Volkswagen

Reference: page 224.

As of December 31, 2025 the Board of Management has eight members. The Supervisory Board has 20 members, half shareholder representatives and half employee representatives; the State of Lower Saxony is entitled to appoint two shareholder representatives while it holds at least 15% of ordinary shares.

The proportion of women on the Board of Management is "currently 12.5%" (page 224). Volkswagen AG is subject to a mandatory participation requirement under the Fuhrungspositionen-Gesetz II requiring at least one woman and one man on the Board of Management. In total, "45% of the members of the Supervisory Board of Volkswagen AG are currently women" (page 225), against a statutory quota of at least 30% each gender. According to the ESRS definition of independence, "all ten workers' representatives and five of the shareholder representatives on the current Supervisory Board are independent, which is equivalent to 75%" (page 225).

The Supervisory Board's expertise in sustainability issues (resources, supply chains, energy, sustainable technologies) is tracked via a qualification matrix referenced in the Group Corporate Governance Declaration (page 224).

Reference: pages 224, 227, 229.

The Chair of the Board of Management holds overall cross-functional responsibility for sustainability, supported by board members with responsibility for specific management systems and by the Chief Sustainability Officer (page 227). The Audit Committee of the Supervisory Board "deals with matters such as the audit of the sustainability report and the monitoring of processes relating to the sustainability report" and the Supervisory Board "takes this prior examination and the findings of the audit of the sustainability report by the auditor engaged for the purpose into account" (page 224). The Supervisory Board has appointed an ESG officer, currently Hans Dieter Potsch.

In the 2025 reporting year, "the results of the double materiality assessment were confirmed by the Group Board of Management", and the Audit Committee "reviewed the results of the materiality assessment" (page 229), comparing them against the regenerate+ strategy's objectives.

Reference: pages 224-226.

The annual bonus for the Board of Management is tied to financial targets (net cash flow, RoS) and to an ESG factor comprising the decarbonization index, the diversity index and a governance factor (page 226). "For fiscal year 2025, the Supervisory Board used the option provided to apply the diversity index only for the social subtarget and to suspend the employee satisfaction index as an ESG criterion" (page 226); the employee satisfaction index is to be replaced by an engagement index from FY2026.

The decarbonization index "operationalizes the Volkswagen Group's climate change mitigation targets" as the environmental subtarget. The diversity index measures the proportion of women in management and internationalization of top management; for 2025 the target value of 154 (149) "was exceeded with a score of 168 (168)" (page 225). The governance factor expresses the Supervisory Board's assessment of the Board of Management's integrity and compliance conduct (page 226). Below Board level, an ESG factor in management's annual bonus has embedded the diversity index since 2023 (page 344-345 context).

Reference: page 427.

The Annex carries a "Due diligence index in the sustainability report" mapping the five core due-diligence elements to report sections: embedding due diligence in governance, strategy and business model (Sustainability management; remuneration; topical standards); engaging with affected stakeholders (Interests and views of stakeholders; Sustainability management; DMA results); identifying and assessing adverse impacts (DMA procedure and results); taking actions to address adverse impacts (topical-standard action sections); and tracking effectiveness and communicating (topical-standard explanations of whether and how effectiveness is tracked and communicated) (page 427).

This index is explicitly cross-referenced from GOV-4 in the main ESRS disclosure index as "Annex to the Sustainability Report: Disclosures on Due Diligence" (page 427).

Reference: page 230.

The Risk Management System (RMS) and standardized Internal Control System (ICS) aim "to identify potential risks at an early stage so that suitable countermeasures can be taken". The ICS applies "26 catalogs of controls" covering process risks including compliance and sustainability (page 230). In the reporting year, "mitigating internal controls were implemented in the standardized ICS... using a catalog of controls for the sustainability reporting process", covering scope completeness, the materiality assessment, and accuracy of external reporting.

A risk-oriented policy addresses "the risk of incorrect calculation, recording or processing of datapoints", with datapoints routed to central ICS control or decentralized documentation depending on risk classification. "Reports are submitted each quarter to the Group Board of Management and the Audit Committee of the Supervisory Board" on remediation of identified control weaknesses (page 230).

Reference: pages 212-218 (value chain); pages 81, 72 (cross-referenced, not in this excerpt); page 356 (employee metrics).

The upstream value chain covers raw-material extraction, component and parts production, and the Group's own engine, motor, transmission and suspension manufacturing. Core business is vehicle, engine, software and battery development and production, plus the Financial Services Division (leasing, financing, insurance). The downstream value chain covers the use phase, servicing and repair, mobility services (including MOIA autonomous ridepooling) and end-of-life management including "product and battery recycling" (pages 213-214).

The Group sustainability strategy regenerate+ "takes a broad and comprehensive approach to sustainability - environmentally, socially and economically" across four dimensions: nature, people, society and business (page 215), including a net carbon-neutrality target by 2050 and a 2030 intermediate target of a 30% cut in per-customer-kilometer carbon footprint versus 2018.

Reference: pages 220-222.

The Volkswagen Group "has identified ten groups as its most important stakeholder groups" with employees and customers at the center, plus eight further groups (page 220). Stakeholder engagement indirectly integrates stakeholder concerns into the materiality assessment; "direct consultations did not take place" for the DMA itself, but a refined stakeholder relationship strategy, annual stakeholder forums, and topic-specific dialogue formats operate at Group, brand and regional level.

The revised reputation study, run in 2025 across Germany, other European markets, the USA, Mexico, Brazil and China, produced a "Global Reputation KPI" (arithmetic average of regional scores) of 89% (page 222). The Volkswagen Group Sustainability Forum (second edition, June 2025) and the independent Sustainability Council, organized into four regenerate+ dimension-based Practice Groups with twelve external members, provide further structured stakeholder input into strategy (pages 221-222).

Reference: pages 230-236.

"In the context of the double materiality assessment, 28 of the 38 subtopics considered were identified as material... A total of 17 positive impacts, 20 negative impacts, 8 risks and no opportunities were categorized as material" (page 235). Versus 2024, "Pollution of soil" and "Communities' economic, social and cultural rights" became newly material; "Impacts on the state of species" and "Impacts on the extent and condition of ecosystems" are "no longer classified as material and are no longer reported on" (page 235). "Management of relationships with suppliers including payment practices" was renamed "Management of relationships with suppliers", "as payment practices were not assessed as material" (page 235).

Material impacts, risks and opportunities are presented under the respective topical standards rather than in one consolidated table, each under a "Material impacts, risks and opportunities" section (pages 248, 282, 296, 303, 312, 342, 370, 387, 392, 403, 408).

Reference: pages 230-234.

The process runs in four steps: context analysis, collection of impacts/risks/opportunities, assessment, and validation (page 230). In FY2024 a context analysis fixed "38 topics" (the 37 ESRS subtopics plus an entity-specific "societal impact" topic) as the binding basis; for 2025 the prior assessment was updated where no significant change had occurred (page 231).

Impact materiality: negative impacts are scored on scale, scope and irremediable character, positive impacts on scale and scope, multiplied by likelihood; impacts are "material if their risk score is 50 or higher on a scale of 1 to 100" (page 232). Financial materiality: risks and opportunities are scored by likelihood times severity (financial effect and reputational effect, 0-10 each); they are material "if their risk score is 50 or above or their potential financial effect is EUR1 billion or more" (page 233). Validation included a human-rights-severity comparison against LkSG-prioritized risks and Board of Management approval (page 231).

