Årsredovisning 2024

In 2024, TRATON launched a set of circular design principles to ensure that circularity is 
embedded in vehicle designs from the outset. These principles facilitate the use of recy-
cled content and enhance recyclability, remanufacturability, durability, and repairability. 
Initial measurements for the first circular principles have been developed, with further 
integration planned for the coming years.
By implementing these principles, TRATON supports opportunities to increase profit pools 
and revenues while reducing costs for circular services such as remanufacturing, repair, 
refurbishment, and reuse. These efforts also strengthen TRATON’s ability to align with 
upcoming regulatory demands such as circular design standards and requirements for 
end-of-life collection and dismantling. Furthermore, they contribute to building compe-
tencies essential for a circular economy, improving access to green financing for the 
transition to a circular economy, and increasing the use of recycled and renewable content 
in vehicles to enhance recyclability and sustainability. 
A key aspect of TRATON’s approach to circularity involves expanding circular services, 
including remanufacturing, repair, refurbishment, and reconditioning. To support these 
efforts, TRATON has prioritized scaling up remanufacturing services across brands through 
a dedicated cross-brand Remanufacturing Task Force.
The ongoing development of the common modular platform, the TRATON Modular System 
(TMS), plays a significant role in supporting TRATON’s circularity agenda. TMS enables 
brands to share standardized components, systems, and technology platforms across 
models. While primarily designed to drive compatibility, operational flexibility, and scal-
ability across regional markets, TMS also contributes to circularity by facilitating the reuse 
and refurbishment of standardized components such as engines, transmissions, and 
electronics. This alignment with circular principles enhances maintenance services, 
improves efficiency, and supports resource conservation. By considering circular design 
principles from the early stages of vehicle development and production and expanding 
remanufacturing options, TRATON integrates its circularity efforts with its broader 
 sustainability objectives, relating to the TRATON sustainability management guideline 
and the sustainability management process.
Business model and partnerships development
Developing innovative business models and strengthening partnerships are key to 
TRATON GROUP’s journey toward becoming a more circular company. To achieve its 
 circularity ambitions, TRATON is committed to sourcing more renewable and recycled 
materials and scaling up circular services through essential collaborations, within the 
Group, along the value chain and beyond. 
TRATON will work on developing further partnerships with suppliers, customers, govern-
ments and even competitors to create a more circular transport system. The company is 
committed to advocate for the changes required to build more circular economy and are 
exploring new business models, such as product as a service, in partnerships with others. 
One example is JUNA, a joint venture established in partnership between Scania and 
Sennder. It aims to drive forward the electrification and decarbonisation of European road 
logistics with the help of an innovative pay-per-use approach.
Currently, the TRATON GROUP and its brands collaborate with multiple recycling partners 
in Europe. One of the major tasks of these recyclers is the safe recovery of lithium through 
complex processes. These partnerships are crucial for advancing sustainable material 
recovery within TRATON operations.
External advocacy is a key part of our partnership approach. The TRATON GROUP is con-
vinced that the transition to a circular economy is imperative.
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By intensifying cooperation within the TRATON GROUP and strengthening relationships 
with external stakeholders, the company aims to further advance the development of a 
circular transport system. This approach relates to the TRATON sustainability management 
guideline and the sustainability management process and aligns with the principles of 
the Code of Conduct for suppliers and business partners.
2.5.2. Metrics related to resource use and circular economy
Resource inflows
Resource inflows of materials and products
With the continued transition toward e-mobility and the production of BEVs, demand for 
raw materials is expected to rise. To address this, TRATON remains committed to closely 
monitoring the sourcing of these materials, ensuring compliance with human rights 
 standards and ethical practices throughout the supply chain. For more information, please 
refer to section “Management of climate change”.
Material composition and integration of recycled content
The total weight of vehicles produced by TRATON, including technical and biological 
materials, amounts to 2,473,853 tons in the reporting year 2024.33 This figure is calculated 
based on either supplier-provided data on the weight of parts or by directly weighing 
the vehicles. The weight data is averaged for each product group and multiplied by the 
production volume to derive the total value. The percentage of biological materials that 
were sustainably sourced is 0%. 34
The weight of recycled materials is 604,511 tons, which corresponds to a percentage of 
24% of total material usage. The total weight of products is broken down into material 
groups, and the corresponding share of secondary materials is applied. While brands 
calculate this in slightly different ways due to data availability, the overall approach follows 
the same principle of material classification and reference vehicle analysis.35 The second-
ary material share is expected to be an accurate representation. The figure is based on 
industry data and has been externally audited through the Volkswagen Group. Given the 
potential for a large range in the secondary material share of some materials, the lower 
percentage has been used to ensure a conservative approach. To enhance accuracy in 
the future, plans are in place to actively request and collect information from suppliers 
on secondary material rates when supplying a part to TRATON brands.
