experts were consulted as part of the double materiality analysis" (page 128).

Reference: page 123

The SBM-3 table runs across pages 123-126 and sets out all 23 material IROs with, for each, the standard, sustainability topic, IRO name and type, an explanation, the expected time horizon and the allocation to own operations or value chain.

Climate carries four: the positive impact "Pioneering role of the decarbonization of industry", the negative impact "Increase in global greenhouse gas concentrations", the long-term transition risk "Imponderables surrounding the transformation of primary steel production" and the opportunity "Climate protection as value creation driver". Energy carries four more, including "Use of finite, fossil energy sources", "Promotion of energy transition" and "Hydrogen as a future source of energy" (pages 123-124). Pollution carries two, water two, circular economy five, own workforce three, value chain workers one and business conduct two (pages 124-126).

Changes on the year are disclosed: "The energy risk, hitherto classified as material, was no longer deemed to be material"; a new positive water impact was added because "The significance of a safe drinking water supply was classified as nationally material for the economic infrastructure"; and the "skilled labor shortage" risk "does not reach the defined thresholds" (page 127). Risk aggregation "showed that Salzgitter AG is not exposed to any existential threat" (page 127).

Reference: page 128

The DMA was built on the business model, strategy and value chain: "All business units and key activities were included in the materiality analysis ... Consequently, no further breakdown was required here", and the process "did not focus on different geographical circumstances or other factors" (page 128). Sources were "the topic-specific ESRS sustainability aspects, the Global Reporting Initiative, the World Economic Forum, the SASB and the results of our materiality analysis from the 2024 financial year", with risks from the risk inventory or the Supply Chain Due Diligence Act analysis.

Scoring is described precisely: actual impacts on severity (scale, extent, irreversibility), potential impacts on severity plus likelihood; "Negative impacts were evaluated in all three severity categories on the basis of a 5-point scale while positive impacts were only assessed in accordance with their scale and extent". For human rights, "severity takes precedence over probability" (page 129).

"A threshold of 3.5 on a scale of 1 to 5 was defined for determining material IROs" (page 130). Validation ran through the ESG Steering Committee, the Executive Board and Group management, then the Audit Committee, and "The result of our materiality analysis comprises 23 material IROs" (page 130). The process "was last completed in November 2025". Stakeholder input was internal: "No external experts were consulted" (page 128).

Reference: page 131

The IRO-2 narrative explains the mapping method and points to the index: "The list of sector-independent disclosure requirements covered and the list of datapoints from other EU legal regulations can be found in the Appendix to the Sustainability Statement" (page 131). The index itself sits on pages 195-198.

No thresholds were used: "it proved possible to unambiguously match the material IROs and sustainability aspects with the ESRS disclosure requirements. Wherever a material IRO was determined on a particular subject, the entire sub-topic in each case was classified as material together with all disclosure requirements", and "No use was made of the option under ESRS 1 34 b to omit the information specified for a datapoint ... on grounds of materiality" (page 131).

The index lists disclosure requirements covered under 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 E2-4), E3 (E3-1 to E3-4), E5 (E5-1 to E5-5), S1 (S1-1 to S1-6, S1-13, S1-14, S1-17), S2 (S2-1 to S2-5) and G1 (G1-1, G1-2, G1-6). E4, S3 and S4 do not appear (pages 195-196). The second index marks the E1-9 and one S1-14 datapoint "Phase-In" and the S1-16, S3, S4, G1-1 corruption and G1-4 datapoints "not material" (pages 197-198).

Reference: page 141

The transition plan is the SALCOS(R) programme. Salzgitter "has embarked on the 1.5-degree pathway enshrined in the Paris Climate Accords, with validated targets in accordance with the Science Based Targets initiative (SBTi)" (page 141). "Once all the stages have been fully implemented, we will have the technical capability to save around 95 % of our Scope 1 carbon emissions from primary steel production", with full transformation by "the mid-2030s" and net zero by 2050 at the latest.

Financing: "The entire CapEx budgeted for implementation of the first SALCOS(R) stage amount to EUR 2.7 billion", around EUR 1 billion of it subsidised (pages 141-143). The Group "has no coal, oil or gas-related business activities" (page 142).

Approval and embedding are explicit: the plan "is, for the first stage, firmly embedded in our Group strategy as well as our Group finance planning ... The Supervisory Board approved the company funds required on July 13, 2022, and issued its agreement to the adjustments to the overall budget on March 23, 2023, and again on September 18, 2025" (page 142). On locked-in emissions, "we are addressing more than 90 % of today's Scope 1 and Scope 2 emissions" (page 142).

Progress is itemised by sub-project, the electrolyser to "supply around 9,000 tons of green hydrogen per year" (pages 142-143). Against that, "it was decided in September 2025 to postpone the investment decision on further expansion stages ... until 2028/29" (page 142).

Reference: page 144

Back-filled from ESRS 2 IRO-1 as applied to climate and from the E1 SBM-3 section, where this content is disclosed in the FY2025 report (pages 143-145). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification: only one climate risk is material and it is a transition risk, "Imponderables surrounding the transformation of primary steel production", long term, own operations and upstream (page 123). On physical risk the finding is nil: "no physical climate risks had been identified which lead to material impacts, risks and opportunities ... For that reason, the sub-topic of 'climate change adaptation' is not material and thus not reportable" (page 144).

Methodology: Salzgitter "takes the framework offered by the Task Force on Climate-Related Financial Disclosures (TCFD) as its guideline. Physical risks were analyzed with the aid of a data-driven risk analysis for the Salzgitter Group's facilities ... until 2050 ... The climate scenarios used are SSP1-2.6 and SSP5-8.5" (page 144).

Scenario analysis: scope is the Steel Production and Steel Processing units, "responsible for more than 95 % of Scope 1 and Scope 2 emissions" (page 143). High-emission scenario SSP5-8.5; transition scenario the IEA "Net Zero Emissions by 2050" 1.5-degree pathway, chosen for its iron and steel pathway (pages 143-144). Horizon to 2050. No temperature projection is stated per scenario.

Reference: page 143

Back-filled from ESRS 2 SBM-3 and the E1 resilience section (pages 127 and 143-144). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results: "In the reporting year, a resilience analysis was conducted with a time horizon stretching to 2050 and using relevant climate scenarios", covering units "responsible for more than 95 % of Scope 1 and Scope 2 emissions" (page 143). The conclusion is a nil finding: "As our transition plan and the ongoing measures derived from them meet the requirements for the 1.5-degree pathway, no additional material impacts, risks and opportunities were identified from examination of the scenario" (page 144). "Even in the IPCC SSP5-8.5 scenario ... no physical climate risks had been identified" that might put the strategy, facilities or business model at risk (page 144).

