Sartorius Stedim Biotech

France|Life Sciences Tools & Services|Reporting year:FY2025FY2024|Auditor: PricewaterhouseCoopers Audit|View original report →

Sustainability statement, in full

The complete text of Sartorius Stedim Biotech’s FY2025 sustainability statement is held here – 133 pages, captured from the published report. Every disclosure below also links to its own passage.

ESRS 2 – General Disclosures

GOV-1The role of the administrative, management and supervisory bodies
Reported

Governance roles

Reference: pages 89-92.

Sartorius Stedim Biotech S.A. is administered by a Board of Directors of nine members, five of whom are independent (page 89), tabulated at page 90 with gender, age, nationality, independence and committee membership.

Board metrics (page 91): women 62.5% (five members); independent directors 62.5%; executive members 12.5%; one director represents the employees. All ratios exclude the employee-representative director "in line with French regulations".

Responsibility (pages 91-92):

  • The Audit & Sustainability Committee monitors sustainability IROs, makes recommendations for the Board to decide upon, and monitors sustainability reporting.
  • The Board defines the sustainability strategy, monitors implementation, and "decides and monitors the setting of targets".
  • A parent-level Corporate Sustainability department under the Sartorius AG Group CEO serves both companies.

Expertise is self-assessed: the Board "directly and indirectly has the necessary skills and expertise necessary to monitor the material sustainability-related impacts, risks and opportunities" (page 92), with ESRS topics mapped to four competence areas.

A control gap is stated: "Specific controls for impact, risk and opportunity management are still being defined and were therefore not implemented in the reporting year" (page 91).

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

Information provided to the administrative bodies

Reference: pages 92-93.

The Board of Directors and the Audit & Sustainability Committee "are currently informed by the Head of Corporate Sustainability on an ad hoc basis" about material impacts, risks and opportunities, the implementation of sustainability due diligence, and the results and effectiveness of policies, actions, metrics and targets (page 92). No fixed reporting cycle is disclosed.

Matters addressed in the reporting year (pages 92-93):

  • The Board was briefed by Corporate Sustainability on the results of the updated double materiality assessment, including the description of material IROs given under SBM-3.
  • Possible further development of policies, actions, metrics and targets was discussed.
  • "With regard to climate change mitigation, the implications for corporate strategy and operational planning were discussed."

The Corporate Sustainability department attended Board meetings in the first and fourth quarters of 2025 to report on current sustainability topics, in particular CSRD implementation and the climate targets of parent company Sartorius AG (page 91).

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

Sustainability in incentive schemes

Reference: page 93. Full remuneration detail is cross-referred to the remuneration report on page 249.

Only the Chief Executive Officer's remuneration carries sustainability-linked components. "The remuneration system for the non-executive Directors did not include any sustainability-related components in the reporting year" (page 93).

Short-term incentive (STI). The Employee Motivation & Commitment (EMC) metric, assessed over one year, accounts for 10% of total STI and is paid in cash. EMC replaced the Employee Net Promoter Score in 2025 "because it did not adequately reflect the underlying aspects and developments of employee satisfaction and was also subject to significant fluctuations".

Long-term incentive (LTI). A cash component with a four-year assessment period is tied to the reduction of CO2eq emission intensity of the parent company Sartorius AG, with a target of "an average annual reduction of 10% over the relevant assessment period". It accounts for 50% of total LTI. The first tranche started on 1 January 2022, so allocation including the CO2eq component "will take place for the first time in 2026 based on the actual values in 2025".

GOV-3(was GOV-4)Statement on due diligence
Reported

Statement on due diligence

Reference: pages 93-94.

Sartorius Stedim Biotech treats due diligence on sustainability matters as "a business conduct task" and presents the ESRS mapping table of the five core elements of due diligence to the paragraphs of the statement covering them (page 94):

Core elementParagraphs in the statement
a) Embedding due diligence in governance, strategy and business modelESRS 2 GOV-2, ESRS 2 GOV-3, ESRS 2 SBM-3
b) Engaging with affected stakeholders in all key stepsESRS 2 GOV-2, SBM-2, IRO-1, E1/E2/E5/S1/S2 MDR-P
c) Identifying and assessing adverse impactsESRS 2 IRO-1, ESRS 2 SBM-3
d) Taking actions to address those adverse impactsE1/E2/E5/S1/S2 MDR-A
e) Tracking effectiveness and communicatingE1/E2/E5/S1/S2 MDR-M and MDR-T

The table covers only the standards the company found material (E1, E2, E5, S1, S2), consistent with the DMA outcome. The operational human rights due diligence system it points to is the parent company's LkSG risk management system, described under S1-1 (page 169).

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Risk management and internal controls over sustainability reporting

Reference: page 94.

The reporting process in 2025 comprised "a double materiality analysis, data collection, and text preparation", governed by manuals that "define the principles, standards, and key internal controls that are relevant to the entire reporting process".

Risks prioritised to date: "incorrect or incomplete data deliveries and possible misstatements in the report".

Mitigations implemented: process-specific controls, "in particular the dual control principle and plausibility checks (e.g., completeness checks, deviation analyses, comparisons, and internal text reviews)".

The company is explicit about the maturity of the system. "The implementation of structured risk analyses and prioritizations as well as corresponding internal controls at all process levels is being continuously advanced", and reporting to the governance bodies is ad hoc rather than periodic: "Regular, structured reporting on the results of risk management and internal controls for sustainability reporting is not yet in place and is being gradually established" (page 94). Read with GOV-1, where specific IRO-management controls "are still being defined" (page 91), this is a candid statement of an incomplete control environment in the second reporting year.

SBM-1Strategy, business model and value chain
Reported

Strategy, business model and value chain

Reference: pages 95-96. The paragraph 40(a) and 42(a)-(b) datapoints are incorporated by reference to the management report, pages 26, 28 and 42 (page 88).

The value chain is set out in eight stages (page 95): raw material extraction; production of raw materials, intermediates, auxiliary and operating materials and finished products; product manufacturing; assembly and system integration; quality assurance; distribution and sales; use by customers; customer service. Named inputs include plastics and chemicals, cell culture media components, electronic components, mechanical assemblies and stainless steel tanks.

The company defines end users narrowly, which matters for the S4 conclusion: "The end users of Sartorius Stedim Biotech products are therefore the employees of its direct customers... The end users of Sartorius Stedim Biotech products are therefore not patients" (page 95).

On strategy (page 96), single-use technologies "have the greatest impact on sustainability goals" and although they enable resource-efficient production "they pose challenges in terms of waste management and recycling". Strategic sustainability goals sit at parent level: reducing CO2 emissions along the value chain, promoting the circular economy, and responsible supply chains.

SBM-2Interests and views of stakeholders
Reported

Interests and views of stakeholders

Reference: pages 96-97.

Four stakeholder groups are named as most important (pages 96-97): customers, own workforce, investors, and suppliers / business partners and workers in the value chain.

Engagement channels disclosed:

  • Customers - individual dialogues and industry association work, naming BioPhorum, NIMBL and PSCI.
  • Own workforce - "pulse checks" twice a year, plus manager-led employee discussions, works councils, and employee representation on the Board.
  • Investors - regular capital-market communication, ESG conferences and ESG calls "in some cases held directly with the specialized ESG teams".
  • Suppliers - training sessions, structured self-disclosures, surveys, audits and anonymous whistleblower systems, against the Sartorius Code of Conduct for Business Partners.

Corporate functions (Investor Relations, Sales, Human Resources, Corporate Compliance, Corporate Sourcing) hold the day-to-day contact; Corporate Sustainability consolidates the topics and briefs the Board.

The company names the issues stakeholder dialogue surfaced in 2025 - "climate change mitigation, resource conservation, and the use of chemicals" - and states these were integrated into the double materiality assessment (page 97).

SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

Material impacts, risks and opportunities

Reference: pages 98-105. Per-topic IRO tables at pages 98 (E1), 100 (E2), 101 (E5), 102 (S1), 103 (S2), 104 (G1).