Resource outflows
Circular economy in products and materials
In alignment with circular economy principles, TRATON GROUP is focused on minimizing 
resource and energy consumption. Initial efforts have prioritized batteries, steel, alu-
minum, and plastics as critical materials for a circular approach. These initiatives lay the 
foundation for further advancing the Group’s joint impact area circularity and exploring 
innovative business models.
End-of-life handling for heavy-duty vehicles is supported by TRATON brands through 
 dismantling information, which includes guidelines for draining and removing hazardous 
waste, managing safety systems, and identifying key materials in vehicles. Additionally, 
TMS supports circularity by standardizing components across brands. This approach not 
only enhances operational efficiency but also simplifies maintenance and optimizes 
resource use throughout the vehicle lifecycle. As high-voltage batteries and other key 
components such as electric drive systems enter circulation due to legislative require -
ments, their raw materials play an increasingly vital role in climate protection. These 
materials are not only valuable but also critical for ensuring resource security. Maintaining 
these materials in circulation supports the decoupling of production from virgin raw 
material dependency while safeguarding access to essential resources. Furthermore, the 
extraction and use of these raw materials are associated with emissions and other 
 environmental impacts. By reusing battery raw materials multiple times, TRATON GROUP 
can mitigate these effects, contributing to a reduction in the overall CO2 footprint. The 
reduction potential is important, and underscores TRATON’s commitment to resource 
efficiency and sustainability.
33  The same total vehicle weight (kg) is also used for calculating CO2 emissions for purchased goods and services 
in Scope 3.
34   TRATON’s materials are considered technical as there is insufficient information available regarding certified 
biological materials. Therefore, the percentage in this case is 0%.
35  Scania uses the International Material Data System (IMDS) to classify material weights per VDA 231-106 cate-
gories and calculate total material weight by applying reference vehicle production volumes. International 
and VWTB derive the weight of hotspot materials from purchasing data and supplier/engineering data, 
 respectively, in alignment with VDA 231-106. MAN, without access to granular IMDS data, calculates material 
 distribution based on LCA analyses of reference vehicles. Secondary material shares for Scania, VWTB, and 
 International rely on association data for metals (VDA categories 1–3), with non-metals assumed to have 0% 
secondary materials due to limited data availability. MAN has developed expert estimations, with supplier 
 input, for hotspot material groups.
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Given the increasing complexity of supply chains and the geopolitical and material 
 availability challenges of recent years, TRATON recognizes the need to develop an efficient, 
Group-wide strategy for material security. This is not yet an active strategy, but the plan 
is to establish a comprehensive raw material procurement process aimed at securing 
critical and strategic raw materials for key components. This strategy will focus on strate-
gically relevant raw material groups to define, assess, and implement optimal security 
scenarios. These groups may include battery materials, rare earth elements ( REEs), plat-
inum group materials (PGMs), semiconductor materials, tin, tantalum, tungsten, and gold 
(3TGs), and mica (a silicate mineral widely used in electronics and industrial applications). 
Other critical resources such as magnesium, aluminum, plastics, and copper will also be 
considered. Once established, this process will help TRATON proactively address material 
risks and ensure long-term resource security for the group.
Durability
TRATON vehicles are designed and constructed to remain functional for extended periods, 
with their longevity further supported by regular servicing and the repair or replacement 
of broken parts. However, there is currently no industry-wide standard or average method 
for calculating the durability of heavy-duty vehicles. Additionally, the durability of such 
vehicles is influenced not only by their design and construction but also by factors such as 
intensity of use, geographic conditions, and the frequency of repairs and servicing. As a 
result, the TRATON GROUP is unable to provide a definitive durability figure for its  products.
Repairability
TRATON GROUP’s focus on high quality and low repair needs ensures the long durability 
of its vehicles during their usage phase, significantly contributing to resource efficiency 
and sustainability. If a part fails, customers benefit from established repair and mainte -
nance services, which not only extend vehicle lifespan but also provide a key revenue 
stream for the Group.The exchange parts program is a cornerstone of this approach. It 
enables the return of “old parts” by importers and national subsidiaries for industrial 
processing, remanufacturing, or refurbishment, making these components suitable 
for reuse in other vehicles within the Group. Parts that cannot be remanufactured or 
refurbished are replaced with brand-new components. This program reduces waste and 
maximizes resource efficiency. During the vehicle design phase, TRATON evaluates repair 
activities for heavy-duty vehicles using a standardized rating scheme. This scheme objec-
tively assesses repair-specific criteria to ensure repairs are quick and efficient, ultimately 
enhancing the customer experience and minimizing downtime.