Uncertainty is carried by the transition risk: the financial viability of further transformation, "especially as project and budget planning for further SALCOS(R) stages are not yet complete", plus green lead markets, border adjustment systems and renewable energy cost (page 143).

Capacity to adapt: SALCOS(R) is modular, letting the Group "flexibly adapt the remaining transformation steps to changing market conditions" (page 141), and risk aggregation "showed that Salzgitter AG is not exposed to any existential threat" (page 127). The September 2025 postponement of later stages is that flexibility in use.

Reference: page 145

"Our 'Climate change' company guideline describes the policies related to climate protection ... Ultimately, the Executive Board of Salzgitter AG bears the responsibility and has the decision-making authority for the topic of climate change. The guideline's scope covers all Group companies, both domestically and abroad" (page 145).

Three levers are prioritised for Scope 1 and 2: "Saving process-related CO2e emissions", "Boosting the share of electricity from renewable sources" and "Optimizing production processes and raising energy efficiency". The first is the largest and "essentially means the transformation of primary steel production which is pooled in our SALCOS(R) program" (page 146).

Energy has separate governance: a "Strategic Energy steering committee" at the holding company and an "Operational Energy steering committee" at Salzgitter Flachstahl GmbH (page 146).

The guideline "stipulates that 100 % of the Salzgitter Group's requirements for purchased electricity should come from renewable sources by 2030". Power Purchase Agreements are the instrument, and "According to the RE-Source platform, the contracts already concluded put Salzgitter AG among the top 15 companies in Europe for the most PPAs concluded"; a further photovoltaic PPA tender with on-site battery storage was issued in the year (page 146). ISO 50001 certification covered 66 % of facilities by employee numbers (page 147).

Reference: page 147

"Our current action plan comprises the four relevant measures in the first SALCOS(R) stage": the direct reduction plant, the electric arc furnace, the 100 MWel electrolyser and the 380 kV grid connection, with ancillary facilities (page 147).

Timing: "We intend to commission the first SALCOS(R) stage in the first half of 2027 and shut down the first blast furnace once operation is stable. The direct reduction plant with connecting electric arc furnace using the hydrogen from a 100 MWel electrolyzer will then be set to account for more than 30 % of SZFG's primary steel production capacity" (page 147).

Value chain actions name counterparties: SZFG works with "Binding Solutions Ltd for cold agglomerated, CO2e-reduced iron ore pellets and with Oldendorff Carriers GmbH for maritime, CO2e reduced iron ore transport" (page 147).

Resourcing: "In the current financial year, capital expenditure for the first stage less subsidies received totaled EUR 174.9 million (previous year: EUR 413.6 million). Of this figure, EUR 24.9 million represents capitalized borrowing costs"; Taxonomy OpEx was "around EUR 5 million" (pages 148-149). The company adds that continuation "is heavily dependent on the availability and allocation of financial resources" (page 149). A waterfall on page 148 breaks the 2021-2028 pathway down by lever, on the operational control basis rather than E1-6's.

Reference: page 149

Targets run from a 2021 base year and are SBTi-validated. Short term: "We want to reduce our CO2e emissions per ton of hot-rolled steel by 20 % by 2028" under the sector-specific SBTi "Iron & Steel" guideline, covering "more than 95 % of our Scope 1 and Scope 2 emissions" plus specified upstream Scope 3. "For the target year of 2028, we want to achieve an average intensity of 1.49 t of CO2e per ton of hot-rolled steel product", assuming "a constant scrap rate averaging 32 %" (page 149).

Alongside: a 35.6 % cut in Scope 1 and 2 in the Technology business unit by 2028; a 20 % absolute cut in the most relevant Scope 3 categories (purchased goods and services, fuel and energy-related activities, waste, use of products sold, investments); and "33.6 % reduction in absolute Scope 3 CO2e emissions from the use phase of fossil fuels sold" (pages 149-150).

Long term: net zero by 2050, with "One fixed milestone ... 2045, by which time we want to reduce our Scope 1 and Scope 2 emissions by 90 %" (page 150).

Progress is reported candidly: "As expected, for the reporting year we are not seeing any major progress by comparison with the baseline year either in absolute or relative terms ... we achieved an average intensity of 1.75 t CO2e per ton of hot-rolled steel product in 2025. The scrap rate averaged 31 %" (page 150). Against the 1.49 t target, the gap depends almost entirely on SALCOS(R) stage 1 from mid-2027.

Reference: page 150

Energy use is dominated by iron ore reduction and process heat. By-product gases from coal are recovered on site: "Almost 100 % of the 1,564,071 MWh of self-generated electrical energy comes from this origin and thus from non-renewable sources. Steam generation amounted to a further 697,483 MWh of thermal energy. We also produced less than 1.5 GWh of renewable electricity in our own generation systems" (page 150).

The ESRS energy table on pages 150-151 reports the full breakdown by source, with total fossil, nuclear and renewable consumption and their shares. FY2024 comparatives survive text extraction - 27,920,291 MWh from coal and coal products, 3,455,947 MWh from natural gas, a 99.0 % fossil share - but the FY2025 column did not and is not reproduced here.

Apart from a few subsidiaries in NACE sections J, K, L and M, "nearly all the subsidiaries of Salzgitter AG operate in high climate impact sectors. Consequently, their energy consumption is more or less equal to the Group's entire energy consumption" (page 151). Energy intensity per net revenue from those activities is disclosed with a connectivity table to Group net revenues.

The Group-wide "EnERGY" efficiency network dates from 2016; "The saving of at least 100 Gwh / a will be verified by an external body in the first quarter of 2026" (page 150).

Reference: page 151

Scope 1 and 2 cover Group companies held above 50 % plus joint operations pro rata - "This procedure corresponds to the financial control approach" - while remaining associates are handled on operational control, their emissions recognised in Scope 3 category 15, Investments (page 151). Scope 2 is dual-reported location-based and market-based; Scope 3 is primarily activity-based on physical data, spend-based "in exceptional cases".

A methodology change is quantified: "As of this reporting year, the corporate carbon footprint has been calculated entirely internally", and restating for comparability "led to a difference in Scope 3 emissions of approximately - 2.5 % or roughly - 500 kt CO2e in the baseline year of 2021 and - 8.8 % or roughly - 1,500 kt CO2e for the 2024 reporting year" (page 151).

