Stroeer

The role of the administrative, management and supervisory bodies

Role of the management body

Due to its legal structure as a partnership limited by shares (KGaA), Ströer does not have a classic board of management as in a stock corporation under German or European law. In a KGaA, the responsibilities of the board of management are performed by the general partner, which is determined by the articles of association of the partnership limited by shares rather than by the supervisory board. The general partner of Ströer SE & Co. KGaA is Ströer Management SE, which is responsible for managing Ströer SE & Co. KGaA.

The Board of Management of the unlisted Ströer Management SE consists of three people. The proportion of men on the board is 100%.

Allocation of responsibilities within the Board of Management of the general partner

Role of the administrative body

The Executive Committee is the highest management body in the Ströer Group after the Board of Management. It has six members, drawn from operating units and head office. At the time of preparing this report, four members are male and two are female. Accordingly, 67% of the Executive Committee members are male and 33% are female.

Supervisory body

The Supervisory Board is the highest governing body of Ströer SE & Co. KGaA. The Supervisory Board has equal representation and consists of eight shareholder representatives and eight employee representatives. As at the reporting date, the Supervisory Board has eleven members who are male and five who are female. This means that 69% of the members of the Supervisory Board are male and 31% are female. All members on the shareholders' side are deemed independent.

Skills and expertise of shareholder representatives on the Supervisory Board

Where the Supervisory Board members representing the shareholders consider criteria from the profile of skills and expertise to be met, this is shown in the following table:

Sustainability organization

Overall monitoring of the sustainability performance of Ströer SE & Co. KGaA is the responsibility of Henning Gieseke (CFO), ESG officer of the Board of Management of the general partner, and Martin Diederichs, ESG officer of the Supervisory Board.

The ESG officer on the Board of Management of the general partner is responsible for overall monitoring of the sustainability performance of Ströer SE & Co. KGaA. Together with the Board of Management, he or she also makes strategic decisions on environmental and climate issues and monitors material impacts, risks, and opportunities. The ESG officer is also responsible for human rights and the Group's duty of care in this respect, along with all central governance topics. He or she reports to the ESG officer of the Supervisory Board at meetings of the Supervisory Board or its committees.

The Board of Management of the general partner as a whole bears overall responsibility for compliance with the Ströer Social Charter and Policy Statement on Respect for Human Rights of Ströer SE & Co. KGaA. The Board of Management of the general partner is also responsible for risk management at Ströer SE & Co. KGaA, which forms an integral part of corporate governance and of the planning and control process. It is supported in this by the Governance, Risk & Compliance (GRC) corporate unit.

The duties of the Supervisory Board ESG officer include overall monitoring of the sustainability performance of Ströer SE & Co. KGaA. The ESG officer ensures that regulatory requirements and strategically relevant sustainability matters are implemented appropriately by the general partner. This supervisory function therefore covers topics ranging from the environment, occupational health and safety, and general health through to welfare matters. The ESG officer of the Supervisory Board also puts sustainability matters forward at meetings of the Supervisory Board and the Audit Committee. This ensures that potential sustainability targets and related actions are monitored on an ongoing basis.

The head of Investor Relations & Sustainability bears particular responsibility for the sustainability management system of Ströer SE & Co. KGaA and works tirelessly on keeping it up to date and relevant. He or she is supported in this by the Sustainability Management Group function, which is based in the Investor Relations & Credit Relations corporate unit, the Group Financial Planning and Reporting unit, and the GRC (Governance, Risk & Compliance) department. The corporate units and central support functions are responsible for the operational implementation of sustainability topics.

Ströer SE & Co. KGaA has a multi-level sustainability organization, which includes a Sustainability Council in addition to the highest level organization and control functions described above. This is the Group's central steering committee for sustainability, which is chaired by the Board of Management ESG officer. The committee comprises decision-makers from all relevant divisions and departments of the Company. It approves and coordinates important overarching sustainability topics. Current developments are also presented and discussed and, as part of the sustainability reporting, the IROs (impacts, risks, and opportunities) are communicated and presented to the supervisory bodies.

Additional sustainability-related roles have also been created at the two subsidiaries AsamBeauty and Statista. The sustainability management team works directly with the relevant divisions and subsidiaries to coordinate measures to achieve the sustainability targets that apply across the Group.

Reporting to administrative, management and supervisory bodies (GOV-2)

The head of Investor Relations & Sustainability and the senior sustainability manager report directly to the Board of Management ESG officer each month on the setting and achievement of targets relating to sustainability processes and the matters arising from them. If required, they brief the ESG officer of the Board of Management of the general partner on an ad hoc basis.

The Board of Management of the general partner, represented by the Board of Management ESG officer, reports to the ESG officer of the Supervisory Board at meetings of the Supervisory Board and its committees.

The double materiality assessment analyzed impacts, risks, and opportunities over the course of 2024. The results were presented to the ESG officers of the Board of Management of the general partner and of the Supervisory Board and the impacts, risks, and opportunities were discussed and evaluated.

The double materiality assessment was not completed until the second half of 2024, in connection with the preparation of the first planned CSRD report. The Board of Management of the general partner and the Supervisory Board therefore did not consider impacts, risks, and opportunities in the remaining months in their fundamental, strategic decisions.

The Investor Relations/Sustainability department provided materials for the documentation and monitoring of sustainability topics in order to facilitate the cooperation between the ESG officer of the Managing Board of the general partner and the Supervisory Board. The Audit Committee, of which the Supervisory Board ESG officer is a member, was informed of ongoing developments.

Sustainability-related incentive schemes (GOV-3)

The remuneration of the Board of Management of the general partner of Ströer SE & Co KGaA includes a sustainability-related component. Since 2024, the remuneration system has factored in two strategic targets from the areas of environment and social:

1. Reduce CO2eq emissions and revenue growth (absolute CO2 emissions)
2. Improve the Healthy Workplace Score (satisfaction and health of the employees)

The Remuneration Committee of the Supervisory Board approves the remuneration-related incentives for CO2eq reduction measures. The ESG target (1) assesses the progress on reducing greenhouse gas emissions (GHG emissions) each year. Ströer SE & Co KGaA also takes climate-related sustainability matters into account when determining remuneration.

ESG target 'CO2eq emissions'

Strategic target: CO2eq-neutral growth

Assessment basis: Groupwide Scope 1 and Scope 2 emissions in the prior year, as the Group can directly influence these emissions.

Mechanism: CO2eq target is used as a sustainability factor and short-term incentive (STI) multiplier (0.8–1.2).

• A reduction of 4.2% a year or more constitutes full target achievement and corresponds to a multiplier of 1.2.
• If emissions are largely identical year on year (–0.5% to +0.5% of the prior-year figure), the multiplier is 1. Intermediate values are determined using linear interpolation.
• If the prior-year emissions are exceeded by 4.2% and the target is thus missed, the multiplier is lowered to the minimum (0.8).

ESG target: Healthy Workplace

The Supervisory Board of the general partner has also set a 'Healthy Workplace' ESG target for the Board of Management's remuneration, in order to create incentives for improving the working environment. Each year, progress on the Healthy Workplace Score (HWS) is measured and incorporated into the system of performance-related Board of Management remuneration as a short-term incentive (STI) multiplier. The aim of the Healthy Workplace concept is to use an annual survey to measure employees' motivation, mental ability, and active willingness to dedicate themselves to their employer's corporate goals and business strategy, and the actual degree to which they have done so.

Strategic target: Improve the Healthy Workplace Score

Basis of assessment: HWS derived from survey (minimum score: 0, maximum score: 5)

Mechanism: Healthy Workplace Score is used as a sustainability factor and STI multiplier (0.8–1.2).

• An HWS of between 3.5 and 5 constitutes full target achievement and corresponds to a multiplier of 1.2.
• A score of between 2.45 and 3.449 corresponds to a multiplier of 1.
• A score of between 0.0 and 2.449 corresponds to a multiplier of 0.8.

Proportion of variable remuneration dependent on sustainability-related targets and/or impacts in the reporting year: 27%.

The STI, which is dependent on ESG components via an ESG factor, was set as a proportion of the total variable remuneration.

Integration of sustainability-related performance in incentive schemes

Roles Covered

The remuneration of the Board of Management of the general partner of Ströer SE & Co KGaA includes a sustainability-related component.

Sustainability KPIs Tied to Remuneration

Since 2024, the remuneration system has factored in two strategic targets from the areas of environment and social:

1. Reduce CO2eq emissions and revenue growth (absolute CO2 emissions)
2. Improve the Healthy Workplace Score (satisfaction and health of the employees)

The Remuneration Committee of the Supervisory Board approves the remuneration-related incentives for CO2eq reduction measures. Ströer SE & Co KGaA takes climate-related sustainability matters into account when determining remuneration.

ESG Target: CO2eq Emissions

Strategic target: CO2eq-neutral growth

Assessment basis: Groupwide Scope 1 and Scope 2 emissions in the prior year, as the Group can directly influence these emissions.

Mechanism: CO2eq target is used as a sustainability factor and short-term incentive (STI) multiplier (0.8–1.2).

• A reduction of 4.2% a year or more constitutes full target achievement and corresponds to a multiplier of 1.2.
• If emissions are largely identical year on year (–0.5% to +0.5% of the prior-year figure), the multiplier is 1. Intermediate values are determined using linear interpolation.
• If the prior-year emissions are exceeded by 4.2% and the target is thus missed, the multiplier is lowered to the minimum (0.8).

ESG Target: Healthy Workplace

The Supervisory Board of the general partner has also set a 'Healthy Workplace' ESG target for the Board of Management's remuneration, in order to create incentives for improving the working environment. Each year, progress on the Healthy Workplace Score (HWS) is measured and incorporated into the system of performance-related Board of Management remuneration as a short-term incentive (STI) multiplier. The aim of the Healthy Workplace concept is to use an annual survey to measure employees' motivation, mental ability, and active willingness to dedicate themselves to their employer's corporate goals and business strategy, and the actual degree to which they have done so.

Strategic target: Improve the Healthy Workplace Score

Basis of assessment: HWS derived from survey (minimum score: 0, maximum score: 5)

Mechanism: Healthy Workplace Score is used as a sustainability factor and STI multiplier (0.8–1.2).

• An HWS of between 3.5 and 5 constitutes full target achievement and corresponds to a multiplier of 1.2.
• A score of between 2.45 and 3.449 corresponds to a multiplier of 1.
• A score of between 0.0 and 2.449 corresponds to a multiplier of 0.8.

Weighting and Performance Period

Proportion of variable remuneration dependent on sustainability-related targets and/or impacts in the reporting year: 27%

The STI, which is dependent on ESG components via an ESG factor, was set as a proportion of the total variable remuneration.

Both ESG targets assess progress each year and are incorporated as short-term incentive (STI) multipliers.

Strategy, business model and value chain

Description of products/services and key markets

Ströer is a provider of out-of-home and online advertising space and of manifold aspects of dialogue marketing. It focuses on the German advertising market. It also operates 'data as a service' services (DaaS, brought together under the Statista brand) and an online cosmetics store (via the AsamBeauty brand).

The most important market for Ströer SE & Co KGaA is Germany, which accounts for around 90% of revenue. The Company also has out-of-home activities in Poland, the UK, the Netherlands, and Belgium and international activities through the subsidiaries Statista, AsamBeauty, and Ranger.

At the end of the reporting year, the Ströer Group had 11,858 full-time and part-time employees.

Significant groups of products/services (and their share of revenue if given)

The Ströer Group's three reporting segments are:

Out-of-Home Media

Revenue 2024: EUR 953.2m (2023: EUR 856.4m)

The Out-of-Home Media segment incorporates all of Ströer's analog out-of-home advertising spaces (OOH) and all of its digital out-of-home advertising spaces (DOOH).

Product groups:

• Classic OOH: EUR 527.4m (2023: EUR 497.0m)
• Digital OOH: EUR 369.2m (2023: EUR 299.3m)
• OOH Services: EUR 56.7m (2023: EUR 60.1m)

The OOH business uses around 300,000 advertising media, predominantly in Germany. The service offering includes traditional formats, such as posters or screens and projectors, and digital formats featuring electrically powered LED/LCD screens.

Digital & Dialog Media

Revenue 2024: EUR 878.3m (2023: EUR 815.8m)

Product groups:

• Digital: EUR 452.9m (2023: EUR 418.7m) - encompasses online advertising business and programmatic marketing activities
• Dialog: EUR 425.3m (2023: EUR 397.1m) - comprises call center activities and direct sales activities (door to door)

Ströer Digital Media: Provides solutions for online advertising in the context of proprietary and third-party content. The scalable products marketed range from branding and storytelling through performance and native advertising to social media. Websites include t-online.de, giga.de, familie.de, desired.de, and kino.de.

