Westwing Group SE

The role of the management and supervisory bodies

Governance structure and board composition

Westwing has a two-tier (dualistic) board structure, consisting of a Supervisory Board and a Management Board. In total, the Management Board, according to the German system, is responsible for the management of the company and comprises two executive members. The Supervisory Board comprises five (non-executive) members and has the task of advising and monitoring the Management Board. In line with the applicable legislation, the Supervisory Board of Westwing Group SE does not include employees or other workers' representatives. Four of the five Supervisory Board members are deemed independent.

The board members have experience relevant to the e-commerce, retail, and financial sectors, ensuring effective oversight of business operations. The Management Board is currently all-male. The Supervisory Board has a 40% female representation, with the average ratio being 3:2.

Experience and expertise of board members

Sustainability Expertise in Governance

Westwing systematically ensures the sustainability expertise of its management and supervisory bodies. The Management Board has access to an in-house sustainability team with proven expertise, is supported by external experts as needed, and relies on clearly defined processes for integrating sustainability into decision-making and governance. The Supervisory Board incorporates relevant sustainability expertise through its composition, including experience in social engagement, Environmental, Social, and Governance (ESG)-related committee work in other companies, and active involvement in overseeing sustainability topics within corporate strategy and risk management.

To strengthen ESG expertise, Management Board members receive regular training and briefings on current regulatory developments, particularly regarding the EU Taxonomy, CSRD, and other ESG-related standards. In addition, regular assessments of sustainability risks and opportunities are integrated into strategic decision-making processes.

The Supervisory Board regularly monitors sustainability aspects, particularly through the Audit Committee. It also evaluates the adequacy of its expertise in sustainability through annual self-assessments and consults internal and external sustainability specialists as needed.

This process ensures continuous development and the availability of relevant knowledge to effectively oversee material sustainability impacts, risks, and opportunities. Sustainability topics can thus be monitored with expertise aligned with Westwing's specific IROs.

Roles and Responsibilities in Overseeing IROs

The Management Board is responsible for ensuring compliance with all legal provisions, internal policies, and risk management processes. It supervises and has the responsibility for the integration of sustainability objectives within corporate governance and decision-making processes. The Management Board also oversees the implementation of sustainability initiatives, ensuring integration into operational and financial planning. Its role includes setting sustainability-related objectives and monitoring progress through internal governance structures.

The Sustainability Steering Committee, chaired by the Director of Corporate Sustainability, comprises the Management Board, C-level executives from core business areas, and the Group's Vice President Legal. plays a key role in overseeing sustainability strategy implementation, reviewing progress, and aligning sustainability objectives with financial and operational targets.

The Supervisory Board's responsibilities include overseeing sustainability-related matters, risk management, compliance, and corporate governance. It advises and oversees the Management Board in developing the strategic guidelines for sustainability, ensuring alignment with regulatory requirements and business strategy. The Audit Committee of the Supervisory Board, is responsible for the review and compliance with sustainability reporting, internal controls, and risk management processes, ensuring integration with financial oversight.

The responsibilities of the Management Board and Supervisory Board with respect to IROs are reflected in their mandate as well as in the Sustainability Policy.

Delegation and Reporting Lines

The Audit Committee of the Supervisory Board monitors the aspects of sustainability and also supervises the broader topics of Governance, Risk, and Compliance (GRC). In this context – next to the Management Board – the Director for Sustainability, the GRC Manager, and the VP Legal report regularly directly to the Audit Committee.

The Corporate Sustainability team (reporting to the CFO) and the Quality and Sustainability team (reporting to the Chief Operations and Sourcing Officer) provide focused expertise to the Management Board, connecting sustainability with financial and operational decision-making. In 2025, sustainability-related expertise was consolidated as the sustainability functions of the Quality and Sustainability team were integrated into the Corporate Sustainability team. This restructuring further strengthened cross-departmental collaboration in materiality assessments and risk evaluations.

Internal Controls

Sustainability-related controls are embedded within Westwing's GRC framework, linking sustainability with financial reporting and compliance functions for a cohesive management approach. These controls are integrated into existing risk management processes, ensuring that sustainability-related risks are considered in internal risk assessments and reviewed by the Audit Committee. Compliance tracking systems monitor key sustainability performance indicators, which are aligned with broader company risk management functions.

The governance structure supports cross-functional collaboration between finance, compliance, and sustainability teams, reinforcing accountability and ensuring sustainability-related controls are effectively implemented and maintained. These controls are embedded within Westwing's GRC framework, integrating sustainability objectives with financial reporting and compliance functions for a cohesive management approach. While this framework is in place, CRSD-related controls are not yet implemented and are planned for introduction next year.

Target Setting and Monitoring

The Sustainability Steering Committee, which includes the Management Board, monitors progress quarterly. The Supervisory Board receives at least one annual update from the Management and Corporate Sustainability Team on specific sustainability metrics and the effectiveness of the Sustainability Policy. The Audit Committee reviews regularly sustainability-related risks and mitigation strategies, and monitors compliance with Westwing's broader governance framework.

Information provided to and sustainability matters addressed by the undertaking's management and supervisory bodies

The Sustainability Steering Committee which includes the Management Board is informed by the Corporate Sustainability team about the company's material sustainability IROs as part of the materiality assessment process. It is also informed on a quarterly basis on the effectiveness of due diligence processes and related policies, actions, metrics, and targets, if and as appropriate. The Corporate Sustainability team is responsible for monitoring and analysing these factors across the value chain in cooperation with experts across all Westwing departments. The Audit Committee of the Supervisory Board is updated regularly on key sustainability topics, including material impacts, risks, and opportunities, as well as the implementation and effectiveness of due diligence processes. These updates are provided by the Corporate Sustainability team, which monitors and analyses these factors across the value chain in cooperation with experts across relevant Westwing departments. The Chair of the Audit Committee reports back to the Supervisory Board regularly and ensures that the Supervisory Board is informed about these topics. Additionally, at least once a year, the Director of Sustainability provides an overview directly to the Supervisory Board, covering, as necessary, the results and effectiveness of policies, actions, metrics, and/or targets adopted to address material impacts, risks, and opportunities.

The Management Board and Supervisory Board evaluate IROs as part of their management and oversight duties, focusing on the company's strategy, key transactions, and risk management processes. Each year, sustainability goals are integrated into the company's business strategy as well as into departmental strategies as appropriate. The corporate risk register is updated biannually, under the supervision of the Management Board, to reflect current IROs. The management and supervisory bodies consider IROs through regular reviews of strategy, risk management, and major operational decisions. These reviews include an assessment of trade-offs to align business goals with environmental and social factors.

During the reporting period, the management and supervisory bodies have addressed the IROs related to climate change and energy, resource use and circular economy, own workforce, workers in the value chain, consumers and end-users, and business conduct.

Integration of sustainability-related performance in incentive schemes

Westwing integrates sustainability performance and climate-related considerations into its incentive schemes of the Management Board through a variable remuneration system, with a portion of the variable pay tied to the achievement of non-financial parameters such as the emission reduction targets. This system comprises a short-term variable remuneration (STI) and long-term variable remuneration (LTI). The STI pertains to annual targets related to sustainability performance, while the LTI is structured to incentivize longer-term environmental and social objectives that align with Westwing's sustainability goals. In accordance with the German Corporate Governance Code, there are no variable components, and therefore no climate-related considerations, in the remuneration of the Supervisory Board.

For 2024, the selected non-financial STI component is the "Share of plastics containing over 60% recycled materials." The selected non-financial LTI components for the 2023–2025 performance period are the "Share of suppliers committed to setting science-based targets (SBTs)" and the "Percentage reduction of Scope 1 and Scope 2 emissions. A significant portion of the variable remuneration consists of share-based payments, aligning management's interests with those of shareholders. Other remuneration components are designed to support sustainability goals. Sustainability-linked remuneration accounts for 20% of the total long-term variable remuneration.

Sustainability-related performance metrics are not currently considered as performance benchmarks or included in remuneration policies. This exclusion reflects a current focus on financial performance metrics as the primary benchmarks in remuneration policies.

The remuneration system for the Management Board is established by the Supervisory Board based on the remuneration systems approved by the Annual General Meeting (AGM). The Remuneration Committee of the Supervisory Board prepares the details and provides recommendations to the full Supervisory Board. The current remuneration system was approved by shareholders at the 2023 AGM, and the remuneration report for FY 2023 was further approved at the 2024 AGM. This process reflects a structured governance approach to regularly updating and approving the remuneration framework. This process reflects a structured governance approach to regularly updating and approving the remuneration framework.

Statement on due diligence

Risk management and internal controls over sustainability reporting

Westwing's risk management and internal control processes in relation to sustainability reporting are designed to ensure accuracy and reliability, particularly for ESG metrics. These processes are built on the COSO framework (Committee of Sponsoring Organizations of the Treadway Commission), which includes control environment, risk assessment, control activities, information and communication, and monitoring. The Non-Financial Internal Control System is a key feature, providing a structured approach to managing and mitigating risks related to non-financial reporting, including compliance with regulatory requirements such as the Corporate Sustainability Reporting Directive (CSRD). This framework is planned for implementation next year.

Westwing's risk assessment is carried out through a detailed risk manual that undergoes regular review and updates. All risks are assessed based on their likelihood and potential impact over a one-year horizon. Mitigation measures are considered, and an aggregated risk assessment is conducted for the most critical risks, rated on a scale from "low" to "extreme." This prioritization ensures that the most significant risks are addressed with appropriate mitigation strategies.

Key risks identified within the sustainability reporting process include non-compliance with the CSRD regulation and the potential for receiving an adverse opinion from external auditors. These risks pose reputational and financial threats to Westwing. In response, Westwing has updated its risk catalogue to include these risks and has implemented the COSO-based Non-Financial Internal Control System to mitigate them. Controls are in place to help ensure that sustainability data is accurately reported, and any gaps identified during assessments are addressed through corrective action plans.

The findings from Westwing's risk assessments and internal controls are integrated into the company's relevant internal functions and processes. Corrective action plans, informed by risk assessment outcomes, are developed and implemented by the responsible departments. This integration aims to ensure that sustainability reporting practices are continuously improved, and any risks identified are systematically addressed. Continuous monitoring reinforces accountability and ensures that team members are aware of their roles in maintaining data integrity.

Specific risks monitored include the completeness and integrity of data, estimation accuracy, data availability from upstream and downstream sources, and timing for the inclusion of this information in the reporting cycle.

Westwing's findings related to risk assessments and internal control evaluations are periodically reported to the Management and Supervisory Board (and/or the Audit Committee). These reports provide insights into the effectiveness of internal controls and highlight any risks related to sustainability reporting. This is aimed to enable the management and supervisory bodies to oversee the sustainability reporting process, ensuring compliance and alignment with the company's risk management objectives.

Strategy, business model and value chain

Westwing aims to be Europe's leading one-stop destination for premium home and living. The company offers a carefully curated selection of Home & Living products across key categories such as textiles, décor, kitchen accessories, lighting, and furniture. Each item is thoughtfully designed and sourced to balance premium quality with responsible material choices, including an increasing share of certified and recycled materials where feasible. In addition to its own collection, Westwing provides a curated range of premium products from third-party brands, complemented by regularly refreshed content featuring daily shopping themes. The company does not impose product bans in specific markets, enabling it to offer a diverse assortment of items across regions. The product categories for the Westwing Collection remained consistent during the reporting year.

In 2024, Westwing expanded its operations to include Portugal, bringing its presence to a total of 12 European countries. The company's business is divided into two primary segments: DACH, which includes Germany, Switzerland, and Austria, and the International segment, which covers Spain, Portugal, Italy, France, Poland, the Czech Republic, Slovakia, Belgium, and the Netherlands. The company's key customer group, the "Design Lover" community, values premium design products which aligns with the emphasis on high-quality and durable products. This focus supports the increasing integration of certified materials and responsible sourcing practices. Additionally, growing sustainability awareness among consumers in key European markets drives efforts to improve transparency and product sustainability information.

As of December 2024, Westwing employs a total of 1,392 people, with 660 based in Germany, 667 in Poland and 54 in other locations. In 2024, the company generated total revenue of €444 million, with 57% coming from the DACH region and 43% from international markets. As a retail company without own manufacturing facilities, Westwing's primary impacts and risks are concentrated within its value chain, particularly in its supply chain. Westwing is not involved in industries such as fossil fuels, chemical production, controversial weapons, or tobacco cultivation and production.

Westwing's sustainability goals focus on areas where the company has greater operational control, particularly the Westwing Collection and its supplier base, as well as the countries where most of its operations are located - Germany and Poland. These goals also emphasize strengthening relationships with key stakeholders, including suppliers, logistics partners, and customers, to drive progress toward sustainability targets. For instance, supplier engagement initiatives focus on sustainable sourcing practices, while logistics partners are involved in efforts to reduce emissions.

Westwing prioritises the Westwing Collection in its sustainability strategy, increasing the use of certified materials and responsible sourcing. Additionally, as a curated platform, it influences sustainability through third-party brand selection. Across its 12 European markets, customer expectations for responsible products drive efforts to improve transparency and offer more sustainable options.

Westwing's key customer groups shape its sustainability approach. "Design Lovers" prioritise premium aesthetics and durability, reinforcing the focus on high-quality, long-lasting products. Sustainability-conscious consumers expect clear information on product certifications and sourcing. Additionally, consumers who rely on product labels and manuals to prevent misuse, particularly for items with potential health or safety implications, are a key consideration in Westwing's approach to transparency. Ensuring product information is accessible and accurate supports responsible consumption.

As Westwing expands its collection, product range, and offline presence, key sustainability challenges include logistics emissions, packaging waste, and supply chain risks. Planned initiatives such as improving logistics efficiency and increasing European-based sourcing aim to mitigate these impacts while maintaining sustainability progress across all markets.

In the context of Westwing's expansion, collecting data from offline stores on energy consumption and emissions will be important to enhance our sustainability reporting and keep us aligned with our targets as we expand.

Business Model and Value Chain

(a) Inputs and Approach to Securing Them

Westwing's business model is built on sourcing key materials such as wood, cotton, wool, and leather from suppliers primarily located in Europe and Asia. These materials are critical for manufacturing products for both the Westwing Collection and third-party brands. Key activities in securing these materials include product development, sourcing, procurement, and quality control.

Westwing aims to ensure the quality of materials used in the Westwing Collection through strategic, long-term relationships with suppliers, though the company has limited operational control over them. This effort is supported by a combination of strategic suppliers and in-house design and buying teams that develop and curate the Westwing Collection. Investments in talent and technology also play a critical role in securing and optimizing inputs for the company's unique group strategy.

From a materiality perspective, the upstream value chain for the Westwing Collection is essential to value creation, as it directly impacts the availability, quality, and cost structure of materials. Through a materiality assessment conducted under ESRS 1, Chapter 3, the company has identified raw material price fluctuations and supply chain disruptions as key risks, particularly relevant in the home furnishings sector. These risks have prompted Westwing to prioritize sustainable sourcing practices and minimize resource use where possible in the creation of the Westwing Collection.

(b) Outputs and Outcomes for Customers, Investors, and Other Stakeholders

Westwing's outputs primarily consist of a wide array of Home & Living products sold via its e-commerce platform, with the Westwing Collection contributing more than 50% of the gross merchandise value (GMV). Current benefits of these outputs for customers include a differentiated shopping experience that aims to blend lifestyle content with premium products. Expected benefits of these outputs for customers include long-term satisfaction, supported by the Westwing Collection's continued expansion and enhanced product quality.

The key resources driving these outputs include Westwing's in-house design teams, who aim to create exclusive product designs, and marketing and creative teams, whose goal is to lead impactful brand and product campaigns. These teams also strive to develop engaging daily content that inspires customers, fosters high retention rates, and strengthens the brand's presence.

For investors, current benefits of Westwing's outputs include a clear path to improved profitability and cash flow, driven by the strategic focus on high-margin proprietary products and operational efficiency, supported by financial performance metrics such as €444 million in revenue and an Adjusted EBITDA of €24 million in 2024. Expected benefits for investors include higher enterprise valuation based on further profitability improvements, driven by the continued expansion of the Westwing Collection, efficiency improvement measures, and scale effects from expansion.

For other stakeholders, including employees and the broader community, Westwing delivers current benefits of its outputs, such as employment opportunities and contributions to addressing sustainability challenges. Expected benefits for these stakeholders include enhanced career opportunities for employees through company growth and broader adoption of sustainable practices throughout the value chain, including further reductions in environmental impacts through minimising packaging waste and emissions reductions.