The table on pages 152-153 gives the 2021 base year as published and restated, 2024, 2025, the year-on-year change and the 2028 and 2050 milestones, for Scope 1, both Scope 2 measures and all 15 Scope 3 categories. Direction is legible: Scope 1 down 8 %, location-based Scope 2 down 12 %, market-based Scope 2 down 54 %, Scope 3 down 11 %. The FY2025 values did not survive text extraction and are not reproduced here.

Scale is given in E1 SBM-3: "over 10 million tons of direct CO2e emissions per year", "more than 1 % of all direct CO2e emissions in Germany", and purchased goods plus use phase "cover more than 70 % of our entire Scope 3 CO2e emissions" (page 143).

Reference: page 153

A short but complete nil return. "With regard to our net zero target, we are focusing first on the long-term reduction of our Scope 1, 2 and 3 emissions in order to save at least 90 % in absolute terms through suitable levers. Carbon credits and offsets form an exception as these are not part of Salzgitter AG's climate protection strategy and accordingly were not used in the reporting year" (page 153).

There are therefore no GHG removals in own operations or the value chain to report, no carbon credits cancelled in the reporting year, and no planned future cancellations. The net zero claim is anchored to abatement first: E1-4 sets the same 90 % floor, with a 2045 milestone of a 90 % cut in Scope 1 and Scope 2 and residual emissions "subsequently offset in full" by 2050 (page 150). The report does not describe what instrument that eventual offsetting would use, and discloses no carbon-credit purchase policy or quality criteria, because none applies for the reporting year.

The datapoint "ESRS E1-7 GHG removals and carbon credits paragraph 6", flagged under the EU Climate Law in the appendix index of datapoints derived from other EU legislation, is cross-referenced to this section (page 197).

Reference: page 154

Salzgitter operates one internal carbon price, a CapEx shadow price for investments outside EU ETS-reportable installations. "Internal CO2e prices for measuring CapEx-based investments outside of EU ETS-reportable systems are defined for the reporting year as part of Group budgeting. These are based on the national emissions trading scheme and were centrally fixed and distributed to subsidiaries by Group controlling" (page 154).

The table on page 154 has four columns - type of internal carbon price, volume concerned in kt CO2e (previous year), price applied in EUR per tonne of CO2e (previous year), and description of scope. The type is "CapEx shadow price". The two numeric cells read 55 (previous year 45) and 91 (previous year 94). The scope note reads: "The CapEx shadow price stipulated was valid for the reporting year. The shadow price is based on the fixed price per certificate of the German national emissions trading scheme in 2025." The two-column PDF extraction does not preserve which cell belongs to which column, so price and volume are given here as the table prints them rather than assigned.

No internal carbon price is applied to operating decisions, procurement or product pricing, and none to installations inside the EU ETS. The report does not say how the shadow price is expected to develop over the transition period.

Reference: page 154

The policy instrument is the "Environmental protection" company guideline, an annex to the "Environment" Group directive: "We have set out our principles, responsibilities and targets, as well as the central levers and action plan with respect to air quality and the protection of water resources" in it (page 155). "Ultimately, it is incumbent upon the Executive Board with the support of the Group Management Board to actively track Group specifications, strategies and targets and convert them into appropriate measures" (page 155), with Group-wide coordination through the "Environment and Energy" steering committee.

Scope and cause are stated plainly: "Emissions of air and water pollutants are particularly significant due to the processes necessary for steel production and processing", and "The majority of the air and water pollutants emitted are caused by the system and power plant operations of Salzgitter Flachstahl GmbH (SZFG)" (page 154).

The pollutants covered are defined and tabled: "Particulate matter, sulfur dioxide and nitrogen oxides are particularly prevalent, while dioxins and heavy metals occur in smaller quantities" (page 155). ISO 14001 certification covered "70 % - based on the number of employees" (page 155). The company commits to E-PRTR limits at European facilities and routes external complaints through the FAIR TOGETHER whistleblower system, open to local residents (page 156).

Reference: page 156

Salzgitter states that it has no formal action plan for pollution and explains why: "The key levers and measures for avoiding air and water pollutants are essentially summarized under the environmental protection measures. There are currently no comprehensive action plans." Actions "are to be continuously implemented and perceived as an ongoing assignment for which there are no defined implementation deadlines. Instead, the environmental protection activities of the Salzgitter Group are based on an established organizational structure" (page 156).

The value chain position is a stated nil return rather than a silence: "As things stand today, no further measures will be implemented in the upstream and downstream value chain as, in our view, there is no need for them" (page 156).

Two concrete measures are named. An in-house capability: "the Salzgitter facility has its own accredited immisions protection laboratory ... which conducts on-site measurements and analyses, which are subject to regular checks by an external expert". And a capital project: "the investment in a modern walking beam furnace and an exhaust gas heat recovery system at Salzgitter Flachstahl GmbH ... Commissioning is scheduled for 2028" (page 156).

The measures are then listed by category - best available technologies, low-emission production processes, modernisation, filter and capture technologies, and regular maintenance. No monetary amounts are attached (page 156).

Reference: page 157

The target is qualitative and the company says so directly. "Salzgitter AG is committed to the goal of reducing emissions of harmful substances at all production facilities to a minimum through the use of suitable processes and technologies, thereby contributing to air quality and the protection of water resources. The observance of statutory provisions and official requirements represents an unshakeable framework within which we conduct our entrepreneurial activities. Breaches of the law are not tolerated" (page 157).

The reason no measurable target exists is given: "No further measurable targets were set out beyond the qualitative target for maintaining clean air and protecting water resources, as minimum requirements and limits are defined in the comprehensive legal provisions" (page 157). Effectiveness is tracked through E-PRTR reporting of unintentional releases and through ISO 14001 recertification, under which "the existing systems for guaranteeing environmental protection are also subjected to constant review and refined".

The Group target table carries the same ongoing qualitative target: "Conscientious compliance with national laws and official requirements in relation to the release of pollutants in order to maintain operating permits" (page 116). No baseline year, target year or reduction percentage is disclosed for air or water pollutants: legal compliance is the whole of the stated ambition.