Ströer X (Avedo/Ranger): The call center business focuses on customer experience and sales. One of the largest providers of performance-based direct sales via call centers in Germany and via nearshore locations in five countries. The Ranger Group is a field sales specialist providing performance-based direct sales services.

DaaS & E-Commerce

Revenue 2024: EUR 357.8m (2023: EUR 350.9m)

Product groups:

• Data as a Service: EUR 164.1m (2023: EUR 148.8m)
• E-Commerce: EUR 193.7m (2023: EUR 202.0m)

Statista: Operates a global database for statistics and reports that offers users access to information on over 80,000 different topics, including business, politics, society, media, technology, and science.

AsamBeauty: A company offering premium beauty products. Own brands include M. Asam, ahuhu organic hair care, YOUTHLIFT®, and Kräuterhof and offer a wide variety of facial, body, and hair care products, as well as make-up.

Significant markets / geographies

The German advertising market is of key strategic importance for the Group as almost 90% of its revenue is generated there. Aside from this, Ströer has:

• Out-of-home activities in Poland, giant poster business in Benelux and the UK
• Further international activities through Statista, Asam, and Ranger

Number of employees by geography

Total employees at end of reporting year: 11,858 full-time and part-time employees.

(Note: Detailed geographical breakdown is provided in chapter S1 of the non-financial statement but not extracted here)

Total revenue by significant ESRS sustainability matter

Not disclosed.

Sustainability-related goals embedded in the business model

Ströer uses financial and non-financial key performance indicators to manage the Group. The most important KPIs are organic revenue growth and EBITDA (adjusted).

Remuneration includes sustainability factors:

• Healthy Workplace Score (HWS): Used as a sustainability factor and STI multiplier (0.8–1.2)
• An HWS of between 3.5 and 5 constitutes full target achievement and corresponds to a multiplier of 1.2
• A score of between 2.45 and 3.449 corresponds to a multiplier of 1.0
• A score of between 0.0 and 2.449 corresponds to a multiplier of 0.8
• Proportion of variable remuneration dependent on sustainability-related targets and/or impacts in the reporting year: 27%

Ströer strives to pursue a dividend policy under which between 50% and 75% of the adjusted consolidated profit for the period is paid as a dividend to shareholders.

Description of the upstream and downstream value chain

Core business (OOH)

Upstream value chain:

• External workers are involved in the production of advertising media and street furniture
• Workers carry out activities in logistics and warehouse management, construction and planning (e.g. installation and removal of advertising media and street furniture, technical commissioning and maintenance of advertising media, planning of advertising media installations in the electrical and construction sector)
• Most complete advertising media and street furniture, mechanical and electronic components, spare parts, materials and supplies, and technical services are purchased in Germany (88% of the hardware procurement volume in 2024)
• Advertising media and street furniture developed inhouse by Ströer are commissioned for production from external manufacturing companies in China (9.5% of the hardware procurement volume in 2024)
• Large proportion of purchasing relates to services, particularly IT and telecommunications, as well as technical services connected with the advertising media infrastructure
• Technical Purchasing works with employees of logistics service providers in international and national transportation and with workers of warehouse providers
• Ströer sources products and services from 29 countries, primarily from Germany, the UK, and the USA

Downstream value chain:

• Output covers digital display of advertising on digital advertising media, display of posters by service providers on classic advertising media, and subsequent disposal
• Aim of advertising is to speak directly to end users and gain their attention

Digital & Dialog Media

Upstream value chain:

Not extensively detailed for digital segment.

Downstream value chain:

• Main outputs are presentation of editorial content (e.g. t-online) and display of advertising on contracting partners' advertising pages
• In Dialog (call center and direct sales), main output is sales services

AsamBeauty

Upstream value chain:

• Workers involved in extraction of various raw materials and production of packaging and intermediate products
• Most work takes place in Europe (73% of input materials purchased), followed by Asia (13%) and North America (3%)
• AsamBeauty sources packaging materials from Europe and Asia

Downstream value chain:

• Work relates to transportation, storage, filling, packing, and dispatch of goods

Statista

Upstream value chain:

• Supplier structure encompasses local and international partners selected based on criteria including sustainability standards and certifications
• Suppliers mainly provide software licenses and IT equipment
• Consultancy firms and agencies are also important suppliers

Downstream value chain:

• Use and processing of data supplied
• Businesses, research institutes, media, governmental organizations, and private users use data for strategic decision-making, reporting, and scientific publications
• Content accessed via digital platforms and content licensing, disseminated in customers' publications and media
• Individualized services such as market studies, consultancy services, and design services flow directly into customers' business processes

Key inputs and outputs

Core business (OOH)

Key inputs:

• Electricity for digital advertising spaces (LED displays)
• Paper for posters and flyers
• Metal and glass for digital and classic advertising media, bus and tram shelters, and other advertising media and structures
• Suitable spaces for installation of advertising media (provided by local and municipal authorities)
• IT systems for online advertising

Key outputs:

• Digital display of advertising on digital advertising media
• Display of posters on classic advertising media
• Advertising aimed at end users in public spaces

Digital & Dialog Media

Key inputs:

• Powerful IT systems for creation and display of digital advertising formats

Key outputs:

• Presentation of editorial content (e.g. t-online)
• Display of advertising on advertising pages
• Presentation of retrieved data on user's screen
• Sales services (Dialog)

AsamBeauty

Key inputs:

• Electricity for production, administration, and development
• High quality raw materials and active ingredients (synthetic: retinol, niacinamide, peptides; natural: grapeseed extract, argan oil, almond oil)
• Packaging made from paper, cardboard, glass, or plastic
• High-tech IT systems for management, development and distribution

Key outputs:

• Broad range of beauty and skincare products
• Sold through online shop, teleshopping, drugstore chains, and online marketplaces

Statista

Key inputs:

• Electricity for IT infrastructure
• Access to data (freely accessible data sources and purchased data sets)
• Panel data for long-term trend analysis
• IT infrastructure for publishing statistics

Key outputs:

• Statistics and reports made available to customers in various formats on the Company's own website

Sales channels

Core business (OOH)

• Large portfolio of advertising media on roadsides, at train stations, on and in public transportation, and in pedestrian areas
• Offers products on local, regional, or national basis
• Digital municipal information systems included in federal and regional government emergency plans

Advertising media in DOOH business divided into three categories:

• Premium Public Video Roadside Screens: Digital advertising spaces installed along a road and more than 2m² in size
• Premium Indoor Screens: Digital advertising spaces with screen size of at least 60", installed in train stations, public transportation systems, shopping malls, and airports
• Longtail: All digital advertising spaces installed indoors in smaller format, mostly in retail settings

AsamBeauty

• Strong presence in leading drugstores in Germany, Austria, and Switzerland
• Global presence on Amazon (Marketplace)
• Online shop
• Teleshopping and leading TV shopping channels such as QVC in the UK and HSN in the USA

Statista

• Direct sales through subscriptions and content licensing agreements
• Bespoke solutions and partnerships with media companies via B2B collaborations
• Digital channels (website, social media, search engine marketing)
• Consultancy services with individual market analyses
• Special programs for schools and universities

Interests and views of stakeholders

Stakeholder identification and prioritization

For Ströer, stakeholders are individuals or groups of people within the Company or outside it, who are directly or indirectly affected by the Company's business and who therefore have needs and expectations vis-a-vis the Group. The selection of relevant stakeholders is based on standard definitions of internal and external stakeholder groups. These groups are prioritized in a stakeholder management process to determine the focal point of dialogue and make the most efficient use of limited resources.

The relevant stakeholder groups for the Ströer Group are:

• Employees
• Customers
• Analysts and investors
• Private landowners and concession-givers
• Suppliers and business partners
• Consumers and end-users
• Environment

Stakeholder engagement approach

Stakeholders are involved on an ongoing basis as part of the Company's general business activities. Specific stakeholder groups were also polled on ESG topics for the double materiality assessment. This involvement did not result in any direct adjustment of Ströer's business or strategy.

The collaborative partnership with stakeholders is critical to the Company's success. Stakeholders provide important indications of the expectations the Group faces in terms of sustainability, and of areas where it can potentially improve. This enables the Company to identify risks for its business and its green credentials at an early stage, and provides a mechanism for recognizing opportunities, for example through innovation processes.

Dialogue with stakeholders creates transparency and can reveal any conflicts of interest and conflicting objectives between stakeholder groups – an important starting point for discussing possible solutions. The Company therefore maintains regular dialogue with its stakeholders in order to ascertain their concerns and expectations, and also to set out its own position. Stakeholder feedback plays an important role in the success of the business and, for the customer stakeholder group, is documented in accordance with the relevant processes.

Key stakeholder concerns raised during reporting period

The Board of Management and Supervisory Board were briefed on stakeholder concerns as part of the double materiality assessment in 2024. Stakeholders (employees, customers, service providers, interest groups, trade associations, consumers/end-users, investors, analysts) were asked about specific ESG topics relating to Ströer SE & Co KGaA. The Ströer Group will develop action plans on the basis of the findings and implement these in the coming years.

The individual business units also regularly discuss stakeholder suggestions, requests, and criticisms as part of the ongoing process optimization. If found to be in the interests of both Company and stakeholders, these are then implemented.

Engagement by stakeholder group

Employees

The Ströer Group's employees are critical to its success. Their importance is reflected in the pivotal position of HR within the organizational structure. The head of HR reports regularly to the Board of Management and is a member of the Executive Committee. Sustainability-related topics affecting employees are also discussed in the Sustainability Council.

Employees are involved via various formats and committees. Direct feedback is gathered through channels such as the Healthy Workplace survey, for example (see also chapter S1-4).

Close collaboration with the entities' works councils ensures that consideration is given to the concerns and interests of the workforce. Entities with works councils hold regular works meetings to create transparency and promote dialogue. Discussions with the works councils take place at least once a month, while communication with the employees is regular as well as in response to specific events. Half the seats on the Supervisory Board of Ströer SE & Co. KGaA are filled by employee representatives, which ensures employee involvement in the Company's ultimate governing body.

The Group also offers various communication formats that allow employees to become actively involved. Quarterly town hall meetings enable a direct dialogue with the Board of Management, while the series of virtual talks with the Co-CEO ('Fre1stunde') provides a forum where questions and suggestions can be raised. The CFO also organizes regular getting-to-know-you chats with new employees to encourage dialogue at an early stage.

The employees and works councils were also involved in the double materiality assessment process, to identify the relevance of various sustainability topics. Employees were also involved in the assessment of the IROs.

Customers

Within its core business of out-of-home advertising, Ströer has built a broad and deep customer portfolio with national, regional, and local customers from a range of sectors and industries. In sales, direct dialogue with customers takes place via the customer relationship managers. Ströer also attends trade fairs in order to stay in touch with its customers. Customer and user surveys are conducted on a regular basis to gather feedback. The Net Promoter Score (NPS) is measured, and customer surveys conducted on the importance of sustainability. The performance of agency services is also assessed, to measure customer satisfaction and quality of service. Results are fed into management decision-making processes on a topic-by-topic basis and provide the basis for future decisions.

Within the wholesale business, AsamBeauty's customers are mainly drugstores in Germany and German-speaking countries and e-commerce sales channels. It also sells to retail customers through TV shopping and via Asam's e-commerce platform. Various tools are used for this dialogue, such as feedback from customers.

Analysts and investors

Selected feedback from the investors and analysis is incorporated into the strategic planning. In addition to financial expectations and market analysis, consideration is increasingly being given to ESG criteria in order to better meet the expectations of the capital markets and to develop sustainable growth strategies.

Various analysts and investors were also involved in the double materiality assessment process by means of face-to-face interviews, which were used to identify the relevance of various sustainability topics.

Private landowners and concession-givers

Private landowners and concession-givers are important stakeholders in the out-of-home advertising business.

Local authority partners award concessions to Ströer which allow the Company to carry on its OOH advertising business on public land in a specific town or local area for a fixed contract term. Similarly, private landowners are important partners for site utilization, generally for individual plots.

Material impacts, risks and opportunities and their interaction with strategy and business model

Material IROs Overview

Ströer analysed the material impacts, risks, and opportunities (IROs) and their interaction with the strategy and business model in 2024. Risks and opportunities are assessed as part of the strategy and management of the business model and value chain. The Company's activities and partnerships have both a positive and negative impact on the environment, welfare and community matters, and corporate governance. The material impacts affect environment, particularly in respect of energy consumption and greenhouse gas emissions, and waste produced by business activities, as well as social and welfare matters such as the Company's own workforce, working conditions and advertising content, and corporate culture and governance. At the same time, the business activities also give rise to opportunities, such as lower energy consumption as a result of technical advancement or less waste through the switch from analog, paper-based advertising media to digital. Naturally there are also risks, however.

The topic-specific chapters discuss in detail the material impacts, risks, and opportunities and their interaction with the strategy and business model.