Customer satisfaction is key in driving repeat business and long-term growth. The downstream value chain also presents expected downstream outcomes, such as opportunities for further optimisation, including reducing carbon emissions through enhanced packaging and operational efficiencies.

(c) Main Features of the Upstream and Downstream Value Chain

Westwing's upstream value chain encompasses the sourcing, procurement, and shipment of products to its logistics centre. The key business actors in this value chain include Westwing Collection suppliers and third-party brands located in Europe and Asia, as well as logistics operators responsible for transporting goods. Westwing acts as a strategic partner to its suppliers, focusing on quality management while having limited direct operational control. These suppliers provide essential materials and products that significantly contribute to Westwing's gross merchandise value, particularly through the Westwing Collection, which accounts for more than half of the company's sales.

Downstream, Westwing oversees the packaging, order processing, and shipment of products to customers across 12 European countries. Distribution channels involve third-party logistics operators, complemented by partial control over deliveries through the Westwing Delivery Service. Efficient logistics are critical to Westwing's business, as fast and reliable delivery enhances customer loyalty and drives repeat purchases. The company's logistics providers play a vital role in this value chain, ensuring products are delivered efficiently, safely, and on time, contributing to Westwing's overall performance.

Interests and views of stakeholders

Westwing engages with its primary stakeholders—investors, customers, employees, suppliers, and business partners—through dedicated channels tailored to each relationship. Investor relations are managed via quarterly earnings calls, investor conferences and meetings, and the investor relations website. Employee feedback is collected through regular surveys, the eNPS (employee Net Promoter Score), and company-wide meetings. Customer input is gathered via surveys, product reviews, and customer service interactions. Suppliers engage through performance reviews, audits, and regular business meetings.

The purpose of engagement varies for each stakeholder group: for investors, it focuses on transparency and financial performance; for employees, it emphasizes workplace culture and satisfaction; for customers, it aims to improve product offerings and experiences; and for suppliers and business partners, it ensures quality, sustainability alignment, competitive pricing, and reliable product availability.

Westwing recognizes that aspects of its business model, such as reliance on logistics operations and a temporary workforce structure, may influence workforce-related risks, particularly regarding health and safety. To mitigate these risks, the company implements relevant training and collects stakeholder feedback through surveys and meetings. Insights into workforce interests, including health and safety, well-being, and professional development, are analyzed to refine operations and adjust working conditions, training, and development programs. This ensures workforce needs are integrated into the business model and strategic decisions, reflecting Westwing's commitment to fair and safe workplace practices.

Value chain workers are key stakeholders affected by Westwing's sourcing practices, particularly regarding human rights and fair working conditions. While Westwing does not directly engage with value chain workers, it relies on recognized bodies

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

Material IROs identified

The materiality assessment has shown that the main IROs for Westwing are as follows. Please refer to section IRO-1 for the detailed materiality assessment process.

Material impacts, risks, and opportunities across operations and the value chain

Westwing's material IROs arise from its operational activities and extensive relationships within its upstream and downstream value chain. These impacts are central to Westwing's business model, informing its approach to sustainable operations, product sourcing, distribution, and customer engagement. Through a materiality assessment, Westwing identified key focus areas across climate change, circular economy, labour conditions (own operations/value chain), and consumers/end-users, which influence the company's decision-making and strategic adaptations.

Westwing's operations, primarily based at its headquarters in Germany and logistics centre in Poland, contribute to carbon emissions and resource use impacts. To address these challenges, Westwing implements energy-efficient practices, waste reduction programs, and renewable electricity sourcing wherever possible to minimize its environmental footprint.

In its upstream value chain, the company prioritizes sustainable materials such as Forest Stewardship Council (FSC)-certified wood and organic cotton, reducing environmental degradation risks and aligning with its sustainable product strategy. This commitment is supported by partnerships with Westwing Collection suppliers, many of which are based in Europe. Regular supplier audits ensure compliance with fair labour practices and sustainable standards, mitigating reputational and compliance risks related to labour conditions.

In the downstream value chain, Westwing's distribution network spans 12 European countries. The company minimizes environmental impact through optimized logistics and efficient routing. Furthermore, its product design emphasizes durability and recyclability, addressing increasing customer demand for sustainable products while fostering brand loyalty over the long term.

Effects on business model, strategy, and decision-making

Westwing's strategy and business model are shaped by material IROs across key areas such as climate change, circular economy, workforce, and value chain. Immediate measures, such as sustainable sourcing, packaging optimisation, and waste reduction, address short-term challenges like carbon emissions and operational efficiencies, aligning with resource optimisation goals. Current opportunities, such as adopting energy-efficient practices and leveraging circular product design, contribute to cost savings and enhance customer loyalty, further strengthening the business model.

Anticipated effects of long-term risks, such as resource scarcity and disruptions in logistics and raw material production due to climate change, drive Westwing's focus on diversifying sourcing strategies. Similarly, medium-term risks, including rising costs in manufacturing and logistics, influence sourcing decisions and supplier partnerships. In parallel, long-term opportunities, such as the growing demand for resale and refurbished products, shape efforts to enhance product durability and refurbishment capabilities, ensuring alignment with shifting consumer preferences and sustainability goals.

Westwing's value chain is influenced by risks like regulatory compliance challenges and inefficiencies in resource use, which necessitate enhanced supplier engagement strategies. At the same time, opportunities such as resource optimisation and emissions reductions are pursued to achieve cost savings and support environmental objectives.

Decision-making processes are informed by material impacts, risks, and opportunities, with priorities set around addressing regulatory compliance risks. Strategic adjustments, such as strengthening supplier relationships, reflect Westwing's proactive approach to managing these factors while adapting to long-term sustainability and operational challenges.

Connection of impacts to strategy, time horizons, and nature of involvement

Westwing's strategy and business model impact both people and the environment, with specific actions in place to manage these effects. Carbon emissions from logistics, supply chain activities, and internal operations contribute to climate change, creating short-term environmental challenges. These emissions stem directly from Westwing's operational and distribution model across Europe. To address this, the company is implementing energy-efficient practices, packaging and waste reduction programs, and increasing its use of renewable electricity, aligning its operations with environmental goals in the short and medium term.

Resource use in sourcing materials for Westwing's products also impacts the environment, particularly within the upstream supply chain. To mitigate these effects, Westwing prioritizes sustainable materials, such as FSC-certified wood and organic cotton, as part of its sustainable product strategy. This approach reduces resource-related impacts and strengthens the company's commitment to sustainability through partnerships with responsible suppliers.

Social impacts are also a key focus for Westwing, particularly in the upstream supply chain. The company promotes fair and ethical treatment of workers by supporting labour standards and social responsibility through its partnerships with Westwing Collection suppliers. Regular audits ensure compliance with these standards, reducing short-term compliance and reputational risks related to worker treatment.

In the downstream value chain, Westwing manages potential negative impacts on consumer safety and satisfaction through stringent quality controls to prevent harm from unsafe products. Additionally, by providing sustainability information, Westwing encourages responsible consumer choices, contributing to long-term brand trust as demand for sustainable products continues to grow. This downstream impact on consumer behaviour aligns with Westwing's mission to offer safe, reliable home and living products.

Westwing continually evolves its strategy, prioritising sustainable sourcing, energy-efficient upgrades, and waste reduction to address its material impacts. These adaptations help to ensure that Westwing remains aligned with regulatory requirements, customer demands, and long-term growth objectives, providing resilience across its value chain.

Financial effects

Based on our climate risk assessments and double materiality assessment, we have not identified any current financial effects of our material risks and opportunities on our financial position, performance, or cash flows.

Investment and funding

Westwing's current investments are focused on reducing carbon emissions, enhancing resource efficiency, and sourcing sustainably. While these initiatives are intended to support long-term financial and sustainability goals, they remain flexible and are not yet contractually committed, allowing Westwing to adjust its plans as needed. Funding will primarily come from internal sources.

Resilience of strategy and business model

Westwing has assessed the resilience of its strategy and business model by evaluating its capacity to address material impacts, risks, and opportunities through existing risk management and business planning processes. This assessment considered short- and medium-term risks, including regulatory changes, supply chain disruptions, and operational constraints in leased logistics centres, as well as opportunities arising from expanding sustainable product lines and responsible sourcing. Westwing's sustainability-focused practices inherently reinforce this resilience by integrating sustainability into core business functions. For example, sustainable sourcing and packaging optimisation reduce environmental impacts, while efforts to strengthen supplier relationships mitigate risks related to regulatory compliance and resource scarcity. Additionally, the focus on product durability and longevity aligns with consumer demand, enabling Westwing to capture market opportunities. A more structured and comprehensive resilience analysis, incorporating long-term time horizons and scenario-based assessments, is planned for completion in 2025.

Additional notes

Material IROs are reported this year for the first time. In this report, with the exception of IROs linked to resource outflows related to products and services, the personal health and safety of consumers and/or end-users, and business conduct, all other IROs are covered by entity-specific disclosures in addition to the ESRS Disclosure Requirements.

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

Overview

The Double Materiality Assessment (DMA) enabled Westwing to identify and evaluate its environmental and social impacts across the upstream, internal, and downstream value chain. Aligned with CSRD requirements, the assessment process involves selecting relevant ESG topics, evaluating impacts across the value chain, and gathering stakeholder insights on both potential and actual effects on people and the environment. The assessment outputs inform Westwing's corporate risk management process for sustainability-related risks, ensuring alignment with the company's broader risk framework.

Impact Materiality Assessment Process

The assessment examines potential and actual impacts on people, including unsafe working conditions, limited growth opportunities, and risks to physical and mental health, as well as environmental impacts. These are evaluated across Westwing's own operations, including its logistics centre and offices, and its business relationships, encompassing suppliers and downstream logistics such as final customer delivery.

Inputs to the Assessment:

• Expert judgment and stakeholder engagement—through surveys, interviews, and follow-ups with employees, customers, suppliers, business partners, and top management
• Stakeholders ranked by influence, urgency, and legitimacy to weigh their input appropriately
• External experts consulted for additional insights on complex issues

Impact Assessment Criteria:

• Negative and positive impacts are prioritized based on their severity and likelihood
• Focus on those with the most significant adverse effects, such as unsafe working conditions or human rights violations, and environmental harms
• Negative impacts assessed by their scale, scope, and remediability
• Positive impacts evaluated by their scale and scope

Materiality Threshold:

• Materiality thresholds, as defined by ESRS standards, determine which impacts are deemed material
• 5-point scale where a severity score of 3 or above designates an impact as material

Monitoring: The process to monitor impacts on people and the environment includes periodic engagement with stakeholders such as employees, customers, and suppliers, along with internal reviews of operational practices, supplier audits, desk research and the analysis of key performance indicators related to identified material impacts. The monitoring process is aimed at the evaluation of both negative and positive impacts on people and the environment, enabling updates to the priorities, mitigation strategies and the corporate risk management, as necessary.

Financial Risks and Opportunities Assessment Process

The DMA incorporates an evaluation of financial risks and opportunities linked to ESG issues, linking Westwing's identified impacts with associated financial dependencies to create a view of potential effects on financial stability. While impacts and opportunities are not part of Westwing's corporate risk management framework, impacts are assessed separately through the DMA to support strategic business planning and provide context for related risks and opportunities. Sustainability-related risks, however, are integrated into the corporate risk management process and inform decision-making at both operational and strategic levels.

Financial Risk Assessment Criteria:

• Likelihood, magnitude, and nature of financial risks assessed using a 5-point scale
• Established thresholds from general risk management process, where magnitude is linked to specific monetary sums
• Financial materiality designated when the score (likelihood × magnitude) reaches a threshold of 3 or above and/or magnitude has a value of 3 or above

Process: The process for identifying sustainability-related risks and opportunities involves:

1. Collecting data from internal and external sources
2. Evaluating potential dependencies
3. Determining material risks and opportunities
4. Assessing impact on financial and operational outcomes
5. Ensuring consistency with corporate risk management methodology

Sustainability-related risks are categorised and prioritised alongside other strategic risks to support Westwing's overall risk management objectives.

Input Parameters: Westwing's input parameters for risk assessment include quantitative and qualitative data sources across the value chain, reflecting a comprehensive scope of operations. These data points incorporate stakeholder perspectives, potential regulatory changes, and financial thresholds, with assumptions informed by historical data, current market trends, and stakeholder feedback.

Climate-Related IROs Assessment

To assess its climate-related impacts, Westwing has focused on its GHG emissions across Scopes 1, 2, and 3. Scope 1 emissions encompass direct emissions from Westwing's operations, including heating systems and company vehicles. Scope 2 covers indirect emissions from purchased electricity, while Scope 3 addresses emissions generated along the value chain, such as raw material sourcing, transportation, and product disposal.

GHG Emissions Assessment:

• Full carbon footprint evaluation by assessing both current and potential future GHG emission sources
• Setting assessment boundaries, gathering internal and external data, and evaluating emissions from both operational and supply chain activities
• Anticipates future growth, projected energy needs, and potential shifts in material sourcing that may influence GHG emissions
• Additional climate-related impacts, such as land-use changes within the supply chain, considered where relevant

Climate Risk Assessment:

Time Horizons:

• Short-term: 1–3 years
• Medium-term: 3–10 years
• Long-term: up to 2050

These horizons broadly reflect Westwing's planning approach, which typically focuses on the next year for operational decisions, three-year horizons for business growth and strategy execution, and longer-term considerations for sustainability and market developments. While not fully aligned, these horizons are used as a basis for capital allocation decisions.

Climate Scenario Analysis: The climate-related scenario analysis includes identifying climate hazards and transition events and assessing how assets and business activities are exposed to and sensitive to these hazards and events, resulting in gross climate risks.

Scenarios Used:

• SSP5-8.5 (high-emissions)
• SSP1-2.6 (low-emissions)

Selected for their alignment with state-of-the-art climate science. The scenario analysis does not currently include a specific 1.5°C-aligned scenario, such as SSP1-1.9. These scenarios are widely recognized and form part of the IPCC Sixth Assessment Report.

Scenario Considerations:

• Policy changes
• Macroeconomic trends
• Energy usage
• Technological developments
• Regulatory policies and emissions standards

Transition Events Identification: Transition events were identified through desk research, focusing on publicly available sources such as regulatory roadmaps, industry reports, and climate science literature, including the IPCC Sixth Assessment Report (AR6). This research aimed to understand potential drivers of change, such as stricter emissions regulations, technological advancements, and shifts in consumer preferences for sustainable products. Transition events were assessed for their relevance to Westwing's operations and value chain, highlighting potential exposure to increased compliance costs, supply chain disruptions, and changing consumer demand. This analysis is qualitative in nature and serves as a preliminary step toward more detailed assessments.

Key Constraints:

• Uncertainties in climate projections, particularly regarding the frequency and severity of extreme weather events
• Lack of granular, localized data
• Assumptions about policy, technology, and socio-economic conditions may not fully reflect future developments
• Static nature of assumptions limits adaptability
• Long-term projections less reliable due to complexity of climate systems and interdependencies with other risks

Circular Economy and Resource Use IROs Assessment

Westwing's assessment of IROs related to resource use and the circular economy aligns with the ESRS 2 IRO-1 guidance. Based on the Locate, Evaluate, Assess and Prepare (LEAP) approach, the materiality assessment began by identifying where Westwing's operations and value chain interact with environmental resources.

Key Stages Identified:

• Sourcing
• Warehousing
• Logistics
• End-of-life product management

This helped locate dependencies on renewable and non-renewable resources, assess environmental impacts, and classify these as either actual or potential over the short-, medium-, and long-term horizons.

Methodologies Used:

• Desk research
• Expert judgment
• Existing risk management system
• Benchmarking against industry standards and peers

Screening Approach: Westwing screened its assets and activities across its value chain, including the leased logistics centre and stores, to identify areas of significant resource use, emissions, and waste generation. The screening assumed that impacts stem mainly from sourcing, packaging, logistics, and product end-of-life.

Stakeholder Input: Findings were validated through consultations with stakeholders, including suppliers, customers, and internal experts, who provided valuable insights into resource use and circular economy considerations. Though no direct consultations with affected communities were conducted, this stakeholder feedback informed the materiality assessment and supported decision-making on resource use and circularity goals.

Assessment Focus:

• Resource inflows: Focusing on circularity and optimisation of renewable and non-renewable material use
• Resource outflows: Impacts linked to products and services, particularly regarding waste reduction and hazardous waste management

Internal methodologies, combined with benchmarking against peers, provided a framework for evaluating impacts on resource use.