Reference: page 157

The metric basis is disclosed before the numbers. "Environmental metrics are recorded in the Salzgitter Group through a central data management system ... Absolute volumes of air and water pollutants were used to determine the key IROs" (page 157). Measurement follows the regulatory regime: pollutants "essentially occur in our PRTR-reportable systems and are continuously measured or calculated at regular intervals", with annual loads determined "in compliance with the requirements of the German PRTR Ordinance" and reported at Group level to the European Pollutant Release and Transfer Register.

The tables on pages 157-158 report air and water pollutant loads in tonnes, substance by substance, with prior-year comparatives. The water pollutant table covers total nitrogen, total phosphorus, zinc, cyanides, nickel, lead, chromium, mercury, arsenic, copper and phenols as total carbon (page 158). Several substances carry a footnote marking that no previous-year figure is available.

A restatement is disclosed: "The calculation methods used for key indicators for air and water pollutants were standardized and adjusted leading to an adjustment of the figures for the previous year" (page 102). HKM "is included in the metrics" but "not included in the strategic presentation due to a lack of operational control" (page 154). The FY2025 column of the pollutant tables did not survive text extraction from the PDF and the 2025 tonnages are not reproduced here.

Reference: page 159

"The resource of 'water' enjoys an invaluable standing for Salzgitter AG. Not only is it a crucial production factor, but it also forms the basis for the activity of our manufacturing Group companies. For example, Salzgitter AG with its affiliated companies is both the operator of waterworks, a major consumer of water, a water supplier and the operator of wastewater treatment plants" (page 159).

The policy instrument is the "Water management" company guideline, an annex to the "Environment" Group directive, applying to all Group companies. It commits to "avoiding negative, water-related impacts from our business activities through the use of suitable processes and technologies at all facilities", and "Besides setting targets, the guideline also defines the principles and responsibilities as well as the central levers and measures relating to the material sub-topic of 'water'" (page 159). Responsibility sits with the Executive Board supported by the Group Management Board.

Salzgitter Flachstahl also acts as a water utility, passing water from its own Boerssum-Heiningen waterworks to industrial customers "such as MAN, Alstom and VW"; the lime softening residue "is used as certified fertilizer" (page 159). "All facilities with high water stress are covered by our 'Water management' company guideline" (page 160), and ISO 14001 covers 70 % of employees. No marine resources policy is disclosed; the material sub-topic is "water" only (page 158).

Reference: page 160

As with pollution, the company states that it runs continuous improvement rather than a plan: "Due to the constant refinement of improvement processes, we do not define any specific deadlines for concluding these interlocking measures. There are currently no comprehensive action plans" (page 160).

Two named investments anchor the disclosure. Wastewater treatment: "The extension of SZFG's own wastewater treatment system to include a fourth purification stage in 2024 created the conditions for enhanced water pollution control" (page 160). And the drinking water supply role behind this year's new positive IRO: "The Boerssum-Heiningen waterworks and the treatment plant in Adersheim use common groundwater resources and contribute to the region's secure water supply ... SZFG supports reliable drinking water provision for industry and residents, thereby reinforcing the economic infrastructure in the Salzgitter and Braunschweig area." Group-made water pipes are used in supply projects "such as recently in Angola" (page 160).

The measures are then listed by category. Technical: best available technologies, water-saving production processes, modernisation, water treatment and recovery systems, closed water circulation loops, and technologies to reduce withdrawal. Operational: regular inspection and maintenance, employee training, and policies to reduce consumption (page 160). No monetary amounts or completion dates are given, by design.

Reference: page 160

The target is qualitative and stated as such: "We have set ourselves the overarching target of achieving sustainable water management in order to secure the quality and availability of water resources for the long term. The target is not subject to measurable specifications as it is embedded in daily operating processes and is thus implemented by Group companies as an ongoing assignment as part of day-to-day operations. This target also applies to regions affected by water shortages or stress" (page 160).

Two priorities give it shape. Compliance: the Group is "reinforcing its resolve to adhere to the national legal requirements in place at each production facility and specifically recognize in full the limits enshrined in them regarding water quality and pollutants". Recirculation: "we aim to use the resource of water as carefully as possible. This is a binding target for all Group companies" (page 161).

Ecological limits were not used: "No account was taken of ecological thresholds in defining the targets" (page 161). Effectiveness is tracked through ISO 14001 recertification, applying "in particular to the Steel Production and Steel Processing business units due to their high levels of water consumption".

The company closes the point explicitly: "No further measurable targets were set at a Group level beyond the qualitative target and its priorities" (page 161).

Reference: page 161

Three tables on page 161 report water withdrawal (total, and split into surface water, groundwater and third-party water), water recirculation on the same split, and total water consumption, each with a prior-year comparative in thousand cubic metres. FY2024 comparatives survive text extraction - 16,242 thousand m3 of surface water and 20,817 thousand m3 of groundwater withdrawn, 400 thousand m3 from third parties, 29,487 thousand m3 of surface water recirculated - but the FY2025 column did not and is not reproduced here.

The commentary is the substantive part of the year's answer: "In the reporting period, water withdrawal recorded a production-related decline while lower rainfall led to a corresponding reduction in recycled water. Less than 1 % of the Group's total water consumption occurs in regions affected by high water stress. No material water risks were identified" (page 161).

Water stress is screened with a named tool, the "Aqueduct Water Risk Atlas of the World Resources Institute (WRI)" (page 158). HKM "is included in the metrics" though left out of the strategic presentation for lack of operational control (page 158).

A prior-year error is corrected here: "An error occurred in the calculation for water intensity and proportion of secondary materials used in the 2024 reporting year. The figures for the previous year were corrected accordingly" (page 103).

Reference: page 163

Circularity is a strategic objective, not a compliance topic: "the Salzgitter Group's Executive Board denotes careful handling of resources and focus on circular business models as a central management task. This corresponds to the objective set out in the 'Salzgitter AG 2030' Group strategy to place 'circularity' at the heart of our transformation" (page 163). The stated ambition is "to position ourselves as the market leader for the circular economy".

The approach follows the cascade of the German Waste Management and Product Recycling Act in four steps - Reduce, Reuse, Recycle and Rethink, the last being "questioning our accustomed habits and processes" (page 163).

Context: "Nearly three quarters of the cost of steel production is accounted for by raw materials such as iron ore, scrap, reducing agents and energy" (page 163). A named partnership illustrates the policy: with Volvo Cars, "high-quality steel scrap from the Swedish car body company in Olofstroem will be fed back into steel production and processed to form new steel products with no loss of quality from 2026 onward", moved by a DB Cargo rail shuttle avoiding empty journeys and using "100 % climate-neutral traction power" (page 163).