Climate Change (E1) IROs

Greenhouse gas emissions caused by our business activities: Ströer's business activities have negative impacts on the environment, especially through the generation of greenhouse gas emissions, including in various parts of the upstream and downstream value chain. In our own business operations, the majority of emissions are produced through energy consumption, particularly in relation to the operation of analog and digital advertising media. The energy requirements of the office buildings and the vehicle fleet emissions also contribute substantially.

Energy consumption caused by our business activities: Most of the energy consumption relates to the electricity used to power the analog and digital advertising media, the electricity and heating energy for the office buildings, and the energy needs of the vehicle fleet – including fuel consumption of gasoline and diesel vehicles, and the electricity consumption of electric vehicles.

Physical risks: Ströer's assets, such as real estate or advertising media, are vulnerable to the impact of potentially extreme weather events such as storms and floods, and may suffer damage. Weather events can also cause disruptions to the energy supply, which adversely affects value creation.

Rising energy costs (transition risk): Electricity is a material factor in Ströer's provision of services. Rising energy prices therefore increase costs, potentially significantly, and reduce margins or even result in losses. The same applies to other sources of energy, such as gas and heating oil, used to heat office space, for example. The price trend is contingent on the one hand on the availability of energy relative to demand, and on the other on government levies/taxes on the purchase and consumption of (fossil) fuels.

Energy reduction through technical advancements: Technical progress may lead to ever less energy-intensive advertising media, which means lower energy requirements and a downward trend in costs for the same scope of services. The strength of this effect depends primarily on the speed and extent of technical developments.

Interaction with strategy and business model: The Ströer Group does not currently have a transition plan that meets the requirements of E1-1 14-16. This is due in part to changes to the conversion factors and to the way in which data is collected. Due to the change of base year in connection with the CSRD reporting, however, there is currently no transition plan with regard to the Environmental Policy. For this reason, the policy currently does not cover climate change mitigation, climate change adaptation, energy efficiency, or the use of renewable energies. Nor does it cover managing physical climate risk, or the climate change adaptation-related transition risks. Ströer intends to formulate a transition plan in the future, based on the first dataset to use 2024 as the new base year.

Given the still high proportion of energy generated from fossil fuels, Ströer is continuously working to minimize its own energy demand while maintaining the same performance by optimizing efficiency.

Circular Economy (E5) IROs

Waste generated through advertising materials: In out-of-home advertising, Ströer generates revenue by selling advertising space – including on analog infrastructure such as billboards, City Stars, and City Light Posters. Customer posters (specialty paper) are affixed to the advertising spaces (using poster adhesive) or inserted into the infrastructure. Advertising materials include regular and specialty paper, adhesives, and resins. The waste generated through the use and disposal of such materials can have a negative impact on the environment. If the materials are not recycled or are not disposed of properly, waste can accumulate, air and water can be polluted, and health hazards may be created.

This relates in particular to waste that is difficult to recycle, such as paper coated with polyethylene, aluminum, or plastic that is used by Ströer in the classic poster business, or products with chemical additives. Industrial adhesives and resins used by Ströer in the classic analog OOH advertising business may contain volatile organic compounds (VOCs) and other chemical components.

Waste in cosmetics manufacturing (AsamBeauty): Waste is generated in the manufacture of cosmetics. This can have a negative impact on the environment and human health if the materials are not recycled or properly disposed of. Waste is divided into four categories: Production waste (unused input materials and defective products), Packaging waste (recyclable materials such as cardboard boxes, plastic films, and glass jars), Hazardous waste (chemical residues and other materials that require special disposal), and General waste (non-recyclable material).

Reduction in waste through digital media: The switch to digital advertising media and materials creates an opportunity for cost savings in the handling of waste, as there are no longer any physical posters and similar advertising media to be recycled or disposed of. Digital advertising media can also be easily adapted, which means advertisers can continuously optimize their campaigns or make changes at short notice without having to dispose of physical materials. In particular, the use of digital media eliminates the need for costly disposal or recycling of coated paper and plastic films.

Interaction with strategy and business model: A waste management policy in respect of resource use and circular economy has not yet been agreed, as this requires a comprehensive analysis of the existing waste streams and the related processes. The purpose of this analysis is to identify the specific requirements and optimization potential in order to develop an effective and practical policy.

In February 2024, Ströer Media Deutschland GmbH (SMD-Group) initiated a Germany-wide waste disposal project in the area of 'Central Technology'. This is a joint project with Remondis GmbH & Co. KG, which should in the future create a system for the structured and regular collection of waste at all the SMD Group's warehouses, for every category and material group.

Own Workforce (S1) IROs

Promotion of safe and fair working conditions: The safety of our employees is a fundamental need and a priority for Ströer. Ströer is committed to creating working conditions that prevent accidents and also promote health. Particular attention is given to the creation of a 'healthy workplace', which not only helps to retain employee expertise, but also adds to the Company's attractiveness when recruiting.

The 'Promotion of safe and fair working conditions' impact is fundamentally linked to the business strategy. By attaching importance to safety at work and to preventive health measures, Ströer becomes a more attractive employer. This applies equally to all age groups and all employees of the Company.

Promoting a 'healthy workplace' is a key part of this for Ströer, and underlines the Company's responsibility for the wellbeing of its workforce. Specific actions to ensure that the safety and healthy of the employees is not put at risk are developed through regular H&S meetings, workplace inspections and the Healthy Workplace survey.

Promotion of diverse working environment: A diverse working environment that offers employees opportunities for personal and professional development has a significant positive impact on corporate culture and value creation. Diversity and inclusion foster innovative ways of thinking, boost creativity within teams, and allow different perspectives to be brought into decision-making processes. This helps to strengthen the Company's resilience so that it is better able to respond in a more agile way to the challenges of a constantly changing market. In addition, the promotion of development opportunities has a direct positive impact on the motivation, satisfaction, and loyalty of employees. It raises individual performance levels and ensures that employees identify more strongly with the corporate values. Over the longer term, the result is higher productivity and lower employee turnover.

Skills shortage and employee turnover risk: The loss of key employees or poor staff retention rates can jeopardize stable business operations. The skills shortage in Germany and the growing importance of skilled staff mean that the loss of existing, knowledgeable employees in particular can be existentially threatening. Additional effects include damage to reputation as an employer and difficulty in recruiting new employees. The cost of recruitment and integrating new employees is usually time-consuming and costly.

Workers in the Value Chain (S2) IROs

Working conditions for value chain workers: Ströer relies on stable, trust-based relations with its stakeholders in the supply chain to guarantee high-quality products and services at all times. Attention is paid to compliance with sustainability standards and human rights in the supplier evaluation.

Ströer has no direct access to the dialogue with employees in the upstream and downstream value chain. There may therefore potentially be negative impacts on the value chain workers if suppliers fail to comply with the specified standards for working conditions and health that they have committed to uphold.

The majority of suppliers and business partners are based in Germany, the UK and the USA. The most frequently purchased product groups are services, particularly IT, telecommunications and advertising media, as well as technical services connected with the Company's internal infrastructure.

Every supplier is assessed during the onboarding process as part of the Company's risk management process. The assessment is carried out via the EcoVadis IQ Plus tool, which analyzes risks relating to occupational health and safety, fair pay, child labor, and forced labor. Additional studies, such as that of the International Labour Organization (ILO), are used for high-risk countries. The analysis has shown that the risks are higher in countries in Asia and South America (e.g. China, Malaysia and India) in certain industries such as agriculture, coal mining, and textile production. There is a risk of child labor or forced labor through our collaboration with Chinese suppliers (manufacturers of advertising media, street furniture, and individual mechanical and electronic components).

Consumers and End-Users (S4) IROs

Strengthening freedom of expression: The Ströer Content Group publishes free content on a wide variety of topics, such as politics, sport, health, and finance, via its analog and digital out-of-home advertising media. Ströer's own editorial team produces and curates information and analysis and strengthens freedom of expression. Ströer also uses its news and information portals to increase the visibility of sustainability topics.

Statista provides customers with editorial content and data to ensure objectivity. A small portion of this data is provided free of charge via social media and the Statista website in the form of 'daily data' on current topics. Publicly available statistics foster transparency and promote opinion-forming.

Protecting children through responsible advertising: Ströer does not specifically target children and young people with advertising, and does not display content specifically aimed at children. However, advertising is a part of everyday life for children and young people, as they automatically encounter advertising content on a daily basis, both in public and on the media they themselves use.

German and European advertising law contains clear provisions relating to responsible advertising, and this includes the protection of children and young people. Clients are fundamentally responsible for the format and content of advertising and thus for ensuring that it is legal. Ströer does not have a formal obligation to inspect such content but, as part of its due diligence – including with regard to reputational risk – it examines whether there is potential for violations.

Increasing awareness of health and social/environmental issues: Awareness of the need for greater sustainability means having a responsible approach to social and environmental issues in advertising that is aimed at all end-users and consumers. Ströer therefore participates in information and advertising campaigns in these areas.

Governance (G1) IROs

Identity-creating corporate culture: Work that gives all employees a sense of identity and makes them feel valued is of central importance to the Ströer Group, and it demonstrates this through a clearly communicated and lived corporate culture. This also helps Ströer to attract new employees and secure the long-term loyalty of the workforce.

Supplier dependency risks: Within the Ströer Group's core business of out-of-home advertising, most of the supplies needed to install and operate advertising media such as electrical and electronic components and assemblies (PCs, LED modules, switches, routers, control units, etc.) are sourced from single suppliers in Asia. Economic volatility that affects suppliers presents a risk here. In addition, advertising media and street furniture is mostly sourced via one Asian supplier. The loss of this core supplier could result in a delay in installation and thus in the expansion of the advertising space portfolio.

Revenue in the businesses with primarily digital business models (digital marketing, content, and DaaS) are heavily dependent on online visibility and the related website traffic. Changes in the algorithms used by the search engines can have a direct impact on the amount of relevant website traffic for our services.

Financial loss from corruption: Potential corruption-related risks and associated financial damage could arise from various aspects of the business operation. For example, pressure to generate revenue in Sales in connection with lots of large public tenders could lead to cases of corruption in customer or supplier relationships. Consequently, the Company could be excluded from local or national public tenders, which would result in financial loss to the Ströer Group.

Risk from tighter legal requirements: The risk of business being curtailed as a result of tighter legal requirements, such as the extension of advertising bans or restrictions, is relevant for us as a media group as an extension of bans on e.g. advertising tobacco or sugary products could have a direct impact on the Ströer Group's business activities. This presents a heightened risk of a decline in revenue for Ströer.

There is a cost risk to Ströer in the area of energy regulation, for example in relation to CO2 emissions or electricity consumption, as electricity consumption represents a significant cost factor in the operation of digital media.

Within the area of data protection, there is a risk of stricter regulation in respect of the use of cookies. This directly affects the business activity of our digital segments.

Reputational harm from political support: There could be a risk of reputational damage to Ströer as a result of supporting certain political parties. Supporting a specific political party, for example through donations, could give the impression that Ströer has a political agenda and uses its media reach to promote this party. This harbors the risk of damaging public trust in the Company and thus harming Ströer's reputation.

Opportunity from political engagement: By supporting and helping to shape legislation through political engagement, Ströer sees the opportunity to raise its profile and thus also strengthen its reputation and brand. Political engagement aimed at protecting freedom of expression, diversity, and integrity can have a positive impact on a Company's brand. Where legislative initiatives relating to sustainability and social responsibility are concerned, Ströer also sees an opportunity to play a proactive role in shaping standards, thereby benefiting both society and the Ströer Group's own long-term business.

Materiality Assessment Process (IRO-1)

The double materiality assessment for Ströer SE & Co KGaA has been prepared in accordance with the ESRS standards. The assessment covers the same basis of consolidation used in the Ströer financial report, i.e. all operating units, all business activities, and all regions where the Group does business.

To determine the impacts, risks, and opportunities to be reported, key components of the value chain were identified. These provided the focus for the double materiality assessment. Direct and indirect business relationships were taken equally into account. IROs subsequently identified and assessed were allocated on the basis of this value chain.

Based on the ESRS-relevant topics (ESRS 1 AR 16), a granular list of topics was created for Ströer SE & Co KGaA. Further topics were then added, such as those arising from a sector analysis or rating perspective. In a second step, this topic list (long list) was pruned, with the removal of those topics deemed highly likely to be categorized as non-material.

In line with the double materiality principle, stakeholders were involved in both the impact analysis and the financial analysis. The impact-stakeholders consulted (including employees, works council, suppliers, key customers) were asked to rate the relevance of selected sustainability topics. Interviews were also conducted with representative stakeholders (including banks, investors, and analysts), in order to identify risks and opportunities.

The final validation of the overall process, including validation of the material IROs, was carried out by the Board of Management and the Supervisory Board's ESG officer.