Key Prioritised Resources:

• Wood
• Cotton
• Plastics
• Packaging materials

These resources were selected based on their significance to regulatory compliance and operational efficiency, as well as their potential for optimisation within a circular model.

Outcomes: Business units such as logistics centre, Westwing Collection, and Brand Partners identified as the most relevant contributors to resource use and circular economy impacts. Across the value chain, material sourcing, logistics, and end-of-life stages concentrate the most significant resource use, risks, and impacts. These stages serve as focal points for improving resource efficiency and minimising waste.

Business Conduct IROs Assessment

Westwing's process to identify and assess material impacts, risks, and opportunities related to business conduct matters considered location, activity, sector, and transaction structure.

Assessment Considerations:

Location: Reviewed supplier regions, focusing on differences in regulatory frameworks, with European countries offering stricter governance compared to regions with weaker enforcement of labour rights or anti-corruption measures.

Activities: Sourcing, supplier onboarding, and third-party logistics evaluated as they involved higher engagement with external partners.

Sector: Risks common in the e-commerce retail industry, such as supply chain transparency and customer data protection.

Transaction Structure: Long-term supplier contracts seen as reducing risks, while spot transactions received additional scrutiny.

Outcome: The evaluation revealed one material risk linked to corporate culture: possible reputational damage and regulatory penalties arising from non-compliance with ethical standards and business conduct policies. No material opportunities were identified.

Pollution, Water and Marine Resources, and Biodiversity and Ecosystems IROs Assessment

Westwing evaluates its operations and value chain to screen for material impacts, risks, dependencies, and opportunities related to pollution, water and marine resources, and biodiversity and ecosystems. These evaluations were informed by internal expertise, supplier data where available, peer benchmarking and publicly available data.

Pollution: Westwing screened its site locations and value chain activities to identify pollution-related impacts, risks, and opportunities, focusing on air, water, and soil pollution. This screening considered indirect pollution risks arising from supplier practices and logistics operations. The findings confirmed that pollution is not material for Westwing, as the company's operations do not include pollution-intensive activities, and its value chain operates largely under strict environmental regulations, particularly in Europe. While indirect risks exist, they are not significant enough to pose material financial, operational, or strategic implications.

No consultations with affected communities regarding pollution-related impacts were conducted, as the preliminary assessment indicated that pollution was not a material issue.

Water and Marine Resources: Westwing assessed water-related risks and impacts across its operations and value chain, focusing on sourcing activities and supplier regions where water scarcity might pose challenges. The findings indicated that water and marine resources are not material issues for Westwing, given the low water intensity of its e-commerce operations and the absence of significant direct water use or marine resource dependency. Supplier regions, particularly in Europe, operate under strict environmental regulations that mitigate water-related risks. No consultations with affected communities regarding water-related impacts were conducted, as these issues were deemed immaterial.

Biodiversity and Ecosystems: Westwing evaluated its site locations and value chain for impacts, risks, dependencies, and opportunities related to biodiversity and ecosystems. The assessment used internal expertise and information along with publicly available data to identify potential interactions with biodiversity-sensitive areas. The findings confirmed that biodiversity is not material for Westwing due to its low reliance on activities that directly harm ecosystems, such as deforestation or intensive agriculture.

(a) Actual and potential impacts on biodiversity and ecosystems were assessed, focusing on supplier practices and locations near biodiversity-sensitive areas.

(b) Dependencies on ecosystem services were evaluated, considering critical resources like timber, which are largely certified (e.g., FSC®) to mitigate biodiversity risks.

(c) Transition and physical risks, such as habitat loss and regulatory changes, were considered alongside potential opportunities to enhance biodiversity through sustainable sourcing.

(d) Systemic risks, including broader ecological degradation, were also part of the evaluation but were found to pose no significant threat to Westwing's operations or value chain.

No consultations with affected communities were conducted regarding biodiversity-related impacts, risks, or dependencies, as significant negative impacts were not identified. Westwing's sourcing practices emphasise responsible certifications, such as FSC® and GOTS, to minimise potential impacts.

Scenario Analysis: Westwing has not conducted scenario analyses related to pollution, water and marine resources, or biodiversity and ecosystems. These topics were determined to be immaterial based on screening results, and therefore scenario analysis was not applied to assess material risks and opportunities over different time horizons.

Integration with Corporate Risk Management

Sustainability-related risks are fully integrated within Westwing's corporate risk management framework, offering a unified perspective on the company's risk profile and facilitating a coordinated response to market or regulatory changes. Opportunities identified through the Double Materiality Assessment (DMA) are managed separately but pursued through strategic initiatives that align with Westwing's business objectives.

Westwing's input parameters for risk assessment include quantitative and qualitative data sources across the value chain, reflecting a comprehensive scope of operations. These data points incorporate stakeholder perspectives, potential regulatory changes, and financial thresholds, with assumptions informed by historical data, current market trends, and stakeholder feedback.

Once sustainability-related risks are identified, risks are reviewed and validated by relevant departments, with decision pathways evaluated against regulatory standards and strategic priorities. Post-implementation monitoring ensures that adjustments align with Westwing's broader risk strategy and provide ongoing refinement of the process.

Frequency and Review

The materiality assessment process undergoes regular updates to ensure alignment with evolving standards. The most recent modification was completed in October 2024, with the next scheduled review set for the upcoming fiscal year to incorporate updates from ESRS and CSRD guidelines.

Value Chain Mapping

Westwing's sustainability statement covers both the upstream and downstream value chains, as well as its own operations. The materiality assessment extends to both upstream and downstream value chains, capturing the impacts, risks, and opportunities (IROs) within these areas.

Upstream value chain: Includes sourcing, procurement, and shipping from suppliers and brand partners in Asia and Europe, over which Westwing has limited operational control.

Own operations: Span its offices, logistic centres, and stores, all of which are located in leased spaces, limiting the extent of direct operational control.

Downstream value chain: Includes order processing, packaging, shipping to customers, and product end-of-life management across 12 European countries. While Westwing has direct operational control over specific processes such as selecting packaging materials, and managing order processing systems, broader responsibilities within the value chain, such as the practices of packaging suppliers or outsourced customer service providers, remain outside direct operational oversight.

Transition plan for climate change mitigation

Overview and governance

Recognising the urgency of adapting and responding to climate change, Westwing has recently developed a formal Climate Transition Plan to consolidate and expand upon our ongoing efforts for climate change mitigation. Approved by the company's management board, this plan aligns with Westwing's overall business strategy and financial planning, and main elements embedded within the annual strategy development process. It informs the overarching 3-year Group Strategy, which emphasises areas like expansion and premium positioning. Each department develops annual strategies aligned with Group priorities, with the Corporate Sustainability team working closely with the Executive team and other departments to embed sustainability initiatives throughout these strategies. The Executive team reviews the strategies to maintain consistent alignment with the long-term Group Strategy and sustainability goals.

Alignment with Paris Agreement and 1.5°C pathway

While currently excluded from the EU Paris-aligned Benchmarks, Westwing is committed to decarbonisation and aligning with the 1.5°C pathway of the Paris Agreement. Westwing's GHG emission reduction targets, validated by the Science Based Targets initiative (SBTi), align with the 1.5°C pathway using cross-sector guidance due to the lack of an e-commerce-specific pathway.

GHG emission reduction targets

Scope 1 and 2 targets: Our Scope 1 and 2 emissions reduction targets include a 75% reduction in Scope 1 and 2 greenhouse gas (GHG) emissions by 2030 (from a 2022 baseline). Both direct emissions from our own operations (Scope 1) and indirect emissions from purchased energy sources (Scope 2) are covered.

Scope 3 supplier engagement target: We also set a supplier engagement target, committing ourselves to ensuring that 80% of all our suppliers, measured in terms of our spend on purchased goods and services, and upstream transportation and distribution providers will have set their own science-based targets by 2027. This target includes Westwing Collection suppliers, third-party brand suppliers, and logistics carriers.

Renewable energy target: As part of our Sustainability Strategy 2030, we also aim to increase the share of renewable energy we use in our operations. Currently, the larger of our two warehouses in our logistics centre in Poznan uses solar PVs for 14% of its electricity, and all offices (except our office in Hong Kong and China) and delivery hubs use renewable electricity. For sites where the transition to renewable energy sources is not feasible due to technical or other constraints, Guarantees of Origin will be considered as an alternative.

Scope of the plan

Westwing's decarbonisation efforts cover its entire operations across all geographic regions and value chain activities, including upstream suppliers and downstream partners.

Decarbonisation levers and actions

Westwing's decarbonisation levers include:

• Use of renewable energy
• Energy efficiency measures
• Electrification of owned and operated vehicle fleet
• Supply chain decarbonisation
• Changes in product portfolio
• Sustainable procurement of packaging materials
• Resource efficiency measures

Specific actions to reduce carbon emissions include sourcing renewable electricity, where feasible, and exploring opportunities to transition to renewable heating for our logistic centre, supported by energy-efficient technologies to lower energy demand. In product design for Westwing Collection, the company sources certified raw materials and collaborates with suppliers to develop innovative recycled materials, in efforts to reduce emissions associated with raw material extraction. To minimise value chain emissions, Westwing engages suppliers to set science-based targets and optimises logistics operations. Within its own operations, the company aims to transition its fleet to electric vehicles.

Summary of decarbonisation actions

Progress in 2024

Supply-chain decarbonisation:

• Upskilled internal teams on carbon emissions and science-based target setting
• Piloted our supplier engagement program by engaging with all key Westwing Collection suppliers, logistics carriers and a selection of third-party brand partners on the topic of carbon emissions
• Increased linehaul utilisation
• Moved primary injection hub closer to our logistics centre
• Piloting pick up and drop off locations for customer orders (planned for 2025)

Electrification:

• Monitor market for suitable options to transition owned/operated vehicle fleet (2024-2027 time horizon)

Sustainable procurement:

• Increased the use of recycled plastics in plastic packaging materials
• Inbound plastic bags and plastic used for the automatic bagging machine is now made with more than 60% recycled content
• Increased the use of 100% recycled paper in packaging materials

Resource efficiency measures:

• Replaced the main foams used in packaging with internally repurposed shredded cardboard
• Reduced single-use plastics in the logistics centre except for tape
• Replaced plastic packaging materials with paper alternatives for bags, ribbons, and tape
• Replaced non recyclable packaging with recycled plastic

Investment commitments

Investments have been allocated to energy optimisation in the logistics centre and renewable electricity procurement.

The implementation of the climate action plan did not require significant capital expenditures (CapEx) or operational expenditures (OpEx) in 2024. The implementation of Westwing's climate-related action plan may require CapEx and OpEx in the future.

Key performance indicators

Key performance indicators (KPIs) include tracking renewable energy use, Scope 1 and 2 GHG emission reductions, and the share of suppliers by spend with science-based targets.

Locked-in emissions and stranded assets

A qualitative assessment indicates no locked-in GHG emissions from key assets or products that could jeopardise emission reduction targets, as Westwing does not own fossil fuel-intensive infrastructure. Operations focus on reducing emissions through renewable energy sourcing, energy efficiency measures, and responsible sourcing practices, mitigating the risk of significant locked-in emissions. If relevant, Westwing will consider potential Scope 3 locked-in GHG emissions from the use of sold products if these emissions are found to contribute significantly to the total Scope 3 emissions footprint.

EU Taxonomy alignment

In 2024, Westwing's activities were not classified as sustainable under the EU Taxonomy, and the company had no CapEx investments in coal, oil, or gas-related activities. Additionally, no future investments in these areas are currently planned. The alignment of CapEx, OpEx, and revenues with taxonomy-aligned criteria is expected to remain unchanged in the long term.

Implementation preconditions

Westwing's ability to implement its climate-related actions depends on several key preconditions. The availability and scalability of decarbonisation technologies are crucial for reducing emissions across operations and the value chain. Additionally, successful implementation relies on strong alignment with suppliers and logistics partners to ensure that sustainability measures are adopted throughout the supply chain. Government regulations and incentives also play a significant role, as supportive policies can accelerate efforts, while stricter environmental requirements may increase compliance costs. Access to renewable energy infrastructure is essential, especially in regions where Westwing operates, as is the availability of financial resources to invest in decarbonisation technologies and energy-efficient processes. Lastly, consumer demand for sustainable products influences the pace at which Westwing can adapt its offerings and business models to meet climate goals.

Scope 1 and 2 GHG emission reduction target pathway

The efforts to date have already significantly contributed to meeting our science-based emissions reduction target. Specifically, the insourcing of several operational sites, the energy efficiency measures implemented and the introduction of renewable electricity have led to an approximate 64% reduction in Scope 1 and 2 emissions compared to the 2022 base year. This tracking process includes ongoing monitoring of emissions data and internal reporting to ensure accountability and transparency in achieving our targets. To further support the achievement of our GHG emissions reduction targets, we closely collaborate with our logistics centre landlord to evaluate available options such as the implementation of heat pumps to reduce emissions associated with heating at our logistic centre, as well as the potential expansion of on-site photovoltaic (PV) systems.

Graphical representation (tCO2eq):

Monitoring and review

Westwing monitors progress against its science-based emissions reduction targets to track the effectiveness of its actions and policies. This includes annual evaluations of Scope 1, 2, and 3 emissions reductions relative to the selected baselines, focusing on material impacts such as carbon emissions from supply chain, logistics, and own operations.

To track the effectiveness of measures related to material risks and opportunities, Westwing reviews the progress of planned mitigation actions, such as energy efficiency improvements and renewable electricity adoption. These reviews are data-driven, allowing us to assess alignment with our emissions reduction goals and identify areas requiring further action.

Policies related to climate change mitigation and adaptation

Sustainability Policy

Westwing has established a Sustainability Policy that addresses climate change mitigation and adaptation.

Scope:

• Covers all Westwing operations across geographies and value chain activities, with no exclusions

Key content and principles:

• Focuses on managing climate-related material impacts, risks, and opportunities (IROs), including:
  • Emissions from operations and logistics
  • Challenges in raw material availability
  • Cost implications of transitioning to lower-carbon production
  • Opportunities for cost savings through greater efficiencies
  • Increased customer appeal through more climate-friendly operations and practices
• Directly addresses climate change mitigation by prioritizing emissions reduction and promoting sustainable practices across operations
• Climate change adaptation is incorporated through resilience-building measures, including sourcing strategies and logistical adjustments to manage risks posed by climate impacts
• Energy efficiency improvements are pursued across operations, supported by increased sourcing of renewable energy and partnerships with sustainable energy providers
• The policy does not currently address additional climate-related areas beyond those explicitly mentioned

Governance and accountability:

• Approved by the Management Board
• Accountability rests with the Management Board, which ensures the policy is integrated into daily operations
• Corporate Sustainability team and other company experts handle day-to-day implementation
• Guidance from the Sustainability Steering Committee ensures alignment with internal goals

Alignment with international standards:

• Aligned with the Science Based Targets initiative (SBTi)
• Aligned with the Paris Agreement (1.5°C pathway)

Monitoring and implementation:

• Monitoring of climate commitments is conducted through a KPI system, with indicators tracked monthly, quarterly, or annually, as appropriate
• Annual assessments of GHG emissions are complemented by more frequent reviews of material sourcing, energy efficiency metrics, and progress on supplier engagement targets under the SBTi

Stakeholder engagement:

• The policy is shaped by stakeholder insights, including feedback from suppliers and industry experts during materiality assessments, as well as input from Westwing experts, benchmarking, and assessments of applicable regulations

Public availability:

• Accessible to affected stakeholders through Westwing's intranet and a digital tool, the "Policy Manager," which provides employees with compliance rules and corporate governance practices
• Also available on the corporate website

Actions and resources in relation to climate change policies

Westwing has established an action plan to address climate change, focusing on key decarbonisation levers including the use of renewable energy, energy efficiency measures, electrification of the owned and operated vehicle fleet, supply chain decarbonisation, changes in product portfolio, sustainable procurement of packaging materials, and resource efficiency measures.