Recyclability and recoverability of products
As part of its commitment to circularity, the TRATON GROUP evaluates its vehicles to 
ensure compliance with international standards and advance sustainability. A recyclability 
calculation conducted on two 12-meter Citywide urban buses, one ICEV and one BEV, 
using the guidelines set out in ISO 22628:2002, showed a recyclability rate of 91% for both 
vehicles. 
Additionally, a study of TRATON’s heavy-duty truck portfolio, including ICE models TGX, 
TGS, TGM, TGL, and the BEV truck model eTGS, revealed recyclability rates exceeding 85%. 
Waste streams and material management
TRATON GROUP generates diverse waste streams across its production processes. A 
 significant portion consists of scrap metal, metal filings, and metalworking fluids from 
machining operations. Paint waste is another major category, containing residues of 
organic solvents and other chemical components from vehicle painting. Additionally, 
casting sand from foundries and packaging materials such as cardboard, plastics, and 
wood are common waste types. The materials present in these waste streams include 
metals, oil, organic solvents, plastics, sand, cardboard, and wood. Each material requires 
tailored waste management strategies to minimize environmental impact and comply 
with regulations. 
TRATON receives detailed reports from waste management companies outlining the 
quantity and type of waste generated. These reports categorize the waste as hazardous 
or non-hazardous and specify the recovery or disposal methods used, such as re-use, 
recycling, landfilling, incineration or other recovery/disposal operations. This data is then 
uploaded to the brands’ environmental IT systems, where environmental coordinators 
consolidate and calculate total figures.
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Waste streams and material management
 2024
Total waste generated [t] 363,680
Non hazardous  
Total amount diverted from disposal  
Preparation for reuse [t] 8,540
Recycling [t] 182,749
Other recovery operations [t] 32,579
The amount directed to disposal  
Incineration [t] 1,864
Landfill [t] 56,663
Other disposal operation [t] 6,553
Hazardous waste  
Total amount of hazardous waste [t] 75,053
Total amount diverted from disposal  
Preparation for reuse [t] 4,798
Recycling [t] 24,889
Other recovery operations [t] 21,181
The amount directed to disposal  
Incineration [t] 1,273
Landfill [t] 20,784
Other disposal operation [t] 1,880
Total amount of non-recycled waste [t] 142,446
Percentage of non-recycled waste [%] 39.2
Total amount of radioactive waste [t] 0
  
3. Social
3.1. Own workforce
The attractiveness and innovative strength of an organization is largely dependent on 
how well it recognizes and leverages the individual capabilities of its employees. Especially 
considering the ongoing structural change in our working world, diversity in our employ-
ees’ job profiles and qualifications is becoming increasingly important. Providing the 
right skills is a key success factor for the TRATON GROUP. TRATON relies on qualified and 
motivated employees, and we want to offer our employees a safe and attractive working 
environment in which they can develop their full potential.
3.1.1. Process for engaging with own workers and workers’ representatives
In the TRATON GROUP, we attach great importance to the participation of our employees 
and their representatives. Therefore, decisions and activities aimed at managing actual 
and potential impacts are informed by the perspectives of TRATON GROUP’s workforce. 
This engagement occurs mainly with representatives.
Employee representation
The employee representatives are involved in various bodies at TRATON GROUP. One such 
is the TRATON Supervisory Board, which is made up of an equal number of shareholder 
and employee representatives and, hence, ensures an equal say of both groups in 
 decision-making. 
At Group-level, TRATON has two labor forums — the GROUP Works Council (KBR “Konzern-
betriebsrat”) and the SE Works Council — that are designed to ensure the multinational 
involvement of our employee representatives. As part of an additional agreement with 
the SE Works Council, the company enables participants to be invited from outside the 
European Union, so that employee representatives from locations around the world 
can take part in the meetings. We conduct at least five SE Works Council Meetings and 
four Group Works Council Meetings per year to ensure effective communication and 
collaboration across the organization. In addition, the Executive Board and the employee 
representatives established an economic committee held twice per year for information 
on economic matters at the level of the SE Works Council. Sub-committees held several 
meetings for matters related to our Group Industrial Functions, ensuring that the repre -
sentatives are kept informed about the latest developments.
