Westwing Group SE

Reference: page 58

Westwing has a two-tier board structure: a Management Board of two executive members (currently all-male) and a five-member Supervisory Board, four of whom are independent, with 40% female representation. The Supervisory Board does not include employee representatives, in line with applicable law. A skills matrix (page 58) maps each member against areas including e-commerce/retail, finance, audit, cybersecurity, supply chain and sustainability.

Sustainability expertise is embedded through the in-house Corporate Sustainability team, external experts, and regular Management Board training and briefings on the EU Taxonomy, CSRD and other ESG standards. The Supervisory Board monitors sustainability primarily through its Audit Committee, and evaluates its own sustainability expertise via annual self-assessments. The Sustainability Steering Committee, chaired by the Director Corporate Sustainability and including the Management Board and C-level executives, oversees implementation of the sustainability strategy and reports through the Director Corporate Sustainability, GRC Manager and VP Legal directly to the Audit Committee.

Reference: page 60

The Sustainability Steering Committee, including the Management Board, is briefed by the Corporate Sustainability team on material sustainability IROs identified through the DMA, and quarterly on the effectiveness of due diligence processes, policies, actions, metrics and targets. The Audit Committee of the Supervisory Board is updated regularly on material impacts, risks and opportunities and on due diligence effectiveness; its Chair reports back to the full Supervisory Board. At least once a year the Director Corporate Sustainability presents directly to the Supervisory Board on the results and effectiveness of policies, actions, metrics and targets.

The corporate risk register, which includes sustainability-related risks, is updated biannually under Management Board supervision. During 2025 the Boards addressed IROs relating to climate change and energy, resource use and circular economy, own workforce, workers in the value chain, consumers and end-users, and business conduct, including the DMA update.

Reference: page 61

Westwing links sustainability performance to Management Board variable remuneration through Short-Term Incentive (STI, annual) and Long-Term Incentive (LTI, multi-year) components. For 2025 the non-financial STI component is the "Share of plastic packaging material used per item shipped"; the 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." Sustainability-linked remuneration accounts for 20% of total long-term variable remuneration and 25% of short-term variable remuneration.

In line with the German Corporate Governance Code recommendations, the Supervisory Board receives no variable remuneration and therefore has no climate-related remuneration components. Sustainability metrics are not yet integrated into remuneration for employees below the Management Board. The remuneration system is set by the Supervisory Board based on the framework approved at the 2023 AGM, with the FY2024 remuneration report approved at the 2025 AGM.

Reference: page 61

Westwing presents its due diligence process against the four core UNGP/OECD elements using a table that cross-references each element to specific sustainability-statement sections. Embedding due diligence in governance, strategy and business model maps to GOV-2 (page 60), GOV-3 (page 61) and SBM-3 (page 67). Engaging with affected stakeholders maps to GOV-2, SBM-2 (page 66) and IRO-1 (page 73), plus the MDR-P policy disclosures across E1, E5, S1, S2, S4 and G1.

Identifying and assessing negative impacts maps to IRO-1 and SBM-3; taking action maps to the topical MDR-A actions disclosures (E1-3, E5-2, S1-4, S2-4, S4-4); and tracking effectiveness maps to the MDR-M metrics disclosures (E1-5, E1-6, E1-7, E5-4, E5-5, S1-6, S1-14, S1-17) and MDR-T targets disclosures (E1-4, E5-3, S1-5, S2-4, S4-4). The table (pages 61-62) gives page references for every element rather than a narrative description.

Reference: page 63

Westwing's Non-Financial Internal Control System (NFICS) is built on the COSO framework, covering control environment, risk assessment, control activities, information/communication and monitoring, in the same way as its Internal Controls over Financial Reporting. In 2025 the GRC department, with the Corporate Sustainability department and process/control owners, assessed selected qualitative and quantitative disclosures to identify risks and design controls; controls were designed and implemented for selected ESRS E1 and E5 metrics but "Westwing has not yet implemented and tested sustainability-related controls" – testing is scheduled to start in FY2026 for selected metrics only.

Key ESG-related risks named include regulatory non-compliance, the still-developing internal control system, product-quality deficiencies, value-chain working conditions and labour-law compliance, and the accuracy, completeness and availability of upstream/downstream ESG data. Findings are reported to the Management Board, Supervisory Board and/or Audit Committee.

Reference: page 64

Westwing is an e-commerce Home & Living retailer operating in 22 European countries (DACH and International segments), with 1,289 employees (641 Germany, 595 Poland, 53 elsewhere) and FY2025 revenue of EUR 449.2m. The proprietary Westwing Collection generates roughly two-thirds of sales and about 63% of GMV; the company also sells curated third-party brands. Westwing is not involved in fossil fuels, chemical production, controversial weapons or tobacco.