Summary of Actions by Decarbonisation Lever

Use of Renewable Energy

Action 1: Source renewable energy across all operational sites

• Scope: Own operations (Scope 1 and 2)
• Time horizon: 2024–2030
• Expected outcome: Reduction in Scope 1 and 2 GHG emissions; reduced reliance on fossil fuel electricity sources
• Expected GHG emission reduction: 2,400 tCO2e
• Progress in 2024: Active engagement with logistics centre operators to collaboratively explore options for installing additional solar PVs at leased sites and to identify renewable energy sources for both heating and electricity beyond solar PV
• Related targets: To reduce absolute Scope 1 and 2 GHG emissions 75% by 2030 from a 2022 base year; to source 100% of overall energy used from renewable sources by 2027

Action 2: Purchase Renewable Electricity Certificates (RECs)

• Scope: Own operations (Scope 2)
• Time horizon: 2024–2030
• Expected outcome: Reduction in Scope 2 GHG emissions
• Progress in 2024: Exploration of options to cover remaining electricity consumption through the purchase of Renewable Energy Certificates (RECs) or Guarantees of Origin
• Related targets: To reduce absolute Scope 1 and 2 GHG emissions 75% by 2030 from a 2022 base year; to source 100% of overall energy used from renewable sources by 2027

Action 3: Transition to renewable heating sources across all operational sites

• Scope: Own operations (Scope 1)
• Time horizon: 2024–2027
• Expected outcome: Reduction in Scope 1 GHG emissions; reduced reliance on fossil fuel heating sources
• Expected GHG emission reduction: 2,600 tCO2e
• Progress in 2024: Conducted feasibility studies for the leased logistics centre in Poland to identify options for renewable heating transition
• Related targets: To reduce absolute Scope 1 and 2 GHG emissions 75% by 2030 from a 2022 base year; to source 100% of overall energy used from renewable sources by 2027

Energy Efficiency Measures

Action 4: Implement energy-efficient technologies and practices across operations

• Scope: Own operations (Scope 1 and 2, Logistics centre)
• Time horizon: 2024
• Expected outcome: Reduction in Scope 1 and 2 GHG emissions; reduction in overall energy consumption and expenses
• Achieved GHG emission reduction: 700 tCO2e
• Progress in 2024: Implementation of door seals and optimised charging patterns for forklift batteries
• Related targets: To reduce absolute Scope 1 and 2 GHG emissions 75% by 2030 from a 2022 base year; to source 100% of overall energy used from renewable sources by 2027

Changes in Product Portfolio

Action 5: Sourcing certified raw materials

• Scope: Upstream value chain (Scope 3)
• Expected outcome: Reduction in Scope 3 GHG emissions related to raw material consumption
• Expected GHG emission reduction: N/A
• Progress in 2024: Collaborated with suppliers to enhance sustainable sourcing practices

Action 6: Developing products with innovative recycled materials by collaborating with suppliers

• Scope: Upstream value chain (Scope 3)
• Expected outcome: Reduction in Scope 3 GHG emissions by reducing use of virgin material consumption
• Expected GHG emission reduction: N/A
• Progress in 2024: Launched innovative products made from recycled materials, including recycled plastic

Resources Allocated

The implementation of the climate action plan did not require significant capital expenditures (CapEx) or operational expenditures (OpEx) in 2024. The implementation of Westwing's climate-related action plan may require CapEx and OpEx in the future.

Specific investments mentioned:

• Investments have been allocated to energy optimisation in the logistics centre and renewable electricity procurement (amounts not specified)

Key Performance Indicators

Westwing tracks the following KPIs to monitor progress:

• Renewable energy use
• Scope 1 and 2 GHG emission reductions
• Share of suppliers by spend with science-based targets

Dependencies and Preconditions

Successful implementation depends on:

• Availability and scalability of decarbonisation technologies
• Strong alignment with suppliers and logistics partners
• Government regulations and incentives
• Access to renewable energy infrastructure
• Availability of financial resources to invest in decarbonisation technologies and energy-efficient processes
• Consumer demand for sustainable products

Additional Actions Not in Summary Table

• Electrification of owned and operated vehicle fleet: Westwing aims to transition its fleet to electric vehicles (timeline and resources not specified)
• Supply chain decarbonisation: Engaging suppliers to set science-based targets (linked to supplier engagement target: 80% of suppliers by spend to adopt science-based targets by 2027)
• Sustainable procurement of packaging materials: Action mentioned but not detailed in E1-3 section
• Optimisation of logistics operations: To minimise value chain emissions (specific actions not detailed)

Targets related to climate change mitigation and adaptation

Westwing Group SE has set three climate-related targets validated by the Science Based Targets initiative (SBTi), aligned with the 1.5°C pathway of the Paris Agreement. The targets cover emissions reduction, supplier engagement, and renewable energy sourcing.

Target 1: Absolute Scope 1 and 2 GHG Emissions Reduction

Target 2: Supplier Engagement (Scope 3)

Target 3: Renewable Energy Sourcing

Decarbonisation Pathway

Westwing's emissions reduction pathway shows:

• Base year 2022: 5.18k tCO2eq
• Reductions achieved: -2k tCO2eq from operational closures, -712 tCO2eq from logistics centre efficiencies
• Planned reductions: -2k tCO2eq from logistics centre renewable electricity, -71 tCO2eq from renewable electricity at other sites
• Target 2030: 1.04k tCO2eq

Approximately 64% reduction in Scope 1 and 2 emissions has been achieved compared to the 2022 base year through insourcing of operational sites, energy efficiency measures, and introduction of renewable electricity.

Key Decarbonisation Levers

• Use of renewable energy (expected reduction: 5,000 tCO2e)
• Energy efficiency measures (achieved reduction: 700 tCO2e)
• Electrification of owned and operated vehicle fleet (expected reduction: 120 tCO2e)
• Supply chain decarbonisation
• Changes in product portfolio
• Sustainable procurement of packaging materials
• Resource efficiency measures

Energy consumption and mix

Westwing's energy consumption for 2024 is presented below. The company reports total energy consumption of 6,941 MWh (2024), with renewable sources accounting for 9% of total consumption.

Energy consumption by source (2024)

Scope and methodology:
Westwing calculates energy consumption using the latest available data at the time of reporting. When the most recent data pertains to the prior year, adjustments are made to estimate values for the reporting year, accounting for significant changes such as warehouse space variations. Energy consumption is apportioned based on the share of space exclusively occupied by Westwing during the reporting period. Heating data received in cubic meters (m³) of natural gas is converted into megawatt-hours (MWh) using best-practice guidance. For electricity mix calculations, the methodology incorporates data on grid energy sources, supplier-specific information (where available), and green electricity supply contracts. Electricity generated and consumed from on-site solar panels is monitored through an automated system providing daily tracking in MWh.

Energy intensity:
Westwing does not operate in any high climate impact sectors and therefore does not publish energy intensity from high climate impact sectors. The company's 2024 net revenue was €444.3 million (per consolidated financial statements), yielding an implied energy intensity of approximately 15.6 MWh per million EUR revenue (6,941 MWh / 444.3 M€), though this metric is not formally disclosed by the company.

Gross Scopes 1, 2, 3 and Total GHG emissions

GHG emissions inventory (tCO2eq)

Westwing has calculated its carbon footprint for Scope 1, 2, and 3 emissions. The table below shows the breakdown of scope emissions for the reporting year and base year(s).

Financial statement reference: Annual Report (2024) – Note 5

Scope 1 and 2 GHG emissions – Methodology

Scope 1: Westwing calculates Scope 1 GHG emissions using emission factors provided by the UK Department for Environment, Food and Rural Affairs (DEFRA). The measurement methodology follows the average-data method, which utilizes activity data such as heating consumption from utility providers and fuel consumption from gas receipts. In cases where activity data is unavailable for the reporting period, historic data is used as the basis for estimation, adjusted for significant changes such as differences in the area size occupied during the current period.

Scope 2: Westwing calculates Scope 2 GHG emissions using both location-based and market-based methodologies. For location-based Scope 2 emissions, grid-average emission factors from reliable sources such as DEFRA and the International Energy Agency (IEA) are applied. The calculation is based on energy consumption data provided by utility providers for Westwing-occupied spaces, using the average-data method. For market-based Scope 2 emissions, renewable electricity contracts with suppliers and energy generated from Westwing's own solar PV installations are utilized. The calculation methodology follows the market-based method as outlined in the GHG Protocol, using supplier-specific emission factors and residual emission factors from DEFRA or the IEA for any electricity not covered by renewable energy contracts.

Biogenic emissions cannot be reported separately as the emission factor databases used do not differentiate between biogenic and non-biogenic emissions.

Scope 3 GHG emissions – Methodology and coverage

Westwing calculates and measures its Scope 3 GHG emissions in accordance with the GHG Protocol. The reporting boundary includes all indirect emissions arising from activities within the upstream and downstream value chain of Westwing Group and its entities. The following Scope 3 categories are included in the emissions inventory:

• Category 1: Purchased goods and services
• Category 4: Upstream transportation and distribution
• Category 11: Use of sold products
• Category 12: End-of-life treatment of sold products

The following Scope 3 categories have been excluded from the inventory as they represent a smaller proportion of total emissions, involve minimal financial expenditure for Westwing, and offer limited opportunities for the company to influence or reduce emissions:

• Category 2: Capital goods
• Category 3: Fuel- and energy-related activities (not included in Scope 1 and Scope 2)
• Category 5: Waste generated in operations
• Category 6: Business travel
• Category 7: Employee Commuting

The following Scope 3 categories have been excluded as they are not relevant to Westwing's business activities:

• Category 8: Upstream leased assets
• Category 9: Downstream transportation and distribution
• Category 13: Downstream leased assets
• Category 14: Franchises
• Category 15: Investments

Calculation approach by category:

• Category 1 (Purchased goods and services): Emissions are measured using a hybrid approach combining average-data and spend-data methodologies. For products and packaging, emissions are calculated using material composition and weight data provided by suppliers, when available. For purchased services, emissions are primarily estimated using spend data, as direct activity data is limited.
• Category 4 (Upstream transportation and distribution): Emissions are measured using activity data derived from average distances based on customer shipping information and carrier-specific hub locations, which are stored in the warehouse management system.
• Category 11 (Use of sold products): Emissions are estimated based on generic assumptions about customer behavior, product lifespan, and typical usage patterns. These assumptions are based on general industry data and consumer behaviour and differ between product categories. Indirect use-phase emissions are not included.
• Category 12 (End-of-life treatment of sold products): Emissions are estimated based on common disposal practices assumed for each product category, such as recycling for packaging materials, landfilling for non-recyclable items, and incineration for products that may not be recycled. These assumptions do not account for regional variations in disposal methods or infrastructure.

Emission factors: Various emissions factors are sourced from reputable databases such as DEFRA, EcoInvent, and ADEME, depending on the category.

Westwing uses a software tool to facilitate all GHG emission calculations.

Regulated emissions

The percentage of Scope 1 GHG emissions from regulated emission trading schemes is not applicable (n/a) for Westwing.

Biogenic CO2 emissions

Biogenic emissions cannot be reported separately as the emission factor databases used do not differentiate between biogenic and non-biogenic emissions.

Internal carbon pricing (E1-8)

Westwing does not apply any internal pricing schemes.

GHG removals and carbon credits (E1-7)

Westwing's focus with respect to climate change is on avoiding and reducing GHG emissions. In 2024, Westwing purchased 6,728 tCO2eq carbon credits outside the company's value chain, verified against quality standards and cancelled during the reporting period. These carbon credits were sourced from a mix of mitigation projects and removal projects using biogenic sinks. Westwing has not developed any projects within its own operations or contributed to any projects in its upstream or downstream value chain. The company does not plan to cancel any carbon credits in the future based on existing contractual agreements.

These credits do not contribute to Westwing's GHG emission reduction targets.

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

Phase-in exemption

As this is the first reporting year under the CSRD, Westwing is using phase-in provisions in accordance with Appendix C of ESRS 1 for the following disclosure:

• E1-9 Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Time horizons

Westwing has defined the following time horizons to align with its operational and strategic planning:

• Short term: 1–3 years, reflecting immediate supply chain needs
• Medium term: 3–10 years, aligning with typical supplier contract durations
• Long term: Up to 2050, considering infrastructure lifetimes

Physical risks

Physical risks were assessed using the SSP5-8.5 high-emission scenario. This scenario assumes continued reliance on fossil fuels and limited mitigation measures, resulting in a high-emission, high-temperature pathway. It includes a projected global temperature rise of 4°C or more by 2100, significant sea level rise of up to one meter, and increased frequency and severity of extreme weather events.

Under this scenario, an increased frequency of extreme weather events is assumed, posing risks to supply chains and logistics infrastructure for retail operations, particularly over the medium and long term. This necessitates potential investments in resilient infrastructure and diversified supplier networks.

Short term (1–3 years): Acute risks such as extreme weather events (e.g., storms and floods) were identified as key hazards due to their potential to disrupt logistics and supply chains.

Medium term (3–10 years): Chronic risks, such as water scarcity and heat stress, are expected to increase in relevance, alongside continuing acute risks.

Long term (up to 2050): Both chronic risks, such as prolonged droughts and soil degradation, and the compounded effects of frequent extreme weather events, impacting sourcing regions and logistics infrastructure.

The assessment highlighted risks in sourcing regions in Asia and Europe, particularly for areas likely to experience water stress or extreme weather events under the SSP5-8.5 scenario.

Transition risks and opportunities

Transition risks and opportunities were identified using the SSP1-2.6 low-emissions scenario. The analysis also drew on data from the International Energy Agency's Net Zero Emissions by 2050 scenario to assess the effect of potential regulatory trends, market developments, and technological innovation opportunities.

The SSP1-2.6 scenario describes a world where strong climate action drives transition to a low-carbon economy, with widespread adoption of clean technologies. The global temperature rise is limited to 1.5°C to 2°C above pre-industrial levels by 2100, with gradual warming. Sea level rise is projected to be between 0.3 to 0.6 meters, reducing the risk of severe coastal flooding.

This approach allowed Westwing to gauge its capacity to adopt low-carbon technologies and adjust product offerings to meet emerging sustainability standards, identifying both risks and opportunities linked to the shift toward a low-carbon economy.

Future refinement

As the company refines its approach to climate-related risks and opportunities, it may further integrate these considerations into financial planning processes.

Policies related to resource use and circular economy

Westwing has policies in place that address resource use and circular economy. The company references two specific policies: the Sustainability Policy and the Raw Material Sourcing Policy.

Sustainability Policy

Scope:

• Covers the entire company and its value chain, including upstream raw material sourcing, internal operations, and downstream suppliers and partners
• Includes standards for both Westwing Collection and broader supplier networks
• Encompasses all Westwing operations across geographic regions and value chain activities, covering both upstream suppliers and downstream partners without exclusions

Key content and principles:

• Focuses on sustainable sourcing, reducing reliance on virgin resources, and prioritising the use of renewable sources
• Enhances waste prevention and embeds circularity into Westwing's operations
• Promotes the use of recycled and renewable materials
• Encourages designs that enhance product longevity
• Aligned with the waste hierarchy: focuses on minimising waste through product durability, repairability, reuse, and recycling
• Prioritises waste prevention through the use of reclaimed materials, considering energy recovery as a secondary option and disposal only as a last resort
• Addresses the impact of supplying home and living products on people and the environment
• Promotes the integration of recycled and renewable inputs into product design and packaging

Governance and accountability:

• The Management Board is the most senior level accountable for implementation and directly responsible for embedding policy commitments into Westwing's operations
• The Corporate Sustainability team, along with other company experts, leads day-to-day implementation
• The Corporate Sustainability team is responsible for defining the sustainability strategy and reporting on relevant KPIs
• Benchmarking against industry best practices, assessment of relevant regulations and input from Westwing's internal experts and the Sustainability Steering Committee informed the policy's development

Links to international standards and frameworks:

• Paris Agreement
• United Nations Sustainable Development Goals
• Science-Based Targets initiative (SBTi)
• FSC (Forest Stewardship Council)
• PEFC
• GOTS (Global Organic Textile Standard)
• BCI (Better Cotton Initiative)
• Global Recycled Standard (GRS)
• REACH
• OEKO-TEX®

Monitoring and implementation:

• Monitoring of resource use and circular economy commitments is conducted through KPIs tracked at monthly or quarterly intervals
• Regular audits of Westwing Collection suppliers ensure adherence to sustainability standards under recognised frameworks like Higg FEM, OEKO-TEX® STeP, and amfori BEPI
• The Corporate Sustainability team reviews progress and adjusts policies and practices based on audit findings and stakeholder inputs, if and as necessary

Public availability:

• Policies are accessible via Westwing's intranet, Policy Manager, and corporate website

Raw Material Sourcing Policy

Scope:

• Covers the entire company and its value chain, including upstream raw material sourcing, internal operations, and downstream suppliers and partners
• Includes standards for both Westwing Collection and broader supplier networks

Key content and principles:

• Outlines commitments aimed at managing material impacts, risks and opportunities related to resource use and circular economy practices
• Focuses on sustainable sourcing
• Prioritises certified materials such as FSC-certified wood and GOTS-certified cotton

Governance and accountability:

• The Management Board is the most senior level accountable for implementation
• The Corporate Sustainability team leads day-to-day implementation

Public availability:

• Accessible via Westwing's intranet, Policy Manager, and corporate website

Actions and resources related to circular economy

Westwing is committed to improving resource efficiency by reducing resource consumption and increasing the sourcing of sustainable materials, particularly for its products and packaging. These efforts extend to Westwing Collection suppliers and logistics centre operations across all regions where Westwing operates.