Reference: pages 230, 428-432.

The statement's own "Index of ESRS Disclosure Requirements" (pages 428-432) is the ESRS content index underlying this data file's classification of every disclosure requirement below: it lists, for each DR, the report chapter/section and page number where it is addressed, and a supplementary "Index of ESRS datapoints that derive from other EU legislation" (pages 432 onward) cross-references specific datapoints to SFDR, Pillar 3 and Benchmark Regulation references, flagging some as "Not material" or "Phased-in Disclosure Requirement; not relevant for reporting year 2025" at the datapoint level.

"The relevant disclosure requirements from the ESRS for the report on fiscal year 2025 were identified on the basis of the material impacts, risks and opportunities" (page 234), with immaterial-subtopic datapoints, irrelevant voluntary/phased-in datapoints, and other excluded metrics removed in sequential steps (page 234).

Reference: page 252; pages 251-254.

"We have not yet implemented a Group-wide decarbonization plan within the meaning of ESRS E1 paragraph 16, since the TRATON GROUP and Everllence (formerly MAN Energy Solutions) do not have transition plans"; the plan and the metrics below focus on the passenger cars and light commercial vehicles business (page 252).

The plan follows a hierarchy of actions: avoid CO2e emissions first, then shift to renewable energy, then offset remaining hard-to-abate emissions (page 252). "It is our aim to be a net carbon-neutral company by 2050"; production (Scope 1 and 2) already carries a 2040 net-carbon-neutral target. Four decarbonization levers are defined: e-mobility, conversion of energy supply, energy efficiency and value-chain decarbonization. The Green Finance Framework links financing (green bonds/loans) to taxonomy-aligned capex for BEVs.

Reference: pages 249-251. Back-filled from the E1 climate risk analysis section of the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Transition risk: "The 'Announced Pledges' scenario (APS) and the 'Net Zero Emissions by 2050' (NZE) scenario from the International Energy Agency (IEA) were used", sourced from the IEA's "Net Zero Roadmap" (2023 update) and "Global EV Outlook 2024". NZE implies "a decline in the global temperature rise to around 1.4 degrees C by 2100"; APS corresponds to "a global temperature increase of well below 2 degrees C" (page 249). Time horizons: medium-term to 2030, long-term to 2035.

Physical risk: climate hazards for "around 200 of the most important sites" and "approximately 1,000 key supplier sites" were assessed using "the IPCC Shared Socioeconomic Pathway (SSP5-8.5) scenario", a high-emission scenario implying warming of "3.3 degrees C to 5.7 degrees C by the end of the 21st century" (pages 250-251). Own-site production-outage risk was found "not material"; upstream supply-chain disruption from climate hazards was found material over all time horizons (page 251).

Reference: pages 253-255. Back-filled from the "Strategy: Climate change resilience" section of the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The resilience analysis was performed in the year 2024" and covers operational control mechanisms, their inclusion in corporate planning, and the capacity for a more far-reaching business-model alignment (page 253). Key levers cited include electrification of the product range, the Green Finance Framework for refinancing decarbonization capex, and supply-chain crisis-management structures (pages 254-255).

"Overall, the resilience analysis revealed that the company is addressing the material impacts and transition risks comprehensively, specifically and in an integrated way. The ability to adapt the business model... is therefore considered to be secured for the short, medium and long-term time horizons" (page 254). A site-level physical-risk countermeasure analysis "has not yet been possible" across the full site portfolio beyond the EU Taxonomy-relevant sites (page 255); uncertainty remains for the "indirect or further upstream supply chain" (page 255).

Reference: pages 255-256.

Five overarching environmental policies apply, one of which is decarbonization (page 255, cross-referenced from the Introduction to Environmental Management chapter, page 239). The decarbonization policy derives from the GHG Protocol and the SBTi and is implemented through the Group sustainability strategy regenerate+, the goTOzero environmental mission statement, and the Code of Conduct for Business Partners.

Energy efficiency is covered as a climate-change-mitigation policy element: "a CO2e-free energy supply is not currently feasible for all aspects of global energy needs, so energy efficiency remains an important basis for effective climate change mitigation" (page 256). Climate change adaptation is acknowledged as a developing policy area: "we are placing greater emphasis on developing policies and guidelines for climate change adaptation" in line with the Group's "Increase Global Resilience" imperative (page 256). Suppliers are contractually required via the Code of Conduct for Business Partners to reduce GHG emissions and report energy/CO2e data on request (pages 256-257).

Reference: pages 261-268.

Four decarbonization levers are detailed: e-mobility ("around 90% of the decarbonization targeted... can be realized through electrification of the fleet and switching to renewably generated energy", page 262); conversion of energy supply (renewable PPAs, e.g. a Swedish wind farm where Volkswagen "purchased 70% of all EACs", page 262); energy efficiency (10,485 (9,113) cumulative actions implemented by 2025, saving 4.0 (3.5) million MWh annually, page 264); and value-chain decarbonization, including PowerCo's Salzgitter cell gigafactory, which began operating in 2025 on green-electricity contracts expected to "save around 115,000 tonnes of CO2e annually" (page 265).

Other named actions: Wolfsburg's coal-to-gas cogeneration conversion, completed with the "last coal blocks... shut down on April 1, 2024" (page 264); Zero Impact Logistics (rail shift, LNG/biofuel charter ships, page 266); and the goTOzero RETAIL dealership certification program (page 267).

Reference: pages 257-261.

Scope 1+2 (production): "reducing absolute GHG emissions in production (Scope 1 and 2) by 50.4% worldwide by 2030 compared with base year 2018"; baseline 9.03 million tonnes CO2e; "The Group met this target ahead of time, in 2024," and by end-2025 emissions were already down 60% versus 2018 (pages 257-258). This target "is in line with the 1.5 degree C pathway of the SBTi and was also validated by the SBTi" (page 257).

Scope 3 use phase: a 30% cut in use-phase CO2e per vehicle-kilometer by 2030 versus an (recalculated) 2018 baseline of 191.5 g CO2e/vehicle-km, "which the SBTi confirmed as in line with the limitation of global warming to a maximum of 2 degrees C" (page 258). A footnote states "it is not possible at present to reliably identify a 1.5 degree C climate transition pathway, for which there are currently no final requirements from the SBTi, particularly for Scope 3 emissions" (page 252). Further targets: energy efficiency (4.9 million MWh/year savings by 2030), renewable electricity generation (1.2 million MWh/year by 2030) and 100% renewable procured electricity (ex-China) by 2030, already at 95 (94)% (pages 258-259); dealership-network CO2 cut of 30% by 2030/55% by 2040/75% by 2050 versus a 2020 baseline of 3.22 million tonnes (page 259).

Reference: pages 269-270.

Group standard 98000 records generation, purchase and use of fossil, nuclear and renewable energy at worldwide production sites. In 2025, Volkswagen Group total energy consumption was 19.2 (19.0) million MWh, of which 11.4 (11.9) million MWh from fossil sources, 0.04 (0.04) million MWh nuclear and 7.8 (7.1) million MWh renewable (page 269). Purchased renewable electricity (bundled) was 90.3% of purchased renewable electricity for the Group (page 269, footnoted as excluding TRATON GROUP).

