FULLTEXT DEL 5 AV 7
Årsredovisning 2024
Reference to related disclosures The Company’s disclosures regarding the recognition and measurement of provisions for warranty obligations are contained in section “32. Other provisions” of the notes to the consolidated financial statements. Accounting treatment of risks in connection with the EU antitrust proceedings Reasons why the matter was determined to be a key audit matter In 2011, the European Commission initiated fine proceedings on suspicion of breaches of European antitrust law in the European truck sector. By decision dated 19 July 2016, the fine proceedings against MAN and four other European truck manufacturers (with the exception of Scania) were concluded in a final and unappealable settlement. While the other four truck manufacturers were fined, MAN’s fine was waived under the leniency program. Scania was fined approximately EUR 880.5 m in a decision by the European Commission on 27 September 2017. The fine was paid in full fiscal year 2022. Following the fine decision, a significant number of customers in various jurisdictions initiated or joined lawsuits against MAN and/or Scania, claiming damages for potentially excessive prices. The claims differ significantly in scope. Furthermore, some truck cus - tomer damages claims have been combined in class actions or through claim aggregators to which the truck customers assigned their respective damages claims. As part of our audit, we determined this to be a key audit matter because the risk assess- ment and the amount of the provision to cover the aforementioned risks from civil proceedings are subject to a high level of uncertainty and are influenced by estimates and assumptions made by the executive directors with regard to the outcome of the proceedings. Auditor’s response As part of our audit procedures, we obtained an understanding of the process installed by the Group to deal with the facts of the civil lawsuits. We discussed with the executive directors and the Company’s legal department the estimates and assumptions made by the executive directors and the Company’s internal lawyers in connection with the current development and the reasons underlying these estimates and assumptions, and assessed them with the involvement of internal experts for antitrust law. We also discussed the development in the various countries arising from new judgments or additional claims with the executive directors and internal and external lawyers. In addition, we obtained quarterly confirmations from external lawyers and addressed the significant topics and developments in discussions with the external lawyers. The signif- icant results of various economic reports (party reports, court reports) were also explained to us in this context. For the discussions with the Company and the external lawyers, we also consulted relevant publications in the specialist literature and other sources such as databases. Where provisions were recognized and contingent liabilities disclosed for individual cases or in some countries, we reperformed the calculations and checked the underlying assumptions against the confirmations from external lawyers and the corresponding settlement agreements. Our audit procedures did not lead to any reservations relating to the accounting treatment of the provision for civil law risks from EU antitrust proceedings. Reference to related disclosures The Company’s disclosures regarding the accounting treatment of risks in connection with the EU antitrust proceedings are contained in sections “33. Other provisions” and “38. Litigation/legal proceedings” of the notes to the consolidated financial statements. Other information The Supervisory Board is responsible for the Report of the Supervisory Board in the 2024 Annual Report. The executive directors and the Supervisory Board are responsible for the declaration pursuant to Sec. 161 AktG [“Aktiengesetz”: German Stock Corporation Act] on the German Corporate Governance Code, which is part of the Corporate Governance Statement. In all other respects, the executive directors are responsible for the other information. The other information comprises the parts of the annual report listed in the appendix. 219 Further InformationConsolidated Financial Statements Sustainability StatementCombined Management Report Responsibility Statement and Independent Auditor’s Reports To Our Shareholders ===== SIDA 220 ===== Our opinions on the consolidated financial statements and on the group management report do not cover the other information, and consequently we do not express an opinion or any other form of assurance conclusion thereon. In connection with our audit, our responsibility is to read the other information and, in so doing, to consider whether the other information – is materially inconsistent with the consolidated financial statements, with the group management report or our knowledge obtained in the audit, or – otherwise appears to be materially misstated. Responsibilities of the executive directors and the Supervisory Board for the consolidated financial statements and the group management report The executive directors are responsible for the preparation of the consolidated financial statements that comply, in all material respects, with the IFRS Accounting Standards as adopted by the EU and the additional requirements of German commercial law pursuant to Sec. 315e (1) HGB, and that the consolidated financial statements, in compliance with these requirements, give a true and fair view of the assets, liabilities, financial position and financial performance of the Group. In addition, the executive directors are responsible for such internal control as they have determined necessary to enable the preparation of consolidated financial statements that are free from material misstatement, whether due to fraud (i.e., fraudulent financial reporting and misappropriation of assets) or error. In preparing the consolidated financial statements, the executive directors are responsible for assessing the Group’s ability to continue as a going concern. They also have the respon- sibility for disclosing, as applicable, matters related to going concern. In addition, they are responsible for financial reporting based on the going concern basis of accounting unless there is an intention to liquidate the Group or to cease operations, or there is no realistic alternative but to do so. Furthermore, the executive directors are responsible for the preparation of the group management report that, as a whole, provides an appropriate view of the Group’s position and is, in all material respects, consistent with the consolidated financial statements, complies with German legal requirements, and appropriately presents the opportunities and risks of future development. In addition, the executive directors are responsible for such arrangements and measures (systems) as they have considered necessary to enable the preparation of a group management report that is in accordance with the applicable German legal requirements, and to be able to provide sufficient appropriate evidence for the assertions in the group management report. The Supervisory Board is responsible for overseeing the Group’s financial reporting process for the preparation of the consolidated financial statements and of the group management report. Auditor’s responsibilities for the audit of the consolidated financial statements and of the group management report Our objectives are to obtain reasonable assurance about whether the consolidated finan- cial statements as a whole are free from material misstatement, whether due to fraud or error, and whether the group management report as a whole provides an appropriate view of the Group’s position and, in all material respects, is consistent with the consoli - dated financial statements and the knowledge obtained in the audit, complies with the German legal requirements and appropriately presents the opportunities and risks of future development, as well as to issue an auditor’s report that includes our opinions on the consolidated financial statements and on the group management report. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with Sec. 317 HGB and the EU Audit Regulation and in compliance with German Generally Accepted Standards for Financial Statement Audits promulgated by the Institut der Wirtschaftsprüfer ( IDW) will always detect a material misstatement. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic deci- sions of users taken on the basis of these consolidated financial statements and this group management report. 220 Further InformationConsolidated Financial Statements Sustainability StatementCombined Management Report Responsibility Statement and Independent Auditor’s Reports To Our Shareholders ===== SIDA 221 ===== We exercise professional judgment and maintain professional skepticism throughout the audit. We also: – Identify and assess the risks of material misstatement of the annual financial state - ments and of the group management report, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinions. The risk of not detecting a material misstatement resulting from fraud is higher than the risk of not detecting a material misstatement resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. – Obtain an understanding of internal control relevant to the audit of the consolidated financial statements and of arrangements and measures (systems) relevant to the audit of the group management report in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Group’s internal control and of such arrangements and mea- sures. – Evaluate the appropriateness of accounting policies used by the executive directors and the reasonableness of estimates made by the executive directors and related disclosures. – Conclude on the appropriateness of the executive directors’ use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Group’s ability to continue as a going concern. If we conclude that a material uncer- tainty exists, we are required to draw attention in the auditor’s report to the related disclosures in the consolidated financial statements and in the group management report or, if such disclosures are inadequate, to modify our respective opinions. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may cause the Group to cease to be able to continue as a going concern. – Evaluate the overall presentation, structure and content of the consolidated financial statements, including the disclosures, and whether the consolidated financial statements present the underlying transactions and events in a manner that the consolidated financial statements give a true and fair view of the assets, liabilities, financial position and financial performance of the Group in compliance with the IFRS Accounting Standards as adopted by the EU and the additional requirements of German commercial law pursuant to Sec. 315e (1) HGB. – Plan and perform the audit of the consolidated financial statements to obtain sufficient appropriate audit evidence regarding the financial information of the entities or business units within the Group to express opinions on the consolidated financial statements and on the group management report. We are responsible for the direction, supervision and review of the work performed for the group audit. We remain solely responsible for our opinions. – Evaluate the consistency of the group management report with the consolidated financial statements, its conformity with [German] law, and the view of the Group’s position it provides. – Perform audit procedures on the prospective information presented by the executive directors in the group management report. On the basis of sufficient appropriate audit evidence we evaluate, in particular, the significant assumptions used by the executive directors as a basis for the prospective information, and evaluate the proper derivation of the prospective information from these assumptions. We do not express a separate opinion on the prospective information and on the assumptions used as a basis. There is a substantial unavoidable risk that future events will differ materially from the prospective information. We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit. We also provide those charged with governance with a statement that we have complied with the relevant independence requirements, and communicate with them all relation- ships and other matters that may reasonably be thought to bear on our independence and where applicable, the related safeguards. From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the consolidated financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditor’s report unless law or regulation precludes public disclosure about the matter. 221 Further InformationConsolidated Financial Statements Sustainability StatementCombined Management Report Responsibility Statement and Independent Auditor’s Reports To Our Shareholders ===== SIDA 222 ===== Other legal and regulatory requirements Report on the assurance on the electronic rendering of the consolidated financial statements and the group management report prepared for publication purposes in accordance with Sec. 317 (3a) HGB Opinion We have performed assurance work in accordance with Sec. 317 (3a) HGB to obtain rea- sonable assurance about whether the rendering of the consolidated financial statements and the group management report (hereinafter the “ESEF documents”) contained in the file TRATON_SE_KA_ZLB_ESEF-2024-12-31 and prepared for publication purposes complies in all material respects with the requirements of Sec. 328 (1) HGB for the electronic report- ing format (“ESEF format”). In accordance with German legal requirements, this assurance work extends only to the conversion of the information contained in the consolidated financial statements and the group management report into the ESEF format and there- fore relates neither to the information contained within these renderings nor to any other information contained in the file identified above. In our opinion, the rendering of the consolidated financial statements and the group management report contained in the file identified above and prepared for publication purposes complies in all material respects with the requirements of Sec. 328 (1) HGB for the electronic reporting format. Beyond this assurance opinion and our audit opinions on the accompanying consolidated financial statements and the accompanying group management report for the fiscal year from 1 January to 31 December 2024 contained in the “Report on the audit of the consolidated financial statements and of the group management report” above, we do not express any assurance opinion on the information contained within these renderings or on the other information contained in the file identified above. Basis for the opinion We conducted our assurance work on the rendering of the consolidated financial statements and the group management report contained in the file identified above in accordance with Sec. 317 (3a) HGB and the IDW Assurance Standard: Assurance on the Electronic Rendering of Financial Statements and Management Reports Prepared for Publication Purposes in Accordance with Sec. 317 (3a) HGB (IDW AsS 410 (06.2022)) and the International Standard on Assurance Engagements 3000 (Revised). Our responsibility in accordance therewith is further described in the “Group auditor’s responsibilities for the assurance work on the ESEF documents” section. Our audit firm applies the IDW Standard on Quality Management 1: Requirements for Quality Management in the Audit Firm (IDW QMS 1 (09.2022)). Responsibilities of the executive directors and the Supervisory Board for the ESEF documents The executive directors of the Company are responsible for the preparation of the ESEF documents including the electronic rendering of the consolidated financial statements and the group management report in accordance with Sec. 328 (1) Sentence 4 No. 1 HGB and for the tagging of the consolidated financial statements in accordance with Sec. 328 (1) Sentence 4 No. 2 HGB. In addition, the executive directors of the Company are responsible for such internal control as they have determined necessary to enable the preparation of ESEF documents that are free from material intentional or unintentional non-compliance with the require- ments of Sec. 328 (1) HGB for the electronic reporting format. The Supervisory Board is responsible for overseeing the process for preparing the ESEF documents as part of the financial reporting process. Group auditor’s responsibilities for the assurance work on the ESEF documents Our objective is to obtain reasonable assurance about whether the ESEF documents are free from material intentional or unintentional non-compliance with the requirements of Sec. 328 (1) HGB. We exercise professional judgment and maintain professional skep - ticism throughout the assurance work. We also: – Identify and assess the risks of material intentional or unintentional non-compliance with the requirements of Sec. 328 (1) HGB, design and perform assurance procedures responsive to those risks, and obtain assurance evidence that is sufficient and appro- priate to provide a basis for our assurance opinion. – Obtain an understanding of internal control relevant to the assurance on the ESEF documents in order to design assurance procedures that are appropriate in the circumstances, but not for the purpose of expressing an assurance opinion on the effectiveness of these controls. 222 Further InformationConsolidated Financial Statements Sustainability StatementCombined Management Report Responsibility Statement and Independent Auditor’s Reports To Our Shareholders ===== SIDA 223 ===== – Evaluate the technical validity of the ESEF documents, i.e., whether the file containing the ESEF documents meets the requirements of Commission Delegated Regulation (EU) 2019/815, in the version in force at the date of the financial statements, on the technical specification for this file. – Evaluate whether the ESEF documents enable an XHTML rendering with content equivalent to the audited consolidated financial statements and to the audited group management report. – Evaluate whether the tagging of the ESEF documents with Inline XBRL technology (iXBRL) in accordance with the requirements of Arts. 4 and 6 of Commission Delegated Regulation (EU) 2019/815, in the version in force at the date of the financial statements, enables an appropriate and complete machine-readable XBRL copy of the XHTML rendering. Further information pursuant to Art. 10 of the EU Audit Regulation We were elected as group auditor by the Annual General Meeting on 13 June 2024. We were engaged by the Supervisory Board on 12 July 2024. We have been the group auditor of TRATON SE since fiscal year 2020. We declare that the opinions expressed in this auditor’s report are consistent with the additional report to the Audit Committee pursuant to Art. 11 of the EU Audit Regulation (long-form audit report). In addition to the financial statement audit, we have provided to Group entities the following services that are not disclosed individually in the consolidated financial statements or in the group management report: – Issuance of comfort letters for TRATON SE in connection with the EUR 12 b European Medium Term Notes (EMTN) Program – Audit of the remuneration report in accordance with Sec. 162 AktG – Global Business Services feasibility study for MAN Truck & Bus – Voluntary audits or reviews of annual financial statements Other matter – use of the auditor’s report Our auditor’s report must always be read together with the audited consolidated financial statements and the audited group management report as well as the assured ESEF docu- ments. The consolidated financial statements and the group management report converted to the ESEF format – including the versions to be published in the Unternehmensregister [German Company Register] – are merely electronic renderings of the audited consoli - dated financial statements and the audited group management report and do not take their place. In particular, the ESEF report and our assurance opinion contained therein are to be used solely together with the assured ESEF documents made available in elec- tronic form. German Public Auditor responsible for the engagement The German Public Auditor responsible for the engagement is Heiko Hummel. Appendix to the auditor’s report: 1. Parts of the group management report whose content is unaudited We have not audited the content of the following parts of the group management report: – The Corporate Governance Statement contained in the section “Supplemental Infor - mation on Fiscal Year 2024” of the group management report – The Nonfinancial Group Statement contained in the group management report Furthermore, we have not audited the content of the following disclosures extraneous to management reports. Disclosures extraneous to management reports are such dis closures that are not required pursuant to Secs. 315, 315a HGB or Secs. 315b to 315d HGB. – The section “Appropriateness and effectiveness of risk management” contained in the section “Report on Expected Developments, Opportunities, and Risks, 2. Report on opportunities and risks” of the group management report. 