Strategic Focus Areas

Westwing Collection

• Promotes sustainable materials by using recycled synthetic fabrics
• Actively exploring increased recycled plastic content in furniture items

Packaging Strategy

• Working towards 100% recyclable packaging
• Adheres to Extended Product Responsibility principles
• Shifting from virgin plastics to recycled alternatives
• Focus on enhancing recyclability and reducing single-use plastics

Product Lifespan and Waste Minimization

• Incorporates circular design principles where applicable
• Established a small-scale repair and restoration service within logistics centre for returned products
• Focus on premiumisation to enhance product durability

Collaboration

• Seeks to identify and collaborate with other businesses on innovative products integrating circular design principles and sustainable materials
• Participates in an informal industry group to exchange ideas and best practices with peers

Specific Actions

Goal: Promote product longevity and circular design

Value chain: Upstream/own operations

Scope and Coverage

The outlined actions cover all operation geographies unless stated otherwise. The identified key actions cover multiple stakeholder groups, including suppliers, employees, and customers. Suppliers are engaged through sustainable material requirements and packaging guidelines, employees are encouraged to integrate environmental considerations in decision-making, and customers benefit from products designed with circular principles, durability, and recyclability in mind.

Targets related to resource use and circular economy

Westwing has adopted voluntary targets aimed at addressing its material impacts, risks, and opportunities (IROs) related to resource use and the circular economy. The targets are absolute and account for various lifecycle stages such as production, use, and end-of-life, as well as biodiversity impacts. They focus on virgin renewable resources and select product lines, aligning with Westwing's commitment to sustainable sourcing.

Target overview

Westwing's targets include:

• Increasing the percentage of recycled materials in product manufacturing
• Reducing overall waste generation through recycling and reuse practices across the supply chain
• Minimizing the use of primary raw materials by prioritizing secondary and recycled inputs where feasible
• Improving product durability and repairability, extending product lifespans through circular design principles
• Increasing the proportion of recycled plastics in products
• Sourcing wood, cotton, and animal byproducts from certified sources to ensure responsible management of renewable resources
• Introducing recyclable, biodegradable, or compostable packaging
• Reusing, recovering, or recycling all packaging waste from Westwing's own sites
• Reducing virgin plastics in packaging
• Achieving fully recyclable packaging

These targets encompass both internal operations and the upstream and downstream segments of the value chain, promoting a holistic approach to resource efficiency and circularity.

Performance against these targets is tracked through specific KPIs, available in the Sustainability dashboard, and monitored quarterly by the Sustainability Steering Committee.

Target 1: Reduce the amount of plastic packaging used per item shipped by 40% by 2027 (logistics centre)

Target setting and validation

In setting these targets, the Corporate Sustainability team leveraged their expertise, performed benchmarking, and analyzed current and upcoming policies and regulations. While no formal scenario analysis was conducted, feedback received from stakeholders such as suppliers and customers during target implementation was considered. The proposed targets were reviewed by subject matter experts on resource use and circularity and refined by the Sustainability Steering Committee before presentation to the Supervisory Board.

The disclosed targets are grounded in scientific evidence of the global impacts of increasing waste and plastic pollution on marine ecosystems, wildlife, and human health. Although specific ecological thresholds were not considered, the targets are not externally validated (e.g., SBTi).

E5-4 – Resource Inflows

Westwing's upstream value chain resource inflows include essential materials such as wood, cotton, metal, and various other natural or synthetic materials. These materials are used in producing both Westwing Collection and third-party products. In our operations, material resource inflows encompass the packaging materials used at our logistics centre facilities for safely storing and shipping products to our customers such as paper, plastic, metal, and wood. In addition, Westwing's trade goods, including final products sourced from third-party suppliers for direct sale, are also part of our resource inflows. These trade goods primarily include home and living items such as furniture, decor, and textiles, which are procured and delivered to customers as part of our operations. Westwing considers packaging materials as a resource inflow which is material for the company.

Westwing's operational resource inflows include equipment used in warehousing and packaging processes. For warehousing this includes forklifts, pallet trucks, conveyor systems, and for packaging the automated packaging machine, paper cushioning packaging stations, and the waffle machine, which is used to produce cushioning material from packaging waste. Other equipment includes scanners, computers, pallet strapping and wrapping machines, parcel sorters and a welding machine. Water use is minimal and primarily limited to cleaning and facility maintenance.

In the upstream value chain, suppliers also utilise various machinery to produce Westwing Collection and third-party products. This machinery includes woodworking equipment such as saws, lathes, and computer numerical control (CNC) machines for shaping and assembling wooden furniture; textile machinery such as spinning, weaving, and knitting machines for processing cotton and other fabrics; metalworking machinery such as presses, cutters, and welders for creating metal components; and moulding and extrusion equipment for producing synthetic materials like plastics and acrylics. Other resource inflows include materials such as wood, which is primarily sourced for furniture and decor items; cotton, which is used in textiles and soft furnishings; metals such as steel and aluminium, commonly used for structural components and decor accents; synthetic materials like polyester and acrylic for upholstery and decor; as well as animal by-products such as leather and wool, utilized in furniture, textiles, and decorative items. The upstream value chain also has a much greater reliance on water for manufacturing processes essential to producing materials and finished goods. Water use in Westwing's operations is limited to activities like cleaning, facility maintenance, employee welfare (e.g., sanitation and hydration), and other minor operational needs.

Weight of Packaging

Data Quality and Methodology

The data provided comes from direct measurements and estimations are used in cases where the information is not available from the supplier. In this case, the weight is estimated using an average. These metrics are not validated by an external body other than the assurance provider.

Westwing aims to ensure that a significant part of its resource inflows with respect to packaging material are covered by the Forest Stewardship Council (FSC) and Blue Angel Certification. Adhering to these standards not only demonstrates our commitment to environmental stewardship and ethical sourcing but also enhances our brand reputation, fosters consumer trust, and supports our long-term sustainability goals. Resource inflow data is primarily derived from purchase order reports and Westwing's internal order management system (OMS), supplemented by estimations where necessary. These estimations are based on material handling processes in Westwing's logistics centre, where workers conduct weight-based assessments to generate proxy estimates when direct data is unavailable. In cases where reused and recycled materials may overlap, categorisation is based on primary usage to avoid double-counting.

Summary

Total resource inflows for direct operational activities during the reporting period amount to 2,959 tonnes. Of this, sustainably sourced biological materials (certified by FSC and Blue Angel) make up 93%. Secondary materials account for 1,583 kg [note: likely 1,583 tonnes based on context], representing 54% of resource inflows.

Resource outflows

Products and Materials

Westwing acknowledges the importance of designing products based on circular principles to improve resource efficiency and reduce waste. While the company does not currently offer products specifically defined as circular, considerations such as durability and material selection reflect circular principles in its product design. Westwing does not manufacture or produce the products it sells and does not currently collect data on product durability, repairability, or rates of recyclable content.

Westwing focuses on product durability through its premiumisation strategy, which prioritizes high-quality materials and craftsmanship. Additionally, the company is exploring options for warranties and repairability to ensure products remain functional and valued over time, reinforcing its commitment to longevity and reduced environmental impact.

Packaging Recyclability

During the reporting period, the recyclable content in Westwing Group's product packaging materials amounted to 98.6%, calculated using the total weight of packaging materials as the denominator. This metric is not validated by an external body other than the assurance provider.

Methodology/Assumptions:

• Recyclable packaging material includes:
  • The following plastics: LDPE, HDPE, PP, PE
  • All paper that is not covered in wax, foil or plastic
• Product packaging includes:
  • Packaging used at Westwing logistic centre
  • Westwing Collection inbound packaging (from supplier)
  • Third-party products packaging (from partners)

In terms of packaging, all materials used are reported to the relevant authorities to comply with the EU Extended Producer Responsibility scheme, which addresses end-of-life waste management.

The data disclosed under E5-5 is primarily derived from supplier reports on material content, supplemented by estimations based on the types of packaging materials used in Westwing's operations. In cases where supplier data is not available, assumptions are made by using available data as proxies. Specifically, it is assumed that products within the same category use similar packaging materials.

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

Phase-in exemption applied

As this is the first reporting year under the CSRD, Westwing Group SE is using phase-in provisions in accordance with Appendix C of ESRS 1 for E5-6 Anticipated financial effects from resource use and circular economy-related risks and opportunities.

No anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities are disclosed in this reporting period.

Waste

E5-5 Resource outflows / Waste

Although S1 and G1 have been assessed as material, certain specific Disclosure Requirements listed below were not deemed material, and not included in the reporting:

• E5-5 Resource outflows/ Waste

Waste is not reported as a material topic under ESRS E5-5 for Westwing Group SE. The company did not identify waste as material in its double materiality assessment and therefore does not provide quantitative disclosures on total waste generated, hazardous/non-hazardous split, or waste diverted from disposal versus directed to disposal.

Waste Management Approach (Qualitative)

Aligned with the waste hierarchy, the Sustainability Policy focuses on minimising waste through product durability, repairability, reuse, and recycling. In support of circular economy goals, the policy promotes the use of recycled and renewable materials and encourages designs that enhance product longevity. The policy also prioritises waste prevention through the use of reclaimed materials, considering energy recovery as a secondary option and disposal only as a last resort. Each stage of the waste hierarchy – prevention, reuse, recycling, recovery, and disposal – is embedded in this approach, with an emphasis on strategies like repair and refurbishment to minimise waste further.

Packaging Waste Actions

Goal: Reduction of waste, improved waste management, and increased resource efficiency

Actions taken in 2024 include:

• Foam elimination: Replaced all foams used in packaging with internally repurposed shredded cardboard (target: eliminate foam in packaging by 2025)
• Single-use plastics reduction: Reduced single-use plastics in the logistics centre packaging except for tape. For Westwing Collection replaced single-use plastic materials with paper alternatives for bags, ribbons, and tape (target: eliminate single-use plastics in packaging by 2030)
• Recycled paper increase: Cushioning paper switched from 100% virgin fibre paper to 100% recycled paper (target: achieve 100% recycled paper use in packaging by 2025)

Resource targets address reducing virgin plastics in packaging and achieving fully recyclable packaging, aligning with the broader goal of reducing environmental impacts in resource inflows and outflows.

Policies related to own workforce

Westwing manages its workforce through a combination of policies and a Code of Conduct that cover material impacts, risks and opportunities related to the workforce. These policies apply to all regions and all Westwing employees.

Human Rights Policy

Scope: All Westwing employees, all regions

Key content and principles:

• Reflects commitment to international frameworks including the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises
• Explicitly prohibits child labour, forced labour, and human trafficking
• Commits to ensuring fair wages, safe working conditions, and the right to collective bargaining
• Prohibits discrimination on grounds such as racial and ethnic origin, colour, sex, sexual orientation, gender identity, disability, age, religion, national extraction, political views and social origin
• Launched in 2024

Governance: The Management Board is the most senior level accountable for implementation. The Corporate Sustainability team, along with other company experts, leads day-to-day implementation.

Alignment with international standards: UN Guiding Principles on Business and Human Rights, International Bill of Human Rights, ILO core conventions, OECD Guidelines for Multinational Enterprises

Public availability: Corporate website

Monitoring: While the company does not actively monitor compliance with these policies, they track any reported incidents submitted through their whistleblower tool.

Sustainability Policy

Scope: All Westwing employees, all regions

Key content and principles:

• Outlines the company's dedication to fostering a high-performance culture
• Promotes diversity and inclusion
• Provides tailored learning and development opportunities
• Ensures a safe and healthy workplace
• Launched in 2024

Governance: The Management Board is the most senior level accountable for implementation. The Corporate Sustainability team leads day-to-day implementation.

Public availability: Corporate website

Environment, Health and Safety (EHS) Policy

Scope: All Westwing employees, all regions

Key content and principles:

• Outlines commitment to providing a safe and healthy working environment
• Focuses on identifying, assessing, and mitigating environmental, health, and safety risks
• Supports a zero-accident culture through regular safety training and EHS performance reviews at warehouses
• Implements health and safety measures at headquarters, in line with applicable laws and regulations
• Workforce supported by an internal health and safety management system

Governance: The Management Board is the most senior level accountable for implementation.

Public availability: Corporate website

Code of Conduct

Scope: All Westwing Group employees and all members of senior management must comply at all times

Key content and principles:

• Provides employees, suppliers and business partners with guidelines and operating instructions for legally correct, ethical and socially responsible behaviour
• Addresses anti-corruption and handling conflicts of interest
• Ensures a safe, fair working environment
• Upholds employees' rights to form or join trade unions and engage in collective bargaining without fear of retaliation
• Prohibits discrimination

Governance: VP Legal reports on compliance ratios to the Management Board and submits quarterly reports to the Supervisory Board's Audit Committee.

Public availability: Publicly available on Westwing Group SE's corporate website (ir.westwing.com, in the Corporate Governance/Compliance section)

Monitoring: All Westwing staff are required to read the Code of Conduct. White collar workers must take a final test in the digital Policy Manager to demonstrate what they have learned. This is monitored and a report is submitted to management. Blue-collar workers at Westwing Germany receive personal training and access to the guidelines. The Legal department tracks whether final tests have been taken.

Anti-corruption Policy

Scope: All Westwing staff

Key content and principles:

• Summarizes binding rules developed for employees
• Goes into greater detail than the Code of Conduct
• Zero-tolerance policy on bribery
• Forbids making improper payments and accepting inappropriate gifts or incentives from third parties
• Introduces limits on the value of gifts and invitations that can be accepted
• Regularly reviewed and adapted

Governance: VP Legal reports on compliance to the Management Board and submits quarterly reports to the Supervisory Board's Audit Committee.

Public availability: Publicly available from the Corporate Governance/Compliance/Anti-corruption Policy section of Westwing Group SE's corporate website (ir.westwing.com)

Monitoring: All Westwing staff are required to read the Anti-corruption Policy. White collar workers must take a final test in the digital Policy Manager. This is monitored and a report is submitted to management. Blue-collar workers at Westwing Germany receive personal training and access to the guidelines.

Other Company Policies

Westwing has additional corporate guidelines that must be observed by both management and staff:

• Two-person principle policy for entering into contracts or placing orders
• IT/information security policies covering data protection, data security, and application usage. All white-collar staff are obliged to take information security training and complete a final test in the digital Policy Manager.
• Capital Markets Compliance Policy explaining capital market law obligations, prohibition on insider dealing and unlawful disclosure of inside information
• Anti-money Laundering Policy ensuring compliance with the German Anti-money Laundering Act (Geldwäschegesetz – GwG)
• Confidentiality Policy providing an overview of key corporate measures for ensuring confidentiality

Public availability (other policies): Staff can access these policies on the Company's intranet and via the digital Policy Manager tool.

Policy Development Process

Development informed by: Benchmarking against industry best practices, assessment of relevant regulations, input from Westwing's internal experts and the Sustainability Steering Committee

Grievance Mechanisms

Westwing has introduced a whistleblower tool that allows employees and third parties to submit tip-offs about potential unlawful activity in a protected manner. The tool complies with the recommendation in section A.4 of the 2022 German Corporate Governance Code and with the Whistleblower Directive. The whistleblower tool is publicly available from the Corporate Governance/Compliance/Open Whistleblower Channel section of Westwing Group SE's corporate website (ir.westwing.com).

Taking action on material impacts on own workforce

Material negative and positive impacts on the workforce

In situations where material impacts may arise and adversely affect employees, measures are implemented to identify, prevent, and mitigate these potential negative impacts. To date, Westwing has not had to take action to provide or enable remedy in relation to an actual material impact.

Initiatives to deliver positive impacts for the workforce include:

• Flexible work arrangements
• Paid time off
• Wellbeing initiatives
• Childcare support
• Training and development programs
• Mentorship
• Leadership development programs
• Employee recognition programs

These initiatives address the key material impacts identified, focusing on employees' health, safety, and overall well-being. During the reporting period, Westwing has advanced its wellness and work-life balance initiatives, including workshops and activities focused on various health and safety aspects in its logistics centre, with specific targets set for improving employee engagement and health.