Energy intensity (energy consumption per sales revenue) was 0.06 (0.059) kWh/EUR in high-climate-impact sector activity of EUR321,913 (324,656) million sales revenue (page 270); "all activities within the Volkswagen Group... relate to NACE code C.29.10 (Manufacture of motor vehicles)" and are therefore classed as high-climate-impact. Total energy generation (self-generated) was 6.1 (6.4) million MWh Group-wide, of which 0.9 (0.8) million MWh renewable (page 270).

Reference: pages 271-279.

Scope 1 GHG emissions: 2.4 million tonnes CO2e (Group, 2025) versus 3.0 million tonnes in 2024 (page 271-272). Scope 2: location-based 2.6 million tonnes, market-based 0.4 million tonnes (page 272). Scope 3: 883.74 million tonnes CO2e across all 15 categories in 2025, versus a restated 824.00 (originally reported 812.01) million tonnes in 2024 (page 272); "around 11.8% (12.1%) of total Scope 3 emissions fall under... Purchased goods and services, while 85.2% (84.4%) arise due to the use of sold products" (page 273).

Total GHG emissions: "Total GHG emissions - location-based... 890.4 (831.5)" and "Total GHG emissions - market-based... 887.4 (828.5)" million tonnes CO2e (page 279). GHG intensity (market- and location-based) was 2.3 (2.1) kg CO2e per EUR of sales revenue (page 279). Methodology uses the GHG Protocol and VDA emission factors, with recalculations in the reporting year for LCIA factors (IPCC AR6) and logistics-emissions extrapolation (pages 276-277).

Reference: pages 279-280.

"No actions have been implemented for the removal and storage of GHGs in the Group's own business activities or value chain," and consequently "no metrics on GHG removal or storage are reported" (page 279).

Carbon credits are used within the transition-plan hierarchy of actions for "hard-to-abate emissions", expected to affect "less than 10% of emissions" and based on SBTi requirements. "Total carbon credits canceled in the reporting year" fell sharply to 680,379 tonnes CO2e in 2025 from 6,076,738 tonnes in 2024 (page 280); in 2025 none of the canceled credits were from removal projects (0% biogenic, 0% technological), and 30% originated from projects within the EU. "There are as yet no valid certification standards for a binding net zero target," so the Group has no specific removal/storage targets but caps offsetting's contribution to its net-carbon-neutral 2050 ambition at under 10% (page 280).

Reference: page 281.

"We do not currently use an internal carbon price in investment decisions." Instead, the Group "applies an abatement cost approach to support strategic decisions and to calculate and prioritize decarbonization actions in production," expressing abated emissions relative to net present value in EUR per tonne of CO2e, which produces "an abatement cost curve, from savings per tonne of CO2e (energy efficiency actions) to high costs per tonne of CO2e (use of synthetic fuels)" used "to prioritize actions and estimate the total expenditure required to achieve the goal" (page 281).

Reference: pages 284 (pollution of air/water/soil) and 291 (substances of very high concern).

Avoiding pollution sits under the goTOzero mission statement: "We reduce harmful emissions into air, soil and water bodies" (page 284). The Zero Impact Factory vision commits sites to emit "as few substances as possible that are harmful to the health of humans, animals, or vegetation, or to soil, water bodies, or air" (page 284). The Code of Conduct for Business Partners requires suppliers to avoid harmful soil changes, water pollution, air pollution, noise and excessive water consumption (page 284); the raw materials policy commits to excluding toxic substances and protecting biodiversity in sourcing (page 284).

For substances of very high concern, the topic is anchored in the "environmental standard on material and chemical conformity of products," referencing the Global Automotive Declarable Substance List (GADSL), with SVHC use under EU REACH Article 57(2) "largely to be avoided" and subject to case-by-case assessment (pages 291-292).

Reference: pages 286 (air/water/soil) and 292 (SVHC).

Air: thin-film paint materials, low-solvent thinners and filter technologies reduce emissions at paint shops, body shops and mechanical manufacturing; suppliers must act under the Code of Conduct for Business Partners (page 286). Water: the Group "does not discharge untreated wastewater," using pretreatment (light-liquid/grease separators, physico-chemical precipitation for heavy metals) ahead of biological treatment such as membrane bioreactors (page 286). Soil: guidelines govern safe storage/disposal of hazardous waste and avoidance of toxic substances (page 286); the Raw Materials Due Diligence Management System (RMDDMS) covers 18 priority raw materials, with audits assessed against RMI's RMAP (pages 286-287).

SVHC: a "Three Lines Model" governance structure, regulation coordinator/regulation expert process, and IMDS-based supplier chemical-composition verification manage chemical compliance (page 292); SVHC substitutability is reviewed for EU Taxonomy-relevant all-electric-vehicle materials (page 292).

Reference: pages 285 (air/water) and 292 (SVHC).

Air and water pollution are addressed through the overarching UEP metric (VOC emissions, wastewater COD/nitrogen/phosphorus/nickel/zinc) and the Impact Points method, with the Site Checklist setting criteria on VOC-reduced materials, dust limits and wastewater concentration caps (page 285). Compliance with "Directive (EU) 2024/1785 on industrial emissions" and the German Waste Water Ordinance (AbwV) is the regulatory floor (page 285).

For SVHCs: "No measurable outcome-oriented targets within the meaning of the ESRS have been defined for the production sites in relation to the prevention and control of SVHCs. Systematic data collection is currently being worked on to enable complete quantitative reporting" (page 292); the challenge cited is "the large number of substances, as well as the concentration data of SVHCs in chemical mixtures, which are often only specified by suppliers within concentration ranges" (page 292).

Reference: page 288.

Air emissions (Group, 2025, sites above E-PRTR thresholds): VOC 10,300.6 (10,962.9) tonnes; NOx 902.8 (1,126.1) tonnes; dust (PM10) 284.6 (148.4) tonnes; SO2 0.0 at Group level (page 288). Water emissions: TOC 549.8 (463.1) tonnes; zinc 1.0 (2.2) tonnes; nickel 2.1 (2.6) tonnes; dissolved fluoride 17.5 (26.6) tonnes (page 288).

Measurement follows Group standard 98000, with VOC emissions calculated for all paint shops and CO2 from thermal/regenerative post-combustion of VOCs also recorded; wastewater pollutant sampling frequency ranges from quarterly to daily depending on site permits (pages 288-289).

Reference: pages 290-293.

Inflow (generated, used or procured): "An evaluation of substance-related quantities for SVHCs cannot currently be fully carried out at Group level. An approach for recording the quantities of all SVHCs used as substances or in mixtures (SVHCs > 0.1 M%) during vehicle production is currently being developed" (page 293).

Outflow as emissions: "There is currently no limit that encompasses the full range of all known SVHCs... it is therefore not possible to gather data on these emissions" (page 293). Outflow as part of products: this limb is quantified. The total amount of each SVHC is calculated per reference vehicle (ID.7 Tourer and Tiguan) using a >0.1% REACH Article 33 threshold and allocated to "reportable hazard classes," presented in the "Substances of Very High Concern for the Volkswagen Group" table for 2025, with figures also given for the Porsche AG Group and TRATON GROUP excluding Everllence (page 293). The company discloses what it can and cannot quantify and why, rather than remaining silent.

Reference: page 297.

Water management is anchored in a dedicated policy focused on conserving water as a resource, aligned with regenerate+'s aim "to continually reduce the need for primary raw materials, including water" (page 297). Production sites should be designed so that "water use has the least possible negative impact on local water resources," covering reduced withdrawal, reuse, responsible use in water-stressed areas, minimized input of water-polluting substances and protection against deterioration of receiving-water quality (page 297).