The instrument is the "Use of resources and circular economy" company guideline. Three levers are prioritised: alternative sources for secondary materials, resource-saving system design, and material efficiency in production (page 164).

Reference: page 164

The headline action is a capital project: "The breaking of ground for the new large capacity shredder system in the summer of 2025 represented a key milestone in strengthening our in-house circular economy and ensuring security of supply. This strategic investment significantly increases intra-Group recycling capacity and the processing of old scrap to form a new, high-quality scrap grade (4 SALCOS(R))." The grade has a "comparatively low proportion of accompanying elements such as chromium, copper and nickel" and so "meets the characteristics required for the SALCOS(R) production process" (page 164).

A second stream targets new scrap sources: "the successes achieved with pilot plants in wind energy are to be consolidated as a specific implementation of our circular approach ... this includes the use of old scrap from the dismantling of demolished wind towers and the restructuring of companies to ready them for new product areas in the offshore wind sector" (page 164).

In the Technology unit, "the KHS Group offers products and services focusing on resource-saving, closed-loop production chains" (page 165).

Waste reduction is framed as a climate synergy: "Enhanced resource efficiency and the resulting fall in material requirements lower our waste and our carbon equivalent emissions in equal measure" (page 165). No monetary amounts are attached to the actions.

Reference: page 165

One quantitative target and one qualitative target. The quantitative target is scrap recycling: "Based on a scrap proportion of 2,111 kt in 2021, the plan is to expand our activities in scrap recycling to 3,000 kt p.a. by 2030 (excl. HKM). This target is based on an analysis of our production capacity, the successful implementation of SALCOS(R) stage 1 and the availability of high-quality scrap on the market" (page 165).

Progress is disclosed and is mixed: "In the 2025 financial year, our activities in the scrap recycling sphere totaled 2,137 kt (excl. HKM: 1,945 kt). This equates to an increase in the base figure of currently 1.2 % (excl. HKM: -7.8 %)" (page 165). On the basis the target is set - excluding HKM - the Group is 7.8 % below its 2021 baseline against a 2030 goal of 3,000 kt.

The qualitative target covers waste: national statutory provisions and official specifications "must be adhered to at each of our facilities", with Group companies obliged to certify environmental management systems (page 165). The Group target table records both (page 116).

"No changes were made to the targets set, the underlying parameters or the measurement methods used in the reporting period. No account was taken of ecological thresholds in defining the targets" (page 165).

Reference: page 165

The inflow boundary is defined before the table: the figures "include the most significant material flows for steel production in terms of volumes, i.e. materials which are used in the products and where the volume processed per year exceeds 40 kt. Added to this for the first time are semi-finished goods in the form of production goods and commercial goods" (page 165).

The selection method is disclosed: "a criteria-based process with input from specialist departments" taking account of "whether resources belonged to the 'critical raw materials' or 'conflict minerals' groups, but also of financial purchasing volumes, the greenhouse gas potential of an inflow of resources and aspects of our supplier risk analysis processes" (page 166).

The materials table on pages 166-167 names the inflows individually - iron ore, total scrap, alloys and metals, coking coal, bought-in coke, anthracite and coal fines, other reduction agents, limestone and dolomite, auxiliaries and ferrous metals - in kilotonnes with comparatives. FY2024 figures survive extraction (7,118 kt iron ore, 2,167 kt scrap, 2,327 kt coking coal); the FY2025 column did not.

"The Group's cost of materials in financial year 2025 amounted to around EUR 7 billion (excl.HKM). A major part of that expenditure, amounting to 28 %, was accounted for by the purchase of raw materials and energy" at SZFG and PTG (page 166). The secondary share is carried by the scrap rate, 31 % in 2025 (page 150).

Reference: page 167

"As a particularly durable, corrosion-resistant and nearly infinitely recyclable material, steel is one of Salzgitter AG's main products. It is the central material and product conceived in accordance with the circular economy principles of durability, recyclability, reparability and return to the cycle" (page 167).

Output is tabled by producing entity - Salzgitter Flachstahl GmbH, Peiner Traeger GmbH and the 30 % HKM joint operation - with comparatives, and the total is in the narrative: "Crude steel production fell in 2025, standing at around 5.9 million tons" (page 167). FY2024 comparatives survive extraction (4,257 kt, 899 kt and 1,205 kt); the FY2025 column did not.

Recyclability is quantified by route: primary steel production requires "around 20 % iron content is contributed by scrap", while with secondary steel "up to 100 % of the iron content can come from the use of recycled material", as at Peiner Traeger's electric steel mill (page 167).

Durability is addressed for the machinery business: "the KHS Group's machinery has a notional lifetime of 15 years which equates to the industry average", supported by modular concepts and modernisation services, with KHS available "to disassemble the system"; for packaging, "KHS is already in a position to offer its customers solutions with a recycled content of up to 100 %" (page 167).

Reference: page 167

Waste is one of the three material sub-topics within resource use and the circular economy, alongside resource inflows and resource outflows (page 162), and is disclosed inside the E5-5 section.

The management position comes first: "Wherever waste in steel production has so far proved to be unavoidable, in spite of innovative methods and high recycling rates of approximately one third, the company attaches great importance to its professional, appropriate disposal" (page 167).

The waste table on page 168 reports total waste generated in kilotonnes with a comparative, split into non-hazardous and hazardous, then waste diverted from disposal broken down into preparation for reuse, recycling and other recovery, and waste directed to disposal on the same basis. FY2024 comparatives survive extraction (1,617 kt non-hazardous, 76 kt hazardous); the FY2025 column did not and is not reproduced here.

Two waste datapoints derived from other EU legislation are indexed here: "ESRS E5 Non-recycled waste paragraph 37 (d)" and "ESRS E5 Hazardous waste and radioactive waste paragraph 39" (page 197).

The IRO behind it is "High amount of waste during steel production (negative impact)" (page 125). The corresponding target is qualitative - minimising waste "to what is technically and economically feasible" - and no quantified waste reduction target is set (page 116).

Reference: page 169

The material S1 IROs are three: health and safety protection as a positive impact and as a negative impact, and training and skills development as a positive impact (pages 125-126). One prior-year IRO was dropped: the "skilled labor shortage" risk "does not reach the defined thresholds and accordingly is classified as non-material in the reporting year. The subject of skilled labor shortages is therefore not given further consideration in the comments below" (page 169).