Summary of actions

In 2024, no actual material negative impacts were identified, hence no actions were needed to remedy their effects. There are no new actions planned at the moment, but many ongoing actions will continue in 2025. The implementation of Westwing's action plan does not require significant OpEx or CapEx.

Goal: Ensure the health, safety and wellbeing of employees

Value chain: Own Operations

Tracking and assessing effectiveness

Westwing tracks and assesses the effectiveness of these actions and initiatives through various methods:

• Feedback mechanisms, such as regular surveys conducted on a per-need basis
• Key performance indicators (KPIs), such as employee satisfaction rates (consistently remain above 80%)
• Internal audits
• External performance ratings
• Benchmarking against industry standards
• Feedback from stakeholders and grievance mechanisms
• Metrics such as decreases in turnover rates and improved satisfaction scores

Processes for identifying actions and managing impacts

Westwing follows a structured process to determine necessary and appropriate actions in response to actual or potential negative impacts. This process includes:

• Prioritisation and evaluation
• Action planning
• Implementation
• Monitoring
• Continuous improvement

Various feedback mechanisms are used to gather information on workforce concerns, including regular surveys, direct communication channels, the elected SE Consultation Body, and local trade unions.

Managing material risks and opportunities

Westwing discloses risks related to workforce dependencies, such as potential disruption to business operations caused by significant employee turnover or a lack of skills or training. To manage and mitigate material risks, the company:

• Improves working conditions through regular assessments and upgrades
• Maintains employee feedback channels
• Conducts employee surveys
• Monitors KPIs such as turnover rates and sickness rates

Addressing negative impacts from business practices

Westwing monitors its practices to prevent contributions to material negative impacts on the workforce through surveys, audits, and assessments. Policies are in place to uphold fair labour standards and protect workers' rights. Open communication channels allow employees to report concerns anonymously.

Westwing does not have specific measures in place to ensure that its practices in relation to procurement, sales, or data use do not cause or contribute to material negative impacts on its own workforce. However, its overall governance framework, policies, and reporting mechanisms are designed to identify and address potential impacts if and where they arise.

Resources allocated for workforce management

A dedicated budget is allocated for health and safety programs and employee wellbeing initiatives (specific amounts not disclosed). Investments in training and development enable employees to enhance their skills and performance.

Employees responsible for monitoring and addressing workforce impacts include:

• P&C team
• Senior management

Westwing tracks and reports on the outcomes of its training and wellbeing initiatives, such as the number of training sessions delivered, but is not yet able to track the actual outcomes.

Targets related to own workforce

Westwing has set two targets related to managing material risks and opportunities within its workforce. These targets were developed based on benchmarking and taking into consideration the employee responses received during Westwing's materiality assessment. The Chief People Officer (CPO) was consulted to refine them, and final targets were reviewed and approved by the Executive Team, the Management Board, and endorsed by the Supervisory Board.

Performance against these targets is tracked through specific KPIs available in the Sustainability dashboard and monitored quarterly by the Sustainability Steering Committee.

Target 1: Maintain Westwing employee satisfaction rate above 80%

Target 2

The excerpt mentions that Westwing has set "two targets" related to workforce, but only Target 1 (employee satisfaction) is fully detailed in the provided excerpts. The second target is referenced but not disclosed in the available text.

Characteristics of the undertaking's employees

Total headcount and FTE

Current period (2024):

• Full-time equivalent employees (FTE): 1,291
• Total headcount: 1,392

Prior year (2023):

• Full-time equivalent employees (FTE): 1,614
• Total headcount: Not disclosed in prior year terms

Headcount by gender

Headcount by country/region

Countries with at least 50 employees representing at least 10% of total:

Employees by contract type, broken down by gender (FTE)

Employees by contract type, broken down by region (FTE)

Employee turnover

Methodology note

The metrics are based on end-of-year values. The total number of employees disclosed in the financial statements is 1,291 FTE, while the headcount reported in the sustainability statement is 1,392. The financial statement figure is based on full-time equivalents (FTE). Full-time equivalent is calculated by standardising employees' total working hours to a full-time workload. Employee turnover is calculated as the voluntary number of employees who left the company during the reporting period divided by the average number of employees (headcount) in the same period.

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

Scope and Definition

Westwing's own workforce includes self-employed individuals (freelancers working on specific projects or tasks) and third-party workers provided by employment agencies (contractors and temporary workers), in addition to employees.

Characteristics and Exposure

Through employee feedback surveys, regular consultations with the Westwing Group SE Consultation Body (SE consultation body), and expert assessments of working conditions, it has been identified that logistics centre workers engaged in more physically demanding tasks and temporary roles may face greater exposure to risks compared to other employee groups. This higher exposure is attributed to the specific context of warehouse environments, which involve physical labour and repetitive tasks.

Benefits and Access

Benefits such as partnerships with mental health providers and other provisions are more accessible to full-time employees and those on long-term contracts compared to temporary workers or contractors, reflecting variations in how these initiatives are experienced.

Quantitative Data

No specific headcount numbers, FTE counts, or breakdowns by type (contractor, agency, self-employed) of non-employee workers are disclosed in the sustainability statement.

Collective bargaining coverage and social dialogue

S1-8 (Collective bargaining coverage and social dialogue) has been assessed as not material and is therefore not disclosed in the sustainability statement.

The company's Code of Conduct upholds employees' rights to form or join trade unions and engage in collective bargaining without fear of retaliation, ensuring full respect for labour rights in compliance with local laws. The company engages with the SE consultation body and worker representatives as part of its regular stakeholder engagement.

No quantitative metrics on collective bargaining coverage or percentage of employees covered by workers' representatives are provided.

Diversity metrics

Disclosure status

S1-9 Diversity metrics has been assessed as not material and is therefore not covered in the sustainability statement.

Board composition

While S1-9 is excluded from reporting, the following governance information is disclosed:

Management Board: Currently all-male.

Supervisory Board: 40% female representation, with an average ratio of 3:2 (female to male). The Supervisory Board comprises 5 members total (4 of whom are deemed independent).

No quantitative age band distribution or detailed diversity metrics for the total workforce are provided.

Adequate wages

Disclosure status: Not disclosed

Westwing Group SE has explicitly stated that S1-10 Adequate wages was assessed as not material and is therefore not included in the reporting.

The sustainability statement notes:

"Although S1 and G1 have been assessed as material, certain specific Disclosure Requirements listed below were not deemed material, and not included in the reporting: [...] S1-10 Adequate wages"

Minimum wage compliance mentioned

While S1-10 is not reported, the company briefly states in the context of remuneration and employment conditions:

"Westwing compensates its employees with wages that meet or exceed national minimum wage standards, with all relevant employment terms clearly outlined in their contracts."

This statement refers only to national minimum wage standards, not living wage benchmarks. No living wage assessment, benchmark, coverage metrics, or targets are disclosed.

Social protection

S1-11 (Social protection) was assessed by Westwing Group SE but not deemed material and therefore not included in the reporting.

No data on the percentage of employees covered by social protection against loss of income from major life events (sickness, unemployment, employment injury, parental leave, retirement) has been disclosed.

The company notes that employees are entitled to allowances for health insurance and retirement benefits. Specifically, for Management Board members, Westwing pays half of the maximum contribution to the statutory pension insurance plan each month, plus half of their private health and long-term care insurance premiums, but no more than the maximum employer contribution payable in the case of an obligation under statutory health and long-term care insurance programmes. However, no quantitative data on coverage percentages for the broader employee population is provided.

Health and safety metrics

Westwing's workforce is supported by an internal health and safety management system that covers 100% of employees.

2024 Health and Safety Performance

Methodology:

• LTIFR: (Number of lost time injuries in the reporting period) × 1,000,000 / Total hours worked in the reporting period
• Workplace accident rate: (Number of workplace accidents) × 1,000,000 / Total hours worked in the reporting period
• Working hours were estimated based on the number of FTEs per month. For simplicity, an average of 30 days per month was assumed.
• Recordable work-related injury or ill health is defined as that which results in: (i) death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness; or (ii) significant injury or ill health diagnosed by a physician or other licensed healthcare professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.

Scope limitation: Westwing is using phase-in provisions for S1-14 data points related to non-employees (contractors) in this first reporting year under CSRD.

Work-life balance metrics

Westwing mentions flexible work arrangements, paid time off, wellbeing initiatives, and childcare support as part of its workforce initiatives. The company references parental leave in the context of equity compensation programs, noting that vesting dates for share-based payment programs would be postponed in the case of parental leave or other time off.

However, no specific metrics are disclosed for ESRS S1-15, including:

• Percentage of employees entitled to family-related leave (maternity/paternity/parental/family care)
• Percentage of entitled employees who took family-related leave (by gender)
• Return-to-work rate after parental leave (by gender)

No quantitative work-life balance metrics are provided in the sustainability statement.

Compensation metrics (ESRS S1-16)

Pay gap

Not disclosed.

Remuneration ratio

Not disclosed.

Methodology

Westwing Group SE has opted to phase in ESRS S1-16 (Remuneration metrics: pay gap and total remuneration) in accordance with Appendix C of ESRS 1 for the first reporting year under CSRD. The company explicitly lists S1-16 among the disclosures for which it is using phase-in provisions (page 81).

Incidents, complaints and severe human rights impacts

Incidents and complaints

In 2024, Westwing received a total of nine cases through its whistleblower tool, seven of which were related to discrimination and harassment.

Total cases received through whistleblower tool: 9 Cases related to discrimination and harassment: 7

Severe human rights impacts

In the reporting year, Westwing has not encountered any severe human rights incidents.

For workers in the value chain, no severe human rights incidents were reported in 2024.

Fines, penalties and compensation

There were no fines, penalties, or compensation for damages associated with these cases in 2024.

Policies related to value chain workers

Westwing manages material impacts, risks, and opportunities related to value chain workers through multiple policies and codes of conduct. During the reporting year, there were no significant changes in the policies for value chain workers; however, the Sustainability Policy and the Human Rights Policy were newly drafted. These policies and Codes of Conduct apply to workers in the upstream and downstream value chain, including brand partners, subcontractors, and other suppliers. There are no exclusions in terms of geographies or stakeholder groups.

Sustainability Policy

Scope:

• Applies to workers in the upstream and downstream value chain, including brand partners, subcontractors, and other suppliers
• Accounts for vulnerable groups, such as migrant and young workers, with safeguards to uphold their rights and welfare
• No exclusions in terms of geographies or stakeholder groups

Governance:

• The Management Board is the most senior level accountable for implementation
• The Corporate Sustainability team, along with other company experts, leads day-to-day implementation
• Development informed by benchmarking against industry best practices, assessment of applicable regulations, input from Westwing's internal experts, and the Sustainability Steering Committee

Key content/principles:

• Contains specific objectives related to the fair and ethical treatment of workers in the value chain, promoting social responsibility, human rights, and improving labour conditions

Public availability:

• Accessible through Westwing's corporate website
• Can be made part of contractual agreements and/or shared with relevant stakeholders during face-to-face meetings
• Translations provided where necessary

Link to international standards:

• Guided by and reflects the UN Guiding Principles on Business and Human Rights
• The ILO Declaration on Fundamental Principles and Rights at Work
• The OECD Guidelines for Multinational Enterprises
• The International Bill of Rights, which includes the Universal Declaration of Human Rights and its two covenants
• UN Global Compact membership

Human Rights Policy

Scope:

• Applies to workers in the upstream and downstream value chain, including brand partners, subcontractors, and other suppliers
• Accounts for vulnerable groups, such as migrant and young workers
• No exclusions in terms of geographies or stakeholder groups

Governance:

• The Management Board is the most senior level accountable for implementation
• The Corporate Sustainability team, along with other company experts, leads day-to-day implementation
• Development informed by benchmarking against industry best practices, assessment of applicable regulations, input from Westwing's internal experts, and the Sustainability Steering Committee

Key content/principles:

• Contains specific objectives related to the fair and ethical treatment of workers in the value chain, promoting social responsibility, human rights, and improving labour conditions
• Explicitly addresses trafficking in human beings, forced labour, compulsory labour, and child labour, prohibiting these practices across the workforce and wider value chain

Public availability:

• Accessible through Westwing's corporate website
• Can be made part of contractual agreements and/or shared with relevant stakeholders during face-to-face meetings
• Translations provided where necessary

Link to international standards:

• Guided by and reflects the UN Guiding Principles on Business and Human Rights
• The ILO Declaration on Fundamental Principles and Rights at Work
• The OECD Guidelines for Multinational Enterprises
• The International Bill of Rights, which includes the Universal Declaration of Human Rights and its two covenants

Monitoring:

• To date, no cases of non-respect involving value chain workers under the UN Guiding Principles on Business and Human Rights, the ILO Declaration, or the OECD Guidelines have been reported in the upstream or downstream value chain

Environment, Health, and Safety (EHS) Policy

Scope:

• Applies to workers in the upstream and downstream value chain, including brand partners, subcontractors, and other suppliers
• Accounts for vulnerable groups, such as migrant and young workers
• No exclusions in terms of geographies or stakeholder groups

Governance:

• The Management Board is the most senior level accountable for implementation
• The Corporate Sustainability team, along with other company experts, leads day-to-day implementation

Key content/principles:

• Contains specific objectives related to the fair and ethical treatment of workers in the value chain, promoting social responsibility, human rights, and improving labour conditions

Public availability:

• Accessible through Westwing's corporate website
• Can be made part of contractual agreements and/or shared with relevant stakeholders during face-to-face meetings

Link to international standards:

• Guided by and reflects the UN Guiding Principles on Business and Human Rights
• The ILO Declaration on Fundamental Principles and Rights at Work
• The OECD Guidelines for Multinational Enterprises
• The International Bill of Rights

Business Partner Code of Conduct

Scope:

• Applies to any company, organisation, entity or person that sells or seeks to sell any kind of product or service to Westwing or any individual or organisation that works or transacts with Westwing, including consultants, agents, business associates, contractors, service providers, who work for and on behalf of, or otherwise transact with, Westwing
• Excludes Private Label Suppliers who are covered by the Private Label Supplier Code of Conduct
• Covers workers in third-party brands employed by companies producing products sold alongside the Westwing Collection
• Covers upstream workers in the supply chain (non-Tier 1) involved in activities like extraction or processing of raw materials (e.g., cotton, wood)
• Covers downstream workers employed by logistics partners responsible for delivering Westwing products to customers
• Accounts for vulnerable groups, such as migrant and young workers

Governance:

• The Management Board is the most senior level accountable for implementation
• Westwing's monitoring is centred on regular audits of private-label suppliers
• For all other policies and codes of conduct, any concerns related to policy adherence may be reviewed if reported, but there is no formal tracking of adherence across all policies

Key content/principles:

• Reflects commitments to prohibit trafficking in human beings, forced labour, compulsory labour, and child labour
• Supports ethical practices for value chain workers

Public availability:

• Publicly available on Westwing Group SE's corporate website (ir.westwing.com, in the Corporate Governance/Compliance section)
• Can be referenced through contractual agreements or presented in in-person meetings and onboarding sessions
• Accessible to all stakeholders through Westwing's corporate website

Link to international standards:

• Alignment with ILO standards
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• UN Global Compact

Monitoring:

• Whistleblower tool can be used for reporting alleged incompliance of brand partners and all other suppliers and service providers

Private Label Supplier Code of Conduct

Scope:

• Applies to all Private Label suppliers across the value chain
• Governs workers employed by Tier 1 manufacturers producing the Westwing Collection
• Accounts for vulnerable groups such as migrant workers, young workers and women who may face higher risks of negative impacts
• Focus on regions in Asia (particularly China and India) and sectors such as textiles, furniture, and decor, and key commodities such as cotton and wood

Governance:

• The Management Board is the most senior level accountable for implementation
• Quality and Sustainability Team, headed by the Director of Quality and Sustainability, and the Buying Teams under the VP of Buying share responsibility for engagement
• The Corporate Sustainability team, led by the Director of Corporate Sustainability, supports these efforts

Key content/principles:

• Explicitly addresses trafficking in human beings, forced labour, compulsory labour, and child labour, prohibiting these practices
• Supports worker representation and unions
• Focuses on fair wages, safe working environments, and regulatory compliance

Public availability:

• Publicly available on Westwing Group SE's corporate website (ir.westwing.com, in the Corporate Governance/Compliance section)
• Referenced in contractual agreements and communicated during supplier onboarding
• Can be presented in in-person meetings

Link to international standards:

• Alignment with ILO standards
• UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises
• International Bill of Rights
• amfori membership supports industry discourse on ethical trade and human rights

Monitoring:

• Workers are regularly audited to mitigate risks like child labour, forced labour, and substandard working conditions
• Compliance monitored through regular social and environmental audits, risk assessments, and corrective action plans
• Auditing includes both Westwing's own internal teams and third-party audits when necessary
• Selected worker interviews conducted periodically as part of externally led audits and Westwing's internal social assessment protocol
• Supplier visits take place regularly as part of supplier management
• Quarterly supplier calls and regular supplier visits
• Capacity-building among key and strategic suppliers through training programs provided by amfori
• Encouragement of supplier participation in local programs such as amfori's Speak for Change
• Whistleblower tool available for workers to raise concerns
• To date, no cases of non-respect involving value chain workers under the UN Guiding Principles on Business and Human Rights, the ILO Declaration, or the OECD Guidelines have been reported

Taking action on material impacts on value chain workers

Scope and approach

Westwing's actions focus on Westwing Collection Tier 1 suppliers (upstream value chain, primarily in Europe and Asia). The company has limited direct involvement with workers of other value chain partners (brand partners, service providers), relying primarily on the Business Partner Code of Conduct communicated during onboarding.