The 2025 update assessed new impacts and risks, and opportunities for the first time (page 98).

Material standards: E1, E2, E5, S1, S2, G1. E3, E4, S3 and S4 were assessed and found not material (pages 113-114, 119-122).

  • Climate (page 98) - three actual negative impacts, upstream, own operations and downstream. "There were still no material climate-related risks in the reporting year".
  • Pollution (pages 99-100) - nine rows: substances of concern, substances of very high concern, and, material for the first time, soil/air/water pollution and microplastics. Two risks concern fines and possible chemical bans.
  • Resource use (pages 100-101) - five negative impacts plus, for the first time, a market risk and a digital-solutions opportunity. Disposables "account for 85% of Group sales".
  • Own workforce (page 102) - two positive, two negative impacts; no material risks or opportunities.
  • Value chain workers (page 103) - three potential negative impacts upstream; child and forced labour risk in electronics sub-supply chains.
  • Business conduct (pages 103-104) - positive culture impact, attrition risk, first-time animal welfare opportunity.

Financial effects (page 104): "Currently, there are no measurable financial effects", and the ESRS relief provisions are applied.

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities
Reported

Process to identify and assess material IROs

Reference: pages 106-115, including topic-specific IRO-1 disclosures for E1 (110-112), E2 (112-113), E3 and E4 (113-114), E5 (114-115) and G1 (115). Results were validated with relevant functions and presented to the Board, which "acknowledged with approval" (page 110).

Run centrally by Corporate Sustainability with Finance & Controlling on a gross basis (page 106). Versus 2024 the process "was expanded and deepened (e.g., in the areas of climate and biodiversity)".

Scoring (pages 107-109). Impacts score 1-4 on scale, scope and irreversibility (negative) or scale and scope (positive); potential impacts add likelihood. Risks and opportunities score on financial magnitude measured as the effect on EBIT and likelihood.

Thresholds (page 109). Actual impacts are material at severity 2 or above. Potential impacts, and risks and opportunities, need both criteria at 2 or above and an average greater than 2, which "excluded 'marginal issues' that have a high degree of severity but only a low likelihood of occurrence".

Limits stated: "No external experts were consulted during this stage of the process" (page 106); "Specific consultations, particularly with affected communities, were not carried out" (pages 113-114); and "The double materiality assessment process is not yet integrated with the company's opportunity management or strategy process" (page 115).

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reported

ESRS content index

Reference: pages 115-122. The "Index of ESRS Disclosure Requirements" runs from page 116 to 119; the Appendix B datapoints table runs from page 119 to 122 and carries an explicit "Materiality for Sartorius" column.

The company states the index "summarizes the ESRS reporting requirements contained in the Sustainability Statement" and that "The reportable disclosures were determined on the basis of EFRAG's implementation guide ('Data Point List'). The company has not identified any immaterial data points and therefore does not make use of the principle of 'materiality of information'" (page 115).

Listed: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2; E1-1 to E1-8; E2-1 to E2-5; E5-1 to E5-5; S1-1 to S1-17; S2-1 to S2-5; and, under Governance information, G1-1 plus MDR-P/A/T/M for corporate culture and separately for animal welfare. For water and marine resources and for biodiversity, only the "related to ESRS 2 IRO-1" row at page 98 appears - no E3 or E4 disclosure requirements.

Absent: E1-9, E2-6 and E5-6, for which the phase-in table at page 88 records "Use of the transition rule" or "Use of the transitional arrangement", as it does for ESRS 2 SBM-3 paragraph 48(e). G1-2 to G1-6 are absent, and Appendix B marks the G1-1 paragraph 10(b) and 10(d) datapoints and both G1-4 datapoints "immaterial" (page 122).

E1 – Climate Change

E1-1Transition plan for climate change mitigation
Reported

Transition plan for climate change mitigation

Reference: page 135.

The company discloses that it has no transition plan and does not intend to prepare one. "Sartorius Stedim Biotech does not pursue its own climate protection ambitions and therefore does not have its own targets in this area. Accordingly, the company does not have its own climate transition plan and also currently does not intend to draw up a transition plan."

The reason given is group structure: "This is due to the management approach of the parent company Sartorius AG, which does not provide for separate management of the Sartorius Stedim Biotech subgroup. Of course, the parent company's climate protection efforts also address the Sartorius Stedim Biotech subgroup." The reader is directed outside the report: "Further information on Sartorius Group ambition and progress can be found in the Sartorius Group Sustainability Statement."

This reverses the FY2024 position, where a transition plan "will be developed in fiscal 2025". The parent's plan is still in preparation (page 136), and its action plan for the 2030 targets, "that includes quantified and scheduled actions, defined responsibilities and necessary financial resources", is unfinished (page 138). The only climate-neutrality ambition stated is the parent's - "The company's aim is to be climate neutral by 2045" - entering the employee Code of Conduct only from 1 January 2026 (page 136).

E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysis
Reported

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 110-112) and ESRS 2 SBM-3 (page 98), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification. Risks are assessed as physical (acute and chronic, "based on the TCFD classification") and transition (regulatory, technological, market), over short, medium and long term. Assessment ran at three levels: upstream by supplier group, own operations at Group-company level, downstream at business-unit level; physical hazards were screened against Commission Delegated Regulation (EU) 2021/2139 (pages 111-112).

Scenario analysis (page 111), refined in 2025: "For the first time, the IPCC database was used... to systematically identify climate risks for two climate scenarios over three time horizons for our own production sites."

  • SSP1 RCP2.6, "in which GHG emissions are limited to 1.5°C"
  • SSP5 RCP8.5, "in which GHG emissions lead to a temperature increase of 3.3°C to 5.7°C ('hot house world')"
  • Horizons: 2025, 2030 and 2050

Transition risks used "the same climate scenarios and time horizons" (page 112).

Outcome. "As in the previous year, no significant climate risks were identified for the upstream and downstream value chain or for the company's own locations" (page 111). Not disclosed: paragraph 17(c) key assumptions, and any monetary exposure.

E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate change
Reported

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 98 and 105). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The company states that no climate resilience analysis was performed, and gives its reason. "As there were no material climate-related risks for the company in fiscal year 2025, it was not necessary to carry out a specific climate resilience analysis in accordance with ESRS E1 SBM-3. The risk situation is continuously monitored as part of the company's sustainability management and risk management activities so that it can react promptly to changing conditions and requirements" (page 98).

No assets or activities were found susceptible to physical or transition gross risk over any horizon (pages 111-112).

A general, all-topic resilience statement sits at page 105: the IROs and current management approaches were presented to the Board, and "the company concluded that, based on current assessments, its business model and strategy are sufficiently resilient to cope with the above-mentioned impacts and risks and to take advantage of opportunities. This is a qualitative assessment by the Board of Directors with no specific time horizon."

There is therefore no disclosure against paragraph 19(a) implications for strategy, 19(b) areas of uncertainty, or 19(c)/AR 10 capacity to adjust or adapt.

E1-4(was E1-2)Policies related to climate change mitigation and adaptation
Reported

Policies related to climate change mitigation and adaptation

Reference: pages 135-136.

Sartorius Stedim Biotech has no climate policy of its own. It is covered by two parent-company instruments described as "the overarching corporate guidelines within the Sartorius Group" (page 135): the Sartorius Code of Conduct for employees, and the Sartorius Code of Conduct for Business Partners, in force since September 2022 and part of the supply contract.

Climate content (page 136). The Business Partner code requires that "Energy efficiency must be continuously improved" and that "Suppliers must be committed to the use and development of climate-friendly products". The employee code contained nothing on climate in the reporting year; the requirements ("Energy must be used conscientiously"; "The company's aim is to be climate neutral by 2045") are new from 1 January 2026 and "In this codified form, the requirements did not yet apply to the 2025 reporting year" (page 135).