The upstream value chain covers sourcing and procurement from Westwing Collection and third-party suppliers, mainly in Europe and Asia, using key raw materials such as wood, cotton, wool and leather, over which Westwing has "limited operational control." Downstream, Westwing manages packaging, order processing and shipping via third-party logistics operators and its own Westwing Delivery Service. Sustainability goals concentrate on the Westwing Collection, its supplier base, and the Germany/Poland operational sites where the company has the greatest operational control.

Reference: page 66

Westwing engages five stakeholder groups through channel sets tailored to each: investors via quarterly earnings calls, conferences and the IR website; employees via surveys and company meetings; customers via surveys, product reviews and customer-service interactions; and suppliers/business partners via performance reviews, audits and business meetings. Value chain workers are not engaged directly; Westwing instead relies on recognised bodies conducting social audits to assess their rights and wellbeing.

Feedback flows through the Corporate Sustainability team into the DMA process and the Sustainability Steering Committee, and different teams update the Management and Supervisory Boards – for example customer feedback informing product design, and employee input shaping workplace policy. Recent strategic responses include an increased share of European suppliers and a data-privacy focus arising from stakeholder input, though no further steps were identified as currently planned as a result.

Reference: page 67

Westwing's DMA identifies material topics of climate change, resource use and circular economy, own workforce, workers in the value chain, consumers and end-users, and business conduct. The material IRO table (pages 68-69) lists 22 individually typed impacts, risks and opportunities across E1 (6), E5 (7), S1 (1), S2 (2), S4 (5) and G1 (1), covering own operations and the upstream/downstream value chain. The 2025 DMA update added data privacy as a material S4 sub-subtopic and refined magnitude/likelihood/severity scoring to align with the company's risk register.

Effects on strategy include carbon emissions from logistics and operations, resource-use inefficiencies in sourcing, and product-quality/data-privacy risk management measures embedded into decision-making. Consistent with the ESRS 1 Appendix C transitional relief Westwing applies (see IRO-2), the anticipated financial effects sub-point of SBM-3 (paragraph 48e) is deferred and not disclosed this year.

Reference: page 73

Westwing's DMA assesses impact materiality on a 5-point severity/likelihood scale (a score of 3+ in any severity parameter is material) and financial materiality where likelihood x magnitude reaches 3, or magnitude alone reaches 3. Climate-related IROs use a qualitative scenario analysis (SSP1-2.6 transition, SSP5-8.5 physical, informed by IPCC AR6) across short- (1-3yr), medium- (3-10yr) and long-term (to 2050) horizons. Circular-economy IROs used a Locate-Evaluate-Assess-Prepare (LEAP) approach; business-conduct IROs considered location, activity, sector and transaction structure; pollution, water/marine and biodiversity topics were screened using internal expertise, supplier data and peer benchmarking and found not material (see IRO-2).

The DMA was most recently updated in October 2025 "in accordance with EFRAG IG 1 FAQ 7," combining peer benchmarking, identification of internal/external developments (geographic expansion, Collection growth, regulatory change) and alignment with the corporate risk register.

Reference: page 80

Westwing states plainly: "In Westwing's DMA, E2 Pollution, E3 Water and Marine resources, E4 Biodiversity and Ecosystems and S3 Affected communities have not been identified as material topics, and therefore not covered in the sustainability statement." Within the material topics E5, S1 and G1, specific disclosure requirements were separately assessed as not material and excluded: S1-8, S1-9, S1-10, S1-11, S1-12, S1-13, S1-15 and S1-16, and G1-2, G1-3, G1-4, G1-5 and G1-6.

Separately, Westwing defers five disclosures under the extended transitional provisions of Commission Delegated Regulation (EU) 2025/1416 amending ESRS 1 Appendix C: ESRS 2 SBM-3 paragraph 48e (anticipated financial effects), E1-9, E5-6, S1-7, and the non-employee data points within S1-14. A full content-index table (pages 81-83) then lists the disclosure requirements actually reported, with their page references.

Reference: page 88

Westwing's Climate Transition Plan, approved by the Management Board and Supervisory Board, "aligns with Westwing's overall business strategy and financial planning" and informs the 3-year Group Strategy. The headline target is a 75% reduction in Scope 1 and 2 GHG emissions by 2030 from a 2022 baseline, validated by the Science Based Targets initiative (SBTi) and aligned with the 1.5°C pathway using SBTi's cross-sector guidance, since no e-commerce-specific pathway exists. A supplier-engagement target covers 80% of spend on purchased goods/services and upstream transport by 2027, and Westwing aims to source 100% renewable energy by 2027; no long-term net-zero target has yet been set.