3. Social
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36  StiBa was paused in 2024. A newly revised employee survey will start in 2025. For more information see the 
section on “Management of corporate culture”.
Frameworks for employee engagement
The rights of TRATON GROUP’s employees are governed by the SE Participation Agreement 
as defined under section 2 para. (3) and para. (4) of the Act on the participation of the 
employees in a European community ( SEBG), in member states of the European Union 
and the European Economic Area. In practice, the Chief Human Resources Officers 
(CHROs) and the Group Labor Relations department are responsible for ensuring 
employee engagement on an operational level. TRATON’s Strategy on labor standards 
and working conditions (see the section on “Management of working conditions”) 
defines common principles and standards for our employees. Further internal agreements 
include the SE Participation Agreement and the Business and Human Rights Commit -
ment. External commitments comprise e.g., the TRATON Modern Slavery and Human 
Trafficking Statement, and the commitment to the United Nations (UN) Global Compact. 
Each brand is responsible for ensuring execution and compliance of these standards and 
agreements and is autonomous in shaping their individual work environment and frame-
work for execution in light of our global operation.  
TRATON GROUP tracks compliance with labor standards through monitoring tools and 
reporting, such as the reporting for CSRD, for the SE Works Council meetings and dialog 
with the SE Works Council (e.g., country reports), the TRATON Speak up! whistleblower 
portal or brand- respective whistleblower initiatives, as well as surveys (e.g., our annual 
employee survey (StiBa 36)). These surveys as well as the SE Works Council meetings are 
used to assess the effectiveness of employee engagement.
At the GROUP Works Council level, TRATON has established over 20 works agreements 
that cover a range of topics, including the proper use of Group-wide IT systems and mea-
sures to protect our employees. At the international level, the Group has implemented 
several agreements that ensure the involvement of employee representatives in key 
decision-making processes. During SE Works Council meetings, a variety of local issues 
are directly adressed and directed to the appropriate individuals within our various brands.
TRATON GROUP has several initiatives in place to gain insight into perspectives of people 
in its own workforce who may be particularly vulnerable and/or marginalized and to 
improve inclusion. For instance, TRATON GROUP has a strategic initiative to improve the 
engagement of underrepresented groups of employees. In 2024, the initiative held a 
diversity and inclusion event with all brands of the TRATON GROUP. Also, the SE Works 
Council representatives for severely disabled employees met twice in the reporting year. 
The TRATON GROUP works together to find solutions for integrating people with disabil-
ities into working life by offering them suitable jobs, work aids, or appropriate support 
measures. The design and application of these diversity and inclusion initiatives and 
programs are subject to applicable local law.
TRATON GROUP’s grievance mechanism as well as policies regarding the protection 
against retaliation of individuals using grievance mechanism are described in section 
“Management of TRATON’s grievance mechanism”. This also includes the description of 
assessments of how TRATON GROUP’s workforce is aware of and trusts available structures 
and processes to raise their concerns and have them addressed.
3.1.2. Management of working conditions
General approach to people and culture management
TRATON’s purpose is to transform transportation together. For a sustainable world. This 
requires a team of dedicated and passionate individuals working collaboratively across 
the entire TRATON GROUP towards a common objective. The TRATON GROUP employer 
value proposition (EVP), “be part of something bigger”, reflects this sentiment.
The culture foundation of TRATON GROUP’s corporate values and shared leadership prin-
ciples (see the section on “Management of corporate culture”) provides the necessary 
support for this purpose and EVP. The Group firmly believes that our actions, behaviors, 
and decision-making processes have a direct impact on its results. Therefore, the culture 
TRATON fosters within the Group is crucial to the success and to promoting cooperation 
across the organization.
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Frameworks for human rights
The TRATON GROUP integrates human rights into its compliance management system 
and respects all applicable regulations in force to protect human rights as a fundamental 
and general requirement throughout the world. We stress this in our internal regulations 
and due diligence processes as described below, where we strive to involve relevant stake-
holders along the way. We are committed to complying with applicable national and 
international human rights legislations and, hence, acknowledge the International Bill of 
Human Rights and have joined the UN Global Compact where we recognize our commit-
ment to its principles regarding human rights and environmental protection. We further 
strive to operate in line with the UN Guiding Principles on Business and Human Rights, 
the OECD Guidelines for Multinational Enterprises, and international labor standards such 
as the International Labour Organization (“ ILO”) Declaration on Fundamental Principles 
and Rights at Work. Furthermore, we acknowledge the following conventions:
 – Minamata Convention on Mercury
 – Basel Convention on the Control of Transboundary Movements of Hazardous Wastes 
and their Disposal
 – Stockholm Convention on Persistent Organic Pollutants
We see these international conventions and declarations as the basis of our commitment 
and the way we want to conduct business.