The company records the gap: "there was no specific concept in place during the reporting year that encompassed the general objectives, responsibilities, and monitoring process for dealing with the impacts identified along the entire value chain in the area of energy and climate protection" (page 136). Implementation runs through the Group-wide compliance management system, with Internal Audit testing effectiveness.

E1-5(was E1-3)Actions and resources in relation to climate change policies
Reported

Actions and resources in relation to climate change policies

Reference: pages 136-138.

Levers named are own energy infrastructure and renewable energy, renewable electricity in the supply chain, ecodesign, logistics and buildings (page 136). The 2025 action table (page 137) records inaction as well as action.

Actions taken:

  • Electrification: more electric company cars in Europe. At Guxhagen, Germany, steam and heat generation was converted to electrical systems and the site "was operated without the use of fossil fuels for the first time".
  • Renewable electricity: Umeå (Sweden) and Illkirch (France) "purchased electricity exclusively from renewable sources for the first time"; guarantees of origin acquired in the UK and US.
  • Own generation: photovoltaic systems at Aubagne, France, commissioned in 2026.

Where nothing was done (page 137): no focus on cooperation with suppliers using renewable electricity; no active actions on reducing materials in products and packaging, on climate-friendly materials in products, or on building materials. Sea freight in place of air freight declined "due to the demand for shorter delivery times", and "No explicit measures were taken in the reporting year to actively reduce business travel".

Resources. Nothing is quantified: results and financial resources "are not yet systematically tracked at Group level" (page 137), and the same applies to planned actions (page 138).

E1-6(was E1-4)Targets related to climate change mitigation and adaptation
Reported

Targets related to climate change mitigation and adaptation

Reference: page 138.

Sartorius Stedim Biotech has set no targets of its own. "Sartorius Stedim Biotech has not adopted any separate targets related to climate change mitigation as a Subgroup, but is targeting the objectives of its parent company Sartorius Group."

The parent-company targets it adopts are:

  • Scope 1 and market-based Scope 2: reduce gross GHG emissions by 42% by 2030 against a 2022 base year, "This corresponds to an annual reduction of 5.4%". These "are absolute GHG reduction targets measured in tons of CO2eq".
  • Scope 3: reduce by 51.6% by 2030 relative to the 2022 base year, in relation to value added - an intensity target, not an absolute one - "This corresponds to an annual relative reduction of 8.7%".

No base-year emissions figure, milestone years other than 2030, or target for 2050 is given in this section, and the E1-6 table records "n.a. = not available (no target and corresponding base year has been defined)" in its target columns (page 142). The reader is referred out of the report: "Further information on Sartorius Group targets can be found in the Sartorius Group Sustainability Statement."

Context that bears on the targets: the restatement of Scope 3 emissions was made "as part of the SBTi validation" (page 141), indicating a validation process at parent level, but no SBTi validation status is claimed for Sartorius Stedim Biotech in this statement.

E1-7(was E1-5)Energy consumption and mix
Reported

Energy consumption and mix

Reference: pages 138-140. Table at page 139.

Total energy consumption rose 15% to 205,265 MWh (2024: 179,188 MWh), "mainly as a result of higher production and capacity expansions in Germany, France, and the US" (page 138).

Line2025 (MWh)2024 (MWh)
Crude oil and petroleum products19,41018,419
Natural gas53,79043,202
Purchased electricity, heat, steam, cooling - fossil55,38958,248
Total fossil128,589119,868
Nuclear616790
Purchased renewable electricity, heat, steam, cooling73,47256,532
Total renewable76,06058,530
Total205,265179,188

Shares: fossil 62.6% (2024: 66.9%), nuclear 0.3%, renewable 37.1% (2024: 32.7%). Coal is zero in both years. Own generation rose 36% to 51,380 MWh, of which renewable generation rose 150% to 7,594 MWh: "The geothermal heat pumps commissioned at the Göttingen site last year have had a significant impact here".

Energy intensity rose to 0.0000692 MWh/EUR (2024: 0.0000645). Around 99% of the business sits in high climate impact sector C "Manufacturing", so total consumption is used, against IFRS revenue from page 236.

Purchased fossil and nuclear energy is extrapolated from country average data (MLC 2025); "At present, no specific actions have been adopted to improve the accuracy of energy data" (page 140).

E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Reported

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 140-150. Main table page 142; restatement comparison page 143; biogenic emissions page 144.

t CO2e20252024 (restated)Change
Scope 116,02613,682+17.1%
Scope 2 location-based47,40144,558+6.4%
Scope 2 market-based29,27930,463-3.9%
Scope 3403,532385,918+4.6%
Total (location-based)466,959444,158+5.1%
Total (market-based)448,837430,063+4.4%

Scope 1 plus market-based Scope 2 was 45,305 t CO2e, up 3%. Scope 3 is around 90% of the market-based total (page 140), led by purchased goods and services 39%, capital goods 18%, upstream transport 18%. Largest movements: purchased goods and services +26,416 t and upstream transport +18,152 t, against use of sold products -21,889 t.

Restatements (pages 141, 143). All scopes were restated. Scope 3 was restated "to optimize all accounting concepts, including emission factors, as part of the SBTi validation", cutting the 2024 figure by 141,877 t (-27%). Total market-based 2024 emissions fell 24%, from 565,909 to 430,063 t CO2e.

Not reported. Categories 7, 9 and 15 are "classified as insignificant"; 8, 10 and 14 "not applicable" (page 145). Biogenic Scope 3 is "Not determinable" pending EFRAG guidance (page 144). The company treats the figures "as an indication" given the estimates involved (page 150).

E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits
Reported

GHG removals and mitigation projects financed through carbon credits

Reference: page 150.

A complete nil return. "In the reporting period, Sartorius Stedim Biotech did not develop any projects for the removal or storage of greenhouse gases, nor did it contribute to any such projects in the upstream or downstream value chain. Please also note that the company did not purchase or plan to purchase any carbon credits during this period. As such, no emission reductions or removals were financed or intended to be financed by climate change mitigation projects outside the value chain."

The disclosure covers both limbs of E1-7 - removals in own operations and value chain, and carbon credits - and is consistent with E1-4, where the adopted parent-company targets are described as absolute reduction targets with no reference to offsetting (page 138). No net-zero claim is made anywhere in the statement for the subgroup, so the E1-7 requirement to reconcile a net-zero claim does not arise.

E1-10(was E1-8)Internal carbon pricing
Reported

Internal carbon pricing

Reference: page 150.

A nil return: "No internal carbon pricing schemes were used or implemented in the reporting period. As such, there are no internal shadow prices, CO2-fees or CO2-funds that influenced decision-making or provided incentives for implementing climate-related policies and targets."

The disclosure explicitly rules out each of the three scheme types the standard contemplates - shadow prices, internal fees and internal funds - and states the consequence for decision-making. This is consistent with E1-3, where the company reports that financial resources for climate actions are not yet systematically tracked at Group level (page 137), and with E1-1, where no transition plan exists to be priced (page 135).

E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Omitted

E2 – Pollution

E2-1Policies related to pollution
Reported

Policies related to pollution

Reference: page 151.

There is no pollution policy specific to Sartorius Stedim Biotech: "As explained in E1-2, Sartorius Stedim Biotech is covered by the policies on the level of the parent company Sartorius AG." The parent also runs a Group-wide Environment, Health & Safety management system, reviewed through internal EHS audits.

Requirements in the two codes (page 151):

  • Soil, air and water pollution including microplastics - Business Partner code: "Damage to health or the environment must be prevented by controlling and managing emissions into soil, air, and water", plus an emergency plan with trained personnel. Employee code: "Not yet considered", with equivalent wording new from 1 January 2026.
  • Substances of concern and very high concern - Business Partner code: "The use of hazardous substances must be minimized. The REACH and ROHS directives must be complied with." Employee code: "Not yet considered"; from 1 January 2026, "The use of hazardous substances must be reduced, and alternatives must be reviewed regularly."