The double materiality assessment process differs from that applied in the prior year, as this year a double materiality assessment in accordance with ESRS was carried out for the first time.

The analyses required in accordance with ESRS IRO-1 of the topic standards for E2, E3, E4, and E5 were not carried out in 2024. They are expected to take place from 2025 onward, and their results should inform future double materiality assessments. Consultations should also take place with the affected communities.

Description of the process to identify and assess material impacts, risks and opportunities

Overall methodology

The double materiality assessment for Ströer SE & Co KGaA has been prepared in accordance with the ESRS standards.

The assessment covers the same basis of consolidation used in the Ströer financial report, i.e. all operating units, all business activities, and all regions where the Group does business.

To determine the impacts, risks, and opportunities to be reported, key components of the value chain were identified. These provided the focus for the double materiality assessment. Direct and indirect business relationships were taken equally into account. IROs subsequently identified and assessed were allocated on the basis of this value chain. The direct basis of consolidation matches that of the annual report.

Step-by-step methodology

Topic identification and long list creation:

Based on the ESRS-relevant topics (ESRS 1 AR 16), a granular list of topics was created for Ströer SE & Co KGaA. Further topics were then added, such as those arising from a sector analysis or rating perspective. In a second step, this topic list (long list) was pruned, with the removal of those topics deemed highly likely to be categorized as non-material. This was done in consultation with the responsible employees and external experts.

Impact assessment process:

Stakeholders were involved in both the impact analysis and the financial analysis. The impact-stakeholders consulted (including employees, works council, suppliers, key customers) were asked to rate the relevance of selected sustainability topics. To guarantee neutral results and avoid preconceived opinion, the impact-stakeholders were also asked about topics that had been excluded from the trimmed-down topic list (shortlist). This allowed them to assess the relevance of excluded topics and suggest further topics that had not been considered. The systematic survey was conducted by means of an online tool and was divided into the categories of environmental (E), social (S), and governance (G). As a manufacturing company, AsamBeauty was subject to particular scrutiny, as its business model and value chain differ from those of the other companies included in the basis of consolidation.

Individual thresholds for the identification of the material impacts were established in connection with the impact-stakeholder survey.

Impacts were identified on the basis of the topics categorized as relevant in the impact-stakeholder survey. This process took into account the fundamental principles laid down by the ESRS. The identification was aided by external experts and the use of various databases. Finally, the identified impacts were categorized across the value chain and by time horizon (short, medium, or long-term) and validated by the relevant employees.

Financial materiality assessment process:

Interviews were also conducted with representative stakeholders (including banks, investors, and analysts), in order to identify risks and opportunities. Interactions with material impacts were examined, together with independent risks and opportunities. The interviews were based on the results of the stakeholder survey and the experience of the external experts, who provided support during the interviews alongside representatives of the Company.

To ensure that interactions between impacts and the resulting risks and opportunities were considered, the material impacts were one of the inputs used to establish the basis for identifying risks and opportunities.

The financial materiality of the risks and opportunities was analyzed in a two-phase process. Ströer has documented the process in its internal policy for recording sustainability risks in the risk management system:

1. Short-term risks and opportunities (up to one year)

• Short-term risks and opportunities are recorded in accordance with the procedure used in groupwide risk management. Accordingly, they are identified and quantitatively assessed locally by the Cluster Risk Officer as part of the semi-annual risk survey. They also inform the semi-annual risk aggregation and simulation.
• Risks and opportunities on the list that were not recorded in the risk management procedure were sent for reassessment. Examples:
  • Rising costs of waste disposal
  • Reputational harm arising from misinformation or breaches of journalistic standards
  • Financial risks arising from corruption
• A sensitivity analysis carried out by Risk Management showed that there are no newly reported short-term ESG risks which are material for Ströer and therefore subject to disclosure requirements.

2. Medium and long-term risks and opportunities (medium-term: 1 to 5 years; long-term: more than 5 years)

• The medium and long-term risks and opportunities were assessed in a workshop (involving the Governance, Risk, Compliance, Investor Relations, Controlling, and ESG functions), where the direct and indirect financial impacts and the likelihood of occurrence were rated on a Likert scale from 1 to 5.

Inputs to the assessment

Data sources: Data sources were drawn on at various stages of the process. For example, publicly accessible and internal databases were used to prepare the impact list.

External consultants: Ströer SE & Co. KGaA engaged two consultancy firms in connection with its sustainability projects, in particular for the CSRD report as 2024 was the first year of reporting under this standard. The firms specialize in sustainability and assisted the relevant Ströer divisions in preparing the report, as well as answering their questions.

Internal experts: The identification was aided by external experts and the use of various databases. Finally, the identified impacts were categorized across the value chain and by time horizon (short, medium, or long-term) and validated by the relevant employees.

The assessment was carried out internally by a selected group of senior employees and subject experts.

Stakeholder consultation:

• Impact-stakeholders: employees, works council, suppliers, key customers
• Financial-stakeholders: banks, investors, analysts
• Surveys conducted via online tool divided into E, S, and G categories
• Face-to-face interviews with representative stakeholders

Scoring criteria for impact materiality

The preparation and performance of the impact assessment followed a clearly structured approach. Firstly, all identified impacts were divided into four categories:

• potentially positive,
• potentially negative,
• actually positive and
• actually negative.

For actual impacts:

• Positive impacts were assessed on the basis of scale and scope
• Negative impacts were assessed on the basis of scale, scope, and irremediability

For potential impacts:

• Potentially positive impacts were assessed according to scale, scope, and likelihood of occurrence
• Potentially negative impacts were assessed according to scale, scope, irremediability, and likelihood of occurrence

When assessing impacts that affect the Company's own workforce, the requirements of ESRS S1 Appendix A.1 were adhered to, in particular with regard to the inclusion of certain parameters that affect scope.

The various aspects were assessed using a Likert scale from 1 to 5, whereby 5 is the highest score.

In the case of a potential negative human rights impact, the severity of the impact takes precedence over its likelihood of occurrence.

Scoring criteria for financial materiality

Short-term risks and opportunities: Identified and quantitatively assessed locally by the Cluster Risk Officer as part of the semi-annual risk survey.

Medium and long-term risks and opportunities: The direct and indirect financial impacts and the likelihood of occurrence were rated on a Likert scale from 1 to 5.

Threshold for materiality

Impact materiality: The thresholds (for the impact assessment) were determined using a statistical assessment, whereby the precise level of the thresholds was also influenced by a qualitative rating.

Once the assessment was completed, the results were statistically evaluated.

Financial materiality: The analysis was carried out in accordance with the procedure used in groupwide risk management.

Frequency / when last reviewed

The double materiality assessment analyzed impacts, risks, and opportunities over the course of 2024. The results were presented to the ESG officers of the Board of Management of the general partner and of the Supervisory Board and the impacts, risks, and opportunities were discussed and evaluated.

The double materiality assessment was not completed until the second half of 2024, in connection with the preparation of the first planned CSRD report.

Use of value chain mapping

To determine the impacts, risks, and opportunities to be reported, key components of the value chain were identified. These provided the focus for the double materiality assessment. Direct and indirect business relationships were taken equally into account. IROs subsequently identified and assessed were allocated on the basis of this value chain.

The identified impacts were categorized across the value chain and by time horizon (short, medium, or long-term) and validated by the relevant employees.

As with the impact perspective, risks and opportunities were also categorized across the value chain and by time horizon (short, medium, or long-term) and validated by the relevant employees.

Additional analyses

Climate scenarios: The Company also examined the potential effects of climate risks and scenarios. At a management workshop at the end of 2022, long-term climate risks were identified and assessed on the basis of recognized climate scenarios (including the IPCC scenarios). The analysis covered three climate pathways: Global alliance (1.5° C global warming), business as usual (2–3° C global warming), and overshoot (+4° C global warming), which model various impacts on markets, regulation and society. The results of the analysis were qualitatively assessed during the reporting period. As there have been no changes to the business model, they remain valid and were taken into account in the updating of the corporate and sustainability strategy and the determination of the material climate-related impacts, risks and opportunities (IROs).

Geographical analysis: The analysis also considered whether Ströer SE & Co KGaA is active – either directly or via its value chain – in countries with heightened risks of human rights abuses and corruption. It was carried out in accordance with the UN Guiding Principles on Business and Human Rights, the OECD Guidelines, and the requirements of ESRS G1 IRO-1. The results provide an initial indication of the relevance of these risks for the Company. The geographical analysis focused on direct business relationships.

Monitoring and validation

The process was closely monitored by internal and external experts. For example, GRC (Governance, Risk, Compliance) was heavily involved in the identification of risks and opportunities.

The final validation of the overall process, including validation of the material IROs, was carried out by the Board of Management and the Supervisory Board's ESG officer.

Future assessments

The analyses required in accordance with ESRS IRO-1 of the topic standards for E2, E3, E4, and E5 were not carried out in 2024. They are expected to take place from 2025 onward, and their results should inform future double materiality assessments. Consultations should also take place with the affected communities.

Material topics identified

Based on the results of the double materiality assessment, the following ESRS topics were identified as relevant:

Transition plan for climate change mitigation

Explicit disclosure statement

The Ströer Group does not currently have a transition plan that meets the requirements of E1-1 14-16. This is due in part to changes to the conversion factors and to the way in which data is collected.

Due to the change of base year in connection with the CSRD reporting, there is currently no transition plan with regard to the Environmental Policy. For this reason, the policy currently does not cover climate change mitigation, climate change adaptation, energy efficiency, or the use of renewable energies. Nor does it cover managing physical climate risk, or the climate change adaptation-related transition risks.

Future intentions

Ströer intends to formulate a transition plan in the future, based on the first dataset to use 2024 as the new base year.

Current focus areas

Given the still high proportion of energy generated from fossil fuels, Ströer is continuously working to minimize its own energy demand while maintaining the same performance by optimizing efficiency.

Key decarbonization levers identified

There is potential for decarbonization by:

• Increasing the proportion of renewable energy relative to total consumption
• Increasing the efficiency of the Ströer advertising media
• Optimizing the vehicle fleet by increasing the proportion of electric vehicles

Use of renewable energy

Ströer is actively committed to decarbonizing its business activities. Continuously increasing the share of renewable energy used in its operations is a key component of this strategy. Ströer has identified the out-of-home advertising business in particular as having potential for further increasing the use of energy from renewable sources.

Technical advancements in advertising media

Another lever is the installation and replacement of technical components and systems with more energy-efficient components. The actions of the Group are focused on out-of-home advertising.

Ströer is continuously looking for ways to optimize the energy efficiency of its digital advertising media. It is reducing its energy consumption and thus also its carbon footprint through the ongoing refinement of technologies and the implementation of innovative solutions. One priority is the use of highly efficient LED technologies, which offer a significant improvement in luminosity while using less energy. Ströer is also focusing on optimized power electronics and advanced control algorithms to further increase the energy efficiency of its systems.

As part of the further expansion of the Ströer digital portfolio, new installations and faulty LED boards that need to be replaced are being upgraded to a technical standard that is commercially viable for Ströer.

Ströer has its own research department where new advertising media prototypes are developed. Economic and environmental requirements go hand in hand here. It is in Ströer's financial interest to ensure that advertising displays use the minimum possible amount of electricity, to keep energy costs low. At the same time, this also ensures that the CO2eq emissions are minimized.

Optimization of the vehicle fleet

The electrification of the vehicle fleet is a cornerstone of Ströer's decarbonization efforts. The switch from vehicles with internal combustion engines to electric vehicles (EVs) will enable Ströer to reduce CO2 emissions in its operations.

Alignment with climate neutrality by 2050

From the SFDR cross-reference table:

Policies related to climate change mitigation and adaptation

Environmental policy of Ströer SE & Co. KGaA

Scope:

• Applies to all Ströer Group employees
• Covers all companies consolidated in the Group reporting

Governance:

• The Sustainability Management corporate unit is responsible for the content of this policy
• The environmental policy was prescribed by head office

Key content / principles:

• Framework of rules to make an effective contribution to mitigating climate change, reducing energy consumption, and strengthening the resource economy/circular economy
• Governs scope, responsibilities, management approach, duties, and organization
• Covers involvement of stakeholders and transparent reporting on all developments in areas affected by this policy
• Environmental management policy covers processes within the Company for the efficient and sustainable use of resources
• Aims to avoid negative environmental impacts from business activities or, where avoidance is not immediately possible, to continually reduce them
• Intends to improve efficiency in respect of use of natural resources and sources of energy
• Sees technical advancement as a key plank, for example the use of the latest LED generation in digital advertising media and the gradual increase in the proportion of electric vehicles in the Ströer fleet
• Central focus on the reduction of greenhouse gas emissions caused by Ströer's own activities
• Provides a framework and sets out actions to reduce material negative impacts such as greenhouse gas emissions caused by business activities

Public availability:

• Publicly accessible to all stakeholders on the Company's website

Links to international standards:

• Ströer does not currently explicitly adhere to any other standards or third-party initiatives which would have to be taken into account when implementing the environmental policy

Monitoring implementation:

• Ströer regularly reports on its sustainability activities and the progress it is making with the matters defined therein of relevance to the environment and society
• These efforts were previously documented in a separate sustainability report, now incorporated into the management report and published as part of the annual report

Important limitations: Due to the change of base year in connection with the CSRD reporting, there is currently no transition plan with regard to the Environmental Policy. For this reason, the policy currently does not cover:

• Climate change mitigation
• Climate change adaptation
• Energy efficiency
• The use of renewable energies
• Managing physical climate risk
• Climate change adaptation-related transition risks

Ströer intends to formulate a transition plan in the future, based on the first dataset to use 2024 as the new base year.