2. Further other information The other information also comprises other parts to be included in the annual report, of which we obtained a copy prior to issuing this auditor’s report, in particular the sections: – Section 1 To Our Shareholders – Section 4 Responsibility Statement – Section 5 Sustainability Report – Section 6 Further Information but not the consolidated financial statements, not the group management report disclo- sures whose content is audited and not our auditor’s report thereon. 223 Further InformationConsolidated Financial Statements Sustainability StatementCombined Management Report Responsibility Statement and Independent Auditor’s Reports To Our Shareholders ===== SIDA 224 ===== Assurance report of the Independent German Public Auditor on a Limited Assurance Engagement 3. Company information outside of the annual report referenced in the group management report The management report contains cross-references to webpages of the Group and the Group companies. We have not audited the content of the information to which these cross-references refer. Stuttgart, 17 February 2025 EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft Meyer Hummel Wirtschaftsprüfer Wirtschaftsprüfer [German Public Auditor] [German Public Auditor] Assurance Report of the Independent German Public Auditor on a Limited Assurance Engagement To TRATON SE Assurance conclusion We have conducted a limited assurance engagement on the disclosures in section EU- Taxonomy disclosures of the Combined Management Report of TRATON SE to fulfill the requirements of Art. 8 of Regulation ( EU) 2020/852 (“non-financial disclosures”) for the fiscal year from 1 January 2024 to 31 December 2024. Based on the procedures performed and the evidence obtained, nothing has come to our attention that causes us to believe that the accompanying non-financial disclosures for the fiscal year from 1 January 2024 to 31 December 2024 are not prepared, in all mate- rial respects, in accordance with the requirements of Art. 8 of Regulation (EU) 2020/852. Basis for the assurance conclusion We conducted our assurance engagement in accordance with International Standard on Assurance Engagements ( ISAE) 3000 (Revised): Assurance Engagements Other Than Audits or Reviews of Historical Financial Information issued by the International Auditing and Assurance Standards Board (IAASB). The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed. Our responsibilities under ISAE 3000 (Revised) are further described in the section “ German public auditor’s responsibilities for the assurance engagement on the non- financial disclosures.” 224 Further InformationConsolidated Financial Statements Sustainability StatementCombined Management Report Responsibility Statement and Independent Auditor’s Reports To Our Shareholders ===== SIDA 225 ===== We are independent of the Company in accordance with the requirements of European law and German commercial and professional law, and we have fulfilled our other German professional responsibilities in accordance with these requirements. Our audit firm has applied the requirements for a system of quality control as set forth in the IDW Quality Management Standard issued by the Institut der Wirtschaftsprüfer [Institute of Public Auditors in Germany] ( IDW): Requirements for Quality Management in the Audit Firm (IDW QMS 1 (09.2022)) and International Standard on Quality Management (ISQM) 1 issued by the IAASB. We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our assurance conclusion. Responsibilities of the executive directors and the supervisory board for the non-financial disclosures The executive directors are responsible for the preparation of the non-financial disclosures in accordance with the applicable German legal and European requirements and for designing, implementing and maintaining such internal control that they have considered necessary to enable the preparation of non-financial disclosures in accordance with these requirements that are free from material misstatement, whether due to fraud (i.e., fraudulent non-financial reporting) or error. This responsibility of the executive directors includes selecting and applying appropriate reporting policies for preparing the non-financial disclosures, as well as making assumptions and estimates and ascertaining forward-looking information for individual sustainability- related disclosures. The supervisory board is responsible for overseeing the process for the preparation of the non-financial disclosures. Inherent limitations in preparing the non-financial disclosures The applicable German legal and European requirements contain wording and terms that are subject to considerable interpretation uncertainties and for which no authorita- tive, comprehensive interpretations have yet been published. As such wording and terms may be interpreted differently by regulators or courts, the legality of measurements or evaluations of sustainability matters based on these interpretations is uncertain. These inherent limitations also affect the assurance engagement on the non-financial disclosures. German public auditor’s responsibilities for the assurance engagement on the non-financial disclosures Our objective is to express a limited assurance conclusion, based on the assurance engagement we have conducted, on whether any matters have come to our attention that cause us to believe that the non-financial disclosures have not been prepared, in all material respects, in accordance with the applicable German legal and European require- ments, and to issue an assurance report that includes our assurance conclusion on the non-financial disclosures. As part of a limited assurance engagement in accordance with ISAE 3000 (Revised), we exercise professional judgment and maintain professional skepticism. We also: – Obtain an understanding of the process for identifying the taxonomy-eligible and taxonomy-aligned economic activities and the corresponding disclosures in the non- financial-disclosures and of the internal controls relating to this process. – Identify disclosures where a material misstatement due to fraud or error is likely to arise, design and perform procedures to address these disclosures and obtain limited assurance to support the assurance conclusion. The risk of not detecting a material misstatement resulting from fraud is higher than the risk of not detecting a material misstatement resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations or the override of internal control. – Consider the forward-looking information, including the appropriateness of the under- lying assumptions. There is a substantial unavoidable risk that future events will differ materially from the forward-looking information. 225 Further InformationConsolidated Financial Statements Sustainability StatementCombined Management Report Responsibility Statement and Independent Auditor’s Reports To Our Shareholders ===== SIDA 226 ===== Summary of the procedures performed by the German public auditor A limited assurance engagement involves the performance of procedures to obtain evidence about the sustainability information. The nature, timing and extent of the selected procedures are subject to our professional judgment. In performing our limited assurance engagement, we – Evaluated the suitability of the criteria as a whole presented by the executive directors in the non-financial disclosures. – Inquired of the executive directors and relevant employees involved in the preparation of the non-financial disclosures about the preparation process and about the internal controls relating to this process. – Evaluated the reporting policies used by the executive directors to prepare the non- financial disclosures. – Performed analytical procedures and made inquiries about the disclosures on the taxonomy-eligible and taxonomy-aligned economic activities. – Performed selective testing and obtained evidence relating to the collection and reporting of the disclosures on taxonomy-eligible and taxonomy-aligned economic activities. – Considered the implementation of key management requirements, processes and data collection requirements through site visits to the selected locations. – Reconciled selected disclosures with the corresponding disclosures in the consoli - dated financial statements and the group management report. – Considered the presentation of the information in the non-financial disclosures. Restriction of use We draw attention to the fact that the assurance engagement was conducted for the Company’s purposes and that the assurance report is intended solely to inform the Com- pany about the result of the assurance engagement. As a result, it may not be suitable for another purpose than the aforementioned. Accordingly, the assurance report is not intended to be used by third parties for making (financial) decisions based on it. Our responsibility is to the Company alone. We do not accept any responsibility to third parties. Our assurance conclusion is not modified in this respect. General Engagement Terms and Liability The “General Engagement Terms for Wirtschaftsprüferinnen, Wirtschaftsprüfer and Wirtschaftsprüfungsgesellschaften [German Public Auditors and Public Audit Firms]” dated 1 January 2024, which are attached to this report, are applicable to this engage - ment and also govern our relations with third parties in the context of this engagement ( ey-idw-aab-en-2024.pdf). In addition, please refer to the liability provisions contained therein no. 9 and to the exclu- sion of liability towards third parties. We accept no responsibility, liability or other obliga- tions towards third parties unless we have concluded a written agreement to the contrary with the respective third party or liability cannot effectively be precluded. We make express reference to the fact that we will not update the assurance report to reflect events or circumstances arising after it was issued, unless required to do so by law. It is the sole responsibility of anyone taking note of the summarized result of our work contained in this report to decide whether and in what way this result is useful or suitable for their purposes and to supplement, verify or update it by means of their own review procedures. Stuttgart, 17 February 2025 EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft Hummel Hinderer Wirtschaftsprüfer Wirtschaftsprüfer [German Public Auditor] [German Public Auditor] 226 Further InformationConsolidated Financial Statements Sustainability StatementCombined Management Report Responsibility Statement and Independent Auditor’s Reports To Our Shareholders ===== SIDA 227 ===== Camburi Beach, São Sebastião – São Paulo, Brazil SUSTAINABILITY STATEMENT 1. General information 228 1.1. Basis for preparation of the sustainability statement 228 1.2. Double materiality assessment 228 1.3. Governance at TRATON 238 1.4. TRATON’s sustainability strategy 242 2. Environmental 250 2.1. Climate change 250 2.2. Pollution 259 2.3. Water 260 2.4. Biodiversity and ecosystems 261 2.5. Resource use and circular economy 262 3. Social 269 3.1. Own workforce 269 3.2. Workers in the value chain 279 3.3. Affected communities 284 4. Business conduct 287 4.1. Corporate culture 287 4.2. Prevention and detection of corruption and bribery 290 4.3. TRATON’s grievance mechanism 293 4.4. Political engagement 295 4.5. Supplier relationships and payment practices 296 5. Annex 298 5 ===== SIDA 228 ===== SUSTAINABILITY STATEMENT 1. General information 1.1. Basis for preparation of the sustainability statement The TRATON GROUP is, with its Scania, MAN, International, and Volkswagen Truck & Bus (VWTB) brands, as well as TRATON Financial Services, one of the world’s leading commer- cial vehicle manufacturers. Unless otherwise stated, the terms “ TRATON,” “Group,” and “Company” used in this sustainability statement refer to the TRATON GROUP. The Corporate Sustainability Reporting Directive (CSRD) was not transposed into national law in Germany in 2024. Nevertheless, TRATON has voluntarily prepared a sustainability report on a consolidated basis for the 2024 financial year. This report is not part of the combined management report and is therefore not audited and not fully ESRS-compliant. However, in our opinion, it largely fulfils the requirements of reporting in accordance with the European Sustainability Reporting Standards (ESRS). The reference table (see section “Reference table”) provides an overview of where disclosure requirements can be found in the report. The scope of consolidation corresponds to that of the consolidated financial statements and was determined based on the criteria of financial reporting, impact materiality and activities with operational control. TRATON reports key metrics to the Volkswagen Group, which are reviewed by a financial auditor in context of the preparation of their non-financial statement. In line with the ESRS, material impacts, risks and opportunities (IROs) have been identified through a double materiality assessment (DMA). If an IRO and thereby its overall sustain- ability matter has been identified as material, the corresponding section of the sustain- ability statement will detail the management of the sustainability matter and its IROs specifically. This includes reporting on related policies, actions, and targets, along with any relevant metrics where applicable. For the preparation of this sustainability statement, both the upstream and downstream value chain were considered when assessing the impacts, risks and opportunities beyond the Company’s own business area. The following information is incorporated by reference to parts of the combined man - agement report: – ESRS 2 GOV-3: “Remuneration Report” – ESRS 2 GOV-5: “Report on Expected Developments, Opportunities, and Risks” – ESRS 2 GOV-1.21, ESRS 2 GOV-1.23 and G1.5b: “Corporate Governance Statement” 1.2. Double materiality assessment 1.2.1. Processes to identify and assess material impacts, risks and opportunities To evaluate the impacts, risks and opportunities in accordance with the ESRS, the TRATON GROUP conducted its first double materiality assessment in 2024. This approach aims to identify and assess the materiality of sustainability matters in two dimensions: Impact materiality reflects the Group’s inside-out perspective and considers all positive and negative, potential, and actual impacts that the TRATON GROUP has on people and the environment. Financial materiality, on the other hand, reflects the outside-in perspective and considers all sustainability-related opportunities and risks that can influence the TRATON GROUP’s financial performance. A sustainability matter must be disclosed in the sustainability statement if it is material in at least one of the two dimensions. 228 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders 1. General information ===== SIDA 229 ===== Double Materiality Double Materiality Financial Materiality Impact Materiality Outside-in perspective Inside-out perspective Planet and Society General approach to the double materiality assessment The process for identifying and assessing IROs is applied consistently across all ESRS standards, ensuring a coherent approach to materiality assessment. It was carried out at Group-level and in close collaboration with all brands, iterating between Group and brand materiality to come to an aligned result. Methodology Methodology Double materiality Scale Scope RemediabilityFinancial effects Reputational effects Reputational effects How much will the issue affect TRATON’ s public image? Scope How widespread is the impact? Remediability How hard is it to counteract or make good the resulting harm? Financial effects How much will the issue affect TRATON financially? Scale How grave is the impact for society and the environment? Likelihood How likely is the issue to occur? Financial Materiality Impact Materiality Likelihood 229 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 230 ===== The TRATON GROUP’s own business activities and the upstream and downstream value chain were analyzed. Each IRO contains an indication of which part of the value chain is affected. The data gathering stage was the first step to gain a thorough understanding of all sustainability issues and ensure sufficient and adequate identification of actual and potential IROs. It comprised extensive desktop research, such as analyzing both external and internal reports and articles to include the perspectives of affected stakeholders. Some activities in the value chain (e.g., raw material mining) and geographies (e.g., con- flict and high-risk areas) led to more significant impacts, which were carefully considered as part of the materiality assessment. Further, workshops with internal stakeholders, for instance, from the Decarbonization core team, the Sustainability and the Governance, Risk and Compliance (GRC) team took place to represent their voices. These teams, com- prised of experts from all over the TRATON GROUP, were able to draw on insights from previous project work, which enabled a focused evaluation of each sustainability matter. Depending on the subject area, different topical experts were involved. Throughout the entire stakeholder engagement process, input was gathered from external and internal sources. In addition, input from Scania, MAN, International, and VWTB was gathered through a variety of channels, including interviews, consultations, outreach surveys, as well as an online questionnaire that received over 1,500 responses. To assess the materiality of potential and actual impacts, an impact risk score was calcu- lated based on likelihood and severity. The likelihood of each impact was rated from 2–10, with 2 being unlikely and 10 being a very likely or actual impact. The severity resulted from the average value of scale, scope, and in the case of negative effects remediability. The severity assessment levels were 0, 2, 3, 5, and 10, with 10 being the most severe factor (i.e., very high scale, global/total scope, and not remediable/reversible). Overall, an impact was material if the multiplication of severity and likelihood resulted in a risk score of 20 or more. In the event of a potential negative human rights impact, even if the likelihood was low, the impact has been reviewed and may be made material if deemed necessary. To determine financial materiality of potential risks and opportunities for the TRATON GROUP, the likelihood factor described above, as well as the magnitude – amount of the potential loss from a risk or gain from an opportunity – of the financial impact and the severity of the reputational effect were assessed. Magnitude and reputation effect were assessed in combination, whereby the magnitude had five (0, 1, 3, 5, and 10) and the rep- utation effect had four evaluation levels (0, 1, 5, and 10). However, with a weighting of 75%, the magnitude was significantly more decisive for the assessment of materiality than the reputation effect. The sum of the two factors was multiplied by the likelihood factor and the result ultimately determined the materiality. Overall financial materiality is established when the analysis results in a risk score of 20 or higher. In general, areas with a greater positive and negative impact on the environment and people are also more likely to represent higher financial risks and opportunities for the TRATON GROUP. Following the evaluation of which scores require further input through the confidence score, impact and financial materiality scores were compared. 