Two gaps are stated directly: "The concept for managing impacts in the upstream value chain does not include the elimination of substances of very high concern. Furthermore, there were no specific concepts in place for managing impacts and risks in our own operations and impacts in the downstream value chain during the reporting year" (page 151).

E2-2Actions and resources related to pollution
Reported

Actions and resources related to pollution

Reference: pages 151-153.

Soil, air and water pollution including microplastics (page 152): supplier compliance is checked by self-assessment, and "There is currently no explicit review of microplastic emissions". Distillation plants at Göttingen, Germany and Yauco, Puerto Rico "recycle almost all of the solvents contained in the production water". Downstream, "no special actions are being taken to prevent soil, air and water pollution... resulting from the improper disposal of Sartorius products".

Substances of concern and very high concern (page 152):

  • Isopropanol reduction in filter production at Göttingen. A solution "developed back in 2018 and patented by Sartorius Stedim Biotech enables integrity testing of hydrophobic filter cartridges and MaxiCaps® using water alone"; in 2025 it was extended to smaller Sartofluor® MidiCaps® and introduced at Yauco.
  • PFAS substitution. The company "is also researching alternatives to products containing PFAS in order to prepare for possible restrictions at an early stage. The PFAS-free Sartopore Evo® sterilization filter was introduced in the reporting year".

Resources. REACH-based hazardous substance management and customer notification continue. "The actions specified are ongoing, without a fixed time horizon", and nothing is quantified: results and financial resources are "not yet systematically tracked or planned at Group level" (page 153).

E2-3Targets related to pollution
Reported

Targets related to pollution

Reference: page 153.

No pollution targets have been set. "The management of environmental pollution, including compliance with legal requirements, is a local responsibility at Sartorius. For this reason, the company has not yet set any Group-wide targets for pollution. Whether it makes sense to set measurable, time-bound and results-oriented Group targets, including key performance indicators for measuring effectiveness in the future therefore still need to be examined."

The disclosure states the reason (local responsibility for pollution management), the current position (no Group-wide targets), and the forward position (whether to set them is still under examination). Under the MDR-T other limb, effectiveness tracking in the absence of targets is addressed through the CMS and the Group-wide EHS management system described under E2-1, whose requirements "are reviewed through internal EHS audits" (page 151). No quantified effectiveness measure for pollution is disclosed. This is unchanged in substance from the FY2024 position.

E2-4Pollution of air, water and soil
Reported

Pollution of air, water and soil

Reference: pages 153-154.

The company narrows the disclosure to water: "Sartorius Stedim Biotech has currently identified only material impacts in connection with water pollution" (page 153). Membrane and membrane filter manufacturing "falls under the EU Industrial Emissions Directive (IED)", and the Göttingen site, Germany reports under the EU Pollutant Release and Transfer Register.

Wastewater emissions (kg)20252024
Total organic carbon (as total C or COD/3)232,127131,567

The 76% increase is attributed to "a capacity expansion and increase in production"; the company adds that "most of the substances contained in the wastewater load are biodegradable".

Scope limits (pages 153-154). The equivalent process at Yauco, Puerto Rico is excluded because its "annual TOC loads... are currently well below the PRTR reporting thresholds". Two companies carry out the IED activity "Surface treatment with an organic solvent consumption capacity of more than 150 kg/h or more than 200 t/year"; all others "do not carry out any IED activities". Data are measured as COD or BOD and converted to TOC, and "Only those values that exceed the PRTR reporting values are fully included in the ESRS consolidation".

Note an internal inconsistency: Appendix B marks the E2-4 paragraph 28 E-PRTR datapoint immaterial (page 120), while the body reports the TOC figure and the index lists E2-4 at page 153.

E2-5Substances of concern and substances of very high concern
Reported

Substances of concern and substances of very high concern

Reference: pages 154-156. The disclosure answers both limbs of ESRS E2 paragraph 34, inflow and outflow, split by main hazard class, with SVHC separate per paragraph 35.

Substances of concern (tonnes, page 154):

20252024
Inflow (generated or used in production, or procured)1,121804
- toxic for reproduction905670
- carcinogenic187126
- persistent, mobile and toxic54
Outflow (left facilities as emissions, products or part of products)427213
- toxic for reproduction21279

Substances of very high concern (page 155): inflow 16 t (2024: 13 t) and outflow 16 t, split toxic for reproduction 8, carcinogenic 3, persistent mobile and toxic 5.

Use and release of SoC rose "primarily due to higher production and purchasing volumes (+39% compared to 2024)", with reproductive toxins released up 169%. The inflow-outflow gap is explained by a solvent sent for recycling and repurchased (page 154).

Method limit (page 156). Substances were identified from the purchasing system and CLP list "as the company has no standardized database". Critically, "The total amount of substances of concern leaving the company as emissions or products is assumed to be the same as the amounts purchased", less recycled returns, which the company names as an uncertainty.

E2-6Anticipated financial effects from pollution-related impacts, risks and opportunities
Omitted

E5 – Resource Use and Circular Economy

E5-1Policies related to resource use and circular economy
Reported

Policies related to resource use and circular economy

Reference: page 157.

The two parent-company codes are the only formal policies, and the mapping table shows how thin the coverage is (page 157):

ESRS sub-topicBusiness Partner codeEmployee code
Resource inflows, including resource useNot yet taken into accountNot relevant
Waste"Waste must be handled in compliance with the applicable laws."Not yet taken into account; new from 1 January 2026
Resource outflows related to products and servicesNot relevantNot relevant

The gap is stated: "Beyond the sustainability requirements set out in the Code of Conduct, the company did not have any specific concepts in the area of resource use and circular economy in the reporting year. The reason for this is that the parent company Sartorius AG is developing its sustainability strategy, including guidelines, step by step."

Direction of travel is recorded. At the beginning of 2024 the Board "once again reaffirmed its ambitions for sustainable resource use and circular economy", focusing on "the further development of eco-design, the gradual decoupling of material use from fossil raw materials, increasing the recyclability of products, and consistently avoiding operational landfill waste". For the newly material digitalisation opportunity, "the company is pursuing an integrated portfolio approach".

E5-2Actions and resources related to resource use and circular economy
Reported

Actions and resources related to resource use and circular economy

Reference: pages 158-159.

Product and packaging design (page 158). Eco-design reduces size and changes material choice and develops alternatives to crude-oil-based virgin plastic. ISCC Plus certification "has already been completed at four sites... Göttingen, Germany, Aubagne, France, Stonehouse, England, and M'Hamdia, Tunisia", with more planned for 2026. The stated result: "an average of 50% of fossil plastics are replaced by bio-circular raw materials in selected product lines - such as Flexsafe® bags, Ambr® bioreactor vessels and Vivaflow® filters".

Supply chain (page 158). In November 2025 the parent published the "Supplier's Sustainability Handbook", setting requirements for waste avoidance, eco-design and circular material use.

Own operations and digital services. "At some production sites" an operational waste management system covers prevention, reuse, recycling and recovery. The "Fully Connected Lab" vision is backed by investment in software start-ups.

Life cycle assessment (page 159). "In the reporting year, two cradle-to-grave LCAs were carried out for a bioreactor", and "More than a hundred cradle-to-gate PCFs" have been conducted, all "confidential and... not published externally".

Resources. No time horizon and no quantification: results and financial resources are "not yet systematically tracked or planned at Group level".

E5-3Targets related to resource use and circular economy
Reported

Targets related to resource use and circular economy

Reference: page 159.

No targets have been set. "The company is carefully analyzing the metrics first prepared and presented in ESRS E5-4 and ESRS E5-5 in fiscal 2024, to identify trends and develop and implement appropriate targets and actions. Due to its incremental approach, the company has not yet implemented any targets for monitoring the effectiveness of policies and actions in the area of resource use and circular economy. The company is working on setting up measurable, time-bound and outcome-oriented targets, including metrics for measuring effectiveness for the entire Group."