Stakeholder engagement: No stakeholders were directly involved in the development of the environmental policy.

Actions and resources in relation to climate change policies

Disclosure statement

The presentation and description of the actions and the decarbonization levers do not meet the requirements of E1-3 26-29, as changes are currently being made to the approach due to the adjustment of the base year and the climate change policies. For this reason, no specific actions have yet been implemented to comply with ESRS 2-62.

Ströer intends to develop actions that will meet the requirements in the next few years, and to publish them.

Actions initiated in 2024

However, in 2024 Ströer introduced actions aimed at directly reducing greenhouse gases and energy consumption:

1. Purchase of renewable electricity

Description: Purchasing electricity generated from renewable sources

Scope: Own operations (out-of-home advertising business)

Time horizon: Ongoing (2024 onwards)

Resources allocated: To make these actions economically viable, Ströer protects itself against price fluctuations/increases by agreeing fixed purchase prices for a specific period. No specific amounts disclosed.

Decarbonization lever: Continuously increasing the share of renewable energy used in operations is a key component of the decarbonization strategy.

2. Energy-saving measures for advertising media

Description:

• Switching advertising media off overnight
• Deactivating advertising media at less frequented times

Scope: Own operations (out-of-home advertising)

Time horizon: Ongoing

Resources allocated: Not quantified

Outcomes: Direct energy savings and reduction in greenhouse gas emissions

Note on approach: The climate mitigation actions initiated are part of an ongoing process in which completed individual actions are immediately followed by new actions of the same type. No large-scale actions with a fixed start and end date are currently being implemented, as such actions are neither technically feasible nor commercially viable.

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Decarbonization levers

Ströer has identified three main areas with potential for decarbonization:

1. Use of renewable energy

Description: Continuously increasing the share of renewable energy used in operations, particularly in the out-of-home advertising business.

Scope: Own operations

Status: Active - 37.1% of total energy consumption from renewable sources in 2024

2. Technical advancements in advertising media

Description: Installation and replacement of technical components with more energy-efficient versions

Specific actions:

• Use of highly efficient LED technologies offering improved luminosity while using less energy
• Optimized power electronics and advanced control algorithms
• As part of further expansion of the digital portfolio, new installations and faulty LED boards are being upgraded to a commercially viable technical standard
• Ströer's own research department develops new advertising media prototypes with minimum electricity consumption

Scope: Own operations (out-of-home advertising - digital advertising media)

Time horizon: Ongoing

Resources allocated: Not quantified

Link to policy: Economic and environmental requirements go hand in hand - keeping energy costs low also minimizes CO₂eq emissions.

3. Optimization of the vehicle fleet

Description: Electrification of the vehicle fleet - switching from vehicles with internal combustion engines to electric vehicles (EVs)

Scope: Own operations

Time horizon: Ongoing

Resources allocated: Not quantified

Expected outcome: Reduction of CO₂ emissions in operations

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Planned capital expenditure 2025

In the Digital & Dialog Media and DaaS & E-Commerce segments, Ströer plans to focus its capital expenditure on:

• IT infrastructure
• Data, data models, and refining AI models
• Increasing and upgrading call center capacity

Total capital expenditure 2025: Expected to be slightly higher than 2024 (EUR 94m)

Note: Capital expenditure in the OOH Media segment will focus on expanding digital out-of-home advertising inventory and upgrading public video inventory, though more selective than previously.

Targets related to climate change mitigation and adaptation

Disclosure Statement

There are currently no climate action-related targets for 2024 that meet the ESRS requirements. The previous reduction targets, which were based on 2019 as the base year, are to be reformulated with 2024 as the base year.

Baseline Data (2024 - New Base Year)

Scope 1 GHG emissions

• Gross scope 1 GHG emissions (tCO₂eq): 6,854.97
• Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%): 0.00

Scope 2 GHG emissions

• Gross location-based Scope 2 GHG emissions (tCO₂eq): 29,152.12
• Gross market-based Scope 2 GHG emissions (tCO₂eq): 31,704.39

Note: The company explicitly states that as described in E1-4, no milestones and target years are identified. Previous reduction targets based on 2019 as the base year are to be reformulated with 2024 as the base year.

Energy consumption and mix

Total energy consumption (2024)

Renewable sources as a proportion of total energy consumption: 37.1%

Methodology and scope

Energy consumption figures were taken from bills or contracts. In some cases, direct meter readings were also taken locally. The energy consumption of the vehicle fleet (fuel and electricity for EVs) was included. Where necessary, units were converted (liters into kWh) by the service provider.

Renewable energy: Guarantees of origin or certificates from the energy provider must be provided as evidence of energy from renewable sources. For Ströer, this requirement applies primarily to electricity and has an impact on the recognition of Scope 2 emissions using the market-based method.

Extrapolations and estimates: To ensure coverage of the entire basis of consolidation, values were extrapolated based on the relevant cluster average for sites where no data was available, using headcount or space occupied. Missing months were extrapolated where the reporting period was incomplete. Primary data relates to the reporting year without extrapolations; however, as a full calendar year had not been completed at the time of data collection, certain datapoints were extrapolated or estimated.

The Group does not operate in high climate impact sectors as defined by EU regulation (pursuant to Regulation (EU) 2022/1288 and Regulation (EC) No. 1893/2006).

Energy intensity

Not disclosed. Ströer does not operate in high climate impact sectors and therefore energy intensity metrics per revenue are not required under ESRS E1-5.

First-time application note

To ease first-time application, the company exercised the option under ESRS 1-136 not to disclose comparative information (2023) in the first year of preparing the sustainability statement in accordance with ESRS. 2024 serves as the new base year.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 and 2 emissions (E1-6)

Current reporting year and base year:

Other emissions data (E1-6):

Scope 1 sub-breakdown:

Scope 1 emissions mainly include material emissions from stationary and mobile combustion, and fugitive emissions. No detailed quantitative sub-breakdown by emission type (stationary combustion, mobile combustion, process emissions, fugitive emissions) is disclosed.

Scope 3 emissions

Disclosure status: Not disclosed. The report states: "There are currently no climate action-related targets for 2024 that meet the ESRS requirements. The previous reduction targets, which were based on 2019 as the base year, are to be reformulated with 2024 as the base year." Scope 3 emissions are not reported for 2024.

Total GHG emissions

Not disclosed. The sum of Scope 1 + Scope 2 (market-based) + Scope 3 is not provided due to absence of Scope 3 data.

GHG intensity

Gross GHG emissions intensity (E1-6 paragraphs 53 to 55): Not reported. The report indicates this datapoint is material but not disclosed for 2024.

Regulated emissions

0.00% of Scope 1 emissions are from regulated emission trading schemes.

GHG removals and carbon credits (E1-7)

Carbon credits (E1-7):

According to ClimatePartner, 1.09% of the total certificates relate to projects to remove carbon emissions through biogenic sinks.

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Methodology notes:

• Base year change: The previous base year of 2019 has been changed to 2024 due to changes in conversion factors and data collection procedures. The company states: "Due to the change of base year in connection with the CSRD reporting, however, there is currently no transition plan with regard to the Environmental Policy."
• Scope coverage: The report covers Ströer SE & Co. KGaA and all controlled Ströer Group companies, both in Germany and abroad, matching the basis of consolidation used in the financial report.
• Emission factors: Scope 1 emission factors are from DEFRA and IPCC databases. Scope 2 emission factors are from DEFRA, GEMIS 4.95, and Ecoinvent 3.10 databases.
• Data quality: The company distinguishes between primary data (relating to the reporting year without extrapolations) and secondary data (extrapolated or estimated). A full calendar year had not been completed at the time of data collection, so certain datapoints were extrapolated. Missing months were extrapolated using prior-year monthly figures or the rule of three. Where no data was available for the reporting year, prior-year figures were used, adjusted for known differences (e.g., change of office space, number of employees). If no prior-year data existed, statistical figures were used with the service provider's assistance.
• Green electricity: Guarantees of origin or certificates from the energy provider are required as evidence of energy from renewable sources. 45.74% of Scope 2 emissions are covered by contractual instruments (green electricity contracts).
• External service provider: Emissions calculations were performed using ClimatePartner's online tool. Consumption data is entered into categories, and emissions factors stored in the tool (linked to databases) automatically convert consumption into emissions.
• Validation: Neither the data nor the associated context information for the corporate carbon footprint was externally validated.
• Exemptions: To ease first-time application under ESRS 1-136, the Company has not disclosed comparative information required by section 7.1 for the first year. No milestones or target years are identified.
• High climate impact sectors: Ströer's business activity (out-of-home advertising and digital media) is not classed as a high climate impact sector under EU regulation (Regulation (EU) 2022/1288 and Regulation (EC) No 1893/2006).

Scope 3 note: The company states it intends to develop a transition plan and report Scope 3 emissions in future years based on the new 2024 baseline.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

The disclosure requirement ESRS E1-9 is listed in the company's CSRD sustainability statement mapping table with the following reporting status:

Exposure to physical risks

• ESRS E1-9 paragraph 66: Exposure of the benchmark portfolio to climate-related physical risks - Not reported
• ESRS E1-9 paragraph 66 (a): Disaggregation of monetary amounts by acute and chronic physical risk - Not reported
• ESRS E1-9 paragraph 66 (c): Location of significant assets at material physical risk - Not reported

Transition risks

• ESRS E1-9 paragraph 67 (c): Breakdown of the carrying value of its real estate assets by energy-efficiency classes - Not reported

Climate-related opportunities

• ESRS E1-9 paragraph 69: Degree of exposure of the portfolio to climate-related opportunities - Not reported

All ESRS E1-9 disclosure requirements are marked as "Not reported" in the company's mapping table.

Policies related to own workforce

Ströer has established policies that provide the foundation for its approach to own workforce management, aligned with international standards and human rights principles.

Ströer Social Charter

Overview and purpose:
The Ströer Social Charter provides the foundation for the Company's social and ethical principles. It sets out binding values that guide the actions of the whole Ströer Group.

Key content and principles:

• Protection of human rights
• Absolute rejection of forced and child labor
• Promotion of equality and diversity
• Protection of health and safety at work
• Strong commitment to environmental awareness and protection of privacy
• Freedom from discrimination on the basis of racial and ethnic origin, color, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction or social origin
• Action against human trafficking
• Compliance with defined standards for employment and compulsory schooling

Scope:
The charter applies worldwide and is binding upon all companies in Ströer SE & Co. KGaA and its affiliated entities. It covers all the Company's employees worldwide and applies without exception.

External stakeholder application:
Ströer also requires its external stakeholders – including suppliers, subcontractors, and business partners – to sign up to these principles to ensure compliance with social and ethical standards across the whole value chain.

Governance and oversight:
The Board of Management is directly responsible for the appropriate communication of the Social Charter and has delegated the rollout and monitoring to those responsible within the organization. The local management team in each country where Ströer operates is responsible for complying with and enforcing the principles and standards set out in the Social Charter.

Links to international standards:
The Social Charter is oriented to global standards and requires the Company to actively promote the protection of human rights, equal opportunity, and diversity in the workforce.

Public availability:
The charter is freely accessible to all employees – both on the Company's intranet and on its publicly available website. It was last updated in October 2023.

Monitoring and implementation:
Incidents and actions in violation of the Social Charter can be reported – anonymously if preferred – to the whistleblower hotline. Mandatory training is provided to ensure that all employees are familiar with and understand the charter's content. Internal and external stakeholders affected are kept informed of the charter's content and any updates on an ongoing basis.

Code of Conduct

Overview:
Ströer has introduced a Code of Conduct which contributes to the promotion of safe and fair working conditions in the own workforce.

Key content:
Section 5.11 of the Social Charter states that Ströer undertakes to respect national and local laws and standards with regard to occupational health and safety in order to ensure the protection of the health and safety of all employees.

Reference:
The Code of Conduct is described in chapter G1 and is referenced for its contribution to safe working conditions.