230 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 231 ===== Impact, Risk and Opportunities Evaluation Methodology Financial Materiality Financial Effect & Reputation X =Likelihood Factor Financial Materiality Score The magnitude of the financial impact and the potential effect on TRATON’s reputation is considered. The likelihood factor for each risk and opportunity is assessed from unlikely to very likely. The risk or opportunity is material if the total score is above the materiality threshold. Evaluation of risks and opportunities Impact, Risk and Opportunities Evaluation Methodology Impact Materiality Severity Factor X =Likelihood Factor Impact Score Severity of each impact is calculated based on the average of scale, scope and remediability. The likelihood factor for each impact is assessed from unlikely to very likely. The impact is material if the total score is above the materiality threshold. Evaluation of positive and negative impacts To ensure the accuracy and reliability of the materiality assessments, several controls were implemented. The assessment was documented and stored. Access is limited to selected people and the document’s history is available to enable traceability. Plausibil - ity checks were done, in particular the results of the assessment were compared to the previous materiality assessment of the TRATON GROUP and other automotive industry players. The DMA was approved in accordance with the TRATON sustainability governance, ensuring review and verification through the hierarchy. Following the approval by the Sustainability Leadership Group in a workshop, it was presented to the Group Sustain - ability Alignment meeting before its approval by the TRATON Sustainability Board. The results were thoroughly discussed, and internal experts and external documentation used to ensure the reliability of the results. Interfaces between DMA and Enterprise Risk Management (ERM) have been defined for alignment. The IROs identified in the DMA are used as input for the ERM process, and the results of the ERM process are considered when updating the DMA. First completed in 2024, the DMA is scheduled for review in 2025. 231 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 232 ===== Project Workflows TRATON Materiality Working Group Runs materiality process according to CSRD and makes initial proposal of material topics for the TRATON GROUP, based on insight from all brands (Internal) Stakeholder Dialog Input Processing Brand Materiality Input External Information (written sources)/uni00A0 WWF Project Human Rights Salience Review/uni00A0 Project Workflows TRATON Human Rights Committee Salience review workshop Sustainability Leadership Group Final definition of material topics to take to board Group Sustainability Alignment Meeting Confirmation of material topics as proposed by SLG TRATON Sustainability Board Approval of final materiality results TRATON GROUP Materiality Additional considerations to the double materiality assessment Beyond the general DMA process for identifying and assessing IROs, for some ESRS stan- dards additional aspects were considered, which are outlined in the following sections. Climate-related scenario analysis In relation to physical risks, the TRATON GROUP has carried out an analysis to determine which production sites could be affected by physical climate risks. For these risks, the analysis covered the 22 of the Group’s 25 own production sites as well as major research and development sites. The focus of the analysis was on the relationship of these sites to battery electric vehicle (BEV) production. It should be noted that other locations, as well as the upstream and downstream supply chain, were not explicitly considered in this analysis. Going forward, the risk analysis will be expanded. No specific types of risk were excluded from the analysis. The analysis of physical risks was based on the Shared-Socioeconomic-Pathway 5 (SSP5) 8.5 of the 6th Assessment Report of the Intergovernmental Panel on Climate Change (IPCC) up to the year 2050 and thus assumes the highest assumed CO2 concentration according to the IPCC. In this scenario the global economy grows rapidly, the population increases moderately, and technological development advances quickly, but with a strong reliance on fossil fuels. This, in turn, leads to high energy demand and high greenhouse gas emissions in the long term if no climate protection measures are taken. SSP5-8.5 thus corresponds to the path with the highest greenhouse gas emissions compared to the representative concentration pathways overall. 232 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 233 ===== For the quantitative analysis, the TRATON GROUP considered a period until 2050 and formed statistical mean values of the SSP5-8.5 scenario for the countries examined, which indicate the probability of occurrence for various climate events. Specific climate hazards refer to multiple subordinated parameters, e.g., changing temperature refers to air, fresh- water, and marine water. For each hazard, an individual science-based threshold was determined to assess whether the climate risk is potentially material to make a well- founded assessment of the vulnerability of the TRATON GROUP’s global production sites to possible climate events. In a first step, the potential material risk on the economic activity or asset was assessed. To include the vulnerability, existing historical damage data as well as asset-specific characteristics and circumstances were considered, such as water consumption patterns or the structure of the building, including materials and stocks. In addition, risk-specific analyses were conducted with additional data sources based on the exact locations. All sites could be affected by potential material physical climate risks. A market model was developed that provides a comprehensive modeling tool for the analysis of all aspects of future development, especially market penetration of various alternative drivetrains. It has been used to compare the expected ramp-up to different climate scenarios, including 1.5, 1.7, and 2.0 degrees Celsius, yielding confidence levels of hitting the respective “fair share” of emissions – prior to or including industry-specific changes to targets. Also, for its qualitative scenario analysis, the TRATON GROUP looked at the period up to 2050 to evaluate pathways toward climate neutrality and net-zero CO2 emissions. The analysis aligns with the goals of the United Nations Paris Agreement, as TRATON is committed to significantly reduce greenhouse gas emissions from commercial vehicles to support global climate ambitions. In addition, the TRATON GROUP was able to differentiate the risk exposure to potential physical climate risks according to the nature and type of event. The relevance of the identified threats was assessed for the local environment and, if necessary, risk mitigation measures were developed. Regarding transition risks, the scenario analysis includes own operations and the value chain. Regarding production-related emissions, the analysis showed that a significant reduction in emissions is necessary to achieve the United Nations climate targets, partic- ularly by means of increasing BEV sales figures. Regarding the truck industry, the analysis has shown that electrification and the development of BEV will become paramount. These results are necessary to make an informed decision for sales planning and production. They are incorporated into the TRATON GROUP’s decarbonization scenarios. In addition, requirements and restrictions are derived for the TRATON GROUP to adjust the internal forecast and planning. In the reporting year, the information obtained was used to eval - uate decarbonization ambitions. The market and product-related outcomes substantiate and fortify the TRATON GROUP’s strategic commitment to substantial investments in electromobility and the enhancement of combustion engine efficiency. However, TRATON’s brands may vary in their development, timing, production and scaling of BEVs. All own assets, business activities, and key suppliers as well as business partners were evaluated for acute and chronic climate-related hazards. No assets or business activities that are incompatible with the transition to a climate-neutral economy have been iden- tified.The findings of the scenario analysis informed the DMA on climate-related risks and opportunities and were used to improve the resilience strategy of the Group. 233 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 234 ===== Do no significant harm assessment For the identification of IROs related to pollution as well as biodiversity and ecosystems, TRATON refers in addition to the general process to the results of the Do no significant harm ( DNSH) assessment for the EU Taxonomy (see the section on “ EU Taxonomy disclosures”). Beyond the general process for identifying and assessing IROs, the TRATON GROUP has not conducted a structured and complete screening of its assets, sites, and business activities to identify IROs related to pollution, water and marine resources, resource use, or the circular economy across its own operations and its upstream and downstream value chain. WWF study on nature risks For the identification of IROs and dependencies related to water and marine resources, as well as biodiversity and ecosystems, the TRATON GROUP used input from the study conducted by WWF Sweden (World Wildlife Fund). The study is titled “The Current and Future Nature Risks of the Commercial Vehicles Industry”. Systemic risks have not been considered at this time. Beyond the information provided by the project, the TRATON GROUP has not conducted further consultations with affected communities regarding biodiversity, ecosystem impacts, or sustainability assessments of shared biological resources and ecosystems. There are no activities related to sites negatively affecting biodiversity-sensitive areas. For sites located in or near biodiversity-sensitive areas, please refer to the section “Management of biodiversity and ecosystems”. Human rights salience assessment In 2023, the TRATON GROUP conducted a comprehensive human rights salience assess- ment to assess its impact on human rights across the entire value chain, focusing on the workforce, workers within its value chain, and affected communities. The process, finalized in 2024, identified key human rights impacts resulting from TRATON’s activities or business relationships. For more information, please refer to the section “Material impacts, risks and opportunities and their interaction with strategy and business model”. Beyond the general process for identifying and assessing IROs, the TRATON GROUP has not conducted a structured and complete screening of its assets, sites, and business activities to identify IROs related to pollution, water and marine resources, resource use, or the circular economy across its own operations and its upstream and downstream value chain. 234 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 235 ===== 1.2.2. Results of the double materiality assessment Sustainability matter Type Time Horizon Scope IRO E1 Climate change mitigation Actual negative impact Short-term Upstream, own operations and downstream Significant contribution to climate change through the use phase of our products Actual positive impact Short-term Upstream, own operations and downstream Implementing fuel efficiency measures and developing BEVs and alternative fuels reduces emissions Risk Short-term Upstream, own operations and downstream Challenges of BEV adoption due to lack of infrastructure, sufficient regulations, and incentives Opportunity Medium-term Upstream, own operations and downstream Unlocking market potential by transitioning to a low carbon economy Climate change adaptation Risk Long-term Upstream and own operations Damage to assets and supply chain disruptions due to extreme weather conditions and inadequate adaptation Energy Actual negative impact Long-term Upstream, own operations and downstream Reliance on fossil fuels contributing to climate change Risk Medium-term Upstream, own operations and downstream Insufficient infrastructure and high green energy costs. Energy price volatility and carbon pricing also add financial strain, and limited electricity access risks supply shortages E2 Pollution of air Actual negative impact Medium- and long-term Upstream, own operations and downstream Emissions from transportation and manufacturing release pollutants (e.g., particulates, nitrogen oxides) that degrade air quality and pose health risks Potential positive impact Medium-term Upstream, own operations and downstream Reduction of air pollution by adopting cleaner technologies and systems to control emissions Pollution of water Potential negative impact Short-term Own operations and downstream Potential release of pollutants into water bodies Substances of very high concern Potential negative impact Short, medium and long-term Own operations Use of substances of high-concern can harm the environment, workers and customers Microplastics Potential negative impact Short-term Downstream Microplastic release through tire and vehicle wear E3 Water Potential negative impact Short-term Upstream and own operations High water consumption in manufacturing and raw materials production 235 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 236 ===== Sustainability matter Type Time Horizon Scope IRO E4 Direct impact drivers of biodiversity loss Potential negative impact Long-term Upstream and downstream Promotion and contribution to adverse land use changes E5 Resources inflows, including resource use Actual negative impact Short-term Upstream High and non-renewable resource consumption Risk Short-term Upstream Rising resource costs and reliance on non-renewable resources pose financial and supply chain risks Resource outflows related to products and services Potential negative impact Short-term Downstream The improper disposal or recycling of vehicles can contribute to landfill waste, increased resource outflows, and the loss of valuable resources. Risk Medium-term Downstream Higher costs from circular design and energy-efficient technologies could impact profitability and market share. Opportunity Long-term Own operations Cost savings and enhanced reputation through circular product design and energy-efficient technologies Waste Potential negative impact Short-term Own operations Landfill waste and contribution to resource depletion due to significant waste generation S1 Working conditions Potential negative impact Short-term Own operations Damage on own workers’ well-being from adverse working conditions, discrimination, and poor safety practices Risk Long-term Own operations Staff turnover, productivity loss, and safety issues in own workforce resulting from adverse working conditions Equal treatment and opportunities for all Potential negative impact Short-term Own operations Negative effects from discrimination in employment like unequal training, promotion opportunities, pay, and benefits Other work-related rights Potential negative impact Short-term Own operations Privacy risks from excessive data access, lack of consent, and data leaks S2 Working conditions Potential negative impact Short-term Upstream Impact of adverse working conditions, occupational health and safety issues, and denial of freedom of association on workers in the value chain. Other work-related rights Potential negative impact Short-term Upstream Potential employment of underage workers and the use of forced labor within the value chain Risk Long-term Upstream Reputational damage, legal risks, and operational disruptions can arise from involvement in child and forced labor cases 236 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 237 ===== Sustainability matter Type Time Horizon Scope IRO S3 Communities’ economic, social and cultural rights Potential negative impact Short-term Upstream, own operations and downstream Harm due to inadequate protection of communities’ rights and vehicle misuse Risk Long-term Upstream, own operations and downstream Legal and reputational risks and operational disruptions from implication in human rights violations Road Safety & Privacy (Entity specific) Potential negative impact Short-term Downstream Data privacy violations from information gathered in vehicles. Safety risks from product defects or quality issues. Potential positive impact Short-term Downstream Increasing data security and road safety encourages privacy- conscious and safe driving behaviours. G1 Corporate culture Potential negative impact Short-term Own operations Disengagement of employees, lack of employee empowerment and motivation, potential unethical behaviour from weak corporate culture. Potential positive impact Short-term Own operations Aligning corporate culture with values and purpose inspires employees, promotes ethical conduct, and builds trust and reputation. Risk Short-term Own operations and downstream Reduced productivity, decreased efficiency, and higher employee turnover fostered by a negative corporate culture. Opportunity Short-term Own operations and downstream Increased productivity and competitiveness and reduced turnover costs from a positive corporate culture. Corruption and bribery Potential negative impact Short-term Upstream, own operations and downstream Corruption can weaken governance, harm environmental initiatives, and foster unfair competition. Management of relationships with suppliers including payment practices Potential positive impact Short-term Upstream and own operations Fair payments build supplier trust, improving loyalty, collaboration, and innovation. Political engagement Potential negative impact Long-term Downstream Threat to democracy and informed decision-making from opaque political involvement. Protection of whistleblowers Potential negative impact Short-term Upstream and own operations Lack of accessible grievance mechanisms may prevent stakeholders from voicing concerns or reporting rights infringements. Potential positive impact Short-term Upstream and own operations Implementing robust speak-up channels promotes trust and a transparent culture. 237 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 238 ===== 1.3. Governance at TRATON 1.3.1. Composition, diversity, and expertise of governance bodies Information on the composition, diversity, and expertise of the governance bodies of the TRATON GROUP is reported in the section “Corporate Governance Statement” of the “Combined Management Report”. 1.3.2. Sustainability management process The governance of sustainability topics and IROs identified through the double materi - ality assessment is organized through various boards, working groups, and reporting streams to ensure full alignment and the involvement of all relevant parties. The central Sustainability function at TRATON reports directly to the Chief Executive Officer and the other Truck Board members via the TRATON Sustainability Board and is responsible for coordinating sustainability management at TRATON. Developing TRATON’s sustainability strategy is a cross-functional task with responsibilities embedded in several central TRATON functions and at the level of the brands. The core committees and processes for sustainability management are: – The TRATON Sustainability Board (TSB) consists of the Truck Board, Heads of Sustain- ability at TRATON GROUP, and all brands and the Head of ESG. The TSB sets the overall direction and ambition level and approves commitments, group targets, and binding regulations. It also oversees the overall approach for managing impacts, risks and opportunities identified via the DMA. New programs and measures, commitments, and the DMA receive their final approval from the TSB and at the level of each brand. The TSB held four meetings in 2024 and approved in particular the material impact, risks and opportunities of the DMA. The outcomes of the TSB are documented through meeting minutes, signed by the CEO and the Chief Sustainability Officer. – The Sustainability Leadership Group ( SLG) consists of the Heads of Sustainability at TRATON GROUP and all brands. The SLG functions as the responsible interface to the brand sustainability functions. It aligns decisions with relevant Group, entity, and brand functions and can approve non-binding documents. Finally, the SLG is responsible for all materials developed for the TSB, informing the TSB, and implementing the decisions made by the TSB. Progress and deviations are tracked on a regular basis, both on Group and brand level. Each brand within the TRATON GROUP is solely responsible for the implementation of approved initiatives at the brand level. – The Group Sustainability Alignment Meeting (GSAM) consists of the Heads of Sustain- ability at TRATON GROUP and all brands and several relevant representatives of TRATON functions. All commitments, action areas, targets, binding, and non-binding regula - tions are aligned in GSAM before being presented to the TSB. These decisions are then communicated during the TRATON Sustainability Network Meetings, which occur quarterly. These meetings serve as an instrument to share information to sustainability topics within the group. Further communication is shared through relevant channels such as the intranet. Core committees and processes for sustainability management Su stain ability Leade rsh ip G rou p Su stain ability A lignm en t Meeting TR A TO N Su stain ab ility B oard Top Level Overall direction and ambition level High Level Strategy and Management 238 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 239 ===== Responsibility for sustainability matters lies also with the Executive Board. The Supervisory Board supervises these activities. Under German law the