Under the MDR-T other limb, the company describes how effectiveness is tracked in the absence of targets: "The effectiveness of the concepts at Sartorius is currently being monitored as part of the compliance management process (see E5-1). The effectiveness of actions at Sartorius is currently mainly monitored through regular progress reports to the divisional steering committees, some of which are held monthly."

This is the second year without targets on a topic the company itself describes as central to its business model, given that disposable products "account for 85% of Group sales" (page 100).

E5-4Resource inflows
Reported

Resource inflows

Reference: pages 159-160.

Resource inflows20252024
Total weight of components, products and materials including packaging (t)27,05517,206
Proportion of biological materials from certified sustainable sourcing (%)Not determinableNot determinable
Proportion of recycled components, products and materials (%)2230
Weight of recycled components, products and materials (t)6,0555,210

Total inflow rose 57%. Recycled material rose 22% in absolute terms but its share fell 8 percentage points, because "primary materials grew disproportionately in 2025 (+75%) - driven by higher procurement volumes" (page 160).

Materials named (page 159): plastics, metal and electronic components, chemicals, and cardboard packaging. "The plastics used are mostly primary materials from fossil sources." On critical raw materials: "The company does not directly procure any critical materials. However, some purchased electronic components... can contain i.a. critical materials like lithium, tungsten and silicon metal. Rare earths are also used in the electronic components."

Certified biological materials remain not determinable. The company "is dependent on information from suppliers" and "is therefore making use of a relief provision that applies in the first three years of reporting under ESRS" (page 160). Total weight used is equated with total weight purchased.

E5-5Resource outflows
Reported

Resource outflows - products and services

Reference: pages 161-162 and 164-165. Waste is presented separately.

Products and packaging placed on the market20252024
Proportion of recyclable products (%)1012
Proportion of recyclable packaging (%)1721

Both rates fell. The product figure "refers to the product category of instruments, which largely do not use adhesive bonds so that the individual parts can be easily separated and thus recycled" (page 161).

Circularity position, stated plainly (page 161): "The company does not currently manufacture any products that are explicitly designed according to circular principles. A large part of the product portfolio, the consumables, is in fact explicitly intended for single use due to legal requirements concerning quality."

Durability and repairability (page 161). Instruments have an expected durability of 9 years on average, larger biopharmaceutical devices up to 15 years; durability "is not relevant for consumables". The industry average is "not known". Repair services continue "for some products even after they have been discontinued", and under the WEEE Directive 2012/19/EU old appliances in the EU are taken back.

Method (pages 164-165). Packaging recyclability assumes "that the quantities purchased correspond directly to the quantities sold", and durability comes from internal expert interviews.

E5-5(was E5-5-Waste)Waste
Reported

Waste

Reference: pages 162-165. Tables at page 163; restatement comparison at page 164.

Total waste generated rose 6% to 7,775 t (2024 restated: 7,423 t), "mainly attributable to production expansions and capacity increases, particularly at the sites in Germany, France, and the US" (page 162).

Waste by treatment (t)20252024
Total generated7,7757,423
Diverted from disposal3,8313,843
- hazardous / non-hazardous31 / 3,800372 / 3,471
Directed to disposal3,9433,580
- hazardous / non-hazardous1,765 / 2,1781,374 / 2,206
Non-recycled waste (%)50.748.2

By composition: hazardous 1,796 t (unchanged), radioactive 0, non-hazardous 5,980 t (residual 1,455, plastic 1,539, paper 1,288, wood 687, other 1,011 t).

The company describes the movements: "In the case of hazardous waste, there was a significant shift from recycling to disposal (recycling -94%, disposal +28%, mainly incineration). For non-hazardous waste, recycling volumes increased (+10%) and landfilling was significantly reduced (-48%)" (page 162). The recycling rate fell from 53% to 49%.

Restatement (pages 162, 164). All 2024 figures were restated "due to a refinement of the calculation method for non-production companies", lifting total waste from 7,313 to 7,423 t and the non-recycled share from 47.4% to 48.2%.

E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Omitted

S1 – Own Workforce

S1-1Policies related to own workforce
Reported

Policies related to own workforce

Reference: pages 166-169. Policy mapping table at pages 167-168.

The Sartorius Code of Conduct for Employees is the governing instrument, and the mapping table is candid about coverage in 2025:

  • Covered: reasonable remuneration "or exceeds the statutory minimum wages or industry standards"; social dialogue; freedom of association and collective bargaining; health and safety; gender equality, non-discrimination and inclusion; child labour; forced labour.
  • "Not yet considered" in 2025, with wording new only from 1 January 2026: secure employment, working hours, work-life balance, training, diversity, and violence in the workplace.

The company summarises: "There were no specific concepts for secure employment, working hours, work-life balance, training and skills development, diversity, or violence in the workplace in the reporting year. There was also no policy on human trafficking" (page 168).

Human rights (page 169). The parent's Declaration of Principles for Respect for Human Rights, aligned to the UN Guiding Principles, is public. Compliance runs through the parent's German Supply Chain Due Diligence Act (LkSG) risk management system: country and industry risk assessment of all subsidiaries and "now also... all active suppliers", self-assessment plus media screening for high-risk entities, and internal and external PSCI audits.

S1-2Processes for engaging with own workforce and workers' representatives about impacts
Reported

Engaging with own workforce and workers' representatives

Reference: pages 169-170.

Channels: an employee survey every six months, year-round manager-led discussions, and works councils. Coverage is quantified: "Works councils have been set up at 22 of 47 companies and cover most of Sartorius' employees (currently: 62%)" (page 170).

The Group Works Council "is also involved in discussions on the impacts on the company's workforce that may arise from reducing GHG emissions and transitioning to more environment-friendly and climate-neutral operations", though SBM-3 records that no such transition plans have been defined (page 102).

Survey findings and employee discussions "are also incorporated directly into the process of assessing material impacts, risks, and opportunities", and "The Board of Directors bears ultimate responsibility for incorporating the interests of employees and ensuring that the results inform the company's approach" (page 170).

Effectiveness is evaluated through the annual Group-wide Employee Motivation & Commitment (EMC) indicator, which since 2025 forms part of short-term executive remuneration, and through externally conducted PSCI audits, where employees are asked on site about the implementation and effectiveness of policies and actions.

One gap is stated: the company has "not concluded a Global Framework Agreement or comparable agreements with workers' representatives in relation to respect for human rights".

S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concerns
Reported

Remediation and channels to raise concerns

Reference: pages 170-171.

Outcome for the year: "The company is committed to taking immediate remedial action in substantiated cases where it has caused or contributed to negative impacts on the workforce. There were no substantiated cases in the reporting year and no remedial action was required" (page 170).

Channels (page 170). Reporting is available round the clock, in various languages, anonymously if preferred, to people inside or outside the company, through the compliance team in person, a hotline, e-mail, or a whistleblower system. The routes are published on both the intranet and the public website, publicly accessible "Rules of Procedure for Whistleblowers" explain the process and protections, and availability is covered in mandatory annual Code of Conduct training.

Protections stated: staff handling reports "are obliged to secrecy and are impartial and free from instructions"; identity is protected within the statutory framework; there are "no negative consequences for whistleblowers who file complaints in good faith and turn out to be unfounded"; and "Retaliatory actions constitute serious misconduct... and will be punished".

Ownership (page 171). The trained Compliance team manages the mechanisms and tracks remedial action, with all cases "documented, reviewed and tracked to ensure the effectiveness of the channels and the actions taken".

S1-3(was S1-4)Taking action on material impacts on own workforce
Reported

Taking action on material impacts on own workforce

Reference: pages 171-173. "Some of these actions are geared towards the local circumstances at the sites and are not consistent throughout the Group" (page 171).

Occupational safety and work-life balance: local hazardous substance management systems; ergonomic design required "in all new buildings and conversions"; therapeutic support for stress and strain, though "At the time of reporting, this is not available at all sites"; flexitime and hybrid working "wherever possible".