The Code of Conduct for Business Partners requires suppliers to minimize water consumption and avoid water pollution that could impair drinking-water resources; "in the downstream supply chain, the Volkswagen Group is unable to regulate relevant water consumption by means of its own levers" (page 297).

Reference: page 299.

At production sites, wastewater is increasingly recycled into production processes, cooling towers, sanitary facilities or irrigation; "the San Jose Chiapa/Mexico site... can be considered a wastewater-free site due to closed-loop circulation" (page 299). At Kariega, South Africa (a high-water-stress area), cooling towers are rainwater-supplied and a production-wastewater recycling system installed in 2023 "is able to save up to 47,000 m3 of freshwater each year" (page 299). In 2025, "approximately 4.0 (3.9) million m3 of water was reused at the Group's production sites," with Ingolstadt and Puebla each contributing 0.7 million m3 (page 299).

In the value chain, the Group has been a member of the Responsible Lithium Partnership in Chile since 2021, whose 2025 actions included "geological and hydrological mapping, campaigns on water scarcity, and graywater recycling" before the project's transfer to a locally managed structure (page 299).

Reference: page 298.

Water withdrawal (ex-TRATON GROUP and Everllence) is targeted for "a 30% [reduction] on average across the Group by 2035 compared with 2018," baseline 45.6 million m3; "hot spot" sites in moderate-to-extreme water stress face a 40% reduction target, baseline 28.1 million m3 (page 298). The Verisk Maplecroft database identifies water-stress and hot-spot locations.

In 2025, Group-wide withdrawal (ex-TRATON/Everllence) was 29.7 (32.5) million m3, "a reduction of 15.9 (13.1) million m3 compared to the base year 2018," already "exceeded by 15.2%" against the 2035 target; hot-spot-site withdrawal was 15.4 (17.8) million m3, exceeding its 2035 target by 13.2% (page 298). Part of the achievement stems from VW Kraftwerk GmbH's coal-to-gas fuel switch, which cut its water withdrawal by "nearly 2 (2) million m3 since 2018" (page 298).

Reference: pages 300-302.

Water consumption equals withdrawal minus wastewater volume, "mainly from evaporation losses that arise during the production processes" (page 301). Around "83% of the volume of water withdrawals... is measured directly, while around 16% is calculated" and about 1% estimated (page 301); roughly 46% of wastewater volume is measured, 29% calculated and 24% estimated (page 301).

25 production sites are classed as "hot spot" sites based on 2018 Verisk Maplecroft water-stress categorization and withdrawal-volume prioritization (page 300). Approximately 43.5 (42.3)% of Group-wide withdrawal (around 13.0 (14.5) million m3, ex-TRATON) occurs at sites in high or extreme water stress (page 299). Around 65% of reused water is directly measured (page 302).

Reference: pages 304-305.

"A resilience analysis did not identify any significant physical risks, transition risks or systemic risks or opportunities in relation to biodiversity and ecosystems (ESRS E4), but it did identify material impacts" (page 304). Key assumptions: continued access to capital, continued investor/lender expectations around biodiversity performance, and supplier provision of relevant data; uncertainty centers on vehicle-market development and evolving biodiversity regulation (page 304).

External stakeholders and people with indigenous/local knowledge "were not included" in the resilience-analysis process (page 305). Regenerate+'s nature dimension is the central strategic response; short-term actions (insect hotels, nesting boxes, flowering meadows) mitigate impacts while "no specific targets for biodiversity and ecosystems were defined for 2025 at Group level; these are currently being developed" (page 305).

Reference: pages 307-308.

Biodiversity is anchored in the environmental mission statement goTOzero ("mitigates the impact of its business operations on biodiversity and ecosystem services and supports projects to conserve these," page 307) and the Biodiversity Commitment. The Group is "a founding and active member of the Biodiversity in Good Company e.V. initiative" and joined the LEAF Coalition in 2024 as "the first automotive manufacturer" to do so (page 307).

The Code of Conduct for Business Partners requires suppliers to avoid logging/deforestation consistent with CBD and IUCN recommendations, and the Group is preparing for the EU Deforestation Regulation (page 308). Biodiversity impact assessments are performed when siting new production facilities, prioritizing land already used for industrial purposes (page 308).

Reference: pages 309-310.

Site-level actions are identified, planned and evaluated locally; the 2024 Zero Impact Factory Award for biodiversity recognized Palmela/Portugal (reforestation, over 2,500 trees planted since 2022), Kariega/South Africa (invasive-species removal at the Van Stadens Wildflower Reserve) and Hanover/Germany (crested-newt relocation) (pages 309-310). "Over 21 projects" of more than 200 Corporate Citizenship projects in 2025 promoted biodiversity (page 310).

Beyond own sites, the Group "launched a biodiversity fund for external nature and biodiversity projects in 2025" with "an annual allocation of up to EUR25 million and a planned term of five years (from 2025 to 2029)"; 2025 work focused on fund design and committee setup, with "operational funding... to start in 2026" (page 310). Existing global projects include Mexico reforestation since 2008 and China's Green Belt project (over 8.5 million trees planned by 2030) (page 310).

Reference: page 309.

"No specific targets for biodiversity and ecosystems were defined for 2025 at Group level; these are currently being developed" (page 305). The Site Checklist carries quantifiable voluntary criteria on biodiversity (local protected areas, funding for biodiversity/environmental education, habitat creation) (page 309).

In 2024 a new metric, the Biodiversity Land Use Indicator (BLI), was introduced at passenger-car and light-commercial-vehicle production sites, built on the EMAS biodiversity guide and the IUCN's No Net Loss/Net Gain approach; it "was measured again in 2025 and a specific BLI target will be set in the future" (page 309). In the interim, existing decarbonization and water targets are described as contributing to biodiversity outcomes (page 305).

Reference: page 311.

Biodiversity Land Use Indicator: "the Group-wide survey of the BLI in 2025 showed a result of approximately 53.4 (28.6)%, taking into account the quality of the area," with the improvement mainly attributed to a methodological change allowing ecologically valuable areas beyond the standard 30 km radius to be counted (page 311).

Sites near or in biodiversity-sensitive areas: using a 4.5 km radius, "the results show that 68 of the 127 sites analyzed are located near biodiversity-sensitive areas" (up from 58 in 2024), covering 9,296 (8,653) hectares (page 311). "No direct negative impacts caused by the production sites and other sites were identified for the protected areas nearby" based on operational-disruption review (page 306); soil degradation/desertification impacts from production "cannot yet be assessed in detail" (page 306).

Reference: pages 314-316.

A Group Strategy Framework for circular economy was "adopted at Group level in October 2025," covering circular material use, circular-economy strategy setting and new business-model evaluation, plus redesign "to make circularity a mandatory consideration already during the development process" (page 313). The policy requires preferential use of recyclates where technically suitable, legally compliant plastics labeling, and supplier obligations on recycling/reuse in the Code of Conduct for Business Partners (page 315).

The Volkswagen environmental standard for "Vehicles Recycling Requirements, Use of Recyclates, Recyclability Type Approval" sets circular-design recommendations (page 315); business partners "should know and document the proportion of recycled content in their products" (page 315).

Reference: pages 317-320.