Supervisory Board and Executive Board are obliged to conduct a comprehensive evaluation of all relevant aspects includ- ing sustainability aspects when making business decisions. This ensures that all factors are taken into consideration and that decisions are made with the utmost care and dili- gence. Failure to do so may result in liability issues, as decisions made without proper evaluation may be deemed faulty. The Board is committed to upholding these rules and making informed decisions that benefit the Company and its stakeholders. Fundamental cornerstones of corporate governance, such as the Code of Conduct for employees and related procedures, are created and supervised with their involvement. Furthermore, the Head of ESG reports regularly to the Audit Committee of the Supervisory Board on the progress of the CSRD reporting. The Chairman of the Audit Committee then reports directly to the Supervisory Board based on the discussions and outcomes of these meetings. In addition to the ESG reporting structure, the Governance, Risk and Compliance ( GRC) organization plays a critical role in ensuring integrity across the TRATON GROUP. Managed by the Head of GRC/Chief Compliance Officer, the organization reports directly to the Chairman of the Executive Board and the Audit Committee of the Supervisory Board. The GRC organization oversees compliance, integrity, risk management, and data protection throughout the Group. Overarching management policies and concepts for sustainability The TRATON GROUP has overarching policies and concepts that provide a foundation for the overall management processes and apply comprehensively to all sustainability mat- ters. These policies ensure a consistent and integrated approach to decision-making on material sustainability measures across the Group. The overarching policies and concepts are outlined in the following sections. Besides these overarching policies and concepts, the TRATON GROUP has additional policies in place that relate to specific sustainability matters. These policies are described in detail in the sections dedicated to the respective ESRS standards in this sustainability statement. General management process for TRATON GROUP policies TRATON has implemented a general process for developing, implementing, and monitor- ing policies on Group-level. This process applies to all Group policies described through- out the report, which are clearly labeled as such. Where policies other than Group policies are described, such as guidelines or frameworks, their individual management processes are described. Group policies regulate substantial topics, thereby protecting employees and the orga- nization, avoiding risks, but also securing TRATON’s reputation and the Group’s assets. Topics that do not relate to any of these categories may be managed through other types of policies or processes. TRATON SE issues Group policies that set minimum standards and requirements for the TRATON brands and companies, but also apply directly to TRATON SE. TRATON brands can also issue further brand policies that apply to their affiliates in case of need. The Code of Conduct for employees serves as the superior governance regulation to which all policies must adhere. Once a new Group policy has been created and checked regarding appli - cable quality standards, it is submitted to the TRATON SE Executive Board for approval, which is, together with the policy owner, the most senior level accountable for the imple- mentation of the policy. After approval, the policy coordinators ensure publication via TRATON’s intranet. The policy coordinators submit the approved policy documents to their equivalents at brand or company level and request implementation within a time frame given. If needed for safeguarding the implementation or compliance, policy owners provide training and guidance for respective target groups of the policies. If applicable, the brands’ policy coordinators publish equivalent policies on the respective topic, and quarterly report the implementation status to TRATON. 239 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 240 ===== Policy owners must review their TRATON GROUP policies at least once a year to evaluate whether they need to be updated. Furthermore, they must assess the need for an amend- ment of existing regulations, or the introduction of new ones as soon as relevant parameters change. TRATON’s corporate audit department conducts audits of topics or processes based on its assessments and planning. It utilizes applicable policies and related govern- ing documents for such audits. TRATON Sustainability Group policy In 2024, the TRATON GROUP developed the TRATON sustainability Group policy, which is to be introduced in 2025. Its purpose is to enable TRATON GROUP to translate its sustain- ability purpose and ambitions into action and results. The policy will enable TRATON to set its own ambitions and priorities while also meeting stakeholder expectations and requirements. This policy defines the sustainability management model, the governance structure, and the roles and responsibilities for ensuring cross-brand collaboration at TRATON in terms of sustainability. TRATON sustainability management guideline This guideline clarifies TRATON’s sustainability management approach. In five steps, the TRATON sustainability management approach connects the efforts to set Group commit- ments and targets to the integration of sustainability into brands and functions. Model for Sustainability Management Prioritize and Commit 1. Enable Communication Capacity for transformative change 5. Monitor and Learn 4.Plan2. Integrate3. Model for Sustainability Management 1. Prioritize and Commit We always start by identifying where we have our biggest impacts and risks. We do this constantly and regularly, together with our whole ecosystem, to ensure that we focus on what matters most. Once we have done this, we prioritize and make a commitment to act on those impacts. Key processes in this step include stakeholder engagement and our materiality analysis. 2. Plan As the next step, we define the action we need to take. By defining an approach, setting requirements or targets, we will enable a better understanding of our impacts and drive action. This can be done on a brand or a Group level. 3. Integrate This is the key to reaching our sustainability ambitions, as we find the right ways to integrate commitments and targets into how we make decisions and operate. Here we rely on our whole organization and our partners to take decisive action towards fulfilling our commitments and targets. 4. Monitor and Learn We ensure that we monitor our progress and learn from our successes and mistakes. This is done within the existing governance structures of all functions, as well as through the TRATON Sustainability Board. 5. Enable Communication We communicate in a transparent way. We strongly believe transparency is key to credible sustainability management. We communicate both internally through various channels as well as externally, where our sustainability statement plays a key role. Overall, this approach helps to drive forward sustainability action within the whole TRATON GROUP, integrating ambitions into daily business. TRATON does not currently track the effectiveness of this policy, though the guideline provides a foundation for actionable impact and integration. 240 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 241 ===== Environmental compliance management system (Group policy) The Environmental compliance management system (ECMS) is a Group-wide policy that covers all environmental sustainability matters and, therefore, relates to all environmental IROs. The ECMS framework directs all TRATON GROUP companies to address environmen- tal management throughout all stages of their operations and the lifecycle of their prod- ucts and services with the goal of minimizing the environmental impact. By integrating compliance aspects into environmental management, the TRATON GROUP ensures con- formity with applicable regulations, uncovers possible misconduct, and prevents it in the future. The policy defines the minimum requirements for operating organizations to implement the ECMS, while providing the flexibility to tailor these requirements to the brands’ specific business needs. It outlines what is necessary for effective environmental compliance management, without prescribing how it should be carried out. In this way, it empowers each operating organization, regardless of size, location, range of activities, or degree of regulation, to identify, assess, and manage environmental aspects and risks. In line with the risk-based approach, this Group policy is divided into nine core premises: leadership and commitment; responsibility and accountability; compliance obligations; managing environmental aspects, risks, and opportunities; improving performance; awareness and competence; stakeholder dialog; evaluating performance; and managing non-compliance. These premises are aligned with internationally recognized standards, e.g., the ISO 14001:2015 and ISO 19011:2018, to enhance environmental compliance across the lifecycle of products and services. The effectiveness of the ECMS is tracked by evalu- ating risks, incidents, and audit findings from both internal and external audits conducted under ISO 14001:2015. These findings are reported annually by the brands to the Group and subsequently presented to the TRATON GROUP Truck Board as part of the annual management review. 1.3.3. Integration of sustainability-related performance in incentive schemes The integration of sustainability-related performance in the overall incentive schemes of the TRATON SE Executive Board is described in the section “Remuneration report”. 1.3.4. Statement on due diligence Core elements of due diligence Core elements of due diligence Reference to sections in the sustainability statement a) Embedding due diligence in governance, strategy and business model 1.3.2. Sustainability management process 1.4.3. Material impacts, risks and opportunities and their interaction with strategy and business model b) Engaging with affected stakeholders in all key steps of the due diligence 1.2.1. Processes to identify and assess material impacts, risks and opportunities 1.3.2. Sustainability management process 1.4.2. Stakeholder engagement 2. Environmental, specifically disclosures on policies 3. Social, specifically disclosures on policies 4. Business conduct, specifically disclosures on policies c) Identifying and assessing adverse impacts 1.2.1. Processes to identify and assess material impacts, risks and opportunities 1.4.3. Material impacts, risks and opportunities and their interaction with strategy and business model d) Taking actions to address those adverse impacts 2. Environmental, specifically disclosures on actions and targets 3. Social, specifically disclosures on actions and targets 4. Business conduct, specifically disclosures on actions and targets e) Tracking the effectiveness of these efforts and communicating 2. Environmental, specifically disclosures on targets and metrics 3. Social, specifically disclosures on targets and metrics 4. Business conduct, specifically disclosures on targets and metrics 1.3.5. Risk management and internal controls over sustainability reporting TRATON GROUP’s approach for risk management and internal controls regarding sustain- ability reporting, as well as a description of the main risks identified, are reported along- side the Group’s general risk management and internal controls processes in the section on “Opportunities and Risks” of the Combined Management Report. 241 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 242 ===== 1.4. TRATON’s sustainability strategy 1.4.1. Strategy, business model, and value chain At TRATON, our commitment to sustainability is reflected in our strategy and our corporate values. TRATON’s purpose is: Transforming Transportation Together. For a sustainable world. This is a commitment to build a profitable business by developing transport solutions fit for a sustainable society. TRATON Way Forward The TRATON GROUP’s strategy, the TRATON Way Forward, is based on a long-term vision that outlines how TRATON will address the challenges and the expected changes in the transportation and logistics industry. The TRATON Way Forward consists of three pillars, one of which is “Responsible Company”. This pillar guides TRATON in its commitment to act in a sustainable and responsible manner. The TRATON GROUP is strongly focused on achieving its environmental ambitions and strengthening sustainable conduct towards people; employees, customers, suppliers, and strategic partners. Responsibility is para - mount and should always guide our actions. Together with the brands, TRATON is inten- sively working on its purpose: “Transform Transportation Together. For a sustainable world”. TRATONs objective is to generate benefit for our customers and society across the entire life cycle of our products. “Responsible Company” also encompasses a corporate culture that prioritizes people and diversity. At TRATON, diversity extends beyond the traditional understanding, emphasiz- ing the inclusion of individuals with varied experiences, educational backgrounds, and personalities. To uphold responsible conduct, the Company also adheres to ethical prin- ciples in corporate governance. The TRATON GROUP intends to become even more respon- sible as a Company in every respect. Our joint impact areas play a key role in this endeavor. By focusing on these areas, we aim to drive significant positive change and ensure that our actions align with our commitment to responsibility and sustainability. TRATON’s joint impact areas The TRATON GROUP’s sustainability management approach outlines how TRATON trans- lates its sustainability purpose and ambitions into action and results in light of the sig - nificant societal and environmental challenges it faces. The significant impact of climate change on the natural world, human populations and society at large cannot be ignored. Biodiversity loss caused by various drivers such as unsustainable industry practices and agriculture further damages the resilience of societies. Further on, inequalities exacerbate the effects of climate change, causing disproportionate damage to the world’s most vulnerable livelihoods. The main challenges related to climate change are the high greenhouse gas (GHG) emis- sions from road freight, which need to be reduced immediately to align with the Paris Agreement. This requires the adoption and harmonization of stricter fuel economy stan- dards and incentives and infrastructure for zero-emission vehicles. Additionally, a signif- icant increase in renewable electricity supply and advancements in battery technology for truck electrification are necessary. A closely harmonised and coordinated approach and resources from large transportation companies and commercial vehicle manufac - turers are crucial to drive decarbonization and foster industry collaboration. Increased resource consumption further drives the triple planetary crisis of climate change, biodiversity loss, and pollution, and the transport sector is a significant contrib - utor. The Earth’s resources cannot sustain current consumption rates, leading to societal inequalities and higher costs. Urgent measures and regulatory frameworks are needed to curb resource exploitation. Transitioning to a circular economy, especially in wealthier countries, could reduce resource use, improve well-being, and stimulate economic growth. TRATON adopts a transformative approach to sustainability. This implies fundamental changes to products and services all the way to the relationships with suppliers, custom- ers, and partners, while ensuring relevance in the transition in the different parts of the world. The TRATON GROUP is active in shaping policies, practices, and collaborations to shoulder our responsibility for the systemic changes needed. However, these sustainabil- ity-related goals are not limited to any specific supplier, customer group, or geographical area, ensuring a broad and inclusive approach to driving transformation. 242 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 243 ===== Joint Impact Areas Decarbonization Reduce greenhouse gas emissions across the value chain in line with 1.5°C Circularity Decouple the use of resources from our business growth Human Rights Respect human rights and enable a just transition Joint Impact Areas For TRATON GROUP to stay focused and use its resources in a manner that creates the most impact, three joint impact areas have been identified: decarbonization, circularity, and human rights. They allow TRATON to address these areas in an integrated and efficient way, based on the sustainability management model. The joint impact areas also have a commitment that indicates the long-term objective and ambition of TRATON: Decarbonization: TRATON is committed to reducing greenhouse gas emissions across the entire value chain to support limiting the global temperature rise to 1.5 degrees Celsius above pre-industrial levels. A substantial portion of global GHG originates from the transport sector. TRATON is com- mitted to be part of the solution and aims to lead the decarbonization of the commercial vehicle sector. Recognizing that almost all of TRATON’s value chain emissions stem from the use phase of its products, TRATON is focusing on electrification as the most impactful lever to decarbonization. The Group aims to offer high-performance BEVs and comple- mentary services such as charging solutions and financing options. At the same time, TRATON keeps improving energy efficiency of vehicles using internal combustion engines. By forming partnerships and advocating for supportive regulations, the Group facilitate access to new technologies and infrastructure. Staying attuned to customer needs, TRATON strives for a low-carbon business model that provides a competitive advantage. Circularity: TRATON is committed to decoupling resource use from business growth. Circularity reduces reliance on finite natural resources, ensuring sustainable development throughout the vehicle life cycle. For TRATON, circularity is not just about doing less harm — it is about doing things differently and better. By adopting circular design , the Group aims to accelerate innovation, developing new products, services, and processes that are reducing and avoiding the virgin materials used, create more sustainable customer offer and aligned with future market demands. Electrification of vehicles not only lowers emis- sions but also reduces the resources used within the value chain. By forming partnerships and advocating for appropriate regulations, the TRATON GROUP wants to play its part in bringing about systemic change. Human Rights: TRATON is committed to respecting human rights and ensuring a just transition. The Group has taken steps to manage its own human rights impacts and is making great progress. Further work is aimed at understanding the impacts in its own operations and value chain, including the social dimension of the green transition. TRATON will place a strong focus on the supply chain and work closely with its own brands and partners to create a transparent, responsible and resilient value chain. Business model The business model of TRATON is centered on the development, production, and sale of commercial vehicles, including trucks, buses, and related services. It operates through a portfolio of well-known brands, including Scania, MAN, International, and VWTB. Each brand targets different market segments and regions, allowing TRATON to cater to a diverse customer base. 243 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 244 ===== Offering a wide range of commercial vehicles, from light to heavy-duty trucks and buses, this extensive product range enables TRATON to meet various transportation needs across different industries. In line with the sustainability-related strategies and ambitions of TRATON, in the reporting period, the GROUP continued its efforts to systematically shift investments from diesel powertrains to alternative drive systems. The TRATON brands are continuing to expand their product and service portfolio and supporting their customers in switching to BEVs. The most significant customers groups in this context are logistics and transportation companies, public transport authorities, and retailers. In a world driven by electrification, autonomous driving, and connectivity, the TRATON GROUP is committed to creating value through innovative business models, solutions, and partnerships. By expanding into logistics, customer solutions, and digital business models, the Group aims to maintain a competitive edge amid technological and market transformations. TRATON is even prepared to invest in charging infrastructure (see the section on “Management of climate change”). Additionally, the TRATON Financial Services segment provides comprehensive financing options for our customers to support new technologies and business models. For further information on TRATON’s business model and the brands’ positioning, see section “Key Information about the TRATON GROUP” of the “Combined Management Report”. Value chain The TRATON GROUP is a commercial vehicle manufacturer and has a widely branched and complex value chain. Both upstream and downstream process steps of this value chain are integrated vertically into the Company’s own operations, in addition to the core business. 