6. The undertaking shall disclose its business conduct policies in accordance with the provisions of ESRS 2 GDR-P.

7. In addition to the information required by ESRS 2 GDR-P, the undertaking shall disclose:

Footnote to paragraph 7(a)
This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts as set out by indicator #15 in Table 3 of Annex I of Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments ('Lack of anti-corruption and anti-bribery policies').

Footnote to paragraph 7(b)
This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts as set out by indicator #6 in Table 3 of Annex I of Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments ('Insufficient whistleblower protection').

AR 1 for para. 6 (corruption or bribery – definition)
For purposes of this Standard, the undertaking shall apply the ESRS definition of corruption and bribery (see ESRS Glossary), which is generic, to overcome the differing definitions found in local laws or in laws applicable in the jurisdiction of the parent company and to ensure comparability across reporting undertakings.

AR 2 for para. 7(b) (whistleblowers)
Undertakings that are subject to legal requirements under national law transposing Directive (EU) 2019/1937, or to equivalent legal requirements with regard to the protection of whistleblowers, can comply with the disclosure specified in paragraph 6(b) by stating that they are subject to those legal requirements.

AR 3 for para. 7(c) (corruption or bribery)
When disclosing information under paragraph 7(c), 'functions or roles most at risk' means those functions or roles deemed to be most at risk of corruption or bribery as a result of their tasks and responsibilities within the undertaking, such as those operating in high-risk countries or interacting with public authorities and governments.

Code of conduct and ethical guidelines

Our code of conduct and internal guidelines form the foundation of our corporate culture. They give direction and promote a way of working based on integrity, responsibility and the shared aim of ensuring ethical business practices. As a globally active company, we are aware of the far-reaching impact of our actions. We therefore commit to integrating into our processes the principles of the International Labour Organization (ILO) on fundamental rights and the guidelines of the Organisation for Economic Co-operation and Development (OECD) for multinational enterprises. We make sure that our activities and practices respect and promote the dignity, rights and wellbeing of all people in our value chain.

Anti-corruption and anti-bribery policy

Our anti-corruption and anti-bribery policy supplements our global code of conduct. It sets minimum standards to make sure that all company activities are carried out ethically and with integrity. The policy aims to ensure compliance with the applicable anti-corruption laws, both national and international. It clearly defines what is meant by bribery, corruption and improper payments, and it sets out which behaviour is acceptable.

In addition, giving and receiving gifts, and accepting or offering invitations or hospitality, are subject to specific approval requirements. Depending on the value of these benefits, approval is required, and it is granted through a dedicated registration tool. We have set country-specific limits for each national subsidiary to ensure transparency and compliance.

Whistleblowing policy

To strengthen our ethical principles, we have introduced a transparent and open reporting system. This system enables us to detect violations of the law at an early stage, act quickly, and continuously improve our operational processes and our internal control system. The whistleblowing system is a central part of our compliance culture and serves solely to promote compliant behaviour – it is not a system for punishment or sanctions.

Whistleblowers enjoy comprehensive protection through strict confidentiality and a ban on pressure or retaliation. This is further secured by a voluntary works agreement. Through a digital platform, we provide a secure and anonymous channel that meets the highest requirements for confidentiality and protection of identity. In this way, both the integrity of our company and the rights of whistleblowers are protected at all times.

Our compliance organisation and control mechanisms

We have established an independent compliance department that reports directly to the company management and operates across the group. This department is divided into several specialised teams, each responsible for specific compliance areas. Through clear responsibilities and deputising arrangements, we make sure that all regulatory requirements are met at all times.

Our compliance organisation includes teams that deal with general regulatory compliance, the prevention of financial and legal violations, and compliance with sanctions and embargoes. Each team is led by qualified experts who ensure the monitoring and implementation of the respective requirements.

Mechanisms for risk monitoring and prevention of misconduct

The compliance department plays a central role in identifying, reporting and investigating potential violations of applicable laws and internal policies. We have implemented a comprehensive system of policies, processes and control mechanisms that detects misconduct at an early stage, initiates the necessary consequences and, where required, informs the competent authorities. We pay particular attention to preventing corruption and bribery. For this purpose, we have introduced clear measures and procedures based on transparency and responsibility, in order to prevent unethical behaviour and promote a culture of integrity.