Battery recycling: in-house expertise since 2009, Re-X business models (reuse, repurpose/second-life, recycle); PowerCo's cell factories are "designed to significantly increase material efficiency... through close-to-production recycling" with a cross-site recycling strategy for NMC and LFP chemistries (pages 319-320). The Aluminum Closed Loop at Audi Neckarsulm (since 2017) sends press-shop offcuts back to suppliers for reprocessing, "saving up to 95% of the energy used in manufacturing when compared with using primary aluminum" (page 320).

Raw-material sourcing: the Responsible Raw Materials Report (annual since 2021) covers 18 high-risk raw materials; leather specifications since 2022 require Leather Working Group certification (pages 318-319). In production, "over 70 tonnes of material that would otherwise have been disposed of was reused in plastic tanks in 2025" at Wolfsburg (page 321). The HVBatCycle research consortium (2023-2026, BMWE-funded) targets multi-cycle recovery of high-voltage battery materials (pages 320-321).

Reference: page 315.

"The Volkswagen Group aims to use 40% circular materials in its passenger cars and light commercial vehicles by 2040 for vehicle projects with production starting from 2040 onwards (excluding China)" (page 315). Upcoming regulatory targets are also tracked: EU post-consumer-recyclate plastic content requirements from around 2032, and EU Battery Regulation end-of-life-material content for lithium, cobalt and nickel rising from 6%/16%/6% (2031) to 12%/26%/15% (2036) (page 315).

Supplier-facing targets: over 95% of relevant direct suppliers by sales revenue to hold a positive Sustainability Rating (S-Rating) by 2040, with an 85% intermediate target for 2025 "exceeded with a result of 87%" (page 315); 95% of suppliers with production sites over 100 employees to hold ISO 14001/EMAS certification by 2040. "The Volkswagen Group has not set any measurable outcome-oriented ESRS-related targets for expanding circular product design" (page 316).

Reference: page 322 (Metrics: Resource use and circular economy); page 299 (Actions: Water).

Resource inflows for 2025 used a reference-vehicle approach (Tiguan and ID.7 Tourer for VW/Skoda/SEAT-CUPRA; Q3/Q4 e-tron for Audi/Lamborghini/Bentley). Total weight of products and materials used: battery-electric vehicles 1,782,194 (1,185,989) tonnes; internal combustion engine vehicles 8,403,399 (8,639,279) tonnes (page 325). Reused/secondary recycled content ranged 12.6-25.5% (BEV) and 16.5-26.2% (ICE) by weight (page 325).

The Group covers 18 high-risk raw materials under its Responsible Raw Materials Report and in 2025 set up a dedicated raw-material procurement process for "nine different raw material groups" prioritized by an internal criticality analysis cross-checked against the EU Critical Raw Materials Act list (page 323). Water inflows (withdrawal/consumption) are reported under the Water chapter (page 299).

Reference: page 327.

"Under the current European End-of-Life Vehicles Directive, passenger cars and light commercial vehicles must be 85% recyclable and 95% recoverable at end of life. All Volkswagen Group vehicles approved for Europe comply with this law" (page 327), calculated per ISO 22628. Average end-of-life-vehicle age in Europe is "19 to 24 years" (page 327); passenger cars are assumed to perform "for up to 200,000 km" for life-cycle assessment, per Weymar and Finkbeiner (2016) (page 328).

Reparability actions include headlight-bracket-only repair options that avoid replacing complex LED units and a damage-assessment catalog for high-voltage-battery components so "reusable components can remain within the vehicle" after accident repair (page 328); the Volkswagen Economy Service offers lower-cost repairs for vehicles over four years old in Germany (page 329).

Reference: pages 320-321, 326, 329.

Waste is generated "from the extraction of raw materials, to production, to the end of the use phase of vehicles" (page 313), managed against the waste hierarchy (avoidance first, then highest-quality recycling, with incineration/landfill as last resorts, page 316). Waste Metrics (2025, Group/companies with operational control): total waste 2,547,290/537,522 tonnes (versus 2,357,654/573,762 in 2024); of which waste for recovery (recycling) 2,089,334/466,024 tonnes (page 329).

Relevant waste streams are scrap metal (varying by process: steel from body production, aluminum from engines/transmissions), plastic waste, paint sludge and hazardous waste from surface treatment and used oils (page 329). Examples of circular waste handling include the Wolfsburg gasoline-tank-to-diesel-tank plastic reuse (over 70 tonnes in 2025) and the Zero Plastic Waste project (page 321).

Reference: pages 349-351.

The fundamental instrument is the "Declaration on Social Rights, Industrial Relations and Business and Human Rights," jointly adopted by the Board of Management, the Group European Works Council and the Global Group Works Council (page 350). It sits within a Three Lines Model governance structure: first-line operational departments (HR, Group Occupational Health and Safety, Group Security, Group Procurement for suppliers), second-line advisory functions (Group Legal, Group Compliance, HR Compliance), and third-line Group Internal Audit (page 350). A "Group Human Rights Officer" role, required under the LkSG, sits between the second and third lines (page 350).

Recognized frameworks include the Universal Declaration of Human Rights, the ILO Core Labour Standards, the UN Global Compact's Ten Principles, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises (page 349).

Reference: pages 345-347.

The Supervisory Board has equal shareholder/employee representation under the AktG and MitbestG, giving employee representatives a direct channel into top-level decisions (page 346). At Group level, the Group European Works Council and Global Group Works Council hold regular advisory meetings with the Board of Management and have concluded binding agreements including the "Declaration on Social Rights," the Charter on Labor Relations (co-determination rights on personnel development and OHS), the Charter on Temporary Work and the Charter on Vocational Training (pages 346-347).

The annual myVOICE employee survey (relaunched in 2025 after a 2024 pause for revision, rolled out to four companies first) had a "participation rate... [of] 45% of employees at the participating companies" in the reporting year (page 347). Employees can also use the Group-wide whistleblower system or report directly to managers (page 347).

Reference: pages 348, 412.

"The Volkswagen Group has established defined complaint channels and remediation processes. If a grievance is identified when a complaint is made, countermeasures are taken immediately... and the implementation of these countermeasures is monitored" (page 348). Individual cases (loss of employment prospects, unhealthy working conditions) are managed locally; serious breaches such as unequal treatment or discrimination are channeled through the Group-wide whistleblower system and handled "in accordance with a uniform standard at Group level" (page 348).

Group HR Compliance, Group Occupational Health and Safety and Group Security act in an advisory/monitoring capacity; remedial action is case-by-case, and effectiveness is checked through "compliance monitoring" (page 348). Full whistleblower-system detail (reporting channels, protection from retaliation) sits in the Business Conduct Information chapter (page 412).

Reference: pages 353-369.

Working conditions: the revised myVOICE survey, digital-training expansion (Success Factors/Degreed platform, 46,000 users, up almost 25%) and the annual budget-planning round (which factors in Supervisory Board-approved plant-utilization plans to protect employment) address impacts (pages 353-354). Occupational health and safety: a Group-wide ISO 45001 certification requirement for sites over 1,000 employees (87 of such sites certified by end-2025, covering 87% of relevant employees) and annual company-level OHS risk analyses (page 362).

Equal treatment: Board and management remuneration linked to the diversity index; an anti-discrimination policy introduced in 2024 (page 344). Other work-related rights: identity/age verification in recruitment to prevent child and forced labor, implemented continuously since 2024 (page 368).

Reference: pages 343, 355, 362, 366, 369.