244 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 245 ===== Value Chain Infographics Value Chain Infographics Upstream Tier N, 3, 2 Raw m a ter ia l s ext r a c t io n , in cluding tr a n s it io n m in e r a ls Supply chain All subsequent tiers up until 1 e.g. refiners, smelters, assembly subcontractor, contracted logistics Tier 1 Corporate offices Supporting services Production R&D Distribution dealership network and services Circular services Transport and logistics companies End of life services P rodu c t s , compon e n t s a n d se r v ic e s (g l o b a l a n d lo c a l p r o c u r e m e n t ) , in c lu d in g lo g is t ic s Corporate functions, procurement, human resources, etc. Manufacturing Sales, finance and insurance, rental and leasing services, repair and maintenance, driver training, fleet management Transport and logistic companies, truck drivers, etc. – Repair – Refurbish – Remanu- facture – Repurpose – Reuse Other companies’ value chains Technology development and integration Se r v ic e s b u s in e s s, fin a n c ia l s e r vic es – Product disposal – Recycle Core business P rodu c t u s e 245 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 246 ===== Upstream The upstream value chain includes the extraction of raw materials and the production of components and parts. TRATON maintains close relationships with a large number of suppliers who play a key role in the provision of raw materials and intermediate products. Core business/own operations TRATON operates its own production facilities and assembly plants in which essential components such as powertrains, transmissions, and chassis are produced, and complete vehicles are assembled. The core business includes the central activities of development, manufacturing, logistics, and sales of vehicles as well as related services. – Development In the development phase, TRATON conducts research and development activities in advanced technologies and innovative designs. – Manufacturing Production takes place in production facilities spread across key geographies. – Logistics Efficient logistics processes ensure integration of all steps, from purchasing, produc - tion, to delivery. – Sales Sales are carried out via a global dealer or distributor network. Parts of the TRATON dealer network are captive. Through TRATON Financial Services, customers can also benefit from financing solutions. Product use & end of life – Product use In the downstream value chain, the use phase and the associated services play a central role. The dealers and service partners offer comprehensive service and repair services, as well as digital services. – End of life The focus here is on the end of life, which includes today’s remanufacturing activities. In the future, battery recycling will likely play a role. As depicted in the value chain description above, TRATON relies on various inputs such as raw materials, components, technology, skilled labor, and financial resources to produce high-quality vehicles. These inputs are secured through strategic supplier relationships, investments in research and development, talent acquisition, and robust financial management. Compliance with regulations and the promotion of innovation are also important aspects of the approach to achieving and maintaining competitive advantages in the respective markets. The outputs of the TRATON GROUP, high-quality commercial vehicles and innovative technologies, offer significant benefits to various stakeholders. Customers enjoy reliable and cost-efficient vehicles that enhance their operations. Investors benefit from strong financial performance, market leadership, and growth driven by continuous innovation. Through TRATON’s investment in low and zero emission technologies, stakeholders as well as wider society and environment benefit from reduced environmental impact through innovative technologies. The TRATON GROUP thereby further supports our customers in meeting their sustainability goals and regulatory compliance. In 2024, TRATON did not generate any revenue from fossil fuels (coal, gas and oil) as defined by CSRD ESRS2 §40 d. Additionally, no revenue was generated from the manufacture of chemicals (pesticides and disinfectants), controversial weapons or the cultivation and production of tobacco. In general, none of TRATON GROUP’s products or services are banned in certain markets. They may be subject to current sanctions or embargos to which the Group adheres in line with applicable laws and regulations as well as internal policies (see also section “Affected communities”). 1.4.2. Stakeholder engagement As a global organization, the activities of the TRATON GROUP impact many individuals. Engaging with stakeholders is essential to identify key areas for the Group strategy and anticipate evolving expectations. TRATON sees stakeholder engagement as its duty to systematically and continuously interact with various interest groups, actively listen to their perspectives, and incorporate their feedback into the own strategy and business model. The goal is to maintain an open, constructive dialog with all stakeholder groups. 246 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 247 ===== To facilitate decision-making processes at TRATON GROUP, the following ten key stakeholder groups were identified as being of particular relevance in the context of sustainability: Customers, employees, society and media, investors, science and experts, competitors, business partners and suppliers, politics and associations, NGOs and NPOs, as well as residents and communities or local authorities. Engagement with these stakeholder groups is designed to foster open dialog, build trust through a variety of processes such as feedback mechanisms, collaborative initiatives, and transparent communication channels. For example, employees are engaged through the TRATON GROUP Works Council, ensuring a continuous exchange of perspectives across different regions. Investors are kept informed and involved through the Annual General Meeting, Investor Calls and Capital Market Days, which provide transparency and an opportunity to align on strategic priorities. In general, surveys and partnerships are used to gather insights and share knowledge across stakeholder groups, while active participation in alliances and networks fosters the exchange of expertise and innovative solutions. By integrating stakeholder perspectives into decision-making and maintaining open, ongoing communication, TRATON ensures that its strategies are both inclusive and aligned with evolving societal and environmental priorities. The frequency of engagement with stakeholders depends on the stakeholder group and engagement format. Some formats are conducted regularly while others depend on specific political, societal, or economic events. The purpose of these actions is to maintain an exchange in both direc- tions and generate insights on interests and views of stakeholder groups. These in return inform the strategy process and subsequently contribute to any changes made to con - tinuous development of the TRATON business model through the responsible functions, working groups and committees. Thereby, ultimately also the highest-level management bodies of the Group are informed about crucial views and interests of stakeholders. As the results of the DMA are incorporated into TRATON’s sustainability strategy, so are the key stakeholders’ views and interests, which were analyzed during this process. Thereby, the sustainability strategy and accompanying processes and guidelines are directly informed by stakeholders’ interests of sustainability matters. For 2025, TRATON plans to further elaborate guidance and actions of sustainability management, which will be thoroughly informed by stakeholder engagement processes performed by the responsible function. The integration of stakeholders’ interests into the DMA process is described in the section on “Processes to identify and assess material impacts, risks and opportunities”. The “human rights salience assessment” provided key insights into the interests, views, and rights of TRATON’s workforce, value chain workers, and affected communities. Beyond its contribution to material IRO evaluation, the assessment also indirectly shaped TRATON’s sustainability strategy and business model. 1.4.3. Material impacts, risks and opportunities and their interaction with strategy and business model In the reporting period 2024, TRATON has taken significant action and outlined plans to address material impacts, risks and opportunities. These efforts and their effects on business model, value chain, strategy, and decision-making of TRATON GROUP are com- prehensively described in the sections “Environmental”, “Social”, and “Business conduct”. All the reported IROs are rooted in TRATON’s core business model, which is outlined in section “Strategy, business model, and value chain”, and occur along the entire value chain. The material impacts are intricately connected to TRATON’s Way Forward strategy through the “Responsible Company” pillar. Additionally, they align with the joint impact areas: decarbonization, circularity, and human rights. Using the TRATON sustainability management process (see the section on “ Sustainability management process” ), impacts, risks and opportunities are integrated into decision-making. Based on the commitments made to the three joint impact areas, these commitments are translated into action. 247 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 248 ===== This can be done through: – Group-level targets, which shall be considered in all relevant decision-making, includ- ing in brands and functions. – Group-level binding policies and procedures (e.g. standards, minimum requirements), which shall apply in all relevant decision making in the specified area. – Group-level non-binding guidance (e.g., recommendations, handbooks), which can be applied on a voluntary basis. These are integrated into existing operations to drive action and ensure progress. The TRATON GROUP consists of a complex web of processes and decisions that make up the foundation from which we can take strategic and operational action. Integration is pos- sible when Group-level commitments and targets become actionable by successfully implementing them into existing accountabilities and responsibilities of relevant brands and functions, ensuring they are considered during decision-making. All functions need to be aware of their impact on the Group targets and relation to Group requirements, ensure alignment to these, and request the information needed to act and reach the targets. Current financial effects of TRATON’s material risks and opportunities on its financial position are described in the section on “Report on Expected Developments, Opportu- nities, and Risks” of the “Combined Management Report”. Resilience analysis The resilience of the strategy and business model to climate change is contingent upon their ability to manage climate-related risks and leverage climate-related opportunities. This includes the capacity to respond to and adapt to transition risks and physical risks. Climate-related resilience is comprised of both strategic resilience and operational resil- ience to climate-related changes, developments, or uncertainties related to climate change. During the DMA, TRATON identified the following IRO regarding physical risks: Damage to assets and supply chain disruptions due to extreme weather conditions and inadequate adaptation. Furthermore, one IRO was identified regarding transition risks: Insufficient infrastructure and high green energy costs. Energy price volatility and carbon pricing also add financial strain, and limited electricity access risks supply shortages. The resilience analysis was performed in 2023 with consideration of the climate scenario analysis. For further information on the scope of the analysis, see the section on “ Processes to identify and assess material impacts, risks and opportunities”. The majority of pro - duction sites as well as some R&D sites were included in the resilience analysis due to an initial risk assessment. Other locations and the upstream and downstream supply chain were not explicitly taken into account. All evaluated sites could potentially be affected by material physical climate risks. Other material risks that occur at more sites include land- slide, soil erosion, cold wave, heat stress, heat wave, permafrost thawing, drought, wildfire, heavy precipitation, flood, water stress, storm, and tornado. The identified threats were then checked for relevance in the local environment and, if necessary, measures to reduce the risk were developed. However, none were considered critical. The time horizons uti- lized for the scenarios in the resilience analysis align with the short-, medium-, and long- term time horizons defined for reporting purposes. The short-term period for this analysis was one year, the medium-term time horizon included an analysis of two to five years, and the long-term horizon was conducted for a period exceeding 5 years. To identify the relevant IROs, TRATON has investigated potential mitigation measures and adaptation strategies. The implementation of the defined measures, as part of the decarbonization strategy, is still underway. As the measures will come into effect from 2025 onwards, the effect on negative impacts and risks is not yet measurable in the reporting year 2024. Nevertheless, the agreed measures should foster greater awareness within the Group, which will facilitate the effective implementation of the measures from 2025. In the medium term, TRATON plans to implement measures focusing on renewable energies and BEVs. Going forward, TRATON will closely monitor new developments in the field of sustainability and review our existing measures for potential improvement. 248 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 249 ===== Own workforce TRATON conducted a human rights salience assessment to capture all aspects of the interaction of human rights with its business model and strategy. Focusing on the areas that are affected by TRATON’s business model, it highlights opportunities for mitigating the negatives as well as create value for people and society. This assessment also serves as a base to further develop the sustainability strategy and specifically the joint impact area of human rights, which ensures the reflection of views, interests, and rights of affected communities in the strategy. Additionally, it has enabled TRATON to identify certain groups within its workforce who may be at greater risk of harm, with particular attention given to vulnerable groups. The material risk of staff turnover, productivity loss, and safety issues in own workforce resulting from adverse working conditions relates to all employees, some groups in TRATON’s workforce may be more vulnerable to these risks and opportunities due to economic, political, and social processes of exclusion and could be disproportionately affected by TRATON GROUP’s operations and value chain. The risk analysis of TRATON GROUP’s own business areas has neither identified a risk of incidents of forced or compulsory labor nor a risk of incidents of child labor. Therefore, there are no specific types of operation, countries, or geographies considered at signifi- cant risk. Nevertheless, due to the global activities of TRATON, the Group operates in countries with significant social, political or economic instability, conflict regions, or high- risk areas, among others. Such an environment, despite all efforts, could complicate TRATON GROUP’s commitment to complying with international standards around the world. Workers in the value chain The material IROs in the context of value chain workers are strongly connected to the “Responsible Company” pillar of the TRATON Way Forward strategy and the joint impact area of human rights. Based on the human rights salience assessment, TRATON developed an understanding of how particular value chain workers may be at greater risk of harm. TRATON’s dependency on value chain workers led to the identification of two material IROs in the area of other work-related rights of value chain workers. The negative impacts on value chain workers evaluated as material in the DMA are rather widespread and systemically rooted in raw materials supply chains, such as extraction and processing of critical minerals and metals, that TRATON depends on and do not relate to specific incidents. Additionally, vulnerable workers at dealerships face systemic risks, making them more prone to negative impacts. While the analysis considered both pos- itive and negative impacts, no significant positive impacts related to value chain workers were identified during the assessment. During the DMA and based on the results of the human rights salience assessment, only workers in the upstream value chain were identified to be potentially impacted materially, with workers in the raw materials supply chain at greater risk of being negatively impacted. In general, certain raw material mining in certain regions are more at risk of child and forced labor, particularly in cobalt mining sites in the Democratic Republic of the Congo. For more details on the human rights salience assessment, please see the section on “Management of working conditions and other work-related rights of workers in the value chain”. 249 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 250 ===== 1 The terms CO2/CO2-equivalents/GHG emissions are used interchangeably throughout this statement. They refer to the GHG listed under the Kyoto Protocol: CO2, N2O, CH4, SF6, Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs). Affected communities The human rights salience assessment was carried out for various groups of rightsholders, one of these groups being local communities surrounding TRATON’s operations and supply chain, who may be impacted by activities such as production or mining of raw materials. The Group therefore identified a material legal and reputational risk of potential impacts on local communities caused by operations of TRATON. Affected communities in scope of this report are all communities affected by material IROs. The following were identified as affected communities in scope of disclosures of this report: 1. Rightsholders affected by crimes and illegal activities facilitated by TRATON’s vehicles such as illegal logging, mining, robberies, terrorist attacks, kidnappings, or human trafficking may experience impacts on their health, living standards, personal security, and life. In conflict zones, misuse of TRATON GROUP’s vehicles may exacerbate these impacts, while in authoritarian states, it could affect political expression and personal liberty. 2. Rightsholders in communities near operations of TRATON or along the supply chain may face impacts from activities like mining. 3. Primary users of TRATON’s vehicles, such as drivers, may have their privacy impacted if smart systems collect data like location history or health information without consent. This also applies to connected devices and vehicle cameras. 4. Drivers and passengers of TRATON vehicles may experience impacts to their right to health, safety, and life if there are accidents associated with poor product or road safety. Other rightsholders that may be involved in accidents with TRATON vehicles, such as pedestrians or passengers in other vehicles, may also experience impacts to health, safety, and life. The material negative impacts on affected communities identified in the DMA are wide- spread and do not pertain to specific incidents or business relationships. The identified risk of legal and reputational risks and operational disruptions from implication in human rights violations may arise from dependencies of TRATON GROUP on communities located near its operations or within its supply chain, potentially leading to disruptions that affect business continuity and local stakeholder relations. The material impacts in the area of product misuse are reflected in our recently introduced strategic work on conflict and high-risk areas, which is described in the section on “Affected communities”. 