Decarbonisation levers named are renewable energy, energy efficiency, supply-chain decarbonisation, product-portfolio change, sustainable packaging procurement and resource efficiency. A qualitative assessment found no locked-in GHG emissions from key assets, reflecting the company's asset-light, no-manufacturing model.

Reference: page 74

Back-filled from ESRS 2 IRO-1 (pages 74-77) and SBM-3 (pages 89-90), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Westwing's climate-related IROs were assessed using two IPCC AR6 scenarios: SSP1-2.6 (broadly 1.5-2°C aligned, low emissions, used for transition risk) and SSP5-8.5 (high-emissions, used for physical risk), cross-checked against IEA WEO 2023 and the IEA Net Zero Emissions by 2050 scenario. The analysis covered own operations (headquarters and the Robakowo, Poland logistics centre), upstream high-risk commodities such as cotton, and downstream order processing/shipping, over short- (1-3yr), medium- (3-10yr) and long-term (to 2050) horizons. It was conducted in 2024, reviewed as part of the October 2025 DMA update, and Westwing states the "climate scenario analysis will be revisited to further refine the methodology" in 2026. Identified physical risks include water scarcity affecting wood and cotton, and extreme-weather logistics disruption; the main transition risk is the cost of decarbonisation technology.

Reference: page 91

Back-filled from ESRS 2 SBM-3, where a dedicated "Resilience Analysis" subsection is disclosed in the FY2025 report (page 91), following directly from the scenario analysis on pages 89-90. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Westwing performed a 2025 climate resilience analysis testing all material climate risks, the one climate opportunity and the negative impact from carbon emissions, comparing gross exposure (no mitigation) against net exposure (with planned Climate Transition Plan actions). Under SSP1-2.6, transition risks are mitigated through renewable sourcing, energy efficiency and supplier engagement on SBTs. Under SSP5-8.5, physical risks "remain moderate" given Westwing's "asset-light model, limited owned physical, climate-exposed fixed assets" and diversified supplier network. The company concludes no short- to medium-term constraint on affordable financing is expected from climate risk alone, and that it is "well positioned to adjust and adapt its business model," while acknowledging that supply-chain and energy-price risks "will remain overtime and require ongoing management."

Reference: page 92

Westwing's Sustainability Policy addresses climate mitigation directly by prioritising emissions reduction and renewable-energy sourcing across operations, logistics and the supply chain, targeting the transition risks of decarbonisation costs and energy-intensive-process dependency. Adaptation is addressed indirectly, through resilience-building measures such as responsible sourcing, resource optimisation and logistics adjustments intended to manage physical risks including water scarcity and extreme weather.

The policy applies across all Westwing operations and geographies with no exclusions; the Management Board is accountable for the policy, with day-to-day implementation led by the Corporate Sustainability team. Commitments are monitored through a KPI system reviewed monthly, quarterly or annually as appropriate, with annual GHG assessments complemented by more frequent reviews of sourcing and energy-efficiency metrics. The policy is accessible via the intranet, the "Policy Manager" tool, and the corporate website.

Reference: page 93

Westwing's climate action plan focuses primarily on mitigation, built around six levers: renewable energy, energy efficiency, supply-chain decarbonisation, product-portfolio change, sustainable packaging procurement and resource efficiency. Given its asset-light model, Westwing has no standalone adaptation action plan; adaptation is addressed indirectly through supplier-base and logistics-continuity resilience measures.

The summary action table (pages 94-97) quantifies expected GHG reductions where available: sourcing renewable electricity is expected to cut 2,400 tCO2e by 2030, transitioning to renewable heating a further 2,600 tCO2e by 2030, and energy-efficiency measures already achieved a 700 tCO2e reduction in 2024. Other actions – recycled-material product design, packaging changes (recycled plastics, foam-to-cardboard substitution), supplier science-based-target engagement, and logistics measures including a DHL GoGreen Plus partnership and new pick-up/drop-off points – are not individually quantified. Implementation "did not require significant capital expenditures (CapEx) or operational expenditures (OpEx) in 2025, but such expenditure may be required in the future."

Reference: page 98

Westwing reports three climate targets (detailed tables, pages 100-101). Target 1: reduce absolute Scope 1 and 2 GHG emissions 75% by 2030 from a 2022 baseline (5,173 tCO2e); SBTi-validated, 1.5°C-aligned; 2025 performance is "82% - above expectations (2024: 64%)." Target 2: 80% of suppliers by spend (purchased goods/services and upstream transport) to hold SBTi-validated science-based targets by 2027; 2025 performance "21% - in line with expectations (2024: 12%)," alongside a related interim commitment metric of 46.5% of suppliers by spend publicly committed to setting SBTs (2024: 22%). Target 3: source 100% of overall energy from renewable sources by 2027; 2025 performance "30% - below expectations (2024: 9%)."