Diversity and prevention of violence and discrimination: managers must complete mandatory annual training on unconscious bias, covering diversity, gender equality and employment of persons with disabilities (page 171).

Wages and development (pages 171-172): performance-related pay, occupational pension and health insurance contributions in some countries, and pay based on collective agreement in several countries (55%); mandatory annual performance reviews, local production training programmes, and HR "talent talks".

Effectiveness (page 173): employee surveys and internal analysis of turnover, sickness rate, training and accident figures, plus voluntary external PSCI audits at five sites each year, selected on the basis of risk.

Resources: staffing is in place and funding "is part of the routine budget", but the company "is unable to provide detailed information on the specific resources allocated".

S1-4(was S1-5)Targets related to own workforce
Reported

Targets related to own workforce

Reference: page 173.

No targets have been set. "Sartorius Stedim Biotech has not yet set any Group-wide, measurable outcome-oriented targets related to managing material negative impacts and advancing positive impacts as the company gradually develops its sustainability strategy."

The company describes the groundwork instead: "During the fiscal year, the Group conducted a survey of the current status of relevant metrics to establish a sound data basis. The Group is continuously moving forward with the process for defining targets, working closely with employees and in consultation with workers' representation bodies to ensure that future targets meet the actual needs and interests of the workforce."

It also disposes of the risk and opportunity limb: "Targets related to material risks and opportunities were not relevant as no risks and opportunities were identified in the reporting period" - consistent with SBM-3, where "No material risks or opportunities arising from the impacts and dependencies related to the company's own workforce were identified in the reporting year" (page 102).

The one quantified workforce-linked target in the report sits under G1 rather than S1: the Employee Motivation & Commitment target of an annual average of 4 points on a 1-5 scale, which reached 3.91 in 2025 (page 196).

S1-5(was S1-6)Characteristics of the undertaking's employees
Reported

Characteristics of employees

Reference: pages 173-177. Tables at pages 174-176.

Employees (headcount)20252024
Total10,2659,901
Total FTE10,1319,766
Male / Female6,180 / 4,0856,015 / 3,886
Permanent / Temporary9,835 / 4309,271 / 630
Non-guaranteed hours00
Full-time / Part-time9,753 / 5129,409 / 492

By region: EMEA 7,131, Americas 1,724, APAC 1,410. Significant countries under the ESRS test are Germany (3,082) and France (1,471) (page 174).

The share on permanent contracts rose to 95.3% (2024: 93.3%) as fixed-term contracts fell 27%; women were 39.8% of the workforce (page 173).

Turnover (page 176): total departures 846 (2024: 1,146) - voluntary 611, dismissal 202, retirement 25, death in service 8. The rate fell from 11.2% to 8.4%, "mainly due to declines in both voluntary departures and terminations as part of the 'Fit for Future' corporate program" (page 174).

Definition (page 176). Only "the active core workforce of the consolidated Group companies" counts. Excluded: "employees in training, employees on leave, employees on long-term absence, temporary workers and members of the Executive Board" - a narrower population than a headcount reader might assume. The "other" and "not disclosed" gender categories are estimated "based on the 2022 German census" and report as zero (page 177).

S1-6(was S1-7)Characteristics of non-employee workers
Reported

Characteristics of non-employee workers

Reference: pages 177-178.

Non-employees (headcount)20252024
Total number of non-employees703430

The number rose 63% year on year (page 177). Non-employees are defined as "contingent workers who work for but are not employed by Sartorius Stedim Biotech and are therefore excluded from payroll" - at Sartorius Stedim Biotech, "generally temporary workers" (pages 166, 178).

The company explains both the purpose and the location of the use: "Contingent workers play an important role in the company's flexibility and adaptability. The targeted use of contingent workers allows the company to respond to changing market demands and short-term project requirements without having to permanently expand the employee base... Sartorius Stedim Biotech hires contingent workers primarily at production sites. In the reporting year, this was essentially the case in France" (page 177).

Only the headcount total is given. No breakdown by type of non-employee worker (self-employed versus provided by an employment agency) is disclosed, and the figure is a 31 December snapshot from the Group-wide HR system (page 178). Non-employees are, however, included in the health and safety metrics under S1-14, where they recorded 13 recordable accidents at a rate of 11.1 per million hours worked, well above the employee rate of 3.0 (page 184).

S1-7(was S1-8)Collective bargaining coverage and social dialogue
Reported

Collective bargaining coverage and social dialogue

Reference: pages 178-179.

Collective bargaining coverage was 55% of all employees at 31 December 2025 (2024: 53%) (page 178).

Coverage20252024
Group total55%53%
Germany82%81%
France100%100%
EMEA69%67%
Americas36%36%
Asia-Pacific5%5%

The company explains the incomplete German figure: it "can be explained by employees who are not covered by collective agreements because their job characteristics and/or remuneration level do not fall within the personal scope of a collective agreement. Some companies are also not bound by collective agreements." On the non-EEA regions: "Coverage outside the EEA is lower due to lower legal labor standards" (page 178).

Workplace representation. In the two significant EEA countries, Germany and France, "the proportion of employees represented in the workplace... was 100% in each case"; across EMEA it was 76% (2024: 75%).

Method is stated: coverage comes from the Group-wide HR system at 31 December; social dialogue is counted by works council presence, where "For Group companies with a works council, 100% of employees are included in the calculation. For Group companies without a works council, 0% of employees are included" (page 179). Read with S1-2, works councils exist at 22 of 47 companies (page 170).

S1-8(was S1-9)Diversity metrics
Reported

Diversity metrics

Reference: pages 179-181.

Gender diversity20252024
Top management (headcount)5548
- male / female40 / 1534 / 14
Top management male (%)7371
Top management female (%)2729
Other gender / not disclosed00
Age distribution20252024
Under 301,540 (15%)1,467 (15%)
30-506,571 (64%)6,331 (64%)
Over 502,154 (21%)2,103 (21%)

The company describes both distributions as unchanged year on year (page 179). In fact the female share of top management fell two percentage points, from 29% to 27%, even though the number of women in top management rose from 14 to 15, because the top management population grew from 48 to 55. The report does not comment on that movement.

Definition (page 180). Top management is "the first and second management levels below the Board of Directors", counting "Employees with global management responsibility or significant local responsibility for the core business and working at the Group's management level 2 or 3".

The 27% female share of top management sits against 39.8% female representation across the workforce (page 173) and 62.5% women on the Board (page 91). Gender data for the "other" and "not disclosed" categories is estimated from the 2022 German census and reports as zero; "an improvement in this specific case is under evaluation" (page 181).

S1-9(was S1-10)Adequate wages
Reported

Adequate wages

Reference: page 181.

Adequate wages20252024
Employees paid below an adequate wage (%)0.00.1

"As of December 31, 2025, no Sartorius Stedim Biotech employee received remuneration that was below the applicable benchmark for fair remuneration (previous year: 0.1%). In the previous year, this was the case in China."

The benchmark used, and its limits. The company benchmarks against statutory minimum wages rather than a living wage: "The benchmark for adequate wages is based on the respective statutory minimum wages of the countries in which Sartorius Stedim Biotech operates. If the benchmark in a country is higher than the annual contractual base salary of an employee in that country, the employee will not be counted as adequately paid."

The company also flags the measurement basis as a source of error: "to determine adequate wages, Sartorius Stedim Biotech uses the contractually agreed base salary and not the actual salary paid. Consequently, factors such as overtime pay are not taken into account in the comparison. This can lead to inaccurate results." No actions to improve accuracy have been decided.

This is a full nil-exception return for the metric, with the caveat that the benchmark is a legal floor rather than the adequate-wage benchmarks contemplated in ESRS S1 application guidance.

S1-10(was S1-11)Social protection
Reported

Social protection

Reference: pages 181-182.