2. Environmental 2.1. Climate change Our TRATON Way Forward strategy (see the section on “TRATON Way Forward”) empha- sizes our commitment to sustainability. It serves as a catalyst for change within a global industrial and transportation ecosystem undergoing a critical transformation. This is reflected through the joint impact areas of decarbonization and circularity, through which TRATON aims to transform the business model and product design to reduce greenhouse gas (GHG) emissions 1 in line with the Paris Agreement. The TRATON GROUP is thereby striving to contribute to keeping the global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and pursuing efforts to limit the temperature increase even further to 1.5 degrees Celsius. Aligned with this strategy and regulatory requirements, TRATON GROUP is committed to playing an active role in shaping the future of transportation by driving innovation in cleaner, sustainable mobility solutions. This includes not only reducing emissions but also setting new standards for efficiency, safety, and circularity in the transport sector. Achieving these goals requires close collaboration with governments, businesses, cus - tomers, and other stakeholders. Stringent regulations in the EU and US are already driving change, and TRATON is advocating for market conditions that support the decarbonization of global transportation. 250 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders 2. Environmental ===== SIDA 251 ===== 2.1.1. Management of climate change During the double materiality assessment, the sustainability matters of climate change mitigation, climate change adaptation, and energy were identified as material for the TRATON GROUP. Policies Material impacts, risks and opportunities that specifically relate to change mitigation and energy are managed through the policies and concepts described below. At present, no Group policies relate to climate change adaptation, as we have not yet initiated a strategic approach to this sustainability matter. The actual positive impact of reducing fossil fuel use through the development of battery electric vehicles (BEVs) and the adoption of alternative fuels to reduce emissions in our vehicles is related to the TRATON sustainability management guideline, in conjunction with the sustainability management process, which also relates to the challenges associated with BEV adoption due to lack of infrastructure, sufficient regulations, and incentives. The TRATON sustainability management guideline, in conjunction with the sustainability management process, as well as the Code of Conduct for suppliers and business partners further relate to the actual negative impacts of the transport industry as a significant contributor to climate change through the use phase of TRATON’s products and its heavy reliance on fossil fuels, as well as the opportunities to unlock market potential by transi- tioning to a low carbon economy through the adoption of low-emission and sustainable transport solutions. The guidelines for renewable and fossil-free electricity also relate to addressing the actual negative impact of reliance on fossil fuels, which is contributing to climate change. Further information on the TRATON sustainability management guideline and the sus - tainability management process is available in section “Sustainability management process”. Additional details on TRATON’s Code of Conduct for suppliers and business partners can be found below and in the section on “Management of relationships with suppliers”. Concepts for climate change In 2024, the following concepts related to climate change were implemented through the TRATON sustainability management guideline in conjunction with the sustainability management process. To strengthen its decarbonization efforts, TRATON GROUP established key levers for decar- bonization. Also, a net-zero feasibility project was initiated to build upon brand-specific decarbonization activities, examining the effects of different levers and sales forecasts on overall emissions. This study also provided recommendations for measures to support further progress in emissions reduction. Additionally, TRATON developed a GHG emissions forecast for its own operations (Scope 1 and 2) and for emissions associated with the use phase of its vehicles (Scope 3, Category 11). Potential decarbonization measures were examined for both operational emissions and vehicle use phase emissions, with the elec- trification of the product portfolio highlighted as a critical approach to reduce emissions. Lastly, principles for materials decarbonization in the supply chain were established, providing a structured approach to addressing emissions related to materials sourcing. The TRATON Sustainability Board played an active role in these efforts by defining spon- sors for sustainability matters to ensure effective implementation and accountability. Guidelines for renewable and fossil free electricity The Guidelines for renewable and fossil free electricity outline the commitment of the TRATON GROUP to reduce GHG emissions by transitioning to renewable and fossil-free electricity sources throughout the value chain. Renewable electricity sources such as wind, solar, sustainable hydropower, certified biomass, geothermal, and marine energy are preferable. While nuclear power is considered as a fossil-free option, it is only accept- able when renewable options are unavailable due to business, infrastructural, or regula- tory constraints. The policy prioritizes on-site electricity generation, followed by off-site generation through investments in renewable projects and contractual solutions for renewable energy procurement. Wherever possible, electricity from renewable sources should be sourced within the same interconnected grid, enhancing the local impact and reliability of renewable electricity use. 251 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 252 ===== For monitoring purposes and to track the effectiveness of this policy, a uniform reporting system is planned for all sites across the brands and the entire TRATON GROUP. This policy applies globally to all TRATON brands, while allowing for regional and operational flexibility in relation to variations in geography, regulatory environments, and business needs. Exceptions are made only when renewable energy sources are inaccessible, in which case nuclear power may be temporarily used with prior consultation from the TRATON Energy department. The Chief Sustainability Officer of TRATON GROUP holds the highest level of accountability for this policy. This guideline is distributed to all TRATON brands and is scheduled for integration into TRATON’s overarching sustainability docu - mentation. The criteria for implementation are aligned with the Scope 2 Guidance of the GHG Protocol and the Technical Criteria of the Renewable Energy Initiative RE100. Com- pliance and transparency are ensured through third-party audits, which also prevent double counting of renewable energy attributes. To support implementation, particularly for regional operational units, the TRATON GROUP Sustainability department offers direct guidance on selecting and procuring renewable and fossil-free electricity. Code of Conduct for suppliers and business partners (Group policy) The Code of Conduct for suppliers and business partners requires that business partners take appropriate measures to reduce air emissions that pose risks to the environment and health, including greenhouse gas emissions. To improve the environmental perfor - mance of products and services, business partners provide for proactive reduction of greenhouse gas emissions along the entire value chain, for instance through increased use of fossil-free energy sources. Business partners who supply products to TRATON pro- vide information to TRATON on request at product level in relation to the overall energy consumption in MWh and greenhouse gas emissions in tonnes of CO2-equivalents (Scope 1, 2 and 3) This enables TRATON to improve the environmental performance indicators of its products. In addition, TRATON business partners are recommended to set science-based and emission reduction targets as well as targets for the use of renewable energy that are aligned with the Paris Agreement. Business partners are also encouraged to take action to drive decarbonisation throughout the value chain. Business partners are also encouraged to commit to the Paris Agreement of a carbon-neutral economy by 2050 at the latest. Further information on TRATON’s Code of Conduct for suppliers and business partners is available in section “Management of relationships with suppliers”. Actions and targets As of the 2024 reporting period, the TRATON GROUP has not yet defined specific actions, targets or a comprehensive transition plan. The focus has been on identifying decarbon- ization levers, which are described in detail in this section as the foundation for climate change mitigation efforts. These levers serve as a preliminary stage. The aim is to develop these levers into specific actions and targets, with a focus on driving meaningful progress, while taking into account the potential development of a transition plan. The operational implementation of the respective measures is currently the responsibility of each brand individually, allowing them to manage decarbonization efforts tailored to their specific circumstances. The main levers are divided into the own operations of TRATON GROUP, focusing on actions related to Scope 1 and Scope 2 emissions, and the use phase, addressing actions related to Scope 3 emissions in the context of climate change mitigation. Of the levers for use phase-related GHG emissions, the most prominent lever is the future production of battery electric vehicles, which is central to the decarbonization efforts. Additional levers include improving the energy efficiency of internal combustion engine vehicles, enabling use of renewable fuels, and creating partnerships for charging infrastructure. Key levers for own operations include renewable electricity, electrification, and renewable heat, as well as electrification and fuel switching for the company’s own trucks and cars. 252 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 253 ===== Decarbonization – Focusing on What Matters Most Decarbonization Focusing on What Matters Most Supply chain Raw material extraction and refining * Scope 1 and 2: in-house production, owned dealership network, own offices, own inbound and outbound logistics Components production (e.g. batteries) In-house production Dealership, inbound and outbound logistics* >97% of value chain emissions Maintenance Landfill, reuse, remanufacture, recycle Product lifecycle Production, other own operations* Distribution Use phase Services and end of life * Scope 1 and 2: own production, own offices, own inbound and outbound logistics Production of battery electric vehicles The TRATON GROUP has been accelerating its investment in BEVs to reduce reliance on diesel engines. TRATON is introducing a large range of battery electric trucks and buses to the market, with a focus on long-haul electric solutions equipped with fast-charging capabilities. The company’s own progress in this area is measured by the ratio of BEV and fuel cell electric vehicles sold to the total number of all vehicles sold, excluding the MAN TGE model (see the section on “Financial management”), as well as measuring the GHG emissions coming from the overall product portfolio. TRATON GROUP further aims to lower the total cost of ownership (TCO) for electric trucks and buses. The brands offer consulting services to fleet operators, helping them evaluate the operational savings BEVs can deliver, including reductions in maintenance and fuel costs. Improving energy efficiency of internal combustion engine vehicles By enhancing the efficiency of internal combustion engines ( ICEs), the TRATON GROUP reduces fuel consumption and GHG emissions as it transitions to full electrification. The TRATON GROUP is developing advanced combustion technologies to achieve better fuel consumption and lower emissions. Advanced engineering and leveraging digital solutions to monitor and adjust engine performance in real time, optimizing fuel use based on load and topography, results in more efficient energy use and minimized emissions. These innovations enable the TRATON GROUP to deliver immediate emission reductions through enhanced ICE efficiency while advancing toward a fully electric future. Enabling use of renewable fuels To enable the use of renewable fuels, TRATON GROUP is making its vehicles’ engines compatible with renewable fuels, such as biodiesel and biogas, which can achieve lower CO2 emissions compared to traditional diesel if sustainably sourced biofuels are used. Partnerships for charging infrastructure For the TRATON GROUP, the introduction of electric trucks, especially for long-haul and heavy-duty applications, would not be possible without a robust charging network. The TRATON GROUP’s key initiatives in this area are TRATON Charging Solutions, strategic partnerships, direct investments and the development of new technologies. 253 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 254 ===== TRATON Charging Solutions focuses on simplifying access to the charging infrastructure by providing reliable charging services for commercial vehicle operators. The network currently comprises around 150 locations and over 400 charging points across 19 Euro - pean countries. The objective is to cover the entire EU by 2025 and support the increasing spread of battery-electric commercial vehicles with scalable, sustainable solutions. To further strengthen its charging network, TRATON Charging Solutions has partnered with Hubject, a leader in eRoaming technology. Since 2023, this collaboration has focused on aligning data model requirements for EU charging points, ensuring the network meets fleet operators’ needs while paving the way for broader global opportunities. Additionally, the TRATON GROUP, in partnership with Daimler Truck and Volvo Group, has launched a high-performance charging network across Europe through their joint venture, Milence. This initiative aims to establish an electric corridor for long-haul trucking by installing a significant number of high capacity charging points along key transport routes and near logistics hubs. Joint investments of €500 million have been allocated for the construction of at least 1,700 charging points for heavy trucks and coaches by 2027. The first charging site was inaugurated on December 7, 2023, in Venlo. In 2024, additional locations were added in Belgium, Germany, France, and Sweden. By the end of 2025, Milence plans to have over 70 sites operational. Despite progress in regulatory frame - works, infrastructure remains a critical barrier to the widespread adoption of BEVs. Through Milence, TRATON is addressing these challenges by focusing on the development of both public and depot charging solutions. This network is designed to accommodate heavy-duty trucks and provide fast-charging capabilities, thereby reducing downtime for fleet operators. Renewable electricity The majority of the TRATON GROUP’s European production sites are already utilising elec- tricity from renewable energy sources. The remaining sites are scheduled to transition to renewable energy sources in the coming years. Electrification and renewable heat When it comes to electrification and the supply of renewable heat, there are various considerations for replacing the existing fossil energy sources. Depending on local requirements, geothermal energy, biogas, or hydrogen are being considered. A timeframe by which all our locations will be converted to renewable energy sources for heat supply has yet to be defined. Electrification and fuel switching In addition, the electrification and transition to alternative fuels for the company’s own fleet is being driven forward. For the company’s own trucks and cars, a steady increase in the proportion of the battery and alternative fuel-powered fleet is planned over the next years. Investments in decarbonization activities TRATON has allocated significant resources toward reducing CO2 emissions. In 2024, €645 million (2023: €611 million) were spent on decarbonization projects. Looking ahead, TRATON plans to invest a further €5.4 billion (2025–2029). A substantial portion of these investments is directed toward projects targeting the use-phase lever, particularly the production of BEVs, strengthening TRATON’s commitment to advancing sustainable transportation solutions. 2.1.2. Metrics related to climate change Energy consumption and mix To track and manage energy consumption, environmental coordinators at each brand collect energy usage invoices and record them in their brand-specific environmental IT systems. These invoices detail the amount of energy consumed from fossil and renewable sources. The consumption of nuclear energy is estimated through multiplying the energy consumption from fossil sources with the, country specific, percentage of nuclear energy in the grid – provided from an external source. The data is then aggregated within the IT system, providing a comprehensive overview of energy use across all sites. 254 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 255 ===== The table below provides an overview of the TRATON GROUP’s total energy consumption for the 2024 reporting year, categorized by energy source. Energy consumption and mix 2024 Total energy consumption (MWh) 2,543,919 Total fossil energy consumption (MWh) 2 1,464,379 Fuel consumption from coal and coal products (MWh) 584 Fuel consumption from crude oil and petroleum products (MWh) 531,528 Fuel consumption from natural gas (MWh) 512,571 Fuel consumption from other fossil sources (MWh) 3,165 Consumption of purchased or acquired electricity, heat, steam, and cooling from fossil sources (MWh) 413,475 Share of fossil sources in total energy consumption (%) 57.6 Consumption from nuclear sources (MWh) 33,312 Shares of consumption from nuclear sources in total energy consumption (%) 1.3 Total renewable energy consumption (MWh) 1,045,633 Fuel consumption from renewable sources (MWh) 3 66,487 Consumption of purchased or acquired electricity, heat, steam and cooling from renewable sources (MWh) 936,591 Consumption of self-generated non-fuel renewable energy (MWh) 4 42,555 Share of renewable sources in total energy consumption (%) 41.1 Non-renewable energy production (MWh) 5 188 Renewable energy production (MWh) 6 44,478 Total energy consumption from activities in high climate impact sectors (MWh) 2,543,919 2 Further disaggregation specifies how much energy is used from coal and coal products, crude oil, and petro- leum products, natural gas, other fossil sources or purchased or acquired electricity, heat, steam, or cooling from fossil sources. 3 The data on energy consumption from biomass (including industrial and municipal waste of biological origin), biofuels, biogas, and hydrogen from renewable sources is directly derived from the respective invoices. 4 The TRATON GROUP consumes only self-generated, non-fuel renewable solar energy. Meter readings specify the amount produced, consumed, and sold. 5 Energy production from combined heat and power plants driven by gas burning, and electricity production from diesel burning in test engines and diesel generators. 