Targets were set using internal expertise and peer benchmarking rather than direct stakeholder involvement, with assumptions on grid decarbonisation, regulatory roadmaps and PPA/REC market availability. No targets exist yet for 2050 or for absolute Scope 3 or Scope 1-only reduction.

Reference: page 102

Westwing's total energy consumption was 6,664 MWh in 2025 (2024: 6,941 MWh). Renewable sources rose sharply to 30% of the mix (2024: 9%), comprising 1,860 MWh of purchased renewable electricity/heat (2024: 506 MWh) and 143 MWh of self-generated renewables, mainly on-site solar at the Robakowo logistics centre (2024: 109 MWh). Fossil energy fell to 4,661 MWh, or 70% of the mix (2024: 6,326 MWh / 91%). Westwing reports no nuclear consumption and does not operate in a high climate impact sector, so no sector energy-intensity metric is disclosed.

Methodology combines invoiced electricity/heating/fuel data, grid-source information, and contractual instruments such as Renewable Electricity Certificates (RECs) and Guarantees of Origin (GOs); on-site solar generation is tracked via an automated daily monitoring system. These metrics "are not validated by an external body other than the assurance provider."

Reference: page 104

Against a 2022 base year, Westwing's Scope 1 emissions fell to 925 tCO2e in 2025 (2024: 1,081, -14%). Scope 2 fell to 1,002 tCO2e location-based (2024: 1,023, -2%) and to just 14 tCO2e market-based (2024: 771, -98%), driven by REC and Guarantee-of-Origin purchases covering 100% of electricity consumption. Scope 3 fell to 93,708 tCO2e (2024 restated: 139,757, -33%) across four disclosed categories: purchased goods and services (50,442, -42%), upstream transportation and distribution (18,377, -13%), use of sold products (16,456, -30%) and end-of-life treatment (8,433, +3%). Total market-based GHG emissions were 94,647 tCO2e (2024: 139,604, -33%), and GHG intensity per net revenue fell 34% to 211 tCO2e/M€.

2024 Scope 3 comparatives were restated following third-party verification conducted in 2025, which revised methodology and emission factors across several categories. Categories excluded as immaterial or irrelevant include capital goods, business travel, employee commuting and downstream leased assets.

Reference: page 106

Westwing states that its "climate strategy prioritises the avoidance and reduction of greenhouse gas emissions within our own operations and across our value chain" and that, accordingly, "in 2025 Westwing did not purchase GHG removals or carbon credits." No GHG removals, mitigation projects financed through carbon credits, or related quantities, are therefore reported for the year, and the disclosure requirement is addressed with this single confirming statement rather than quantitative data, consistent with the company's reliance on direct emissions reduction rather than offsetting.

Reference: page 107

Westwing's E1-8 disclosure is a single confirming statement: "Westwing does not apply any internal pricing schemes." No internal carbon price, shadow price or internal carbon fee is used in investment decisions, capital allocation or product/service pricing, and no further detail (scope, price level, rationale) is provided, since the disclosure requirement does not apply in the absence of such a scheme.

Reference: page 107

Westwing's Sustainability Policy and Raw Material Sourcing Policy apply from raw-material sourcing through internal operations to downstream partners, covering both the Westwing Collection and other suppliers. They rely on standards including FSC, PEFC, GOTS, BCI, the Global Recycled Standard (GRS) and OEKO-TEX, and align with the waste hierarchy by supporting product durability, repairability, reuse and recycling. Policy focus areas are sustainable sourcing, reducing reliance on virgin resources, prioritising renewable inputs, and progressively integrating circularity.

The policies cover all Westwing operations and value-chain activities with no exclusions; the Management Board is accountable, with the Corporate Sustainability team leading implementation. Compliance is monitored through Westwing Collection supplier audits against frameworks such as Higg FEM, OEKO-TEX STeP and amfori BEPI, reviewed monthly or quarterly. The policies are published on the intranet, the Policy Manager tool and the corporate website.

Reference: page 108

Westwing's resource-use actions span product design, packaging and end-of-life. For the Westwing Collection, the company is increasing recycled synthetic-fabric content, expanding certified and traceable raw materials, and offers a 10-year warranty on Collection furniture to extend product life. In packaging, Westwing is moving toward recyclable/recycled materials under Extended Producer Responsibility principles and phasing out single-use plastics (for example replacing foam with shredded cardboard). A repair and restoration service at the logistics centre extends product lifespans: in 2025, 7,016 items – mostly furniture and electrical appliances – were "repaired, refurbished and restored to resale condition," against a target of salvaging 5% of returned Net Purchase Price by 2027.