Actions and programmes

1. Engage with key and strategic suppliers to establish social management systems

• Description: Establish social management systems (SMS) at supplier facilities
• Scope: Key and strategic Westwing Collection suppliers (upstream value chain)
• Coverage: 10% of purchase order value; suppliers from China, India, and Lithuania
• Time horizon: 2024–2028
• Progress in 2024: Suppliers received SMS implementation handbook, toolkit, and self-assessment checklist from World Bank Corporation. Initial training calls conducted with regular follow-ups on milestones
• Expected outcome: Enhanced processes to ensure compliance with social standards and health and safety protocols
• Related target: 50% of Westwing Collection suppliers by purchase order volume to have established social management systems by 2028
• Impact/risk addressed: Risk / Potential positive impact
• Resources: Not quantified; implementation supported by Buying and Sustainability teams

2. Auditing suppliers on social topics, developing corrective action plans, and identifying key areas for improvement

• Description: Regular social audits, corrective action plans, and targeted supplier training programmes
• Scope: Westwing Collection suppliers in all geographies (upstream value chain)
• Time horizon: Ongoing since 2022
• Progress in 2024: 100% of non-EU suppliers have undergone external social audits since 2022. In 2024, most key and strategic EU suppliers were audited either through external audit reports or in-house audits. Third-party social audit reports collected from complementary suppliers
• Expected outcome: Ensure compliance with social standards including human rights
• Related target: 100% of Westwing Collection suppliers to be evaluated regularly on social topics by 2025
• Impact/risk addressed: Risk
• Resources: Auditing conducted by internal teams (Quality and Sustainability Team, Buying Teams) and third-party auditors; membership in amfori supports industry guidance

3. Engage with key and strategic suppliers to take part in programs to improve working conditions

• Description: Supplier participation in 'Speak for Change' initiative to improve working conditions by increasing worker involvement
• Scope: Key and strategic Westwing Collection suppliers (upstream value chain)
• Coverage: Five key and strategic suppliers in India and Vietnam audited under BSCI
• Time horizon: 2024–2028
• Progress in 2024: Suppliers actively participating in 'Speak for Change' initiative. Deployment guides, posters, and flyers provided; meetings held to guide suppliers through the process
• Expected outcome: Improve working conditions by increasing worker involvement
• Related target: 50% of Westwing Collection suppliers by POV to establish programs to measure and improve working conditions by 2028
• Impact/risk addressed: Potential positive impact
• Resources: Leverages amfori membership; coordination by Corporate Sustainability team and Buying Teams

4. Participation of key and strategic suppliers in the amfori training academy

• Description: Suppliers encouraged to participate in amfori Academy training on social topics
• Scope: Key and strategic Westwing Collection suppliers (upstream value chain)
• Time horizon: 2024–2028
• Progress in 2024: Suppliers encouraged and supported to participate in at least one amfori Academy training session
• Expected outcome: Enhanced supplier knowledge of social standards
• Related target: 50% of Westwing Collection suppliers by POV to establish programs to measure and improve working conditions by 2028
• Impact/risk addressed: Potential positive impact
• Resources: Supported through amfori membership

5. Acceptance of Westwing's Code of Conduct by all permanent brand partners and third-party suppliers (TPS)

• Description: All brand partners and third-party suppliers accept Westwing's Business Partner Code of Conduct
• Scope: All third-party suppliers/brand partners (upstream value chain)
• Time horizon: 2023–2027
• Progress in 2024: All permanent brand partners accepted Westwing CoC; process ongoing for non-permanent brand partners
• Expected outcome: Enhanced compliance with Westwing's Code of Conduct
• Related target: All third-party brands to be aligned with Business Partner CoC by 2027
• Impact/risk addressed: Risk
• Resources: Not quantified; communicated during onboarding

6. Certified material sourcing for raw material production workers

• Description: Prioritise sourcing certified materials (BCI cotton, RWS, European Flax™, FSC-certified materials) to support responsible practices at source
• Scope: Raw material production workers for Westwing Collection suppliers (upstream value chain)
• Time horizon: Not specified
• Expected outcome: Mitigate risks for workers involved in raw material production
• Impact/risk addressed: Risk mitigation
• Resources: Not quantified

Resource allocation and responsibility

Teams responsible:

• Quality and Sustainability Team (Director of Quality and Sustainability)
• Buying Teams (VP of Buying)
• Corporate Sustainability team (Director of Corporate Sustainability)

Financial resources: In 2024, implementation did not require significant CapEx or OpEx. Future implementation may require additional resources.

Non-financial resources:

• Capacity-building activities for relevant employees including training on social and environmental requirements
• amfori membership for industry guidance and training
• Participation in multi-stakeholder initiatives

Tracking effectiveness

Effectiveness tracked through:

• Audits: Internal and external social audits, follow-up audits to assess corrective action resolution
• KPIs: Social management systems establishment, audit outcomes, working conditions improvements, reduced non-compliance
• Supplier feedback: Regular engagement and performance reviews
• Grievance mechanisms: Whistleblower tool accessible to all value chain workers (publicly available, confidential/anonymous option)

Comparisons made between current and previous audit results to assess progress.

Key dependencies and preconditions

Implementation depends on:

• Supplier cooperation: As a relatively small player without owned manufacturing, Westwing's influence is limited by business volume
• Supplier prioritization: Suppliers often prioritise larger clients
• Local labour laws alignment: Effectiveness varies by region
• Negotiating power: Limited within supply chain

Links to policies

Actions support:

• Sustainability Policy
• Human Rights Policy
• Environment, Health, and Safety (EHS) Policy
• Business Partner Code of Conduct
• Private Label Supplier Code of Conduct
• Alignment with UN Guiding Principles on Business and Human Rights, ILO Declaration, OECD Guidelines

Remediation process

Whistleblower tool available to all value chain workers (see G1-1 for details). No negative impacts reported in 2024. If negative impacts confirmed:

• Investigation of root causes
• Assignment of responsibility
• Corrective actions implementation
• Preventative measures
• Evaluation through compliance and social audits

Severe human rights incidents

No severe human rights incidents reported in 2024.

Targets related to value chain workers

Westwing has established four time-bound and outcome-oriented targets aimed at addressing material impacts, risks and opportunities related to value chain workers of its Tier 1 Westwing Collection suppliers.

Target 1: 100% of Westwing Collection suppliers to be evaluated regularly on social topics by 2025

Target 2: 50% of Westwing Collection suppliers by POV to have established social management systems by 2028

Note: The document states that four time-bound targets were established, but only two targets are detailed in the provided excerpts.

Policies related to consumers and end-users

Westwing's consumer-related policies address key impacts, risks and opportunities such as promoting sustainable lifestyles through responsible consumption and clear sustainability information, strengthening market differentiation and customer appeal through privacy-respecting services and high customer service standards, and managing impacts as well as reputational, cost, and legal risks tied to product quality, reliability, and safety.

Scope: These policies apply to all regions and Westwing employees. Some policies are relevant to consumer and end-user groups and take into consideration vulnerable groups as they address key areas of interest for consumers such as product safety, privacy, responsible marketing, inclusivity. They apply in general across all Westwing entities, with no geographical exclusions, and it is expected that Westwing suppliers and business partners also adhere to similar principles as those underpinning our policies.

Governance and oversight: The Management Board holds the highest level of accountability for implementing Westwing's policies and Code of Conduct, ensuring these commitments are effectively integrated into operations. The Corporate Sustainability team, alongside other company experts, leads the day-to-day implementation of sustainability-related policies.

Policy development: The development of sustainability-related policies is informed by benchmarking against industry best practices, assessment of applicable regulations, input from internal experts, stakeholder views expressed during materiality assessment, and guidance from the Sustainability Steering Committee.

Public availability: Westwing's policies and handling guidelines are published on the intranet for internal stakeholders. Additionally, relevant policies are embedded in the internal Policy Manager. This system ensures that employees review and complete quizzes on key policies, thereby enhancing comprehension and accountability. Some policies are also accessible to stakeholders through the corporate website.

Monitoring: Adherence to policies is individually monitored when concerns are identified internally or reported through external channels, including customer service, social media, and the whistleblower tool. For the Information Security Policy, data protection training is provided through new starter onboarding and reinforced with ongoing initiatives such as security awareness campaigns and phishing simulations.

Periodic review: Policies are periodically reviewed to ensure alignment with new regulations, support continuous improvement, and address business needs. During the reporting year, the sustainability policy was newly drafted, and the Human Rights Policy was adopted.

Sustainability Policy

Content: This policy extends to consumers and end-users by outlining Westwing's commitment to their health, safety, privacy, and accessibility of products and services.

Responsible Marketing and Communication Policy

Content: Prevents misleading advertising and regulates marketing to vulnerable groups, including children. This policy aims to ensure that Westwing's marketing practices are ethical, transparent, and aligned with consumer protection standards.

Product Safety Policy (GPSR Policy)

Content: Outlines our commitment and guidelines for ensuring that products sold to our customers meet safety standards and regulations to protect consumers. It includes product safety risk assessment, internal procedures for monitoring, testing and quality control. Additionally, it covers mechanisms to react to potential incidents and corrective actions for defective products.

Human Rights Policy

Content: Emphasises non-discrimination, privacy, and product safety, ensuring that all products meet strict safety standards and that information is transparent and accessible.

Link to international standards: This policy is aligned among others with the UN Guiding Principles on Business and Human Rights, the International Covenant on Civil and Political Rights, and the OECD Guidelines for Multinational Enterprises, and is designed to protect the rights of consumers and end-users through robust processes and mechanisms.

Remediation: To safeguard human rights, remediation measures shall be implemented in the event of violations. Westwing addresses human rights concerns primarily through reports received from consumers and end-users via feedback channels, as the company does not conduct independent monitoring or assessments.

Compliance monitoring: During the reporting year, there were no reported instances of non-compliance with the UN Guiding Principles on Business and Human Rights or related instruments in Westwing's downstream value chain. However, should alleged non-compliance occur, it would be investigated by the relevant internal teams, in cooperation with external experts and bodies as necessary and appropriate remediation actions would be taken.

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Overall alignment with international instruments: Westwing is guided by and reflects internationally recognized instruments, including the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. Compliance with international standards is supported through guidance from a group of international advisors, desk research and exchange with other experts.

Stakeholder engagement: Westwing actively engages with consumers and end-users through various channels, such as customer feedback surveys, social media interactions, and direct customer service communications. This engagement ensures that consumer insights inform product development and service improvements.

Taking action on material impacts on consumers

Identification of Actions

Westwing applies a structured process to determine necessary actions in response to potential negative impacts on consumers and end-users. This process includes:

• Regular risk assessments to identify potential negative impacts related to product safety and marketing practices
• Consumer feedback collection through surveys, direct interactions, and focus groups to identify emerging issues
• Analysis of reported incidents from customer service channels and the whistleblower tool to determine root causes and required corrective actions
• Engagement with suppliers and partners through contractual obligations when an impact is linked to business relationships

Managing Material Impacts on Consumers

Scope: Own operations and downstream value chain

Process and actions:

• Structured process for identifying, assessing, and addressing material negative impacts related to unsafe or unreliable products
• Investigation of product-related issues to determine corrective measures and ensure appropriate resolution
• Open communication with affected consumers through customer support channels, ensuring transparency and tracking resolution progress
• Multiple channels provided for consumers to raise product-related concerns, including customer support, social media, and direct contact via email
• Individual evaluation of claims for product defects or delivery errors
• Provision of appropriate compensation, including refunds, replacements, or other corrective actions where necessary
• Logging and review of material impacts to determine whether systemic improvements are needed to prevent recurrence

Effectiveness assessment: Westwing has not yet conducted a formal assessment of whether these processes are effective in their implementation and outcomes. However, customer feedback and resolution timelines are monitored to evaluate whether remedies adequately address consumer concerns related to product safety and reliability.

Addressing Material Impacts Through Business Relationships

Scope: Upstream value chain (suppliers)

Actions:

• Enforcement of strict contractual requirements with suppliers to manage risks related to unsafe or unreliable products
• Supplier compliance with quality and safety standards, verified through supplier audits and performance metrics
• Participation in industry initiatives, such as the amfori BSCI framework, to strengthen oversight and drive continuous improvements in product safety and compliance
• Engagement in collaborative efforts, including the German retailer's Cyber Defence Cooperation, to share knowledge on emerging risks and best practices related to product safety

Resources Allocated to Managing Material Impacts

Westwing dedicates significant resources across various teams to manage material impacts on consumers:

Teams involved:

• Corporate Sustainability team
• Product Development
• Customer Service
• Marketing
• Information Security

Resource types (non-financial):

• Dedicated personnel for compliance and oversight
• Technological systems:
  • Product Lifecycle Management (PLM) system
  • Information Security Management Systems (ISMS)
• Training programs for staff
• Training and awareness programs for employees

Resource types (financial):

• Dedicated budget allocations (no specific amounts disclosed)

Expected outcomes:

• KPIs are used to track the effectiveness of these allocated resources, focusing on product safety and consumer satisfaction (specific KPIs not disclosed)

Note: No specific financial amounts (capex/opex) are quantified for consumer-related actions in the disclosure.

Targets related to consumers

Westwing has set a time-bound, outcome-oriented target to promote responsible consumption by increasing the share of Westwing Collection products labelled as "WE CARE" to 50% by 2027. In addition, Westwing aims to dedicate a significant share of its communication to sustainability topics, ensuring consumers have the information needed to make informed choices.

Westwing has already surpassed this target, with 66% of Westwing Collection products now carrying the "WE CARE" label.

Target 1: Increase the share of Westwing Collection products labelled as "WE CARE" to 50% by 2027

Business conduct policies and corporate culture

Corporate Culture

Westwing defines its corporate culture through its Employer Value Proposition, outlining values and expected behaviour centred around accountability, integrity, collaboration, creativity, growth mindset and shared ambition. These values are communicated through leadership practices, internal channels (insight sessions, group allhands, company intranet), and integrated into hiring, onboarding, and performance management systems. The Employer Value Proposition was integrated into the hiring process and scorecards in 2024, with a review conducted to assess relevance and identify opportunities for deeper integration.

Governance: The Management Board promotes corporate culture by setting clear expectations and embedding values in KPIs, goals, and decision-making. The Supervisory Board ensures alignment through oversight and feedback. Key aspects (employee engagement, adherence to values, ethical behaviour) are reviewed regularly by both boards annually or as part of ongoing compliance and governance meetings.

Monitoring: Westwing tracks KPIs and provides tools and incentives (recognition initiatives, leadership development, employee surveys) to reinforce corporate culture and gather feedback for adjustment.

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Code of Conduct (Employee)

Westwing has a comprehensive Code of Conduct providing employees, suppliers and business partners with guidelines for legally correct, ethical and socially responsible behaviour.

Scope: All Westwing Group employees and all members of senior management must comply at all times. Applies across all Westwing entities with no geographical exclusions.

Key content: Addresses anti-corruption, conflicts of interest, ensuring a safe and fair working environment, prohibition of discrimination (on grounds of racial and ethnic origin, colour, sex, sexual orientation, gender identity, disability, age, religion, national extraction, political views, social origin), prohibition of trafficking in human beings, forced labour, compulsory labour, and child labour.

Governance: The Management Board is the most senior level accountable for implementation, responsible for embedding commitments into operations. Corporate Sustainability team and other company experts lead day-to-day implementation.

Public availability: Publicly available on Westwing Group SE's corporate website (ir.westwing.com, Corporate Governance/Compliance section). Also accessible to employees via company intranet and Policy Manager.