6 Energy production from renewable sources, primarily from solar panels for TRATON, and from biomass pellets, calculated using conversion factors based on invoices detailing the mass (kg) of pellets purchased or from meters in burning stations if mass data is unavailable. The table below outlines energy intensity relative to net revenue in high climate impact sector. The high impact sector used to determine energy intensity is based on the NACE code 29.10: Manufacture of motor vehicles. Energy intensity per net revenue and net revenue from activities in high climate impact sectors Energy intensity per net revenue 2024 Total energy consumption from activities in high climate impact sectors per net revenue from activities in high climate impact sectors (MWh/€ million) 53.6 Net revenue from activities in high climate impact sectors used to calculate energy intensity (€ million) 47,473 Net revenue used to calculate GHG intensity (€ million) 47,473 Total net revenue according to financial statements (€ million) 47,473 GHG emissions The TRATON GROUP annually calculates its GHG emissions using the Scope 1 to 3 inventory, in accordance with the guidelines of the internationally recognized GHG Protocol and the ESRS. Scope 1 and 2: Methods, assumptions, and emission factors Currently, Scope 1 and Scope 2 emissions are calculated by the individual brands and aggregated at Group-level. For Scope 1 emissions, the following emission factors are used: Scania and VWTB apply the Intergovernmental Panel on Climate Change ( IPCC) Guidelines. MAN relies on the German Association of the Automotive Industry ( VDA) guidelines for facilities, as well as the Life Cycle Assessment (LCA) for Experts Software and the Joint Research Centre (JRC) — European Commission and its JEC Consortium for vehicles. International uses factors from the Climate Registry. Scope 2 GHG emissions are calculated using both location-based and market-based approaches in alignment with the Scope 2 Guidance of the GHG Protocol. For US sites, Environmental Protection Agency ( EPA) emission factors are applied. For non- US sites, emission factors provided by the International Energy Agency (IEA) are used. Regarding 255 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 256 ===== the types of contractual instruments used for energy purchases tied to Scope 2 emissions, TRATON currently records Guarantee of Origin, International Renewable Energy Certificate (IREC), Tradable Instruments for Global Renewables ( TIGR) and Non-Fungible Digital certificates (NFD). The percentage of contractual instruments in 2024 is 69.4%. Scope 3: Methods, assumptions, and emission factors For the reporting year 2024, emissions are covered for all 15 Scope 3 categories, with methodologies and assumptions detailed in an internally maintained handbook that is updated annually. However, emissions of some categories are reported together with other categories. Upstream leased assets, primarily vehicles and buildings, are accounted for under Scope 1 and Scope 2 emissions as TRATON has operational control over these assets. Downstream transportation and distribution are classified under upstream trans- portation and distribution (Scope 3 Category 4) as all TRATON brands, except VWTB, out- source these services. To maintain a standardized reporting framework, VWTB’s separately calculated data is manually integrated into Scope 3 Category 4. Downstream leased assets are reported under Scope 3 Category 11 as CO2-equivalent emissions for all vehicles during their use phase are calculated and included in this category, irrespective of whether the vehicles are sold or leased. The emission factors used for calculating Scope 3 emissions are specific to each brand and Scope 3 category. Emissions from the use phase of sold products represent the largest component of TRATON’s emissions balance sheet. The calculation of these emissions is divided into two methods based on the product category. The first method applies to the product category of trucks and buses, while the second method applies to the product category of power solutions and external engines. To calculate emissions for trucks and buses, variables such as the number of vehicles, energy consumption, a well-to-wheel GHG emission factor, and the driven distance are considered. Each brand applies the same general formula by multiplying the values, but due to deviations in product portfolios each brand calculates the total emissions in a customized manner with differently grouped vehicle classes. Scania uses its production volume while MAN, International, and VWTB use sales volumes. Energy consumption values are derived by collecting operational data sent from vehicles and are extrapolated based on vehicle group average. The monitored truck fleet is assumed to be representative of all vehicles. Due to lack of operational data, VWTB uses engineering tests and estimations. Estimates are also used for vehicle groups with no or minimal real-world data available such as vans and BEVs. Scania, VWTB, and MAN derive values of driven distance based on operational data such as survival rates and yearly driven distance for vehicle classes. International sets a value based on the reliability and quality service data for an entire year. Scania, International, and VWTB apply well-to-wheel emis- sion factors differentiated by energy carrier and geographic region. MAN weighs together different geographic groups by energy use share and translates it up once over 80% of total energy is accounted for. In the case of BEVs, the total energy is accounted for in its entirety. AdBlue, N2O, and methane as well as charging losses for battery electric vehicles are also considered. For power solutions and external engines, Scania and MAN estimate total fuel consumption based on input from engine experts and multiply it by a CO2 emission factor. International and VWTB do not sell separate engines and therefore do not calculate emissions for this product category. Primary data in scope 3 reporting When primary data from value chain partners is unavailable for Scope 3 emissions, assumptions, average values, and estimations are used to approximate the emissions. Currently, individual brands within the TRATON GROUP calculate their Scope 3 emissions independently, and the results are subsequently aggregated on the Group-level. This decentralized approach results in variations in calculation methods across brands, con- tributing to a higher degree of measurement uncertainty in certain subcategories. TRATON acknowledges that applying industry-wide, average emission factors does not account for individual measures taken by specific suppliers, which further underscores the challenges of the current approach. There is currently no recognized or standardized method for indicating the share of primary data in Scope 3 as well as measuring the extent of scope 3 GHG emissions measured using inputs from specific activities within upstream or downstream value chain. Recognizing these limitations, TRATON is committed to improving data accuracy and consistency by aligning calculation methods across the Group. This initiative aims to reduce measurement uncertainty and enhance the reliability of reported emissions data in the future. 256 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 257 ===== GHG emissions (in tCO 2-eq) 2024 Scope 1 GHG emissions Gross Scope 1 greenhouse gas emissions (tCO 2-eq) 248,370 Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%) 7 6.5 Scope 2 GHG emissions Gross location-based Scope 2 greenhouse gas emissions (tCO 2-eq) 354,674 Gross market-based Scope 2 greenhouse gas emissions (tCO 2-eq) 8 158,344 Scope 1 & 2 GHG emissions 406,714 Significant scope 3 GHG emissions Total gross indirect (Scope 3) GHG emissions (tCO 2-eq) 354,590,885 Purchased goods and services (tCO 2-eq) 9 8,437,991 Capital goods (tCO 2-eq) 10 639,174 Fuel and energy-related activities (tCO 2-eq) 11 143,118 Upstream transportation and distribution (tCO 2-eq) 12 1,230,802 Waste generated in operations (tCO 2-eq) 13 369,762 Business travel (tCO 2-eq) 14 88,276 Employee commuting (tCO 2-eq) 15 87,160 Upstream leased assets (tCO 2-eq) 16 – Downstream transportation (tCO 2-eq) 17 – Processing of sold products (tCO 2-eq) 18 151,500 Use of sold products (tCO 2-eq) 342,519,213 End-of-life treatment of sold products (tCO 2-eq) 19 622,842 Downstream leased assets (tCO 2-eq) 20 – Franchises (tCO 2-eq) 21 292,358 Investments (tCO 2-eq) 22 8,690 Total GHG emissions Total GHG emissions (location-based) (tCO 2-eq) 355,193,928 Total GHG emissions (market-based) (tCO 2-eq) 354,997,599 7 Percentage is calculated with an online tool from the German Emissions Trading Authority (DEHSt) at the Federal Environment Agency. 8 Location-based emission factors were used for individual sites for which no market-based emission factors are available. 9 Purchased goods = volume of vehicle and components * weight of vehicle and components * kgCO2eq per reference vehicle or components. Purchased services (IT, supplies, packaging, sales marketing) are scoped out due to their minimal impact (<1%). Scania groups similar products together into eight reference groups, using production volumes and an in-house Material Data System (SMDS) with external Life Cycle Assessment (LCA) data. MAN applies LCAs for vehicle categories using sales data, average weight calculations, and expert estimates. For International, ClimatePartner calculates this datapoint. VWTB calculates emissions from com- ponent volumes, applying ecoinvent emission factors based on engineering calculations. 10 Capital goods = monetary input * emission factor. Monetary input based on values from Financial Accounting and Cash Transaction System (FACTS). Emission factors are used from GHG protocols. Factors are converted into kgCO2/€ based on world bank data and adjusted for inflation based on the German Federal Office for statistics. 11 Fuel and energy-related activities = Sum of (emission factor for fuel type * fuel consumption for fuel type). Emission factors are sourced from the DKI handbook (Volkswagen AG), some additional emission factors are used from the Sphera´s database LCA for Experts. VWTB uses the GHG Protocol Scope 3 Evaluator with emission factors from the World Resources Institute, while ClimatePartner calculates this datapoint for Inter- national. The amount of fuel is derived from fuel consumption data differentiated by fuel type. 12 Scania and VWTB apply an activity-based calculation method. MAN employs a cost-based approach. Scania and MAN rely on emission factors from the Global Logistics Emission Council (GLEC). VWTB uses emission factors from the Department for Environment, Food & Rural Affairs (DEFRA) and the Brazilian GHG Protocol Program (PBGHGP). ClimatePartner calculates this data point for International. 13 Waste generated in operations = Sum of (waste outflow * corresponding emission factor). Scania and MAN use emission factors from LCA for Experts. Due to the different type of waste operations in South America, VWTB uses emission factors from the IPCC. ClimatePartner are calculating this datapoint for International. 14 Flight, train, and car data is collected separately at brand level and multiplied with the respective emission factors. MAN gets its data from BCD Travel standard reports for flight emissions. Car rental providers report data on the total annual orders of rented cars. Emissions from train travel are set to zero as Deutsche Bahn re- ports zero CO2 usage. Scania receives its emissions stemming from flight travel from BCD Travel reports. Rent- al cars are reported using data provided by the rental car companies. No emissions from train transportation are reported for Scania. VWTB calculates the emissions based on emission factors from DEFRA 2021 for flights and from PBGHGP for cars. No trains are used in VWTB. ClimatePartner calculates this datapoint for International. 15 Commuting emissions = ∑ number of employees per region * distances * modal split * emission factors. The number of employees is split into regions (Europe, North America, South America, Africa, Asia/Pacific, Australia) and direct (production)/indirect (non-production) sector. VWTB uses a calculation based on primary data since its employees’ main method of commuting is the chartered bus fleet hired by the company. 16 Upstream leased assets, primarily consisting of vehicles and buildings, are reported under Scope 1 and Scope 2 emissions, as their operational emissions can be determined. 17 Reported under upstream transportation and distribution. 18 Only rigids are included in the processing calculation. The emissions are estimated by assuming the process- ing emissions per vehicle are the same as the production emissions per vehicle. Scope 1 and 2 emissions are divided by the total number of vehicles sold and then multiplied by the number of rigids sold. ClimatePartner calculates this datapoint for International. 257 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 258 ===== 19 End-of-life treatment of sold products = ∑ (Intensity factor (CO2 per vehicle group) * product sales amount). Scania and MAN use a combined LCA model to estimate end-of-life CO2 emissions per vehicle group, consid- ering only dismantling and transport, without recycling or energy recovery credits. This method, also used by VWTB, is applied with sales volumes. ClimatePartner calculates this datapoint for International. 20 Reported under use of sold products. 21 Scania and MAN franchise emissions are calculated based on the average Scope 1 and Scope 2 emissions of a typical commercial site. ClimatePartner calculates this datapoint for International. VWTB does not have any commercial sites in scope for CSRD. 22 Scania calculate this datapoint in two steps. Investments are prioritized by importance, selecting the top ten for evaluation. Scope 1 and 2 emissions are then calculated based on Scania’s equity share in these companies, using the formula: Emissions * Share. Emission data is obtained from the companies’ environmental reports or, if not available, through questionnaires sent to the companies. MAN has fewer than ten investments and therefore includes all investments in its calculation. ClimatePartner calculates this datapoint for International. VWTB does not provide financial resources to external companies. Biogenic carbon emissions The biogenic CO2 emissions resulting from combustion or biodegradation of biomass are displayed in the following table, categorized by their exclusion from Scope 1, Scope 2, and Scope 3 GHG emissions across the value chain. For 2024 reporting each brand will use different emission factors to calculate biogenic Scope 1 emissions: Scania and VWTB uses emission factors from the IPCC Guidelines, International uses the Climate Registry. MAN uses VDA emission factors for emissions from facilities and Sphera’s LCA for Experts and JEC emission factors for vehicle emissions. The VDA emission factors utilized to calculate Scope 2 emissions for every brand provide detailed disclosures of the biomass percentage specific to each country. All brands use Sphera LCA for Experts emission factors for Scope 3 emissions. Biogenic carbon emissions 2024 Biogenic emissions of CO 2 from the combustion or biodegradation of biomass in Scope 1 GHG emission (tCO 2-eq) 23 14,971 Biogenic emissions of CO 2 from the combustion or biodegradation of biomass in Scope 2 GHG emission (tCO 2-eq) 24 22,214 Biogenic emissions of CO 2 from the combustion or biodegradation of biomass that occur in its upstream and downstream value chain in gross Scope 3 GHG emissions (tCO2-eq) 25 20,782,563 23 Emissions are calculated using fuel consumption from coal, crude oil, natural gas, and other fossil sources, following the same methodology as gross Scope 1 GHG emissions but applying specific emission factors instead of CO2 factors. Scania and VWTB use IPCC Guidelines, International uses Climate Registry standards, and MAN applies VDA for facilities and LCA for Experts & JEC for vehicles. 24 TRATON brands use VDA emission factors for the biogenic content of fuels. For locations not covered by the VDA, an average “rest of the world” emission factor will be applied. 25 The upstream biogenic carbon component has a minimal impact and is currently omitted due to its low contribution. Plans are in place to include it in future assessments as capacity allows. For the downstream part, TRATON brands utilize emission factors based on LCA for Experts, which differentiate between the biogenic and non-biogenic carbon content of the energy carriers used. At VWTB, the distinctive approach lies in the use of emission factors from the Renovabio database, which aligns with their methodology. GHG emissions intensity The table below presents the total GHG emissions calculated using both the location-based and market-based methods, relative to net revenue. The net revenue of TRATON GROUP amounts to €47,473 million. GHG intensity based on net revenue GHG intensity per net revenue 2024 Total GHG emissions (location-based) per net revenue (tCO 2-eq/€ million) 7,482 Total GHG emissions (market-based) per net revenue (tCO 2-eq/€ million) 7,478 258 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 259 ===== Further information on GHG reporting The calculations presented for gross Scopes 1, 2, 3, and Total GHG emissions metrics have not been independently validated by an external body beyond the use of recognized methodologies and tools provided by external organizations, such as ClimatePartner, the German Emissions Trading Authority (DEHSt), and other industry-standard references. Currently, there are no active carbon removal or storage initiatives integrated in our busi- ness activities or supply chain. Additionally, no formalized internal carbon pricing schemes are currently in place within TRATON GROUP’s business operations. 2.2. Pollution 2.2.1. Management of pollution The TRATON GROUP understands that the transport industry can profoundly contribute to the pollution of the environment. During the double materiality assessment, four sus- tainability matters related to environmental pollution were classified as material: pollution of air, pollution of water, microplastics, and substances of very high concern. Besides the ECMS policy (see the section on “Sustainability management process”) over- seeing environmental topics at TRATON on a Group-level, there are currently no policies, actions or targets in place that specifically relate to sustainability matters of pollution in detail, as this responsibility lies with the individual brands. This includes measures for mitigating negative environmental impacts, minimizing the use of substances of concern, phasing out substances of very high concern, and the specific procedures for preventing and managing incidents and emergency situations. 2.2.2. Metrics related to pollution Pollution of air TRATON brands conducted a threshold analysis to see what pollutants are above the thresholds specified in E- PRTR at all production sites. Of the pollutants referred to in E-PRTR, TRATON has found five substances with emissions above the threshold: Hydro - fluorocarbons (HFCs), Hydrochlorofluorocarbons (HCFCs), Non-methane volatile organic compounds (NMVOC), Nitrogen oxides (NOx/NO2) and Benzene. TRATON brands use local emission factors to calculate the pollutants emitted to air. Pollution of air 2024 HFC (t) 26 29.2 HCFC (t) 1.9 NMVOC (t) 27 1,157.4 NOx/NO 2 (t) 28 167.4 Benzene (t) 29 5.5 26 Hydrofluorocarbons (HFCs) and Hydrochlorofluorocarbons (HCFCs) include gases leaked from cooling equip- ment. Usually, leaks occur when filling up the AC in the trucks and from cooling equipment leakages. It is doc- umented when the coolant is filled up and how much is used. It is also documented when emptied and the difference is the leakage. 27 Volatile Organic Compounds (VOCs – from painting) are calculated from the material balance, with data pro- vided from all production sites. The method analyses how many organic solvents are put into the production process, and this is compared with the outflows to air/water. Abatement incinerates the solvent, and, in these cases, it is measured to see how much is incinerated. 28 Nitrogen oxides (NOx/NO2) are calculated at brand level using local emission factors. In combustion engine development emission factors have been determined from actual measurements of fuel used. The emission factors are calculated using the amount of fuel purchased, compared with the amount of fuel used and con- sidering the type of engine. 29 Benzene is measured in process ventilation. A sample is taken from few hours of product-based on-air flow and ventilation and extrapolated to get an annual value. 259 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 260 ===== Substances of very high concern The IMDS substances of very high concern (SVHC) list of the European Automobile Man- ufacturers’ Association (ACEA), which is derived from the ECHA candidate list, is used as the basis for recording SVHC. If SVHC are used as such (substances) or in mixtures during vehicle production or become a component of the product ‘vehicle’ during the production process, they are checked, recorded and approved in advance by internal chemical management processes. A sub- stance-related quantity analysis of SVHCs cannot currently be carried out in full at Group level. The TRATON GROUP and the operators at the sites of the individual brands always act in accordance with the applicable legal requirements. Sites and plant technology are autho- rised by the authorities in accordance with these requirements. This applies in particular to environmentally relevant plants whose operation results in emissions to air and water, so that far-reaching operator obligations have been defined in their plant licences. As part of such ancillary provisions, recurring emission measurements are also carried out to ensure compliance with applicable limits. There is currently no limit value that covers the entire scope of all known substances of very high concern ( SVHC). There is also no measurement method for recording the entire spectrum of all SVHC. It is therefore not possible to collect data on these emissions according to the current state of the art. With regard to the use of SVHCs as part of TRATON’s products, lead in the starter batteries accounts for 98% of the total amount of SVHCs and is by far the largest component of a typical truck. The total amount of lead in starter batteries sold by TRATON during 2024 amounts to 24,780 tonnes. The data point “total amount of SVHCs leaving facilities as products” is not considered applicable for TRATON as only “vehicles sold” are considered according to the product definition. 