Working conditions: "Apart from the target related to training and skills development, no other measurable outcome-oriented targets... have been set in connection with adequate wages, social dialogue, freedom of association, or collective bargaining" (page 355); the training-hours KPI is itself suspended for 2025-2026 pending revision (page 355). Occupational health and safety: ISO 45001 certification of all 1,000+-employee production sites by end-2026, and a Lost Time Injury Frequency Rate target "below 1 for all brands and companies by 2040" (page 363).

Equal treatment: "No measurable outcome-oriented targets... have been defined for a culture free from discrimination, violence and harassment or an inclusive working environment" (page 366); the diversity index itself (target 154 (149) for 2025, achieved 168) functions as the operative metric. Other work-related rights: "No measurable outcome-oriented targets... are currently defined in connection with child labor and forced labor" (page 369).

Reference: page 356.

"As at the end of reporting year 2025, 602,659 (614,082) employees worked for the Volkswagen Group" (headcount). By gender: male 478,929 (489,917), female 123,664 (124,125), other 37 (7), not disclosed 29 (33) (page 356). In the reporting year, "39,887 (37,516) employees left the Volkswagen Group," a fluctuation rate of 6.6 (6.1)% (page 356).

The employee definition includes members of top management, people in the passive phase of partial retirement, and vocational trainees, but excludes people on parental leave and academic trainees such as interns or doctoral students (page 356). Discrepancies with the 106,123 figure disclosed for "Material non-financial indicators of Volkswagen AG" (page 453) reflect the narrower Volkswagen AG-only scope used there.

Reference: pages 360, 364.

Non-employees are defined as self-employed people and temporary external personnel with no direct contractual relationship with the Group; their commissioning via Procurement is governed by the Responsible Supply Chain System (page 342). "Direct impacts can only arise for non-employees in the area of occupational health and safety or in their encounters with Volkswagen Group employees" (page 342), so non-employee-specific metrics are concentrated in the occupational-health-and-safety disclosures at page 364, cross-referenced from the non-employee characteristics section at page 360.

The Group's policies on working conditions, equal treatment and other work-related rights extend to non-employees commissioned through Procurement via the Code of Conduct for Business Partners and the ReSC-System requirements described in the Sustainability in the Supply Chain chapter (page 343).

Reference: page 360.

"The proportion of employees covered by collective bargaining agreements of 91.6 (92.0)% (European Economic Area (EEA) only) and the proportion of employees covered by a workers' representative of 98.9 (99.1)% (EEA only)" (page 354). The Collective Bargaining Coverage and Social Dialogue table (page 360) bands coverage by country: 80-100% coverage applies in Austria, Belgium, Czech Republic, Finland, France, Germany, Hungary, Italy, Netherlands, Norway, Portugal, Slovakia, Slovenia, Spain and Sweden, while coverage is 0-19% in Bulgaria, Estonia, Ireland, Croatia, Latvia and Lithuania.

Workplace representation is 80-100% in most of the same higher-coverage countries. "For Slovenia only there has been a change in collective bargaining coverage to the next higher category, 80-100%" versus the prior year (page 360).

Reference: pages 356, 367.

"The proportion of women in management... and the internationalization of top management" feed the diversity index, which rose to "168 (168)" against a 2025 target of 154 (149) (page 225, 367). Gender Distribution at Top-Management Level (page 367) covers the Group and brand Boards of Management only (narrower than the full management-level diversity-index population). Employees by age group and by gender/country tables are provided at page 356 and following.

The diversity index was "established in 2017," set to 100 for 2016, and has been "the performance criterion for the Social subtarget within the framework of the ESG factor for the variable remuneration (annual bonus) of the members of the Board of Management" since the Supervisory Board's decision described at page 226.

Reference: page 360.

Adequate wages are benchmarked against the statutory EEA minimum wage, a comparable neighboring country outside the EEA, or the Wage Indicator Foundation's Living Wage database (page 360). After case-by-case review, "these case-by-case assessments showed that nearly all Volkswagen Group employees receive an adequate wage in accordance with the ESRS definition" in 2025; the stated exceptions were "Austria (0.1%/4 employees)," where no statutory/collectively agreed minimum exists and the benchmark sits marginally below Germany's, and "Singapore (23.8%/178 employees)," whose commission-based remuneration components are not counted under the ESRS definition (page 360).

In the prior year, shortfalls (by proportion/headcount) had also been recorded in Morocco, Albania, Sweden, Mexico, Brazil and Germany (page 360); "the prior-year figures are not comparable" following the change to case-by-case assessment.

Reference: pages 356, 361.

"The average number of training hours per employee in accordance with the requirements of the ESRS was 21.6 (18.9) hours in the reporting year 2025" (page 361), calculated from training between December of the prior year and December of the reporting year, covering in-person, online, trainer-led and self-guided training.

Separately, the Group's own pre-existing strategic training-hours KPI "is currently being revised and has thus been omitted for the reporting years 2025 and 2026" (page 355); going forward it will be aligned to the ESRS metric's methodology. Training-program expansion includes the Success Factors/Degreed digital learning ecosystem, with Degreed users up "almost 25% to 46,000" in the reporting year and rollout to 11 further subsidiaries (page 354).

Reference: pages 362-364.

"87 (80) Group production sites (including the Chinese joint ventures) were certified in accordance with ISO 45001" at end-2025, "coverage of 87 (74)% of employees at the Group production sites... with more than 1,000 employees" (page 363). "82 (83)% of employees are covered" by a health-and-safety management system, with "55 (46)% of employees... covered by such a... system that has been audited or certified by an external party" (page 364).

"There were 4 (4) deaths as a result of work-related accidents or ill health during the reporting year," of which one employee, one non-employee and two other (value chain) workers (page 364). "9,917 (10,819) reportable work-related accidents resulting in 10.8 (11.7) work-related accidents per one million completed working hours (TRIR... in accordance with ESRS S1-14)" (page 364); the Lost Time Injury Frequency Rate was "6.2 (6.4)" (page 363).

Reference: pages 364, 367.

"The unadjusted gender pay gap... the difference at the Volkswagen Group was 9 (13)% [in the reporting year]. This value is 4 percentage points below the previous year" (page 364). The figure reflects average gross hourly wages of men versus women without adjusting for structural differences such as role or seniority; an adjusted pay-gap measure (controlling for qualifications, experience, job system and position) is also calculated using the same methodology base (page 364).

Top-management gender distribution and the total-remuneration ratio are reported alongside the pay gap at page 367; the diversity index, linked to Board and management remuneration, is the principal management lever for this topic (page 367).

Reference: pages 368-369.

Discrimination, Harassment and Other Workforce Issues (2025/2024): "Total number of serious violations identified in relation to discrimination and harassment" 20/22; "other workforce issues" 4/2; fines/penalties/compensation (EUR thousand) nil in 2025 versus 9 in 2024 (page 369). Violation of Human Rights: "Serious human rights violations identified in accordance with LkSG" nil in both years, with no associated fines (page 369); because the LkSG draws on the UN Guiding Principles, ILO Declaration and OECD Guidelines, the company states it can be assumed LkSG-relevant violations correspond to violations of those frameworks (page 369).

"No measurable outcome-oriented targets... are currently defined in connection with child labor and forced labor," and "the Volkswagen Group does not tolerate any form of child or forced labor" as a matter of corporate values (page 369).

Reference: pages 372-373.