Additional policy commitments

Ströer has no specific policy commitments related to inclusion or positive action for people from groups at particular risk in its own workforce, though diversity and equal opportunity are promoted through the Social Charter and related initiatives.

Taking action on material impacts on own workforce

Ströer has implemented several ongoing and planned actions to address material impacts on its own workforce:

Safety in the workplace

Description and scope: A long-established, ongoing program to ensure a safe working environment throughout the whole Group. Core actions include:

• Regular meetings of working committees (health and safety committees [ASAs])
• Workplace inspections
• Training courses
• Training of first-aiders and fire officers
• Introduction of emergency alert software (in progress) to optimize availability and readiness of first-aiders and fire officers

Resources allocated: In October 2022, the position of occupational safety specialist was created below HR Director to coordinate and implement actions in partnership with local contact persons in German workplaces.

Approach: Regular evaluation of workplace accidents and analysis of feedback and findings from ASA meetings and workplace inspections. Regular inspections and ASA meetings attended by health and safety officers. Risk assessments drawn up for defined areas at headquarters (IT, accounting, customer service, sales, R&D).

Target/outcomes: General target of accident prevention. Objective to maintain the low level of workplace accidents in the future.

Policy link: Links to 'Promotion of safe and fair working conditions' impact.

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Healthy Workplace

Description and scope: Employee feedback initiative to assess risks to mental health in the workplace as required by section 5 of the German Health and Safety at Work Act (ArbSchG), including recording and assessment of mental stress.

Time horizon: First carried out in 2022, originally intended to be repeated at two-yearly intervals. In 2024, the decision was made to carry out the initiative annually (October/November). Starting in 2025, it will be extended to all German companies within the Group.

Approach: Systematic questionnaire sent to employees to record their assessments. Results provide the basis for development and implementation of specific measures to improve working conditions. Information videos and manager workshops developed to create better understanding of findings and assist managers in implementing measures.

Current coverage: Call center business introduced its own employee satisfaction survey in 2021, which will be combined with the Healthy Workplace survey from a software perspective starting 2025 (pilot in April 2025, Group-wide rollout by end of 2025). ASAM took part for the first time in 2024. Ranger does not currently participate.

Target/outcomes: Continuous monitoring of workplace conditions and systematic improvement of working conditions.

Policy link: Links to 'Promotion of safe and fair working conditions' impact and 'Promotion of a diverse, discrimination-free corporate culture'.

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Unconscious bias training

Description and scope: Mandatory online training for all employees introduced in first quarter of 2024.

Objective: Strengthen awareness of diversity and unconscious bias, promote greater sensitivity in dealing with diversity within the organization.

Coverage: Course and subsequent test successfully completed by all active employees in 2024.

Policy link: Links to 'Promotion of a diverse, discrimination-free corporate culture' and 'Promotion of safe and fair working conditions' impacts.

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E-learning platform

Description and scope: Platform aimed at all employees to improve access to continuing professional development, particularly benefiting workers in remote regions.

Approach: Personalized learning content tailored to specific requirements. Courses designed to be inclusive, covering all age groups, hierarchy levels, and departments. Strategic partnership with climate-neutral suppliers and hosting partners.

Target/outcomes: Foster personal and professional development of workforce and improve employability in the long term. Improve employee access to relevant training content.

Material impact: Arises from development and operation of the e-learning platform and strategic partnership with climate-neutral suppliers and hosting partners.

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Note on executive remuneration: Variable remuneration includes sustainability-related components. The Short-Term Incentive (STI) is dependent on ESG components via an ESG factor. Proportion of variable remuneration dependent on sustainability-related targets and/or impacts in the reporting year: 27%.

Targets related to own workforce

Healthy Workplace Target

Target metric: Healthy Workplace employee survey score (measuring how safe and fair employees think their working conditions are across four areas: workplace conditions, work organization, nature of work, and social conditions)

Scale: 1 to 5 (where 5 = 'Agree completely' and 1 = 'Disagree completely')

Baseline:

• Baseline year: 2023
• Baseline value: 3.975 (absolute value)

Target 2024:

• Target year: 2024
• Target value: At least 3.975 (match baseline)
• Progress 2024: 4.01 achieved (above-average score)

Target from 2025 onward:

• Target year: 2025 onwards
• Target value: At least 3.5 baseline value across all participants, including call center business; and match the score of 3.975 among companies that previously participated

Scope: All German companies; expanding to include call center business from 2025 (pilot project April 2025, full integration October-November 2025)

Type: Absolute value target

Review frequency: Annual review through HWP survey

Responsibility: Occupational safety specialist

External validation: External service provider assists with implementation and analysis of the survey

Other material impacts and risks

The company notes that for the following identified impacts and risks, there are no specific targets as the actions are aimed at continuous improvement and long-term progress:

• Promotion of a diverse working environment (identified impact)
• Skills shortages and employee turnover (identified risk)

Characteristics of the undertaking's employees

Total headcount and employees by segment

Total employees (2024): 11,858

Employees by segment (as at Dec. 31, 2024):

Headcount by region

Employees by region (2024):

Total number of employees for countries with 50 or more employees, representing at least 10% of the total number of employees: 11,340

Headcount by gender

Employees by gender (2024):

Gender structure by segment (2024, %):

Headcount by employment contract type

Employees by contract type (by gender) (2024):

Employee turnover

Employee turnover (2024):

• Total number of employees who have left the Company during the reporting period: 4,237
• Total number of employees who have joined the Company during the reporting period: 5,021
• Rate of employee turnover: 26.48%
• Rate of employee turnover (excluding Dialog): 13.73%

Age structure

Age structure in the Group (2024, %):

Employees by age group (2024):

Length of service

As at the reporting date, employees had been working for the Ströer Group for an average of 5.1 years (prior year: 4.6 years).

Non-employee workers

Number of non-employees in the undertaking's own workforce (2024): 10

Methodology notes

The data is taken from Ströer's internal HR system (approximately 50% of total headcount). For employees not in the HR system, standardized templates are used to provide relevant information. The figures refer to headcount. For Ranger Marketing, which includes agents in Italy and France (242 persons), detailed employee information is not available, creating some uncertainty in the recording and evaluation of relevant metrics. The reference date is December 31, 2024. The metric includes all employees with a valid employment contract as at the reference date. Contract workers are indicated with a headcount figure of 0.0. The metric 'Total number of employees who have left the Company' includes all departures regardless of reason (employer/employee-initiated terminations, retirements, deaths, end of training contracts), but excludes contract workers, temporary staff, interns, employees below tax/social insurance thresholds, and temporary student employees. Rate of employee turnover is calculated as: departures in reporting period ÷ (total employees at prior period end + new hires in reporting period).

Characteristics of non-employees in the undertaking's own workforce

Quantitative disclosure

Methodology

The 'Number of non-employees in the undertaking's own workforce' metric records the total number of persons working as contract workers for the Company on the reference date (December 31, 2024). This metric is calculated by requesting the figures from the relevant departments and consolidating this data.

Qualitative context

Contract workers are used only rarely, when there are staff shortages. Freelancers provide occasional support in customer acquisition, special projects, and some editorial areas.

These metrics have not been validated/quality-assured by an external body.

Collective bargaining coverage and social dialogue

Engagement processes

Ströer maintains regular dialogue with its workforce and works councils as an integral part of corporate strategy. Discussions with works councils take place at least once a month, while communication with employees is regular and event-based. Half the seats on the Supervisory Board of Ströer SE & Co. KGaA are filled by employee representatives, ensuring employee involvement in the Company's ultimate governing body.

The Group offers various communication formats including:

• Quarterly town hall meetings enabling direct dialogue with the Board of Management
• Virtual talks with the Co-CEO ('Fre1stunde') providing a forum for questions and suggestions
• Regular getting-to-know-you chats organized by the CFO with new employees

In 2024, Ströer concluded relevant agreements with works councils as a result of this dialogue, including the introduction of an inflation adjustment payment agreed in close consultation with works councils.

Entities with works councils hold regular works meetings to create transparency and promote dialogue. The effectiveness of dialogue with works councils is assessed by measuring the achievement of shared targets, often incorporated into works agreements.

Although no specific adjustments were made to corporate strategy or business model based on workforce perspectives, opinions and feedback collected contribute to addressing employee needs.

Collective bargaining and works council coverage

No quantitative metrics on collective bargaining coverage or percentage of employees covered by collective bargaining agreements were disclosed in the provided excerpts.

Works council representation

The document confirms that:

• Works councils exist at various companies within the Group
• Regular works meetings are held
• Works councils are involved in monthly discussions
• Works council agreements are concluded (e.g., inflation adjustment payment in 2024)
• Employee representatives hold half the seats on the Supervisory Board

However, no specific percentage of employees covered by works councils was disclosed.

Social dialogue mechanisms

The company operates multiple channels for employee voice:

• Works council consultations (monthly minimum frequency)
• Supervisory Board employee representation
• Whistleblowing system accessible to all employees
• Various feedback formats including surveys, town halls, and direct management dialogue
• Focus groups for specific initiatives (e.g., employer branding strategy)

International structures

No specific disclosure was provided regarding a European Works Council or transnational social dialogue bodies.

Diversity metrics

Gender structure (total workforce)

Ströer had a well-balanced gender ratio in 2024. As at the end of 2024, 48% of the Ströer Group's employees were male and 52% were female, which was a slight change compared with the prior year when 47% were male and 53% were female.

Top management diversity metrics

Age band distribution (total workforce)

Methodology notes

A structured model was used to define hierarchy levels and management levels. The model classifies levels based on their responsibility and position within the organization. Senior management is classified as n-0, upper management as n-1, middle management as n-2, and team leaders as n-3.

For reporting purposes, top management was defined as one or two levels below the ultimate decision-making body, i.e. n-1 and n-2.

The Company does not have detailed information on hierarchy levels for Ranger Marketing, whose workforce includes agents in Italy and France (Other 242 persons). This creates a degree of uncertainty and imprecision in the recording and evaluation of the relevant metric.

These metrics have not been validated/quality-assured by an external body.

Adequate wages

All employees received an adequate wage in the reporting period.

Benchmark used

The reference value for the assessment of adequate wages is the minimum wage.

Methodology

The data is taken from the internal HR system (approx. 50% of the total headcount). For employees who are not in the HR system, a standardized template was used via which colleagues can provide the relevant information. This template was issued to the relevant departments, who were asked to fill in the required information. The data returned was then consolidated.

These metrics have not been validated/quality-assured by an external body.

Value chain workers

Ströer stipulates that suppliers and business partners must comply with the applicable laws on working hours, pay, and other benefits and must pay their employees without delay and in accordance with the statutory minimum wage. The remuneration should correspond to the higher industry average in the country.

Social protection

The Company confirms that all workers are protected by public programs or company benefits against loss of earnings due to the specified significant life events.

This includes protection in the event of illness, loss of a job (protection begins when employment at the Company starts), workplace accidents and incapacity for work, parental leave, and retirement. As this protection is guaranteed, the relevant requirement is met with this disclosure and no further information is necessary.

Coverage

100% of employees are covered by social protection against loss of income from:

• Sickness
• Unemployment (protection begins when employment starts)
• Employment injury and incapacity for work
• Parental leave
• Retirement

Type of scheme

Protection is provided through public programs or company benefits (the disclosure does not specify the precise breakdown between public and private schemes).

Methodology note

The data is taken from the internal HR system (approx. 50% of the total headcount). For employees who are not in the HR system, a standardized template was used via which colleagues provided the relevant information. This template was issued to the relevant departments, who were asked to fill in the required information. The data returned was then consolidated.

These metrics have not been validated/quality-assured by an external body.

Training and skills development metrics

Disclosure Statement

Career development reviews are not conducted at Ströer. The company states:

"Performance and career development reviews are well established in many traditional companies, but they are increasingly attracting criticism... More and more companies are relying on continuous feedback instead of rigid annual assessments. Employees receive direct and timely feedback on their performance... We also believe in employee development through personal responsibility. In flat, agile organizations, the focus is on the individual responsibility of the employees for shaping their careers and professional development. Coaching, mentoring, and opportunities for personal development are used in place of career development reviews. Consequently, this datapoint is regarded as non-material for Ströer."

Training and Skills Development Metrics (2024)

Methodology

Based on the data in the learning management system (LMS), the courses passed in the reporting year are analyzed and assessed using a standard unit of time per course/course type (webinar, self-study course, online course, classroom-based training).

For employees who are not in the LMS, a standardized template is used via which colleagues can provide the relevant information. This template was issued to the relevant departments, who were asked to fill in the required information. The data returned was then consolidated.

These metrics have not been validated/quality-assured by an external body.

Health and safety metrics

S1-14 Health and safety metrics

Coverage

99.46% of the Company's own workforce are covered by the health and safety management system based on legal requirements and/or recognized standards or guidelines.