Employees covered for the following life events (%)20252024
Sickness100100
Unemployment100100
Employment injury and acquired disability9191
Parental leave100100
Retirement9392

The company names the gaps rather than leaving them in the percentages: "Coverage for occupational accidents and disability is not available in Ireland and the United Kingdom, and retirement coverage is not available in Argentina. In the USA and Brazil, retirement coverage through Sartorius Stedim Biotech actions is only partially available if certain criteria are met. In the USA, for example, only employees who are older than 59 and have been with the company for more than 25 years are eligible. In Brazil, only full-time employees benefit from retirement coverage" (pages 181-182).

Coverage counts both public programmes and company benefits: "In the reporting year, most employees were covered by public programs or by benefits offered by the company against loss of income due to significant life events" (page 181). The figures are based on a survey of the consolidated Group companies at 31 December (page 182).

S1-11(was S1-12)Persons with disabilities
Reported

Persons with disabilities

Reference: page 182.

People with disabilities20252024
Percentage of employees with disabilities (total)22

"The proportion of employees with disabilities remained unchanged compared to the previous year. As of December 31, 2025, employees with disabilities accounted for 2% of the workforce (previous year: 2%)."

Definition. The company applies local definitions rather than a single Group standard: "The applicable country-specific definitions and local guidelines are used to establish which employees have disabilities." The figure is compiled from the Group-wide HR system and a survey of the consolidated Group companies at 31 December.

No breakdown by gender is given, and the disclosure does not state whether legal restrictions on collecting this data apply in any country. Read against the policy position in S1-1, the employee Code of Conduct addressed inclusion of people with disabilities in the reporting year through the non-discrimination clause, but the company states that "There are currently no significant specific policy commitments regarding inclusion or support actions for people from groups that are particularly vulnerable among our own workforce" (page 168). Manager training on unconscious bias "also addresses diversity, gender equality and the employment of persons with disabilities" (page 171).

S1-12(was S1-13)Training and skills development metrics
Reported

Training and skills development metrics

Reference: pages 183-184.

20252024
Employees who had regular performance and career development reviews (%)8692
- male / female87 / 8593 / 91
Average training per employee (hours)17.718.3
- male / female18.7 / 16.319.3 / 16.7

Both metrics fell. Reviews were down 6 percentage points and average training hours fell 3%. Women completed 16.3 hours against 18.7 for men, a gap that persists from 2024 (page 183). The report gives no explanation for either decline.

Eligibility narrows the denominator (page 183). The review cycle ran from 1 December 2024 to 28 February 2025. Eligible employees "belong to the active permanent workforce, joined the Group before October 1 of the previous year (2024), and are still with the Group at the end of the reporting year". Not eligible: "employees who are on leave at the time the process begins, employees in training, and employees of companies newly acquired within the last six months."

Figures come from a survey of the consolidated Group companies at 31 December, and "No specific actions to improve the accuracy of the data have been decided upon at this time" (page 184). The BP-2 uncertainty table cites the "Exclusion of some employees in companies that are not fully connected to the personnel management system" for S1-13 (page 86).

S1-13(was S1-14)Health and safety metrics
Reported

Health and safety metrics

Reference: pages 184-185.

Health and safety20252024
Workforce covered by a health and safety management system (%)3835
Fatalities - employees / non-employees0 / 00 / 0
Recordable work-related accidents - employees5463
Recordable work-related accidents - non-employees138
Rate per 1,000,000 hours - employees3.03.6
Rate per 1,000,000 hours - non-employees11.111.1
Recordable work-related ill health - employees28
Days lost8801,137

The employee accident rate improved 17% and days lost fell 23%. Two figures stand against that. Non-employee workers are injured at 3.7 times the employee rate (11.1 against 3.0 per million hours), and their absolute accidents rose from 8 to 13 as non-employee headcount rose 63% to 703 (page 177). And coverage by a certified health and safety management system is only 38%, counting "externally certified systems in accordance with ISO 45001" (page 184).

Method caveat (page 185). The rate uses "theoretical rather than measured working hours. It does not take account of absences due to individual short- and long-term absences such as illness, overtime, and trainee absences... Consequently, there are outcome uncertainties in the calculated rate, which may actually be higher or lower." The metric covers employees and non-employees together.

S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Reported

Remuneration metrics (pay gap and total remuneration)

Reference: pages 187-188.

Pay gap and total remuneration20252024
Gender pay gap (%)1111
Ratio of highest-paid individual to median employee remuneration2418 (restated)

The gender pay gap was flat, with "women earning on average 89% (previous year: 89%) of what men earn overall". The company states the ESRS caveat itself: "this is an unadjusted earnings gap because factors such as function, responsibility/hierarchy level, education, and experience are not included in the calculation" (page 187).

The CEO pay ratio rose by a third, from 18 to 24. The report states the movement without explaining its cause.

Restatement (page 187). The 2024 ratio was restated from 21 as originally reported to 18, "Change in calculation methodology to actual remuneration paid". Under BP-2 the company adds that "There is no longer any uncertainty regarding the ESRS disclosure requirement S1-16 for the 2025 reporting year" (page 86).

Method (pages 187-188). Total remuneration is actual payments from local payrolls including base salary, variable and additional remuneration. "The share package, which applies exclusively to the highest-paid individual as part of variable compensation, was included in the calculation at a rate of 25% due to its four-year term." The ratio excludes the highest-paid individual from the median.

S1-14(was S1-15)Work-life balance metrics
Reported

Work-life balance metrics

Reference: page 186.

Work-life balance20252024
Employees entitled to take family-related leave (%)9190
Entitled employees that took family-related leave (%)1917
- male1716
- female2219

Take-up rose 12% year on year. Both metrics are reported by gender, with the "other" and "not disclosed" categories at 0% "because there were no employees in this gender category".

Definition (page 186). Family-related leave "includes maternity leave, paternity leave, parental leave, and carers' leave that is available under national law or collective bargaining agreements". Entitlement requires the employee to be covered by a regulation, policy, agreement, contract or collective agreement conferring the entitlement, and for the entitlement to be reported to or known by the company. The company applies a strict test: "Only employees who are entitled to all family-related leave are counted for the metric."

Figures come from a survey of the consolidated Group companies at 31 December combined with HR system gender data; the "other" and "not disclosed" categories are estimated from the 2022 German census, so "there is slight outcome uncertainty in the disclosures on gender" (page 186).

Note the ESRS 2 uncertainty table cites page 194 for S1-15, while the disclosure itself sits at page 186 - one of several page-reference mismatches in the BP-2 tables (page 86).

S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Incidents, complaints and severe human rights impacts

Reference: pages 188-189.

Own workforce20252024
Incidents of discrimination, including harassment (number)515
Complaints filed through channels for own workforce00
Fines, penalties and compensation for those incidents (EUR)00
Severe human rights incidents (number)00
Fines, penalties and compensation for severe human rights incidents (EUR)00

Complaints regarding discrimination including harassment fell from 15 to 5. The company breaks down the outcome: "Of these, 0 complaints were justified/partially justified (previous year: 0), 0 were unjustified/could not be clarified (previous year: 0) and 0 are still being investigated (previous year: 0)" (page 188). That breakdown sums to zero against a reported total of five, which the report does not reconcile.

No additional complaints were recorded through other channels or to the OECD National Contact Points for Multinational Enterprises, and no severe human rights incidents were identified.

Definitions (page 189). Severe human rights violations are "Cases of forced labour, human trafficking or child labour". Cases counted are restricted to those received through formally opened reporting channels "and for which Sartorius Stedim Biotech is partly responsible and which are related to employment".

S2 – Workers in the Value Chain

S2-1Policies related to value chain workers
Reported

Policies related to value chain workers

Reference: pages 190-192. The governing instrument is the parent's Sartorius Code of Conduct for Business Partners, mapped at page 191.