Upstream, Westwing initiated supply-chain traceability tracking for non-EU wood and leather (2024-2028, expanding to further commodities from 2026 under the EU Deforestation Regulation) and continued sourcing FSC-licensed and other certified materials.

Reference: page 112

Westwing reports six voluntary resource-use targets (detail tables, pages 113-118), all following the waste hierarchy. Plastic packaging per item shipped: -40% by 2027, 2025 performance 50% (13.2g vs a 26.2g 2022 baseline, ahead of pace; 2024: 35%). Recycled-content plastic packaging: >90% by 2025, achieved at 97% (2024: 98%). Single-use plastic packaging: -100% by 2030, at 35.5% (2024: 30%). Recycled paper in packaging: 100% by 2025, at 99% ("full substitution remains unfeasible" for items like labels and tape). Salvaged Net Purchase Price from returns: 5% by 2027, at 3.8% (baseline 3.1% in 2024). Certified responsibly-sourced materials by 2026: wood 98.5% (2024: 94%), cotton 82% (2024: 85%, down), animal by-products 82% (2024: 92%, down) – all against a >90% target, with the Corporate Sustainability team attributing the two declines to portfolio and certification-transition effects.

Targets were set using internal benchmarking and expertise rather than formal scenario analysis, and are monitored quarterly by the Sustainability Steering Committee.

Reference: page 119

Westwing's resource inflows comprise upstream materials for products (wood, cotton, metal, animal by-products, synthetic materials) and operational packaging materials (paper, plastic, metal, wood) used at the Robakowo logistics centre. Own-operations equipment inflows include forklifts, conveyor systems, an automated packaging machine and a "waffle machine" that converts packaging waste into cushioning material.

Total packaging-material inflows for direct operational activities fell to 2,515 tonnes in 2025 (2024: 2,959 tonnes). Of this, 94% was sustainably sourced biological material certified by FSC or Blue Angel (2024: 93%), and 1,309 tonnes, or 52%, was secondary (reused or recycled) material (2024: 1,583 tonnes / 54%, a slight decline). Data derives from purchase-order reports and the internal order-management system, supplemented by weight-based proxy estimates at the logistics centre where direct data is unavailable; "these metrics are not validated by an external body other than the assurance provider."

Reference: page 121

Westwing's resource outflows are dominated by the home and living products it places on the market and the outbound packaging shipped with them; the company does not manufacture products itself but is progressively incorporating circular design features (recycled content, durable materials, modular construction) into development. The recyclable content of Westwing Group's packaging materials rose to 99.4% in 2025 (2024: 98.6%), calculated against total packaging weight and unvalidated by any external body beyond the assurance provider.

Waste is described as "only a small proportion of Westwing's overall resource outflows," consisting mainly of logistics-centre packaging waste and limited retail waste, with collection, sorting and disposal processes in place. Repair and refurbishment activity at the logistics centre restored 7,020 items to first-quality or liquidation-route condition in 2025, extending product lifecycles; Westwing does not yet conduct formal durability assessments by product category.

Reference: page 124

Westwing manages its workforce through its Human Rights Policy (launched 2024), Sustainability Policy, Environment, Health and Safety (EHS) Policy (updated 2025) and Code of Conduct (updated 2025). These align with the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, ILO core conventions and the OECD Guidelines, and explicitly prohibit trafficking, forced labour, compulsory labour and child labour. The Human Rights Policy commits to fair wages, safe working conditions and collective bargaining rights; the updated Code of Conduct upholds employees' rights to join trade unions without retaliation.

Policies apply to all regions and employees, with the Management Board accountable and the People & Culture (P&C) department leading HR implementation. Westwing tracks reported incidents through its whistleblower tool rather than active compliance monitoring. The 2025-updated EHS Policy clarified scope across all offices, warehouses and facilities and strengthened business-partner alignment expectations.

Reference: page 126

Westwing engages employees through multiple channels: the annual "Inside Westwing" survey; Group Allhands meetings; annual Upward and 360° Feedback; the whistleblower tool; the intranet; and an open-door policy. Formal representative engagement runs through the elected Westwing Group SE Consultation Body (SE Consultation Body), which meets the Management Board twice annually and the P&C team regularly, and through local trade unions at the Poland logistics centre, with weekly union-management one-on-ones and at-least-quarterly formal meetings.

The Chief People Officer holds overall responsibility for integrating engagement feedback into strategy, with the P&C team overseeing collection and communication. Westwing states it "currently does not have formal internal or external auditing or benchmarking systems in place to assess the effectiveness of its engagement processes," though it is evaluating whether such mechanisms are needed. No Global Framework Agreement exists with worker representatives.