2.3. Water 2.3.1. Management of water Water is a vital resource, essential not only for human life, but also for the health of our ecosystems and the sustainability of our operations. TRATON recognizes the critical impor- tance of responsible water management and the role the company plays in protecting this precious resource. As TRATON’s double materiality assessment has revealed that marine resources are not material for the TRATON GROUP, this section focuses solely on water as a sustainability matter. Besides the policy ECMS overseeing environmental topics at TRATON on a Group-level, there are currently no policies, actions, or targets in place that specifically relate to the sustainability matter of water in detail, as this responsibility lies with the individual brands. This includes the use, sourcing and treatment of water as well as the prevention of water pollution. Furthermore, on a Group-level, no water-related approaches for product design or commitments have been agreed on so far. However, to ensure responsible water management across its operations, the TRATON GROUP conducted a risk analysis in 2024 to assess whether any of its facilities are situated in water risk areas. This analysis showed that ten of TRATON’s production sites are located in water risk areas and areas with high water stress. Those production sites are fully in compliance with local regulations. 2.3.2. Metrics related to water Water consumption The TRATON GROUP calculates its total water consumption using a systematic approach. For sites where water discharge data is available, the water consumption is determined by subtracting the water discharge from the water usage. Additionally, the percentage of water discharge relative to water usage is calculated for these sites. From these calcula- tions, average percentage of water discharge are identified and used in the next steps. 260 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 261 ===== For sites without water discharge data, water consumption is estimated based on the recorded water usage and the average percentage of water discharge derived from the sites with available data. The estimated water discharge is calculated by multiplying the water usage by the average percentage of water discharge. This estimated discharge is then subtracted from the water usage to calculate the estimated water consumption. The total water consumption is calculated by adding the sum of the calculated water con - sumption from sites with discharge data to the sum of the estimated water consumption from sites without discharge data. For the calculation of total water consumption in areas with water risk, including areas of high water stress, the TRATON GROUP follows a specific procedure before applying the general water consumption calculation method. First, all sites of the TRATON brand are registered with their coordinates in WRI’s Aqueduct Water Risk Atlas. An Excel sheet with the results is downloaded, and sites with an “overall water risk” greater than Medium-High are filtered. The water consumption is then calculated using the same method as outlined earlier, but only for these high-risk sites. It should be noted that the data used in these calculations carry a certain level of measurement uncertainty. There is limited data on discharged water, and the assumption that the average discharge rate accurately represents water discharge across both commercial and production sites may not fully account for variations at all locations. In total, 96% of the measurements for water perfor- mance were obtained using estimations. Water consumption 2024 Water consumption (m 3) 2,125,066 Water consumption in areas at material water risk including areas of high-water stress (m 3) 492,212 Water recycled and reused (m 3) 30 207,444 Water stored (m 3) 31 172,740 Water intensity ratio (m 3/million euro) 32 44.8 30 Water recycling and reuse data is entered into the brand’s environmental IT system based on meter readings. The data consolidator aggregates this information from all sites to compile a comprehensive overview within the system. 31 Water storage data is entered into the brand’s environmental IT system based on meter readings. The data consolidator aggregates this information from all sites to generate a comprehensive overview within the system. 32 The estimated minimum and maximum water consumption is used as the numerator and divided by the TRATON net revenue in the denominator. 2.4. Biodiversity and ecosystems 2.4.1. Management of biodiversity and ecosystems A comprehensive assessment was undertaken to evaluate whether TRATON GROUP’s production sites are located in or near biodiversity-sensitive areas. The evaluation included 25 production sites involved in the manufacturing of vehicles, components, and assemblies. Details of these sites are provided in the section “Annex”. As a commercial vehicle manufacturer, the company acknowledges that activities across our value chain can affect biodiversity and ecosystems. The TRATON GROUP has identified the sustainability matter of direct impact drivers of biodiversity loss as material. No mate- rial impacts, risks, or opportunities were identified for other biodiversity-related sus - tainability matters, and therefore these are not addressed further in this report. The TRATON GROUP has defined a radius of 4500 meters for the assessment of sites located near or in biodiversity-sensitive areas on the basis of the Technical Instruction on Air Pollution Control. This Radius equates to the height of the tallest chimney multiplied by 50. The corresponding protected areas were analyzed by a third party. The data was compared with the information provided by the NALA biodiversity measurement. The analysis revealed that 19 production sites (a total of 1,451 ha) are situated within a 4.5 km radius of 34 protected areas. The status of over 500 protected areas was reviewed as part of this assessment. The evaluation also took into account protected habitats, species at risk, and those endangered or critically endangered. Within the radius of the 25 production sites assessed, endangered species were identified. TRATON identified material dependencies to water and material impacts in the upstream and downstream value chain related to GHG emissions; related to water pollution, non- GHG air emissions and soil pollution; and related to solid waste pollution as well as impacts related to land use change and noise pollution. 261 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 262 ===== At TRATON GROUP level, there are currently no policies and targets in place that specifically relate to sustainability matter of direct drivers of biodiversity loss, such as the production, sourcing, or consumption of raw materials. However, the WWF study, described below, has highlighted the importance of this sustainability matter. Hence, the TRATON GROUP will take steps to address this topic in the future. Actions In 2024, the following key action was taken regarding biodiversity and ecosystems. WWF study on nature risks The TRATON GROUP provided some sector-specific data to WWF Sweden for a project that aimed to explore the interactions between the commercial vehicles sector and nature, focusing on its dependencies and impacts. The WWF Sweden-authored study, titled “The Current and Future Nature Risks of the Commercial Vehicles Industry”, provides informa- tion to the Group to better understand key areas of impact on nature across the sector’s operations and supply chain. The study analyzes how upcoming changes, such as elec - trification, will alter these interactions and assesses the associated impacts, risks and opportunities. To obtain comprehensive insights, the whole value chain is considered. The study took place throughout 2024, and the report offering research-backed recommendations for the industry will be published at the beginning of 2025. This study will provide some crucial insights into the commercial vehicle industry’s impact on nature, enabling TRATON to start developing an approach to manage and mitigate impacts and dependencies on nature. Potential stakeholder groups identified in the study include, but are not limited to, vehicle manufacturers, suppliers, logistics companies, end users, consumers, and com- munities impacted by the commercial vehicle sector’s operations and environmental footprint. The study identified a wide variety of activities across all stages of the commercial vehicles industry’s value chain. Regarding the production stage, the analysis focused on activities such as metal cutting, pressing, grinding, welding as well as painting and polishing. The dependencies considered included water and soil quality and condition, while the impacts examined were land-use change, water pollution, GHG emissions, non-GHG air emissions, solid waste pollution, soil pollution, noise pollution and vibrations, invasive species, and diseases. The TRATON GROUP has not incorporated local and indigenous knowledge or nature- based solutions for this specific action. 2.5. Resource use and circular economy 2.5.1. Management of resource use and circular economy The TRATON GROUP is committed to decoupling resource use from business growth, considering the resource use across the vehicles’ lifecycles. A heavy-duty truck with an internal combustion engine typically consumes a substantial number of raw materials and fuel over its lifetime. LCAs suggest that heavy-duty vehicles can consume roughly 30–40 tons of raw materials throughout their production and maintenance phases, depending on design and specific use cases. Additionally, the use phase of these heavy-duty vehicles involves significant fuel consumption, estimated at approximately 400–500 tons of diesel fuel for long-haul operations over a typical lifespan. This high resource consumption makes the environmental impact of these vehicles substantial, in terms of resource depletion while it also highlights the sustainability advantages of electrification, which reduces overall resource intensity and supports circularity goals. 262 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 263 ===== TRATON Circular Business Model TRATON Circular Business Model Improving resilience in supply chain through reused, recycled and renewable content use Developing market relevant services to grow the revenues through lifetime and utilization optimizing Constant improvement of vehicles’ circularity to make them recyclable, use recycled materials as well as enable scaling-up circular services End of life treatment & Recycling Repair Refurbish/ Recondition Remanufacture Repurpose & Reuse VEHICLE DESIGN FOR CIRCULARITY While vehicles’ embodied materials range from steel, aluminum, plastics, and glass, BEVs additionally depend heavily on essential battery minerals such as lithium, cobalt, and nickel. Adopting circular principles in the product design is essential to mitigating neg- ative environmental impacts and maximize value retention throughout the entire life cycle for customers and wider society. By maximizing the use of secondary materials, TRATON aims to reduce the demand for finite resources and minimize waste at a vehicle’s end of life. 263 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 264 ===== Policies The regulation of resource use and circularity is a central component of the TRATON strategy. It focuses on the use of secondary materials, sustainable sourcing, and the adop- tion of renewable resources, underscoring the commitment of the TRATON GROUP to maximize resource efficiency. The TRATON sustainability management guideline, in con- junction with the sustainability management process, is related to opportunities for cost savings and enhanced reputation, exemplified by initiatives such as achieving circularity principles through product design and adopting energy-efficient technologies like BEV production. They are also related to the potential negative impact of landfill waste and contribution to resource depletion due to significant waste generation. Also, the TRATON sustainability management guideline, in conjunction with the sustain- ability management process, and the Code of Conduct for suppliers and business partners are related to the actual negative impact of resource consumption, which is substantial in the transportation supply chain due to the reliance on non-renewable resources. These policies also address the risks of higher costs associated with circular design and energy- efficient technologies, which could impact profitability and market share, as well as the financial and supply chain risks linked to rising resource costs and reliance on non- renewable resources. Furthermore, the Code of Conduct for suppliers and business partners is related to the potential negative impact of improper disposal or recycling of vehicles can contribute to landfill waste, increased resource outflows, and the loss of valuable resources. Concepts for resource use and circularity In 2024, the following concepts related to resource use and circularity were implemented through the TRATON sustainability management guideline in conjunction with the sus- tainability management process. In response to challenges such as limited resources, stricter regulations on materials, and rising prices, the TRATON Sustainability Board has approved circularity as a TRATON joint impact area, and approved circularity commitment to decouple resource use from business growth. The main decisions taken by the TRATON Sustainability Board and other relevant forums within the TRATON governance structure included were defining four key levers related to resource use and the circular economy: reducing resource consumption and waste; reused, recycled and renewable content; optimizing the lifetime and utilization rate; and business model and partnerships devel- opment. Sponsors were appointed within the TRATON Sustainability Board to ensure the effective implementation of these sustainability matters. Circularity principles were introduced as part of the framework guiding the development of vehicles. Additionally, a remanufacturing framework was developed to integrate reman- ufacturing into the design process, with an ongoing effort to develop an execution plan to scale up remanufacturing business across the TRATON GROUP. Code of Conduct for suppliers and business partners (Group policy) Resource efficiency is a fundamental aspect of the Code of Conduct for suppliers and business. Business partners take appropriate and adequate measures aimed at avoiding waste, re-using resources, recycling as well as the safe, environmentally friendly disposal of residual waste, chemicals and wastewater. Such measures can be applied in develop- ment activities, production, product service life, and subsequent end-of-life recycling as well as in other activities. Thereby, the business partners comply with international agree- ments on the cross-border transport of hazardous waste, in particular the Basel Conven- tion on the Control of Transboundary Movements of Hazardous Wastes and their Disposal of 22 March 1989, as well as with the corresponding, applicable implementation rules at national and supranational level. Whenever technically possible and economically reasonable, business partners should use secondary materials within their processes. Business partners should know the per- centage of recycled content in their products and make this information available to TRATON on request. Business partners should endeavor to pursue and promote circular systems in addition to following these principles. This can generally be achieved by clos- ing the material loop, optimizing the lifetime of products and improving their utilization. Further information on TRATON’s Code of Conduct for suppliers and business partners is available in section “Management of relationships with suppliers”. 264 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 265 ===== Actions and targets In 2024, the four key levers described below guide the company’s effort toward resource use and circularity, forming the foundation for a focused set of actions. The sustainability matter of waste aligns with the key lever of reducing resource consumption and waste. The three additional key levers are: reused, recycled, and renewable content; optimize the lifetime and utilization rate; and business model and partnerships development relate to sustainability matters of resource inflows, including resource use, and resource outflows associated with products and services.The specific actions associated with each lever are further detailed below, providing a comprehensive view of their implementation and impact. The levers are pursued on an ongoing basis, without an explicit time horizon, allowing for flexibility and continuous adaptation to evolving challenges and opportunities. As of the 2024 reporting period, TRATON GROUP has not yet established specific targets related to the sustainability matters of resource use and circular economy. This is because the key levers and their respective set of actions were formalized only earlier in 2024. The Group is actively working on defining concrete targets and will provide updates in the future. Reducing resource consumption and waste TRATON’s ambition is to use resources more efficiently, minimize waste generation, and ultimately reduce resource consumption across the entire value chain, with particular attention to the use phase of the vehicles produced by TRATON and to its own operations. At TRATON, elimination of waste is a corporate value, and our brands are continually iden- tifying more efficient ways to design and produce vehicles. By optimizing these processes, we aim to not only make our operations more sustainable but also improve affordability for our customers. This action relates to and has been determined based on the TRATON sustainability management guideline and the sustainability management process. The responsibility for waste reduction rests with each individual brand, and by 2025, TRATON plans to assess the possibility of setting Group-wide waste reduction targets, informed by the efforts of its brands. In addition to efforts within own operations, the use phase of TRATON’s vehicles plays a crucial role in reducing resource consumption. Electrification is key to this, as it helps to significantly lower GHG emissions and resource usage by reducing reliance on fossil fuels. Moreover, improving engine fuel efficiency remains a focus area, as it further reduces resource consumption and enhances sustainability across the vehicle lifecycle. Reused, recycled, and renewable content In this area of focus, TRATON GROUP is dedicated to sourcing materials with recycled and renewable content while integrating reused parts into its vehicles. We encourage our business partners to prioritize the use of recycled materials and share recycled content data with the TRATON GROUP upon request. Through collaboration, the Group aims to source more sustainable materials and increase the share of recycled and renewable content in TRATONs products. Achieving this requires strong cross-functional efforts to incorporate reused parts and higher recycled material content into vehicle designs. Addi- tionally, TRATON is working to enhance the traceability of material composition, allowing a transparent communication of the product sustainability to customers. This approach is also closely linked to reducing supply chain emissions. By using recycled and reused parts in vehicles, reference is made to the TRATON sustain- ability management guideline, in conjunction with the sustainability management pro - cess, and uphold the principles set forth in our Code of Conduct for suppliers and business partners. Optimizing the lifetime and utilization rate To advance lifetime and utilization rates, TRATON focuses on improving product longevity through enhanced durability and repairability; increasing reuse through reconditioning and repurposing parts; and expanding remanufacturing and refurbishing services to extend the life of components. These efforts primarily target the downstream part of the value chain of TRATON, aiming to reduce resource outflow by prolonging product life. 265 Further InformationConsolidated Financial Statements Responsibility Statement and Independent Auditor’s Reports Combined Management Report Sustainability StatementTo Our Shareholders ===== SIDA 266 =====