Accountability runs to the Chief Personnel Officer and Industrial Relations Director, with decentralised HR in Group companies and an HR Board of the Industrial Relations Director and business unit personnel general managers (pages 169-170).

Safety is governed by a rewritten directive: "the new 'Occupational Safety' Group directive ... defines our health and safety policies as well as the components and standards of occupational safety management ... substantively aligned with the new Health & Safety strategy and ISO 45001" (page 170). "As of the reporting date, 72 % of employees both domestically and abroad were working in companies externally certified to ISO 45001", against an intention that 100 % work to ISO 45001-based standards (page 170).

The company discloses a gap in its own mapping: "we identified individual aspects that do not yet fully reflect the relevant international standards, among them the United Nations Guiding Principles on Business and Human Rights" (page 173).

Reference: page 173

"Regular, ongoing dialog with our employees is a matter of importance to us." Engagement runs "by means of various dialog formats as well as trade unions, works councils and other forms of employee representation in the context of codetermination", with the general procedures described under ESRS 2 SBM-2 (page 173).

The structural channel is German co-determination. "On Salzgitter AG's Supervisory Board, the employee representatives play an active role in preparing the Supervisory Board's targets for the Executive Board and monitoring their implementation" (page 173) - a channel with real content this year, since those non-financial targets include the LTIF accident metric, demographic change and the proportion of women in managerial positions (page 112).

"The (Group) Works Council is the central co-determination and participation body for our workforce. In view of the decentralized Group structure, we also involve workers at a company level ... Various meeting and workshop formats, as well as regular works meetings or joint management bodies and committees, support dialog with the workforce on the ground" (page 172).

The materiality analysis used this route: workforce topics were discussed "with our employee representatives in a joint workshop" (page 128). Accident figures are reported to the Group Works Council for discussion (page 182).

Reference: page 175

"Various channels are available to our workers through which they can express their needs and concerns and address them directly to the company. Besides decentralized reporting channels such as HR departments or works councils, this also includes our whistleblower system FAIR TOGETHER" (page 175). The portal takes reports in 27 languages; the hotline and ombudsperson in German or English, and "Anonymous and confidential tip-offs are permitted" (page 172).

Remediation is case-by-case: management of the Group company concerned "will immediately implement remedial measures - if necessary in consultation with the Human Rights Officer ... selected in terms of measures that appear most suitable to prevent or immediately put an end to any breach or negative impact or to minimize its scale" (page 175). For safety it runs through incident investigations, risk assessments, targeted communication, training and briefings.

Two limitations are disclosed rather than glossed. On awareness: "We do not record either how well known they are or to what extent the workforce trusts the process." On review: internal audit checks the system's efficacy, but "Stakeholders who are intended as target users are not included in the process for tracking the efficacy of the system" (page 175).

Reference: page 175

The company opens by disclaiming action plans and naming the requirement it therefore does not answer: "There are currently no comprehensive action plans. Accordingly, we dispense below with the minimum disclosure requirements in accordance with MDR-A 69 a to c, which are not applicable" (page 175). Resources are addressed generically: they "will be provided by the company or Group companies".

Occupational health and safety is the bulk of the disclosure. The aim is "to avoid and counteract negative impacts such as accidents and risks, and on the other, to reinforce the safety culture in the company" (page 175). The new Health & Safety strategy "reinforces a consistent approach to health and safety throughout the Group", focused on management and responsibility and on risk awareness, with facility-specific measures developed locally (pages 175-176). Health promotion is included: the Group has been committed to "the 'Luxembourg Declaration on Workplace Health Promotion' in the EU since 2004" (page 170).

On skills, the named mechanisms are the Group umbrella agreements "Training" and "Further Training" with the Group Works Council, and the works agreements "Succession planning" and "Talent management" (pages 171-172, 181). Two FORWARD components target women - the "Career Path for Women" programme and a mentoring programme - alongside the "Women of Steel" network at SZFG (page 173).

Reference: page 181

One quantified target, disclosed with its outcome. "We are striving to reduce accidents by 35 % by 2025, and by 50 % by 2030 compared with 2021. The metric here is the Lost Time Injury Frequency (LTIF ...) of our active workforce worldwide. The baseline figure from 2021 is 8.57. In the reporting year, the actual figure stood at 6.66 with the result that the target (5,57) was just missed. There were no adjustments to the targets or measurement methods in the reporting period" (page 181).

The population is defined and explained: the LTIF target "is based on the global active workforce (core workforce and trainees) rather than the ESRS table 'Key figures for health and safety' (global core workforce)" (page 181).

A second, differently scoped LTIF target sits in Executive Board remuneration and was met: "The LTIF target for the whole Group was 7.08 in 2025 while the actual figure in 2025 was 6.92 meaning that the target was hit." Temporary workers are included in that one (page 181).

On training there is no target: "There are currently insufficient empirical data or benchmarks in the Group to formulate specific targets with respect to further training hours per employee." Monitoring continued instead: "In 2025, we recorded 19,305 further training participants across the Group and 94,116 further training measures carried out" (page 182).

Reference: page 182

The methodology is disclosed before the numbers: "The key workforce data are based on the workforces of all consolidated domestic and foreign Group companies. All of these details are based on the number of people on the reporting date. The personnel indicators are recorded in an SAP-BW system as part of Personnel Controlling", largely automated from the central payroll client, with foreign facilities via mini master records and the remainder entered manually on binding reporting dates. "Rounding differences in personnel data can occur due to proportional shareholdings" (page 182).

The headcount is given in the management report: "As of December 31, 2025, the core workforce of the Salzgitter Group numbered 22,014 employees" (page 25).

The tables on pages 182-184 report employees by gender, by country, by contract type and by full or part time, each with comparatives on a headcount basis at the reporting date, together with turnover. FY2024 comparatives survive text extraction - 19,266 male and 3,115 female employees, with zero under "other" and zero under "not disclosed" - but the FY2025 column did not and is not reproduced here.

Gender is self-declared: the tables footnote "other" as "Gender as specified by the employees themselves". The heading carries a typographical error in the source, reading "as of 12/31/225" (page 182).

Reference: page 184

Training and skills development metrics are reported in two tables with prior-year comparatives.

The first gives average training hours per employee by gender - female, male, other and not disclosed, plus total. FY2024 comparatives survive text extraction at 17.0 hours for female employees and 23.2 hours for male employees; the FY2025 column did not and is not reproduced here. The method is stated: "the number of further training hours completed by permanent staff in the reporting year is divided by the number of permanent employees on the reporting date" (page 184).