International standards alignment: Aligned with UN Guiding Principles on Business and Human Rights, International Bill of Human Rights, ILO core conventions, OECD Guidelines for Multinational Enterprises, and UN Convention against Corruption (UNCAC) principles. Company aims to adhere to UN Global Compact and OECD Guidelines.

Monitoring and training: All Westwing staff are required to read the Code of Conduct. White collar workers must take a final test in the digital Policy Manager to demonstrate understanding. Blue-collar workers at Westwing Germany receive personal training and access to guidelines. The Legal department tracks final test completion. VP Legal reports compliance ratios to Management Board quarterly and to the Supervisory Board's Audit Committee. A compliance awareness campaign was conducted in 2024 featuring a dedicated week of activities to increase employee engagement and training completion rates.

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Business Partner Code of Conduct

Westwing has a Business Partner Code of Conduct underscoring the importance of "compliance throughout the supply chain".

Scope: Applies to any company, organisation, entity or person that sells or seeks to sell any product or service to Westwing, or any individual or organisation that works or transacts with Westwing, including consultants, agents, business associates, contractors, service providers (excludes Private Label Suppliers who are covered by separate Code).

Key content: Outlines expectations for ethical practices and adherence to similar sustainability principles as Westwing. Requires compliance with similar standards set in Westwing's policies.

Governance: Management Board accountable for implementation. Corporate Sustainability team leads day-to-day implementation of sustainability-related aspects.

Public availability: Publicly available on corporate website (ir.westwing.com, Corporate Governance/Compliance section). Communicated through contractual agreements, onboarding processes, and supplier meetings.

International standards alignment: Business partners expected to adhere to similar principles as Westwing's policies, which are aligned with international frameworks including UN Guiding Principles on Business and Human Rights, ILO Declaration, and OECD Guidelines.

Monitoring: Concerns related to adherence may be reviewed if reported through whistleblower tool, but no formal tracking of adherence across all business partners.

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Private Label Supplier Code of Conduct

Westwing has a Private Label Supplier Code of Conduct for its Westwing Collection suppliers.

Scope: Applies to all Private Label suppliers (Tier 1 manufacturers producing the Westwing Collection) across the value chain in all geographies.

Key content: Sets supplier expectations and governs ethical sourcing practices. Addresses prohibition of child labour, forced labour, human trafficking, safe working conditions, fair wages, right to collective bargaining, worker representation and unions, health and safety standards. Reflects commitments aligned with ILO standards.

Governance: Management Board accountable for implementation. Corporate Sustainability team, Quality and Sustainability Team (Director of Quality and Sustainability), and Buying Teams (VP of Buying) share responsibility for supplier engagement and monitoring.

Public availability: Publicly available on corporate website (ir.westwing.com, Corporate Governance/Compliance section). Communicated during supplier onboarding, contractual agreements, and face-to-face meetings.

International standards alignment: Aligned with UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, OECD Guidelines for Multinational Enterprises, and International Bill of Rights. Explicitly prohibits child labour, forced labour, and human trafficking per ILO standards.

Monitoring: Regular social and environmental audits conducted by internal teams and third-party auditors. Corrective action plans implemented for identified issues. Compliance tracked through audit reports, supplier visits, and quarterly supplier calls. Westwing is a member of amfori, utilizing their BSCI framework for oversight. References whistleblower tool for reporting non-compliance.

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Anti-Corruption Policy

Westwing has an Anti-corruption Policy introduced years ago and regularly reviewed and adapted.

Scope: Applies to all employees. All Westwing staff are required to read the policy. Applies across all Westwing entities with no geographical exclusions.

Key content: Summarizes binding rules for employees, providing more detailed guidance than the Code of Conduct. Westwing has committed to zero-tolerance policy on bribery. Forbids making improper payments and accepting inappropriate gifts or incentives from third parties. Introduces limits on value of gifts and invitations. Provides answers to frequently asked questions and raises awareness. Aligns with principles of UN Convention against Corruption (UNCAC).

Governance: Management Board accountable for implementation. Legal department responsible for content-related compliance topics.

Public availability: Publicly available on corporate website (ir.westwing.com, Corporate Governance/Compliance/Anti-corruption Policy section).

International standards alignment: Aligns with several principles of the United Nations Convention against Corruption (UNCAC).

Monitoring and training: All Westwing staff required to read the policy. White collar workers must take a final test in digital Policy Manager. Blue-collar workers at Westwing Germany receive personal training and access to guidelines. Legal department tracks completion. VP Legal reports compliance ratios to Management Board quarterly and to Supervisory Board's Audit Committee. All functions in the company considered at risk for corruption and bribery, hence all receive relevant training.

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Sustainability Policy

Westwing has a Sustainability Policy launched in 2024.

Scope: Applies across all Westwing entities with no geographical exclusions. Covers own operations and value chain where feasible.

Key content: Links ESG considerations directly to business decisions. Guides the company in managing environmental and social impacts. Embeds sustainability in everyday business conduct. Outlines dedication to fostering a high-performance culture, promoting diversity and inclusion, providing tailored learning and development opportunities, and ensuring a safe and healthy workplace.

Governance: Management Board is the most senior level accountable for implementation. Corporate Sustainability team leads day-to-day implementation.

Public availability: Accessible to stakeholders through corporate website and to employees via company intranet.

International standards alignment: Development informed by benchmarking against industry best practices, assessment of applicable regulations, input from internal experts, and Sustainability Steering Committee guidance.

Monitoring: No formal tracking of adherence mentioned; concerns may be reviewed if reported.

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Human Rights Policy

Westwing has a Human Rights Policy launched in 2024.

Scope: Applies to all regions and Westwing employees. Extends to value chain workers. No geographical exclusions. Accounts for vulnerable groups (migrant workers, young workers, women).

Key content: Reinforces ethical business practices and respect for human rights across value chain. Sets expectations for non-discrimination, fair labour, and stakeholder engagement. Explicitly prohibits child labour, forced labour, and human trafficking. Addresses trafficking in human beings, compulsory labour. Emphasizes fundamental importance of respecting human rights to ethical and responsible business conduct. Provides staff with guidance.

Governance: Management Board accountable for implementation. Corporate Sustainability team leads day-to-day implementation with other company experts. P&C department leads implementation of human resources-related requirements.

Public availability: Accessible through corporate website and to employees via company intranet and Policy Manager.

International standards alignment: Reflects commitment to UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, OECD Guidelines for Multinational Enterprises, and International Bill of Human Rights (includes Universal Declaration of Human Rights and its two covenants). Development informed by these frameworks.

Monitoring and training: Team members required to read policy on human rights. 'White collar' team members must complete final quiz through Policy Manager. While company does not actively monitor compliance, tracks reported incidents through whistleblower tool. No cases of non-respect reported to date.

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Environment, Health and Safety (EHS) Policy

Westwing has an Environment, Health and Safety (EHS) Policy.

Scope: Applies to all Westwing employees across all entities. Covers workforce at warehouses and headquarters. No geographical exclusions.

Key content: Outlines commitment to providing safe and healthy working environment. Focuses on identifying, assessing, and mitigating environmental, health, and safety risks. Supports zero-accident culture through regular safety training and EHS performance reviews at warehouses. Implements health and safety measures at headquarters in line with applicable laws and regulations. Obliges Westwing to do business responsibly per Code of Conduct to protect environment and health and safety of employees and third parties.

Governance: Management Board accountable for implementation. Corporate Sustainability team leads day-to-day implementation.

Public availability: Accessible to employees via company intranet and Policy Manager.

Monitoring: Workforce supported by internal health and safety management system. Regular safety training conducted. EHS performance reviews at warehouses. At Robakowo logistics centre, adjustments made to physical environment for health and safety including accessibility for workers with disabilities. Workshops and activities focused on health and safety aspects conducted at logistics centre.

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Other Corporate Policies

Westwing has additional corporate guidelines that must be observed by management and staff:

Two-person principle policy: Ensures compliance with two-person principle when entering contracts or placing orders.

IT/Information Security policies: Provide information about data protection, data security, and application use. All white-collar staff obliged to take information security training course and complete final test in Policy Manager. Monitored with reports to management. Data protection training provided through new starter onboarding and reinforced with security awareness campaigns and phishing simulations.

Capital Markets Compliance Policy: Explains capital market law obligations from Company's listing. Covers prohibition on insider dealing and unlawful disclosure of inside information. Provides information on closed periods, silent periods, and recommendations against trading shares in 30-day windows before earnings publications.

Anti-money Laundering Policy: Ensures compliance with German Anti-money Laundering Act (Geldwäschegesetz – GwG). Prevents misuse by third parties for money laundering or terrorist financing. Relevant employees and senior management instructed on statutory requirements and procedures for suspicious cases.

Confidentiality Policy: Provides overview of corporate measures for confidentiality (e.g., document classification).

Scope: These policies accessible to staff on company intranet and via digital Policy Manager tool.

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Grievance Mechanisms

Westwing has introduced a whistleblower tool allowing employees and third parties to submit tip-offs about potential unlawful activity in a protected manner.

Scope: Available to all internal and external stakeholders including employees, value chain workers, consumers, end-users, and third parties. All stakeholders can report - also anonymously.

Key features: Complies with recommendation in section A.4 of 2022 German Corporate Governance Code, Whistleblower Directive and its national implementation. Allows confidential or anonymous reporting. Multiple accessible channels including online forms and in-person reporting. Clear procedures with timeframes for addressing concerns. Protects against retaliation - maintains confidentiality of whistleblowers' identities, secure channels, prompt investigation of retaliation allegations, no penalties for raising concerns.

Governance: Reports handled by Legal, Governance and Risk Management, Compliance, and P&C teams. Initial assessment determines severity. Serious concerns (corruption, fraud) escalated to senior management or external legal counsel. VP Legal reports on cases to Management Board and Supervisory Board's Audit Committee quarterly.

Public availability: Publicly available on corporate website (ir.westwing.com, Corporate Governance/Compliance/Open Whistleblower Channel section).

Monitoring: System ensures traceability and transparency throughout investigation. Regular updates provided to whistleblower when possible. Documented with meeting minutes and follow-up actions. In 2024, nine cases received, seven related to discrimination and harassment, with no fines or penalties. Currently basic training provided to staff managing reports; comprehensive training planned for upcoming reporting year.

Prevention and detection of corruption and bribery

Westwing has implemented policies and mechanisms to prevent and detect corruption and bribery across its operations.

Anti-corruption Policy

Key content and principles:

• Zero-tolerance policy on bribery
• Forbids making improper payments and accepting inappropriate gifts or incentives of any kind from third parties
• Introduces limits on the value of gifts and invitations that can be accepted
• Provides employees with answers to frequently asked questions and common problems
• Raises awareness of corruption-related issues
• Goes into greater detail than the rules given in the Code of Conduct, illustrating comprehensively and explicitly the actions and prohibitions designed to prevent corruption

Scope:

• All Westwing staff are generally required to read the Anti-corruption Policy

Public availability:

• Publicly available from the Corporate Governance/Compliance/Anti-corruption Policy section of Westwing Group SE's corporate website (ir.westwing.com)
• Accessible to internal stakeholders through Westwing's intranet and Policy Manager

Links to international standards:

• Aligns with several principles of the United Nations Convention against Corruption (UNCAC)
• Westwing aims to adhere to international standards such as the United Nations Global Compact and the OECD Guidelines for Multinational Enterprises, particularly in areas related to anti-corruption

Monitoring and implementation:

• White collar workers must take a final test in the digital Policy Manager to demonstrate what they have learned
• This is monitored and a report on it is submitted to management
• Blue-collar workers at Westwing Germany receive personal training and access to the guidelines
• Supported by internal controls and a whistleblower mechanism
• For all policies and codes of conduct, any concerns related to policy adherence may be reviewed if reported, but there is no formal tracking of adherence across all policies

Governance:

• The Management Board is the most senior level accountable for the implementation of Westwing's policies
• The Management Board is directly responsible for embedding the policy's commitments into Westwing's operations and ensuring their effective execution throughout the organisation
• Responsibility for the remainder of the policies, depending on their content, lies with other Westwing departments
• Policies are signed off by the Management Board

Code of Conduct

Key content and principles:

• Provides guidance on legally correct, ethical, and socially responsible behaviour
• Addresses issues such as corruption and bribery and compliance with laws and regulations

Scope:

• Applies across all Westwing entities with no exclusions in terms of geographies
• All employees are required to read the Code of Conduct

Public availability:

• Accessible to internal stakeholders through Westwing's intranet and Policy Manager
• Accessible to all stakeholders through Westwing's corporate website
• Can be referenced through contractual agreements or presented in in-person meetings and onboarding sessions

Monitoring and implementation:

• White collar workers must take a final test in the digital Policy Manager to demonstrate what they have learned
• This is monitored and a report on it is submitted to management
• Blue-collar workers at Westwing Germany receive personal training and access to the guidelines

Private Label Suppliers Code of Conduct

Key content and principles:

• Addresses issues such as corruption and bribery and compliance with laws and regulations

Scope:

• Applies to all Private label suppliers across the value chain

Monitoring and implementation:

• Westwing's monitoring is centred on regular audits of private-label suppliers, which help assess compliance with the respective Code of Conduct

Business Partner Code of Conduct

Key content and principles:

• Addresses issues such as corruption and bribery and compliance with laws and regulations

Scope:

• Applies to any company, organisation, entity or person that sells or seeks to sell any kind of product or service to Westwing or any individual or organisation that works or transacts with Westwing, including consultants, agents, business associates, contractors, service providers, who work for and on behalf of, or otherwise transact with, Westwing (this excludes Private Label Suppliers who are covered by the Private Label Supplier Code of Conduct)

Mechanisms for identifying, reporting, and investigating unlawful behaviour

Westwing has developed secure and confidential reporting mechanisms:

• A whistleblower tool that allows employees and third parties to submit tip-offs about potential unlawful activity at the Company in a protected manner
• Complies with the recommendation and suggestion contained in section A.4 of the 2022 version of the German Corporate Governance Code, and with the Whistleblower Directive and its implementation in national law
• Option for anonymous reporting
• Publicly available from the Corporate Governance/Compliance/Open Whistleblower Channel section of Westwing Group SE's corporate website (ir.westwing.com)
• Available to internal and external stakeholders such as employees and third parties

Incidents of corruption or bribery

Confirmed incidents

Westwing reported that in 2024, it received a total of nine cases through its whistleblower tool, of which seven were related to discrimination and harassment. The company did not disclose specific figures for confirmed incidents of corruption or bribery.

Convictions and fines

Westwing explicitly stated: "There were no fines, penalties, or compensation for damages associated with these cases."

Severe human rights incidents

The company declared: "In the reporting year, Westwing has not encountered any severe human rights incidents."

Investigation procedures and speak-up mechanisms

Westwing has implemented a whistleblower tool that allows employees and third parties to submit tip-offs about potential unlawful activity at the Company in a protected manner, with the option for anonymous reporting. This tool complies with section A.4 of the 2022 version of the German Corporate Governance Code, and with the Whistleblower Directive and its implementation in national law. The whistleblower tool is publicly available from the Corporate Governance/Compliance/Open Whistleblower Channel section of Westwing Group SE's corporate website (ir.westwing.com).

Reports are handled by members of the Legal, Governance and Risk Management, Compliance, and P&C teams. An initial assessment is conducted to determine the severity and potential impact of the reported issue. Serious concerns, such as allegations of corruption or fraud, are escalated to senior management or external legal counsel for further investigation. The system aims to ensure traceability and transparency throughout the investigation, with regular updates provided to the whistleblower when possible.

To safeguard against retaliation, Westwing prioritises maintaining the confidentiality of whistleblowers' identities and ensures that all reporting channels remain secure. Any allegations of retaliation are promptly investigated, and whistleblowers are protected from penalties for raising concerns.

Anti-corruption policy framework

Westwing has committed to a zero-tolerance policy on bribery. Among other things, this forbids making improper payments and accepting inappropriate gifts or incentives of any kind from third parties. The policy also introduces limits on the value of gifts and invitations that can be accepted.

The Anti-corruption Policy is publicly available from the Corporate Governance/Compliance/Anti-corruption Policy section of Westwing Group SE's corporate website (ir.westwing.com). All Westwing staff are generally required to read the Anti-corruption Policy. White collar workers must also take a final test in the digital Policy Manager to demonstrate what they have learned. This is monitored and a report on it is submitted to management. Blue-collar workers at Westwing Germany receive personal training and access to the guidelines.

Westwing considers all functions in the company to be at risk in respect of corruption and bribery, hence all functions receive relevant training.