What the code requires:

  • Working hours - compliance with applicable law and ILO standards.
  • Reasonable wages - at least statutory minimum wage and industry standards including overtime; workers "must be informed regularly and in a comprehensible manner about how their remuneration is calculated".
  • Health and safety - a safe working environment at all production sites "as well as a safe living environment in all accommodation provided by the company", with hazards identified and documented.
  • Equal treatment - non-discrimination, with "equal pay for work of equal value".
  • Violence and harassment - "Physical punishment, psychological or physical coercion, threats, insults, or duress, including (sexual) harassment and (sexual) abuse, are not tolerated."
  • Child and forced labour - both strictly prohibited; retention of passports or work permits is not permitted.

Not covered: "Further training and skills development", "Employment and inclusion of people with disabilities" and "Diversity" are not taken into account (pages 191-192).

Incidents: "no cases of non-compliance with the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration... or the OECD Guidelines... involving workers in the value chain were reported" (page 192).

S2-2Processes for engaging with value chain workers about impacts
Reported

Engaging with value chain workers about impacts

Reference: page 192.

The company states plainly that it does not engage with value chain workers. "Sartorius Stedim Biotech is in constant communication with its relevant stakeholders, including suppliers... However, Sartorius Stedim Biotech does not currently have a process in place for direct or indirect engagement with workers in the value chain."

A second gap follows on vulnerable groups: "In addition, the company has not currently established any specific processes to gain insights into the perspectives of workers in the value chain who are particularly vulnerable to impacts and/or may be marginalized (e.g., female workers, migrant workers, workers with disabilities)."

This is a nil return rather than an omission. It should be read against the material impacts under SBM-3, which include potential negative impacts on suppliers' employees through poor working conditions and, newly material in 2025, child and forced labour risk in electronics sub-supply chains, where risk is "generally increased... particularly in the extraction and processing of rare earths and metals". The company also records that it "has no detailed information about workers in the value chain who may be more severely affected" (page 103).

Supplier-level engagement does exist (page 97), but that is engagement with the business partner, not its workers.

S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reported

Remediation and channels for value chain workers to raise concerns

Reference: page 192, cross-referring to S1-3 at pages 170-171.

"The general human rights due diligence process includes both the company's own workforce and workers throughout the value chain. Sartorius Stedim Biotech refers to the its disclosures under S1-3 concerning the general procedure for improving negative impacts and complaints management."

The S1-3 channels are therefore the channels available to value chain workers: round-the-clock reporting "in various languages and also anonymously if preferred", available "inside or outside Sartorius Stedim Biotech", through the compliance team in person, a hotline, e-mail or the whistleblower system, published on the public website as well as the intranet, with publicly accessible "Rules of Procedure for Whistleblowers" (page 170).

S1-1 confirms the scope: monitoring "applies to both own workforce and workers in the value chain. They have the option at any time to report violations to the responsible manager, workers' representatives, the Compliance Officer or via the compliance or whistleblowing hotline, as well as anonymously via the whistleblower portal" (page 169).

The disclosure does not state whether value chain workers are made aware of the channels or trust them, and no report volumes from that group are given. Read with S2-2, where no engagement process exists, the effectiveness of the channel for this group is not evidenced.

S2-3(was S2-4)Taking action on material impacts on value chain workers
Reported

Taking action on material impacts on value chain workers

Reference: pages 192-193.

Contractual mechanism (page 192). Suppliers are contractually obliged to comply with the Business Partner Code of Conduct, and "direct suppliers are also obliged to ensure that their subcontractors comply with Sartorius' principles". Since September 2022 its signature "has been an integral part of the binding onboarding process for new suppliers".

Risk analysis (page 192). Compliance is monitored through the LkSG-based analyses described under S1-1: country and industry screening of all active suppliers, self-assessment and media screening for high-risk suppliers, and PSCI audits.

New in 2025 (page 193). "Sartorius worked intensively on the creation of a supplier handbook that further specifies the requirements for suppliers. This handbook was published in the fourth quarter of 2025. For fiscal year 2026, there are plans to train selected suppliers in the application of this handbook."

Effectiveness (page 193). Determined "through internal structured interviews conducted on behalf of the company's human rights officer", reported to and evaluated by the Board.

Outcomes and resources. "In the reporting year, there were no material risks and opportunities that would have required action. Furthermore, no serious problems or incidents relating to human rights were reported in the upstream and downstream value chain." Resources are provided but not quantified.

S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Targets related to value chain workers

Reference: page 193.

No targets have been set. "In the reporting year, the company has not yet defined any Group-wide measurable, time-bound and outcome-oriented targets as the company gradually develops its sustainability strategy."

The MDR-M disclosure immediately following is equally direct: "In the reporting year, the company did not define any metrics in relation to material sustainability matters related to value chain workers, as the focus in the first step is on developing Group-wide targets" (page 193).

So for the S2 topic there are neither targets nor metrics in the second year of ESRS reporting. Effectiveness tracking under the MDR-T other limb rests on the qualitative mechanism described at S2-4: "The effectiveness of the due diligence system, including the actions, is determined through internal structured interviews conducted on behalf of the company's human rights officer. The results of these interviews are reported to and evaluated by the Board of Directors" (page 193), together with the supplier rating produced by self-assessment and media screening and the internal and external PSCI audits described under S1-1 (page 169). The company states it "is currently working on defining strategic goals to further improve the monitoring of effectiveness and the methodology for measuring progress".

G1 – Business Conduct

G1-1Business conduct policies and corporate culture
Reported

Business conduct policies and corporate culture

Reference: pages 194-196. G1-1 is the only numbered G1 disclosure requirement in the content index.

Corporate culture.

  • Mission and vision - "to help improve the health of more people".
  • Corporate values - "Sustainability, Openness, and Enjoyment", with a "speak-up culture" in which "employees are encouraged to contribute ideas and openly address concerns".
  • Code of Conduct - "supplemented by a special anti-corruption code, which is fundamentally in line with the United Nations Convention against Corruption" (page 194).
  • Leadership guidelines - active leadership, performance orientation and teamwork.

The Board bears ultimate responsibility, monitored through the compliance management system described under E1-2. Actions (page 195): mandatory onboarding; a development programme for new managers; leadership coaching; year-round performance reviews; anonymous feedback twice yearly through the employee survey.

Animal welfare (page 195), presented by the company under G1. A new policy on the elimination of animal components in growth factor and cytokine products was implemented in 2025, with compliance "ensured by product design"; products on the market are "completely animal-free or xeno-free".

Limits. Appendix B marks the G1-1 paragraph 10(b) and 10(d) datapoints "immaterial" (page 122), and "the company cannot provide disclosures on financial resources at present" (page 195).

G1-2Management of relationships with suppliers
Not Material
G1-2(was G1-3)Prevention and detection of corruption and bribery
Not Material
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conduct
Reported

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed under MDR-T rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Reference: page 196.

A measurable target exists for corporate culture. In 2025 the company "decided to discontinue pursuing the previously communicated target for employee net promoter score (ENPS)... Instead, the effectiveness of concepts and actions in the area of corporate culture will now be monitored on the basis of employee motivation and commitment (EMC)", because ENPS "is influenced by numerous external factors that are difficult for Sartorius to control".

The target and its outcome: "EMC should achieve an annual average value of 4 points on a scale of 1 to 5 points (low to high). Employee representatives were involved in defining an appropriate target value. The target is part of the short-term variable compensation for the Executive Board (see GOV-3) and management. In fiscal year 2025, the EMC value was 3.91 points. Thus, the target of 4 points was almost achieved." The value rose from 3.85 in 2024, and "EMC is visualized in dashboards for the Board of Directors and managers."

For animal welfare there is no target: "Sartorius Stedim Biotech has not set any targets for tracking the effectiveness of concepts and actions in the area of animal welfare", and no metrics were defined (pages 196-197).

G1-4Incidents of corruption or bribery
Not Material
G1-5Political influence and lobbying activities
Not Material
G1-6Payment practices
Not Material