The second gives the percentage of employees who took part in regular performance and career development reviews, again split by gender, with FY2024 comparatives of 54.1 % for female employees and 47.6 % for male employees (page 184).

The volume behind the ratios is in S1-5: "In 2025, we recorded 19,305 further training participants across the Group and 94,116 further training measures carried out" (page 182).

The underlying IRO is positive - "Training and skills development", which helps "to maintain employability and promote employees' career development and promotion prospects" (page 126). No target is attached; the company says it lacks the data or benchmarks to set one (page 182).

Reference: page 184

The occupational safety table on pages 184-185 reports the health and safety metrics with comparatives: the share of the workforce covered by a health and safety management system, fatalities from work-related injuries and ill health for own workforce and other workers on site, the number and rate of recordable work-related accidents, and cases of recordable work-related ill health. The FY2025 column did not survive text extraction from the PDF and the 2025 values are not reproduced here.

Two narrative statements do survive and carry the year's answer. "No work-related fatalities were recorded in the reporting year among other workers deployed at the Salzgitter Group's facilities" (page 185). And on the outstanding 2024 case: "With respect to the fatal accident on the site of Huettenwerke Krupp Mannesmann GmbH (HKM; 30 % stake) in 2024, the official investigation has still not been completed ... In 2025, there were no fatal accidents involving external employees on our sites" (page 185).

Coverage is quantified in S1-1: 72 % of employees worked in companies externally certified to ISO 45001 (page 170). LTIF results are in S1-5: 6.66 against a 2025 target of 5.57, and 6.92 against a Group target of 7.08 (page 181).

One datapoint is deferred: "Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e)" is marked "Phase-In" (page 197).

Reference: page 185

The disclosure gives counts and outcomes rather than a process description. "In the reporting year, twelve cases of discrimination, including harassment, were reported within our own workforce via our whistleblower system FAIR TOGETHER as well as other decentralized reporting channels (e.g. local personnel departments). In addition, three complaints were received via these complaints channels in the reporting year. No fines, penalties or damages were paid in the reporting year in connection with the aforementioned incidents and complaints" (page 185).

On severe human rights impacts the return is nil and explicit: "No serious incidents were reported with regard to human rights in connection with the company's workforce. No fines, penalties or damages were paid in connection with serious human rights incidents relating to the company's workforce" (page 185).

The collection basis is disclosed, including the treatment of the joint operation: "The data were collected worldwide by the responsible bodies in the Group using a questionnaire based on the ESRS. Any HKM data were included in full (100 %) and not on a pro rata basis" (page 185). That differs from the environmental metrics, where HKM is included pro rata at 30 % (page 101), and the company flags the difference.

The report does not disclose the outcome of the twelve cases beyond the absence of fines, and gives no breakdown by country or category.

Reference: page 186

The affected group is defined narrowly and the company says so: "Employees of service companies within the upstream value chain who perform their work in a manufacturing or quasi-manufacturing working environment on our sites are the workers in the value chain who may be significantly affected by our activities" (page 185). The risk was identified in the materiality workshops, "e.g. with respect to complex production processes or construction work forming part of the SALCOS(R) program". The single material S2 IRO is health and safety protection as a negative impact, short term, upstream: accidents involving service company employees "can have a considerably damaging effect on their health and can even be fatal" (page 126).

The policies follow that scope: "Our occupational safety concepts described below apply to all partner companies working in Group companies and to all employees of Salzgitter AG on its sites" (page 186).

Beyond the site, the human rights framework applies: the Supplier Code sets out "our human rights and environmental expectations" (page 194), and the supply chain risk management system under the German Supply Chain Due Diligence Act monitors the UNGPs, the ILO Declaration and the OECD Guidelines "provided this is covered by the requirements of the LkSG", overseen by a Human Rights Officer (page 172).

Reference: page 187

Engagement is operational rather than survey-based. "We take account of the views of workers in our value chain by facilitating a regular exchange through regular processes, such as standard meetings between external company coordinators and representatives of external companies or joint safety meetings. The management of each company bears responsibility for ensuring that this participation takes place and the results are taken into account" (page 187).

Effectiveness is measured through outcomes rather than engagement metrics: "We evaluate the efficacy of our commitment to the workers in our value chain by means of regular inspections and by recording the relevant accident figures" (page 187).

That recording has widened in stages: SZFG's process covers work-related accidents, near misses and unsafe conditions on a standardised form, and "From 2023 onwards, the monitoring was extended to temporary workers worldwide and, from 2024, to the employees of external companies in Germany" (page 188).

The rationale sits under the S2 SBM-2 cross-reference: value chain workers "might be materially affected by our operating activities", so "we regard them as vital stakeholders" (page 185). Engagement is with employer representatives and coordinators rather than the workers themselves; no credible proxy or workers' representative body is named.

Reference: page 187

Remediation mirrors the own-workforce process: management of the affected Group company, "if necessary in consultation with the relevant Human Rights Officer - will take remedial action without delay. This action will be determined on a case-by-case basis and selected in terms of measures that appear most suitable to prevent or immediately put an end to any breach or negative impact or to minimize its scale" (page 187).

The grievance channel is the one used by employees: "We offer workers in our value chain the opportunity to raise their concerns, needs and reservations directly and use our whistleblower system FAIR TOGETHER to convey them to us anonymously and confidentially via our electronic reporting portal, compliance hotline or our ombuds. These channels are set up by Salzgitter AG itself" (page 187), publicised through the homepage, the Group magazine STIL and the Supplier Code of Conduct.

Tracking sits with local management, and "The efficacy of the whistleblower channels is reviewed by management once a year and as warranted; this review includes random checks carried out by our internal auditing department" (page 188).

Two limitations are disclosed: "We do not regularly investigate whether the workers in our value chain are aware of these processes", and "Stakeholders who are intended as target users are not included in the process for tracking the efficacy of the system" (page 188).

Reference: page 188

As with S1-4, the company disclaims action plans and names the requirement it therefore does not answer: "There are currently no comprehensive action plans. Accordingly, we dispense below with the minimum disclosure requirements in accordance with MDR-A 69 a to c, which are not applicable" (page 188).

The measures are specific. Contractor management: "the PAM process (Partnerschaftliches Auftragnehmermanagement - Contractor Management in a Spirit of Partnership) was implemented at SZFG ... This process includes the identification and reporting of anomalies, the classification and escalation of breaches, and efficacy reviews." Pre-qualification: "a comprehensive questionnaire to evaluate and administer external companies and contractors", covering health and safety management, the induction system and risk assessments (page 188).