The Responsible Supply Chain System (ReSC-System) is "a comprehensive management system aimed at identifying matters related to human rights and the environment in our supply chain at an early stage and addressing them with a systematic approach," rejecting "any form of child and forced labor, modern slavery, and human trafficking" (page 372). It draws on the OECD Guidelines, UN Guiding Principles, ILO Core Labour Standards, the UN Universal Declaration of Human Rights and the OECD conflict-minerals guidance, and is aligned with the LkSG (page 372).

The supply chain covered is large and complex: "more than 63,000 supplier sites in 93 countries around the world" (page 372). Risk analysis assigns suppliers to low/medium/high risk categories, with country risk potentially upgrading a low-risk supplier to medium (page 373). Overall strategic responsibility sits with the Board member for the Core brand group/Group Procurement; operational management sits with Group Procurement Sustainability, supported by "more than 130 experts" in the Sustainability Procurement Network (page 373).

Reference: page 381.

Workers in the value chain are engaged indirectly: the materiality assessment and the ReSC-System's risk analysis draw on internal and external data sources on human-rights and environmental risk at supplier level (page 370-373), and stakeholder views more broadly are folded into the Group's "Interests and views of stakeholders" process described in the General Information chapter (page 381).

Vulnerable-worker groups (e.g. young workers, migrant workers) are identified through the ReSC-System's risk-based approach; "these insights were factored into the materiality assessment and are also incorporated into the development of preventive, mitigating and remedial actions" (page 370).

Reference: pages 383, 412.

The Supply Chain Grievance Mechanism (SCGM) "is a continuous action used to process alerts regarding violations of the Code of Conduct for Business Partners by the Volkswagen Group's direct or indirect suppliers" (page 374). Alerts are handled within an internal IT system under a binding process manual; for indirect suppliers, audits may be triggered via the direct supplier relationship, and serious cases can lead to "temporary suspension or full termination of the business relationship" (page 383).

"In the year under review, there were violations of the human rights protected under the [LkSG]... concerning the workforce at suppliers in the upstream and downstream supply chain," related to "the prohibition of a disregard for freedom of association and the prohibition of unequal treatment in employment" (page 383); these are treated as serious human rights violations under ESRS S2. "At present, there is no systematic survey whether workers in the supply chain are familiar with and trust the existing grievance mechanisms" (page 383).

Reference: pages 374, 384.

Standard ReSC-System actions include Code of Conduct for Business Partners confirmation, the SCGM, media monitoring, the S-Rating and supplier training; advanced actions include the Human Rights Focus System (HRFS) and the Raw Material Due Diligence Management System (RMDDMS) (page 373). "One actual positive impact arises in the immediate business environment... linked to aspects including the Code of Conduct for Business Partners, the self-assessment questionnaire (SAQ) and completed audits"; specific examples cited include rubber-processing initiatives in Indonesia (working conditions) and the Responsible Mica Initiative (other work-related rights) (page 374).

Effectiveness is tracked via an Input-Output-Outcome-Impact method for standard actions, HRFS-specific effectiveness criteria, RMDDMS annual risk-analysis feedback for the 18 priority raw materials, and auditor/SCGM-case-handler review of supplier-specific corrective actions (page 384).

Reference: page 384.

"By 2040, the aim is for over 95% of relevant direct suppliers in terms of sales revenue to have a positive S-Rating," with "an intermediate target of 85%... defined for the reporting year 2025" (page 384). "In 2025, the proportion of sales revenue contributed by relevant direct suppliers with a positive S-Rating amounted to 87% of the total procurement volume. The intermediate target was therefore met" (page 384).

"The objectives were developed by a cross-divisional working group. Neither the workers affected nor their representatives were involved" (page 384). Progress is monitored through the Group-wide TOP 10 program, and "no significant deviations from the planned target progression have been identified to date" (page 384).

Reference: pages 372, 387-388.

Affected-communities policy content sits within the Responsible Supply Chain System: the Code of Conduct for Business Partners "contains binding regulations such as the prohibition of forced evictions, respect for humane living conditions and the rights of indigenous peoples" (page 388), while the Responsible Raw Materials Policy "references the right of indigenous communities to Free, Prior and Informed Consent (FPIC)" and their involvement in stakeholder processes (page 388).

"The reporting year marked the first time that the materiality assessment identified a negative impact related to the economic, social and cultural rights of communities along the supply chain" (page 387), focused on regions rich in raw materials such as mining areas in Chile, South Africa, Indonesia, India and Madagascar (page 388).

Reference: page 387.

Communities are engaged through "multi-stakeholder platforms, local partnerships and dialogue formats, enabling the perspectives of indigenous groups, civil organizations and local authorities... to be taken into account" (page 389). Named examples include the Responsible Lithium Partnership's "Mesa Multiactor" platform in Chile, coordinated by GIZ and bringing together "22 local stakeholders since 2021" (page 389), and local NGO involvement in the Indonesian nickel project's preparatory study (page 390).

"While isolated efforts are linked to the in-house due diligence process, for instance under the ReSC System, this does not take place on a systematic basis," and "the perspectives of individual groups within communities (for example, women and girls) are not currently systematically recorded on a comprehensive scale" (page 389).

Reference: pages 388-389, 412.

"The whistleblower system serves as a central complaint procedure for the Volkswagen Group," coordinated by the Central Investigation Office in Wolfsburg, with full detail in the Business Conduct Information chapter (page 388). "In the year under review, there were no violations of the human rights protected by the [LkSG] relating to affected communities in the upstream and downstream supply chain," and so "there are also no cases regarded as serious human rights violations as defined by ESRS S3" (page 389).

Project-level remediation channels also operate: the Indonesian nickel project includes "a new stakeholder forum... intended to safeguard ongoing dialogue with local stakeholders," and the RMI's Community Empowerment Program undergoes regular independent impact assessment (pages 390-391).

Reference: pages 389-391.

Named projects addressing the identified negative impact on communities in raw-material regions: the Responsible Lithium Partnership in Chile's Salar de Atacama (water cadastre, hydrological mapping, graywater recycling at a local school, transferred to a locally embedded structure in the reporting year) (page 389); the Marikana Coalition in South Africa, run via Scania, providing a youth center with "educational services, careers advice and social support" in a platinum-mining region (page 390); the Indonesian nickel project in Halmahera aiming to "protect biodiversity, improve living standards, and preserve water quality" over a three-year term to late 2028 (page 390); and the Responsible Mica Initiative in India and Madagascar, addressing child-labor risk since 2018 with Porsche AG financial support since 2020, current phase running to December 2027 (page 391).

"From Volkswagen's perspective, the [Chile] project's central target of safeguarding and boosting local engagement was achieved" (page 390).

Reference: pages 349, 393-394.

A Group-wide governance structure underpins vehicle safety: the cross-brand Safety System Working Group (AKS) sets requirements, approved by the Board of Management committee for Technology, while the Product Safety Committee (APS) "is responsible for the safety of products placed on the market" at each brand (page 393). The Automotive Cybersecurity Management System (ACSMS) addresses "the risk of unauthorized access to vehicles and their digital services" in line with UNECE Regulation 155, with brand-level certification based on external audits and annual monitoring audits (page 394).

The product safety and conformity Group policy requires "a system... for active and passive product observation" so risks "be identified at an early stage and averted" (pages 394-395). Personal-safety-of-customers policy content is cross-referenced alongside consumer-facing work-related-rights policy in Employees and Non-Employees (page 349).

Reference: page 395.