Methodology notes

The data is taken from the internal HR system (approximately 50% of the total headcount). For employees not in the HR system, a standardized template was used via which colleagues could provide the relevant information. This template was issued to the relevant departments, who were asked to fill in the required information. The data returned was then consolidated.

The rate of recordable employee accidents at work (excluding accidents on the way to or from work) indicates how often the rate assumption occurs relative to the number of accidents at work per 1,000 employees. The unit is expressed as a number.

Formula: (Number of accidents at work/Number of employees as at the reference date of December 31, 2024 x 1,000)

The 'Number of days lost to work-related injuries' metric refers to the number of calendar days lost as a result of workplace accidents.

These metrics have not been validated/quality-assured by an external body.

Work-life balance metrics

S1-15 Metrics (2024)

Methodology notes

The disclosures focused exclusively on parental leave and this was the information requested. The company's system does not enable an analysis of other forms of 'family-related leave', as there is no disclosure requirement for this in Germany.

These metrics have not been validated/quality-assured by an external body.

Compensation metrics (S1-16)

Pay gap

Gender pay gap (unadjusted): 24.90%

The unadjusted gender pay gap shows the difference in average gross pay per hour of women in comparison with the average gross pay per hour of men. The unit is expressed as a percentage.

Remuneration ratio

Annual total remuneration ratio: 169.17

The annual total remuneration ratio shows the ratio of the annual total remuneration of the highest paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual).

Methodology

The calculation of the two metrics gender pay gap and annual total remuneration ratio were essentially based on those employees who were employed by the Company on the reference day (December 31) of the reporting year. The remuneration was calculated according to the inflow principle whereby all gross remuneration paid, including bonuses and non-cash remuneration, was taken into account. The inflow principle was not applied to long term incentives and stock options, for which the vested fair value (= allocation) was used. The calculation excludes payments not arising directly from the employment relationship (severance payments and pension payments).

The exchange rate on the final day of the year was used to convert remuneration paid in foreign currency into euros.

Approximately 97% of Ströer Group employees were included in the calculation. The difference is due to missing or inconsistent datasets.

Unlike the gender pay gap, the calculation of the annual total remuneration ratio included the remuneration of the Board of Management as well as that of the Ströer Group employees.

These metrics have not been validated/quality-assured by an external body.

Incidents, complaints and severe human rights impacts

Methodology

The total number of incidents refers only to reports made via the compliance hotline about cases of discrimination (including all types of harassment) and dealt with by the compliance organization. These metrics were not validated by an external body.

Business conduct policies and corporate culture

Ströer has implemented several policies related to business conduct, corporate culture, and governance. These policies are designed to establish clear ethical standards, ensure compliance with laws and regulations, and promote a responsible corporate culture throughout the Group.

Ströer Social Charter

Scope: The charter applies worldwide and is binding upon all companies in Ströer SE & Co. KGaA and its affiliated entities. Ströer also requires its external stakeholders – including suppliers, subcontractors, and business partners – to sign up to these principles. All employees must observe the Ströer Social Charter.

Governance: Ströer's Board of Management has ultimate responsibility for the Social Charter. The HR director of the Ströer Group is responsible for implementation. The local management team in each country where Ströer operates is responsible for complying with and enforcing the principles and standards set out in the Social Charter.

Key content/principles: The charter provides a framework of ethics for the entire Ströer Group, including:

• Protection of human rights
• Absolute rejection of forced and child labor
• Promotion of equality and diversity
• Protection of health and safety at work
• Strong commitment to environmental awareness and the protection of privacy
• Promotion of safe working conditions
• Respect for national and local laws and standards with regard to occupational health and safety (section 5.11)
• Freedom from discrimination based on racial and ethnic origin, color, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction or social origin

Public availability: The Social Charter is published externally on the Ströer website.

International standards: The Ströer Social Charter is based on internationally accepted standards:

• The principles enshrined in the United Nations Global Compact
• The International Bill of Human Rights
• The fundamental conventions of the International Labour Organization (ILO), including conventions no. 29, no. 138, and no. 182
• The OECD Guidelines for Multinational Enterprises
• The UN Guiding Principles on Business and Human Rights
• The Diversity Charter

Monitoring: Mandatory training has been held and communicated to all employees. A particular focus was placed on unconscious bias. Extensive training was held in 2023, with consistently positive feedback. Unconscious bias training was introduced as mandatory online training for all employees in the first quarter of 2024. Incidents and actions in violation of the Social Charter can be reported – anonymously if preferred – to the whistleblower hotline. The Social Charter was last updated in October 2023.

Ströer Code of Conduct

Scope: The Code of Conduct is implemented groupwide (including online training) and applies to all Ströer Group companies and their employees, both in Germany and abroad. The Code is also published externally and extends to all third parties, such as customers.

Governance: The Ströer Group Chief Compliance Officer is responsible for the Code of Conduct. The compliance organization reports directly to the Board of Management.

Key content/principles: The aim of the Ströer Code of Conduct is to establish clear ethical and legal standards to guide the behavior of employees and ensure that they act in accordance with the corporate values, corporate culture, and the law. Section 2 ('Labor and human rights') contains behaviors and principles intended to form the basis for a work culture that gives all Ströer employees a sense of identity and makes them feel valued. The Code also contains:

• Information on the whistleblowing system
• Rules on preventing corruption
• Rules on donations and sponsorship
• Requirements for product quality and safety (article 6)

Public availability: The Code of Conduct is published externally on the Ströer website and can be accessed at any time by all employees on the intranet.

Monitoring: Behaviors that are inconsistent with the Code of Conduct can be reported (anonymously, if preferred) via the Ströer whistleblowing system by employees or external third parties. All employees receive training on the subject of whistleblowing.

Code of Conduct for Suppliers & Business Partners

Scope: The Code applies across the whole Group, including all subsidiaries, and to all suppliers, business partners, and workers in procurement.

Governance: The Code was published by Procurement. Ultimate responsibility rests with the Board of Management and the Senior Vice President for Procurement & Real Estate.

Key content/principles: The Code emphasizes:

• Compliance with human rights and employment rights across the entirety of Ströer's value chain
• Requirements for corporate governance
• Compliance with environmental standards
• Requirements for product quality and safety
• Legal ramifications in the event of non-compliance
• Clear statement that Ströer will not accept or tolerate child labor, modern slavery, servitude, forced labor, or human trafficking in the value chain
• Workers under the age of 15 must not be employed
• Suppliers and business partners must comply with applicable laws on working hours, pay, and other benefits
• Guarantee and responsibility for health and safety of employees in the workplace
• Minimization of potential risks through preventive and precautionary measures
• Work safety management system must be established and applied

Public availability: The Code is available on Ströer's website (stroeer.de/en). It can be downloaded free of charge by all of Ströer's stakeholders and is also part of every procurement process.

International standards: The Code is based on:

• The principles enshrined in the United Nations Global Compact
• The OECD Guidelines for Multinational Enterprises
• The United Nations Guiding Principles on Business and Human Rights
• The fundamental conventions of the International Labour Organization (ILO)

Monitoring: From 2025, the Code of Conduct will be reviewed annually. Suppliers and value chain workers can contact the compliance hotline to report any violations. Legal action may be taken in the event of violations of the Code of Conduct. No violations were identified in 2024.

Whistleblowing Policy

Scope: The policy applies groupwide to Ströer SE & Co. KGaA and its employees as well as all controlled Ströer Group companies and their employees, both in Germany and abroad. The value chain user group also extends to all third parties.

Governance: The Ströer Group Chief Compliance Officer is responsible for the policy. Internal stakeholders include other departments, all employees, and – where one exists – the works council.

Key content/principles: The purpose of this policy is to:

• Describe the process and principles of the whistleblowing system within the Ströer Group
• Establish guidelines for a fair and transparent investigation of concerns or potential malpractice
• Define actions to protect whistleblowers to the greatest extent possible
• Provide employees with detailed information on how whistleblowers are protected
• Ensure that no person should suffer retaliation or be disadvantaged as a result of reporting a compliance violation

Public availability: The policy and a 'one-pager' describing the hotline process can be accessed by all employees on the intranet.

International standards: Ströer is committed to the provisions of the German Whistleblower Protection Act (HinSchG) and of (EU) 2019/1937.

Monitoring: A mandatory groupwide online training module on whistleblowing and the protection of whistleblowers was rolled out in 2022. The compliance hotline is also covered as part of the onboarding events for new employees. The whistleblowing system is designed so that a compliance violation report is seen by the fewest number of people possible ('need-to-know principle').

Anti-Corruption Policy

Scope: The policy applies groupwide to all Ströer Group companies and their employees.

Governance: The Ströer Group Chief Compliance Officer is responsible for the policy. The compliance organization reports directly to the Board of Management.

Key content/principles: The aim of this policy is to:

• Heighten awareness of corruption and bribery
• Contain minimum requirements for dealing with inducements
• Provide information on value thresholds and an approval process
• Set (approval) processes and general rules for standards of conduct
• Reference the United Nations Convention against Corruption (section 2.7 of the 'Overview of the Ströer Group Compliance Management System')
• Prohibition and condemnation of all inducements aimed at improperly influencing decisions

Public availability: All internal policies are published on the intranet, where they can be accessed at any time by all employees. An overview of the Ströer compliance program is published on the external Ströer website.

International standards: The policy makes reference to and complies with the United Nations Convention against Corruption.

Monitoring: Groupwide training was implemented on the topic of anti-corruption aimed at existing employees and new hires. An online module is interactive and contains general rules, information, videos, real-life examples, and test questions. In December 2024, there was a communication campaign for International Anti-Corruption Day. The whistleblowing system provides a channel for reporting possible cases of bribery or corruption. The functions considered most at risk in respect of corruption and bribery are Procurement and Sales, though overall there is no particularly high risk as risk-mitigating measures have been implemented.

Lobbying and Political Activities Policy

Scope: The aim of the policy is to provide all Ströer employees in every part of the Group with clear rules in respect of current or future political activities and lobbying.

Governance: The Ströer Group Chief Compliance Officer is responsible for the policy.

Key content/principles: This policy sets out the possibilities and limits of lobbying and political activity.

Public availability: All internal policies are published on the intranet.

Monitoring: Not explicitly disclosed.

Ströer Procurement Policy

Scope: The internal procurement policy applies to all Ströer Group companies and is mandatory.

Key content/principles: It provides the basis for all purchases and includes stipulations relating to supplier assessment and supplier onboarding.

Monitoring: Not explicitly disclosed.

Overview of the Ströer Group Compliance Management System

Key content/principles: The document contains an overview of the Ströer Group's compliance management system (based on IDW PS 980, an audit standard published by the Institute of Public Auditors in Germany). It contains information on the subject of preventing corruption.

Public availability: Published externally on the Ströer website.

Monitoring: Not explicitly disclosed.

Prevention and detection of corruption and bribery

Ströer has implemented processes to prevent, detect and address allegations or incidents of corruption and bribery through an organizationally independent compliance function that reports directly to the Board of Management.

Anti-corruption policy

Purpose and content: The aim of this policy is to heighten awareness of corruption and bribery. The policy contains minimum requirements for dealing with inducements, information on value thresholds and an approval process. The (approval) processes and general rules for standards of conduct help the Company avoid financial loss resulting from corruption.

International standards: The Ströer anti-corruption policy makes reference to the United Nations Convention against Corruption and complies with this convention. Reference is made to the UN Convention in section 2.7 ('Anti-corruption') of the document entitled 'Overview of the Ströer Group Compliance Management System'.

Scope: The groupwide user group consists of Ströer SE & Co. KGaA and its employees as well as all controlled Ströer Group companies and their employees, both in Germany and abroad.

Governance: The Ströer Group Chief Compliance Officer is responsible for all compliance policies. The policy is reviewed at regular intervals to ensure it is up to date, and on an ad-hoc basis in the event of important changes. These checks are carried out by the central compliance function, the Chief Compliance Officer, or HR.

Public availability: The policy is published on the intranet where it can be accessed at any time by all employees.

Implementation monitoring: A summary of requests received in respect of these policies is included in reporting to the Board of Management and Supervisory Board.

Whistleblowing policy

Purpose and content: The purpose of this policy is to describe the process and principles of the whistleblowing system within the Ströer Group, to establish guidelines for a fair and transparent investigation of concerns or potential malpractice, and to define actions to protect whistleblowers to the greatest extent possible. The policy provides employees with detailed information on how whistleblowers are protected.

Scope: The groupwide user group consists of Ströer SE & Co. KGaA and its employees as well as all controlled Ströer Group companies and their employees, both in Germany and abroad.

Governance: The Ströer Group Chief Compliance Officer is responsible for all compliance policies. The policy is reviewed at regular intervals by the central compliance function, the Chief Compliance Officer, or HR.