Incident handling at SZFG is set out in detail, including immediate notification under Sec. 193 of the German Social Code Vol. 7, a standardised form, cause analysis, and communication of near misses. "Regular discussions are held on serious accidents in meetings of the Executive Board and Group Management Board" (page 188).

Beyond safety, contracts require "compliance with collective agreements and minimum wages" (page 189). The outcome is a nil return: "We did not identify any substantial risk of child labor or forced labor among workers in our value chain" (page 185).

Reference: page 189

A short disclosure with a clear negative answer. "Currently, we have not set ourselves any measurable, results-driven targets with respect to our material negative impact on workers in the value chain. Details on tracking the efficacy of our policies and measures are explained in S2-4" (page 189).

Under MDR-T the alternative limb applies, and the company points to it: effectiveness is tracked through the S2-4 mechanisms - "regular audits and random checks, as well as execution and efficacy checks", with warnings issued consistently when delays occur (page 188) - and through accident figures, since "We evaluate the efficacy of our commitment to the workers in our value chain by means of regular inspections and by recording the relevant accident figures" (page 187).

There is an indirect quantitative link. Temporary workers sit inside the Executive Board's LTIF target "in order to monitor accident frequencies for this group of people more closely"; that Group target was 7.08 for 2025 against an actual of 6.92 (page 181). The outcome disclosed for the year is that "In 2025, there were no fatal accidents involving external employees on our sites" (page 185).

The Group target table records the ambition as ongoing and qualitative: "Minimising hazards and preventing accidents in order to ensure the physical safety of all suppliers and partner companies" (page 116).

Reference: page 190

The material G1 IRO is positive: "Fostering integrity" under corporate culture - "A healthy corporate culture counteracts breaches of compliance ... we want to ensure responsible entrepreneurship along the entire value chain" (page 126).

Two instruments carry the policy. The Code of Conduct "sets out principles to be observed by all employees of the Group which serve the purpose of ensuring that all laws are adhered to at all times and places in the conduct of our business" (page 190). The "Corporate Compliance" Group directive states a zero-tolerance position and provides "guidelines for complying with the standards in place in certain legal areas, e.g. to prevent corruption and avoid breaches of anti-trust legislation" (page 190).

Governance names roles: "Within the Executive Board, responsibility for compliance is assigned to the CEO"; the Compliance Committee of CEO, CFO, Head of Legal, Compliance & Insurance and Head of Internal Audit "meets as and when required but at least twice a year"; and "One member of the management in each Group company bears responsibility for compliance" (pages 190-191).

The CMS rests on "three pillars Prevent, Detect and React" (page 192). Training covers corruption prevention, antitrust, data protection, money laundering and the Supply Chain Due Diligence Act, delivered "within twelve months" and "repeated after three years at the latest" (page 192).

Reference: page 193

The disclosure is framed around the material G1 opportunity, "Intact supplier relations": "Trusting, intact supplier relationships form the basis for reliable, punctual delivery, can strengthen operating business, and bring about economic benefits over the long term" (page 193).

Payment practice is the mechanism: "we therefore aim to always settle their bills punctually in accordance with the terms of payment agreed. This applies regardless of whether the supplier is a large, small or medium-sized company. The terms of payment to be applied to each order are recorded in the contracts and transparently made available to all parties involved" (page 193), monitored through internal audits.

Supplier assessment is layered and dated. "In addition to the risk analysis of the supply chain which we have been using across the Group since 2023, the purchasing departments of the various Group companies conduct standardized assessments of the main suppliers every year." SZFG "developed a separate questionnaire in 2015 ... closely based on the self-disclosure 'Sustainability for Automotive Sector Suppliers' form", and "Since 2024, suppliers from other product categories have also been included" (page 194).

Sourcing decisions are being connected to that data: work started in 2024 on using emissions data, risk scores and Supplier Code acceptance "in decisions to award contracts" (page 194). No proportion of suppliers covered by the Code is disclosed.

Reference: page 116

The statement was prepared under the 2023 ESRS, which had no standalone business conduct targets disclosure requirement, so business conduct targets fall under MDR-T. Both limbs are answered.

Stated targets. The Group target table carries two entries under the Integrity focus area, both tagged "ongoing" and "qualitative". Under corporate culture: "Preventing breaches of laws as well as internal guidelines or detecting such breaches and instigating suitable responses". Under supplier relationships: "Successive agreement of our Supplier Code with as many suppliers as possible" (page 116). Neither carries a baseline, target year or measurable value, and the table says so.

Effectiveness tracking in the absence of measurable targets. "All wholly owned, operating subsidiaries of Salzgitter AG analyze their compliance risks annually. They check risks arising from corruption, competition, money-laundering and supply chains ... and report on them to the Compliance Committee. The internal Audit department verifies the suitability and efficacy of the preventive measures implemented" (page 191). "Effectiveness control" is a named element of the CMS (page 192), and the Executive Board reports the compliance situation to the Supervisory Board annually (page 192).

The outcome for 2025 is a nil return: "No new compliance matters of heightened relevance or major new findings ... were identified" (page 191).

Reference: page 194

"The average duration until supplier liabilities were paid by our Group companies in the 2025 financial year (Days of Payables Outstanding (DPO)) amounted to around 87 days (DPO for 2024 financial year: around 83 days, value for 2024 from previous calculation method: 27 days.). The DPO is a figure derived from the consolidated balance sheet which reflects the entire group" (page 194).

The methodology change is disclosed twice and matters for anyone comparing years. In the basis of preparation: "the Days of Payables Outstanding (DPO) is now reported instead of the previous figure which was calculated manually. This is a figure derived from the consolidated balance sheet, which is collected routinely and, unlike the value previously calculated manually, reflects the entire group" (page 102). The restated 2024 comparative of about 83 days against the previously published 27 days is a change of basis, not a deterioration, and both figures are shown.

Standard terms and their application are given: "Our standard payment terms provide for payment within 90 days at the latest ... These payment terms were uniformly applied to around 91 % (previous year: 93 %) of all payments in the 2025 financial year, regardless of whether the payee was a small, medium-sized or large company" (page 194).

"Companies in the Salzgitter Group were only taken to court for payment in two instances in the 2025 financial year. In one case, the claim was recognized" (page 194).