The Group works with national and international consumer protection organizations at brand level, coordinated overall by the AKS, including the Insurance Institute for Highway Safety (IIHS), the China Insurance Safety Index, and regional New Car Assessment Programme (NCAP) associations (page 395). NCAP roadmap updates are communicated via industry meetings, e-mail and websites, and are "integrated directly into product development" (page 395).

"The effectiveness of this cooperation can be tracked, for example, through the vehicle ratings issued by consumer protection organizations - such as the NCAP star ratings" (page 396).

Reference: pages 396-397.

Safety-relevant matters identified via passive/active product observation are analyzed by Development or Production; if confirmed as safety-relevant, the APS decides on actions such as "a recall campaign, a service action in a workshop, extended warranty services or a suspension of deliveries," implemented through the retail organization (page 396). Customers can raise safety issues via dealerships, social media, forums or brand hotlines (page 396).

For cybersecurity, customers and security researchers can report vulnerabilities through a dedicated portal ("volkswagen.de/.../kontakt-cyber-security.html") or via dealerships/hotline; reports route to each brand's Incident Management team under the car-security-incident process (CSI) (page 397). Violations can also be reported via the whistleblower system (page 397). "There is no Group-wide approach in place for checking whether customers are familiar with customer portals, trust these, and feel protected against potential repercussions" (page 397).

Reference: pages 398, 401-402 (effectiveness/targets context).

Actions include vehicle-safety research, integration of safety requirements throughout the Product Development Process (PEP), and cooperation with consumer-protection bodies to keep "safety technology up-to-date" (page 398). "As a result, the Volkswagen Group generates an actual and potential positive impact on vehicle safety standards" (page 398).

Effectiveness is tracked via compliance with internal/external safety regulations and NCAP ratings; via Group Accident Research, which runs a "24/7 on-call service" with Lower Saxony and Saxony-Anhalt state authorities and analyzes national/international accident databases including GIDAS (page 401-402); and via CSI lessons-learned reviews after cybersecurity incidents (page 402).

Reference: page 401.

"No measurable, outcome-oriented targets within the meaning of the ESRS are defined in relation to vehicle safety," and "the effectiveness of the policies and actions... [is] currently not monitored" in target terms (page 401). In place of numeric targets, effectiveness is tracked operationally: technical product descriptions set "specific targets for safety standards... even when a model is still under development"; Group Accident Research systematically evaluates accident data; and the CSI process reviews whether cybersecurity actions reach Development and production (pages 401-402).

This follows the same MDR-T pattern used elsewhere in the report (target or, in its absence, a description of how effectiveness is tracked), and S4-5 is explicitly listed in the company's own ESRS index (page 401).

Reference: pages 408, 412, 416.

The Code of Conduct is "the ethical and values-based foundation for acting with integrity and in a compliant manner," binding on all Group brands and companies and based on international human-rights, labour and anti-corruption conventions (page 409). The Group Essentials articulate seven shared values, e.g. "we are honest and speak up when something is wrong" and "we not me" (page 409). An internal compliance risk assessment (ICRA) assigns companies low/medium/high compliance-risk profiles with corresponding training packages (page 409); at end-2025, "280,865 (261,707) employees had a valid qualification on the Code of Conduct," 94 (97)% of the eligible active workforce (page 410).

The Group's whistleblower system (page 412) and its anti-corruption/anti-bribery programme (page 416) sit under the same Integrity & Compliance organization and are cross-referenced from this disclosure requirement in the company's own index.

Reference: pages 424-426, 372, 374.

Relationship management runs through the Responsible Supply Chain System: risk analysis classifying suppliers low/medium/high (page 425), the Business Partner Due Diligence process for integrity verification (page 425), the Code of Conduct for Business Partners (page 425), product-specific "specifications" (e.g. traceability requirements for cobalt, nickel, lithium and natural graphite in battery cells) (page 426), and the Sustainability Rating (S-Rating) (page 426).

"The Volkswagen Group has set the target of being able to demonstrate by 2040 that, in terms of sales revenue, over 95% of relevant direct suppliers have a positive Sustainability Rating (S-Rating)," with an 85% intermediate target for 2025 "exceeded" at 87% (page 426).

Reference: page 416.

The Group pursues "a strict zero-tolerance policy against corruption," anchored in the Code of Conduct and the Code of Conduct for Business Partners (page 416). Prevention tools include a Group policy on benefits and gifts, the Integrity & Compliance Information Point advisory service, risk-based anti-corruption training (at end-2025, "87,620 employees of ICRA high-risk companies had a valid qualification (new training)... equivalent to 69%" of eligible indirect employees; separately, "29,288... had a valid qualification in anti-corruption," 85% of eligible employees) (page 418), and the Business Partner Due Diligence process, which can lead to refusing or terminating a business relationship or blacklisting (page 417).

Breaches are investigated by the Group's investigation offices under a presumption of innocence, with sanctions ranging from a warning to dismissal (page 418).

Reference: page 419. Back-filled from the Prevention of Corruption and Bribery chapter, where business-conduct targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

"No measurable, outcome-oriented targets within the meaning of the ESRS are defined in relation to corruption and bribery. The effectiveness of the management policies and actions related to the positive impacts identified in the materiality assessment, which was performed in the reporting year, is currently not monitored" (page 419).

Despite that statement, the report describes MDR-T's alternate limb in the same section: the internal compliance risk assessment (ICRA) is used "to systematically identify, assess, and minimize compliance risks... particularly corruption and money laundering risks," with "actions for targeted prevention... rolled out to the companies using a risk-based approach," and "in the case of Group companies with a high level of risk exposure, external audits are conducted on the implementation and effectiveness of the prevention actions" (page 419). This effectiveness-tracking in lieu of a formal target satisfies MDR-T's alternate limb.

Reference: page 419.

"In 2025, the investigation offices received a total of 4,214 (3,555) reports," mostly non-anonymous or anonymous-with-contact-option (page 419). Corruption and Bribery table (2025/2024): "Ascertained cases of corruption or bribery (including fraud, extortion, collusion and money laundering)" 4/5; "Convictions for violation of anti-corruption and anti-bribery laws" 3/1 (page 419).

"In the year under review, three final judgments for fraud are known to have been handed down," detailed further in the "Litigation" section of the Group management report's Report on Risks and Opportunities chapter (page 419). Convictions are counted "if and to the extent that the Group is aware of the convictions," with associated fines reported "if they are directly related to the conviction" (page 419).

Reference: pages 420-423.

Lobbying is "organized centrally... in line with the principles of openness, transparency, and responsibility" under a "one voice policy" and the Public Affairs Group Policy (page 420). Registrations include the Lobbying Register of the German Bundestag (Volkswagen AG, Porsche AG, TRATON SE, VW Financial Services AG, PowerCo SE, AUDI AG, MAN Truck & Bus SE, Cariad SE, MOIA GmbH, Everllence SE and Volkswagen Group Charging GmbH) and the EU Transparency Register (Volkswagen AG, Scania AB, Everllence SE, MAN Truck & Bus SE) (pages 421-422). Minister President Olaf Lies joined the Supervisory Board on May 20, 2025, having previously served as Lower Saxony's Minister for Economic Affairs (page 422).

"The value of financial and in-kind political contributions made directly and indirectly by the consolidated companies amounted to EUR185 (92) thousand in 2025" (page 423). Focus topics named include e-mobility promotion, battery regulation, CO2 fleet legislation, regulated trade and automated driving (pages 420-421).