Implementation: In 2022, a groupwide whistleblowing system based on EU 2019/1937 was implemented. The introduction of a compliance hotline and a groupwide policy on the whistleblowing system and protection of whistleblowers ensures that reports received are dealt with promptly, independently, and objectively.

Reporting channels: Various channels are open to all employees and third parties for reporting compliance violations, including line managers, HR, works council, the compliance organization, and a compliance hotline for reporting violations (anonymously if required) either orally or in writing.

Public availability: The policy and a 'one-pager' describing the hotline process can be accessed by all employees on the intranet.

Implementation monitoring: Reports received during the reporting period via the Ströer Group's whistleblowing system were manually investigated by the head-office compliance function. A summary of requests is included in reporting to the Board of Management and Supervisory Board.

Ströer Code of Conduct

Purpose and content: The aim of the Ströer Code of Conduct is to establish clear ethical and legal standards to guide the behavior of employees and ensure that they act in accordance with corporate values, corporate culture, and the law. The Code contains information both on the whistleblowing system and on preventing corruption, which may increase the likelihood of potential irregularities being detected and minimize financial damage resulting from corruption. The Code also contains rules on donations and sponsorship designed to avoid possible reputational damage.

Scope: The groupwide user group consists of Ströer SE & Co. KGaA and its employees as well as all controlled Ströer Group companies and their employees, both in Germany and abroad. The Ströer Code of Conduct is published externally, so the value chain user group extends to all third parties, such as customers.

Governance: The Ströer Group Chief Compliance Officer is responsible for all compliance policies. The HR director of the Ströer Group is responsible for the Ströer Social Charter. Internal stakeholders and other departments were involved in the development of the policies through feedback meetings.

Public availability: The Ströer Code of Conduct is published externally and available on the intranet where it can be accessed at any time by all employees.

Implementation monitoring: A summary of requests received in respect of these policies is included in reporting to the Board of Management and Supervisory Board.

Overview of the Ströer Group compliance management system

Purpose and content: The document contains an overview of the Ströer Group's compliance management system (based on IDW PS 980, an audit standard published by the Institute of Public Auditors in Germany). Among other things, it contains information on the subject of preventing corruption, which both reduces the risk of a corruption incident and enhances the chance of detecting potential irregularities.

Public availability: The overview of the Ströer Group's compliance management system is published externally.

Lobbying and political activities policy

Purpose and content: The aim of the policy on lobbying and political activities is to provide all Ströer employees in every part of the Group with clear rules in respect of current or future political activities and lobbying. This policy sets out the possibilities and limits of lobbying and political activity. It plays a role in minimizing reputational damage as a result of possible support for certain parties while also helping the Company to realize the opportunities available.

Scope: The groupwide user group consists of Ströer SE & Co. KGaA and its employees as well as all controlled Ströer Group companies and their employees, both in Germany and abroad.

Governance: The Ströer Group Chief Compliance Officer is responsible for all compliance policies. The policy is reviewed at regular intervals by the central compliance function, the Chief Compliance Officer, or HR.

Public availability: The policy is published on the intranet where it can be accessed at any time by all employees.

Implementation monitoring: A summary of requests received in respect of these policies is included in reporting to the Board of Management and Supervisory Board.

Ströer Social Charter

Purpose and content: The purpose of the Ströer Social Charter is to provide a framework of ethics for the Ströer Group with regard to its responsibilities as an international group of companies. The Social Charter promotes awareness of the need to conduct business responsibly and sustainably in order to protect current and future living and working conditions.

Scope: The groupwide user group consists of Ströer SE & Co. KGaA and its employees as well as all controlled Ströer Group companies and their employees, both in Germany and abroad. The Ströer Social Charter is published externally.

Governance: The HR director of the Ströer Group is responsible for the Ströer Social Charter. The policy is reviewed at regular intervals by the central compliance function, the Chief Compliance Officer, or HR.

Public availability: The Ströer Social Charter is published externally and available on the intranet.

Implementation monitoring: A summary of requests received in respect of these policies is included in reporting to the Board of Management and Supervisory Board.

Training and awareness

Ströer prohibits and condemns all inducements aimed at improperly influencing decisions. The functions considered to be most at risk in respect of corruption and bribery are Procurement and Sales. Overall, there is no particularly high risk of corruption or bribery as risk-mitigating measures have been implemented, including the anti-corruption policy, groupwide training, and communication measures.

Training on various corporate governance topics is provided across the Group via the internal learning management system. Modules include 'Principles of Compliance', the 'Ströer Code of Conduct', 'Whistleblowing and protection of whistleblowers', 'Preventing corruption', and the 'Ströer Social Charter'. Depending on topic area, the modules are rolled out every two to three years. The training is aimed at all employees within the Group who have access to a PC, including Procurement and Sales. The online modules are available in a range of languages and are interactive, containing general rules, examples, and interactive knowledge control.

In December 2024, there was a communication campaign for International Anti-Corruption Day which took the form of an information video and internal communication on the intranet. A broader campaign on the subject of anti-corruption used public advertising media to raise general awareness among Ströer Group employees and the general public.

Incident investigation procedures

There are procedures to ensure that business conduct incidents, including incidents of corruption and bribery, are investigated promptly, independently, and objectively. When reports of compliance violations are investigated, an organizationally independent compliance function ensures that persons linked to corruption or bribery allegations are kept out of the management chain dealing with the matter.

No reports of compliance violations relating to the value chain were made via the whistleblowing system during the reporting year. Reports received during the reporting period were manually investigated by the head-office compliance function. There is no automated evaluation of reports, and the metrics were not validated by an external body.

Incidents of corruption or bribery

Investigation procedures and speak-up mechanisms

Ströer has implemented a comprehensive whistleblowing system based on EU Directive 2019/1937 and the German Whistleblower Protection Act (HinSchG). The system allows employees and external third parties to report compliance violations, including corruption and bribery incidents, anonymously if preferred. Reports can be submitted orally or in writing through multiple channels including line managers, HR, works councils, the compliance organization, and a compliance hotline.

The whistleblowing system operates on a 'need-to-know principle' to minimize the number of people who see a report. When a report is received via the compliance hotline, it is screened by the Chief Compliance Officer and the central compliance function before being forwarded to the relevant business unit's Compliance Officer. An organizationally independent compliance function ensures that persons linked to corruption or bribery allegations are kept out of the management chain dealing with the matter.

No person should suffer retaliation or be disadvantaged as a result of reporting a compliance violation. Whistleblowers can also use the reporting channels to report any disadvantage they feel they have suffered as a result of reporting a compliance violation.

All employees receive mandatory training on whistleblowing and the protection of whistleblowers. The policy and a one-pager describing the hotline process are accessible to all employees on the intranet. The compliance hotline is also covered as part of onboarding events for new employees.

Anti-corruption measures

Ströer has introduced several measures to prevent, detect, and address corruption and bribery:

• A groupwide anti-corruption policy that heightens awareness and contains minimum requirements for dealing with inducements, value thresholds, and an approval process
• Mandatory groupwide training on anti-corruption for all employees via the learning management system (LMS)
• Reference to the United Nations Convention against Corruption in the compliance program overview
• Regular communication campaigns, including for International Anti-Corruption Day in November/December 2024

The functions within Ströer considered most at risk for corruption and bribery are Procurement and Sales. However, overall risk is not considered particularly high due to the risk-mitigating measures in place.

Anti-corruption and bribery training coverage (2024)

Training is delivered via computer-based learning and is required every 2–3 years depending on the topic. The modules are interactive and include general rules, videos, real-life examples, and test questions.

Confirmed incidents and convictions (2024)

Ströer reported zero incidents of corruption or bribery during the 2024 reporting period:

The company also reported:

• Total number of incidents of discrimination (including harassment): 6
• Number of complaints filed through channels for people in the Company's own workforce to raise concerns: 30
• Number of incidents reported to National Contact Points for OECD Multinational Enterprises: 0
• Total amount of fines, penalties, and compensation for damages as a result of incidents and complaints: €0
• Number of severe human rights incidents connected to the Company's workforce: 0

No reports of compliance violations relating to the value chain were made via the whistleblowing system during the reporting period. Reports received during 2024 via the Ströer Group's whistleblowing system were manually investigated by the head-office compliance function. There is no automated evaluation of reports, and the metrics were not validated by an external body.

Public legal cases

No public legal cases or convictions for violations of anti-corruption and anti-bribery laws were reported for 2024.

Political influence and lobbying activities

Political engagement approach

By supporting and helping to shape legislation through political engagement, Ströer sees the opportunity to raise its profile and thus also strengthen its reputation and brand, particularly through taking part in events or face-to-face meetings with political players. Political engagement aimed at protecting freedom of expression, diversity, and integrity can have a positive impact on a Company's brand.

Ströer has been involved in the sphere of civil protection and disaster assistance since 2018, as a warning system operator. It makes its advertising media infrastructure available for the broadcast of warnings in the event of an emergency, and actively helps to improve the warning infrastructure. Ströer is also active in the areas of freedom of expression and freedom of the press, for example by providing advertising space on a politically neutral basis for party advertising during election periods.

These activities offer the opportunity to create a better legislative environment, which can also have a lasting impact on the media sector. They also present Ströer with the opportunity for growth, innovation, and a better social position.

Lobbying focus areas

Ströer is listed in the German parliament's lobbying register (not in the EU transparency register). The most important topics that are the subject of the lobbying activities of the Ströer Group include:

• General energy policy
• Other aspects relating to health
• Civil protection and disaster assistance
• Other aspects relating to homeland security
• Culture
• Data protection and information security
• Digitalization, internet policy
• Communications and information technology
• Freedom of expression and freedom of the press
• Advertising
• Political life
• Parties
• Urban development
• Species conservation/biodiversity
• Air pollution control
• Climate change mitigation
• Sustainability and conservation of resources
• Road transportation
• Transportation infrastructure
• Transportation policy
• Other transportation-related aspects
• Trade and services

Ethical standards and guidelines

Lobbying and political activities policy

The aim of the policy on lobbying and political activities is to provide all Ströer employees in every part of the Group with clear rules in respect of current or future political activities and lobbying. This policy sets out the possibilities and limits of lobbying and political activity. It thus plays a role in minimizing reputational damage as a result of possible support for certain parties while also helping the Company to realize the opportunities available.

Risk management

There could be a risk of reputational damage to Ströer as a result of supporting certain political parties. Supporting a specific political party, for example through donations, could give the impression that Ströer has a political agenda and uses its media reach to promote this party. This harbors the risk of damaging public trust in the Company and thus harming Ströer's reputation.

Administrative, management and supervisory bodies

With regard to members of the administrative, management, and supervisory bodies who were appointed during the current reporting period, one person was identified who held a comparable position in public administration in the two years preceding their appointment.

Dr. Dieter Steinkamp was appointed for the first time as a shareholder representative. Dr. Steinkamp also sits on the Supervisory Board of Stadtwerke Neuss Energie und Wasser GmbH.

Lobbying expenditure

During the reporting period (January 1 to December 31, 2024), expenditure of EUR 17,943.35 was incurred in connection with lobbying. In addition, entertainment expenses of EUR 2,200 were incurred in connection with internal trade association activity.

The expenditure on lobbying activities (particularly internal entertainment and travel expenses) relate to meetings with various political actors on matters including digitalization, the Child Protection Act, and elections.

Trade association memberships

EUR 564,525.17 was paid in membership subscriptions to trade associations during the reporting period.

All the above amounts were determined in January 2025 via a data request by the central compliance and ICS functions in respect of lobbying activities and political donations for all majority-held subsidiaries of the Ströer Group for the reporting period.

Political contributions

Total financial political contributions: EUR 10,500

Total in-kind political contributions: EUR 10,200

Payment practices

Disclosure statement

Stroeer explicitly states that G1-6 Payment practices is not relevant for Ströer (as indicated in the disclosure requirements index on page 123).

Reverse factoring arrangements

While G1-6 is deemed not relevant, the company does disclose information about reverse factoring (extended payment term) arrangements in its consolidated financial statements:

Reverse factoring volumes:

• As at December 31, 2024: EUR 33,653k (EUR 33.7m)
• As at December 31, 2023: EUR 30,005k (EUR 30.0m)
• Total volume of liabilities assumed in connection with reverse factoring in 2024: EUR 73.9m
• Total volume of liabilities assumed in connection with reverse factoring in 2023: EUR 55.0m

Accounting treatment: Liabilities with extended payment terms (reverse factoring) are recognized as trade payables until the factoring bank settles the liability with the relevant service provider. Upon settlement by the factoring bank, the liability becomes a financial liability. All cash payments to service providers in connection with reverse factoring are recognized in full as an outflow in cash flows from operating activities.

Trade payables (including reverse factoring):

• As at December 31, 2024: EUR 247,056k
• As at December 31, 2023: EUR 220,450k

All trade payables have contractual maturity of less than 1 year.