Reference: page 128

Westwing's primary remediation channel is the whistleblower tool, supplemented by an open-door policy, direct communication, employee surveys, focus groups, Group Allhands Q&A, the SE Consultation Body and local trade unions. When an impact is identified, the process involves investigation to determine cause and responsibility, remedial action, and preventative measures, with clear procedures and indicative timeframes communicated at onboarding.

Policies protect employees and representatives from retaliation, and employees also have access to third-party grievance channels via government or NGO initiatives. Westwing acknowledges that "formal assessments of trust in grievance mechanisms are not conducted"; effectiveness is instead gauged through engagement and participation rates rather than dedicated satisfaction metrics. The investigation mechanism for unlawful behaviour is described more fully under G1-1.

Reference: page 129

Westwing states it "has not identified any material impacts linked to its own workforce," so actions target the one material risk – health, safety and working-condition liabilities tied to logistics operations. In 2025 the company ran a Health & Safety Week, introduced a Behaviour-Based Safety (BBS) programme and an ergonomics programme at the logistics centre, alongside flexible working, wellbeing initiatives, childcare support, training and mentoring programmes company-wide.

Effectiveness is tracked via employee surveys, satisfaction and turnover KPIs on the sustainability dashboard, internal audits, external benchmarking and grievance-mechanism feedback, with senior management reviewing workplace-accident and LTIFR metrics quarterly. 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."

Reference: page 131

Westwing has set one workforce target: a Lost Time Injury Frequency Rate (LTIFR) below 1 for the Robakowo logistics centre, to be achieved annually. 2025 performance was 16.1, moving further from target rather than closer to it (2024: 14.2). The target was developed via benchmarking and employee-survey input, with the Chief People Officer consulted and formal approval from the Executive team, Management Board and Supervisory Board.

Performance is tracked through the sustainability dashboard and monitored quarterly or annually by the Sustainability Steering Committee, with LTIFR at the logistics centre specifically reviewed quarterly given warehouse employees' greater exposure to work-related hazards. Westwing states it "does not actively collaborate with its workforce or workers' representatives" specifically to identify lessons on target performance, relying instead on ongoing survey and SE Consultation Body feedback.

Reference: page 132

Westwing employed 1,289 people (headcount) at year-end 2025 (2024: 1,392): 480 male and 809 female. By country, 641 were in Germany (2024: 660), 595 in Poland (2024: 667) and 53 elsewhere (2024: 65). On an FTE basis, total headcount was 1,207 (2024: 1,291), of which 1,145 were permanent and 62 non-guaranteed-hours; 1,146 full-time and 62 part-time.

Voluntary employee turnover was 19.1% in 2025 (256 employees left; 2024: 20% / 314 departures). Westwing states that "based on the current monitoring and analysis of turnover and related workforce indicators, no material negative impacts on employees or risks to operational stability have been identified," while committing to "further analyse the drivers, patterns and implications of voluntary turnover" in 2026 to reassess materiality. The financial-statement headcount of 1,346 (Note 7, annual-average basis) differs from the 1,289 year-end figure used here per the cross-reference note.

Reference: page 134

Westwing's internal health and safety management system covers 100% of employees (2024: 100%), combining documented procedures and risk assessments, structured incident/near-miss reporting, regular safety audits, and a safety culture built on Safety Alerts, a Behaviour-Based Safety approach, ergonomics assessments (at the logistics centre) and quarterly occupational-health meetings with the company doctor (at the Munich/Warsaw offices).

In 2025 there were 0 fatalities (2024: 0), 16 recordable work-related accidents (2024: 22) and 0 recordable cases of work-related ill health (2024: 0), resulting in 393 lost days (2024: 239). Group LTIFR was 5.5 (2024: 4.64) and the accident rate 6.3 (2024: 6.8). Per ESRS 2 IRO-2 (page 80), the non-employee data points within S1-14 (paragraph 88(e)) are deferred under the ESRS 1 Appendix C phase-in provisions, so figures above cover employees only.

Reference: page 135

In 2025, Westwing received four cases through its whistleblower tool (2024: nine), two relating to human-resources matters and two to "unacceptable behaviour" (2024: seven cases related to discrimination and harassment). No fines, penalties or compensation for damages were associated with these cases in either year, and Westwing states it "has not encountered any severe human rights incidents" in 2025 (2024: zero).

Reference: page 139

Westwing addresses value-chain-worker IROs through its Sustainability Policy, Human Rights Policy, EHS Policy, and its Business Partner and Private Label Supplier Codes of Conduct, both updated in 2025 to sharpen alignment with the Sustainability Policy. These apply to upstream and downstream workers including brand partners, contractors and other suppliers, with specific safeguards for vulnerable groups such as migrant and young workers, and explicitly prohibit trafficking, forced and child labour, aligned with ILO standards, the UNGP, the OECD Guidelines and the International Bill of Rights.

Westwing states it is "not aware of cases of non-respect involving value chain workers" under these frameworks. Compliance for Westwing Collection suppliers is monitored via regular social and environmental audits, risk assessments and corrective action plans, combining internal teams and third-party audits; Westwing is also an amfori member. The Management Board is accountable, with the Corporate Sustainability team leading implementation.

Reference: page 140

Westwing "currently engages with Westwing Collection value chain workers indirectly, primarily through communication with suppliers, who act as proxies." Direct worker engagement is not routine but occurs through periodic worker interviews as part of externally led audits and Westwing's internal social assessment protocol; regular supplier visits provide some observational insight into working conditions. Workers can also raise concerns via the whistleblower tool.

Engagement with Westwing Collection suppliers occurs at selection/onboarding (technical and external social audits) and continues through quarterly supplier calls, visits and corrective-action follow-up, led by the Corporate Sustainability team and the Buying teams. Westwing has no Global Framework Agreements but is a member of the UN Global Compact and amfori. "Beyond the Westwing Collection Tier 1 suppliers, Westwing does not have a process for direct engagement with workers of any other partners or suppliers in its value chain."

Reference: page 140

All value chain workers can access Westwing's publicly available whistleblower tool, which allows confidential or anonymous reporting regardless of employer, with designated Legal/GRC/P&C teams handling follow-up and corrective action. The tool is referenced in Westwing's Codes of Conduct and communicated during supplier onboarding.

Westwing acknowledges it "does not have formal measures to assess whether value chain workers are fully aware of or trust the whistleblower tool," though it is exploring initiatives such as amfori's "Speak for Change" programme to improve worker awareness and access. In the reporting year "Westwing has not been made aware of any negative impacts on its value chain workers"; had any been confirmed, a structured identification, investigation, corrective-action and preventative-measures process would apply, with effectiveness evaluated through compliance and social audits.

Reference: page 141

Westwing manages the material risk of labour-rights violations in its supply chain through social audits, corrective action plans and supplier feedback for Westwing Collection suppliers, and prioritised sourcing of certified materials (BCI cotton, Responsible Wool Standard, European Flax, FSC). A Zero Tolerance Issue Handling Protocol, established in 2025, escalates unremediated violations up to order holds or contract termination. In 2025, "99.9% of the key and strategic EU suppliers were audited either through external audit reports or in-house audits," and one major EU supplier completed Social Management System implementation.

Positive-impact actions include amfori Academy training (62% of Westwing Collection suppliers by purchase-order volume trained in 2025) and participation by eight key suppliers in the "Speak for Change" worker-voice initiative. No severe human rights incidents were reported in 2025 (2024: zero). Implementation "did not require significant CapEx or OpEx."

Reference: page 145

Westwing reports four value-chain-worker targets (detail tables, pages 145-147). 100% of Westwing Collection suppliers evaluated regularly on social topics by 2025: achieved at 99.9% (2024: 98%). 50% of suppliers by purchase-order volume (POV) with established Social Management Systems by 2028: at 31% (2024: 10%). 50% of suppliers by POV with working-condition improvement programmes by 2028: at 62% (2024: 76%, the apparent decline reflecting a stricter 2025 definition requiring completion of at least five social and three environmental training modules). 100% of third-party brands aligned with the Business Partner Code of Conduct by 2027: at 79% (2024: 66%).

Targets were set using Corporate Sustainability team expertise and benchmarking, informed by supplier/brand-partner feedback gathered during the materiality assessment rather than direct worker engagement, and tracked through KPI monitoring and audit review.

Reference: page 150

Westwing's consumer-facing policies are the Sustainability Policy, Responsible Marketing and Communication Policy (which "prevents misleading advertising and regulates marketing to vulnerable groups, including children"), Information Security Policy, Product Safety Policy (GPSR), and Human Rights Policy. Together they address health, safety, privacy, accessibility and product-quality commitments, aligned with the UNGP, ILO Declaration and OECD Guidelines.

These apply uniformly across all Westwing entities and regions, with expectations extended contractually to suppliers and business partners. Westwing relies on customer feedback channels rather than independent monitoring to surface human-rights concerns; "during the reporting year, there were no reported instances of non-compliance with the UN Guiding Principles on Business and Human Rights ... in Westwing's downstream value chain." Policies are hosted on the intranet and Policy Manager (with quiz-based confirmation for white-collar staff) and on the corporate website.

Reference: page 151

Westwing gathers consumer input through satisfaction surveys, product ratings and reviews, direct channels (email, phone, social media) and online return forms, primarily following purchase or customer-service interaction. Engagement KPIs – satisfaction, response times, social-media engagement – are reviewed monthly by the Executive Team, with bi-weekly feedback loops to Quality Managers across departments.

Responsibility is distributed: the Chief Commercial Officer oversees direct customer communication, the Chief Operations Officer supports B2B customers, and the Chief Marketing Officer's social-media team feeds insights into marketing strategy. Westwing states it "does not have a dedicated process for engaging vulnerable or marginalised customers, such as individuals with disabilities or children," and will "consider whether it would be necessary to establish such a dedicated process in the future."

Reference: page 152

Consumers can raise concerns through direct customer-communication channels or Westwing's whistleblower tool, which supports anonymous reporting with confidentiality maintained throughout; Legal, GRC and/or P&C teams review reports depending on topic, and whistleblowers may select which team reviews their case. Westwing states that "no adverse actions are taken against those who report in good faith," and that the number of whistleblower complaints is tracked and reported to the Management Board and Audit Committee.

Consumers in Westwing's operating regions can also access third-party mechanisms via governments, NGOs or industry associations; Westwing does not require business partners to maintain equivalent channels but expects Code-of-Conduct-aligned sustainability principles. Feedback effectiveness is assessed through defined issue-categorisation, trend-analysis and reporting processes rather than a dedicated trust survey.

Reference: page 153

For product-safety risk, Westwing Collection products undergo third-party physical/chemical testing and each product carries a consolidated Global Product Safety (GPSR) document within its Product Lifecycle Management (PLM) system; third-party products rely on brand-partner compliance rather than Westwing's own testing. For data protection, Westwing established a group-wide data retention and deletion framework, revised its AI governance guidelines in response to growing AI tool use, and conducts independent cybersecurity assessments. For sustainability-preference risk, Westwing expanded "WE CARE" product tagging and implemented a Sustainable Communications Plan.

Westwing "has not yet conducted a formal assessment of whether these processes are effective," relying instead on return data, customer feedback, response/resolution times and compliance checks to gauge effectiveness. No severe human-rights issues connected to consumers were identified in 2025 (2024: zero).

Reference: page 158

Westwing's single consumer target is to increase the share of Westwing Collection products tagged "WE CARE" (indicating a recognised sustainability certification or a defined minimum sustainable-material threshold) to 50% by 2027. Westwing has "already surpassed this target, with 71% of Westwing Collection products now carrying the 'WE CARE' tag" (2024: 66%), attributed to supplier engagement, expanded certification coverage and material assessments under its Sustainability Labelling guidelines.

Westwing states that "for the material IROs of product quality and safety, and data protection and customer privacy, Westwing has not set specific targets as of the reporting date." Target-setting relied on benchmarking, internal expertise and Executive Team/Sustainability Steering Committee input; Westwing does not engage directly with consumers in tracking performance, using customer-service feedback and satisfaction ratings as indirect proxies instead.

Reference: page 160

Westwing's Supervisory Board Audit Committee monitors compliance, risk management, internal controls and whistleblower cases, advising the Management Board, which holds day-to-day accountability. In 2025 Westwing introduced a new Culture Code with five principles ("We deliver exceptional results," "Being human is our superpower," "We do business creatively," "We act like business owners," "We apply a growth mindset"), anchored into hiring, onboarding and the People Performance Review process.

Business-conduct governance rests on the Westwing, Private Label Supplier and Business Partner Codes of Conduct and an Anti-Corruption Policy aligned with the UN Convention against Corruption, reflecting "a zero-tolerance stance towards corruption." A publicly available whistleblower tool, compliant with the EU Whistleblower Directive, supports confidential or anonymous reporting; the Legal team leads independent, impartial investigations. The VP Legal reports compliance ratios to the Management Board and quarterly to the Supervisory Board's Audit Committee, and 2025 saw ongoing compliance-awareness campaigns.

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-A/MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; the FY2025 statement was prepared under the 2023 ESRS.

Westwing states directly: "Westwing has not defined specific targets on business conduct, as its approach prioritises continuous compliance, governance oversight, and embedding ethical standards into day-to-day operations" (page 164). Consistent with MDR-T's other limb, effectiveness is tracked in the absence of a measurable target: compliance awareness campaigns run annually since 2024 to raise online-training completion; the Policy Manager records white-collar completion of Code of Conduct quizzes; and the VP Legal "reports on the compliance ratios to the Management Board, as well as submitting respective quarterly reports to the Supervisory Board's Audit Committee" (page 163). Whistleblower case volumes (four in 2025) are similarly tracked and reported to the Management Board and Audit Committee (S1-17, page 135; G1-1, page 160).