As described in the Codes of Conduct (for employees, see the section on “Management of 
corporate culture”, for suppliers and business partners, see the section on “Management 
of relationships with suppliers”), TRATON GROUP rejects all kinds of forced or compulsory 
labor as well as modern slavery and human trafficking. This includes work carried out 
involuntarily due to intimidation, penalty, violence by security forces, or threat of being 
disadvantaged. Employment relationships are based on voluntary participation and can 
be terminated at any time by the employees of their own free will and within a reasonable 
period of notice. We thrive to protect our employees and ensure a safe and healthy 
 working environment for everyone. Child labor is prohibited across the TRATON GROUP. 
The ILO determines the minimum age for employment, which must be adhered to.
The Group has defined clear responsibilities within the organization in the human rights 
risk management system. Moreover, the TRATON Human Rights Committee ( HRC), is a 
multidisciplinary committee that monitors and tracks the implementation of human 
rights’ due diligence obligations in the Group. The HRC meets regularly and reports 
directly to the board of management. Such reports include the results of our risk analysis, 
the effectiveness of our preventive and remedial measures, and relevant findings from 
our complaints procedure. Employees are trained on the Code of Conduct for employees 
in web-based and face-to-face training. Moreover, employees receive specific training on 
business and human rights to provide guidance and raise awareness of TRATON’s corpo-
rate responsibility for this topic (see the section on “Management of corporate culture”). 
They can address questions on human rights, e.g., via the TRATON Compliance helpdesk 
and receive information on human rights through various communication formats. In 
addition to general preventive measures, TRATON continuously evaluates and implements 
measures addressing identified risks.
The TRATON human rights approach encompasses not only working conditions of the 
Group’s own workforce but also of value chain workers as well as other material matters 
such as other work-related rights of TRATON’s own workforce and workers in the value 
chain, equal treatment and opportunities for the Group’s own workforce, and communities’ 
economic, social and cultural rights.
Human rights risk management
A central element of our human rights management is our risk analysis. We conduct 
human rights risk assessment in our own operations on a regular basis, as well as ad-hoc 
when needed. Our entities are categorized into three levels of human rights risk exposure 
(high, medium, or low), considering the results of generic risk assessment questionnaires 
as well as the analysis of internal and external sources (e.g., audit reports and external 
studies). For the high-risk entities, we conduct workshops with local experts from different 
departments to identify more concrete human rights risks. Going forward, we are planning 
to validate and refine the risk assessment annually (for consistency, completeness, 
up-to-dateness) and identify specific areas for further analysis. The results of the risk 
assessment are analyzed in the context of our human rights management system and 
the implemented human rights measures, where potential gaps are being addressed by 
additional measures and controls, if needed.
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Policies
The Policy statement on human rights and the policy TRATON strategy on working 
 conditions and labor standards relate to the potential negative impact of damage to own 
workers’ well-being from adverse working conditions, discrimination, and poor safety 
practices and the risk of staff turnover, productivity loss, and safety issues in own workforce 
resulting from adverse working conditions. 
Currently, a Group-wide policy is under development relating to topics such as occupational 
health and safety and workplace accident prevention but has not yet been implemented.
Policy statement on human rights
All TRATON GROUP entities stand behind the Policy statement on human rights. The 
principles stated therein shall be incorporated and inherent in our systems and processes. 
The management in the TRATON GROUP entities is responsible for the implementation 
of the actions and requirements defined in this commitment in their entities. The TRATON 
approach to human rights is based on the UN Guiding Principles on Business and Human 
Rights and on the International Labour Organization ( ILO) Declaration on Fundamental 
Principles and Rights at Work. The Policy statement on Human Rights covers the entire 
own workforce as well as the value chain of TRATON. The publicly available Policy state -
ment on human rights contains the principles on how TRATON wants to live up to its 
commitment to human rights. The most senior level at TRATON GROUP that is accountable 
for the policy is the Executive Board of TRATON SE and the TRATON SE Works Council.
TRATON Strategy on working conditions and labor standards
This strategy aims to secure fair working conditions and labor standards and is based on 
the International Labour Standards as well as on the TRATON Policy statement on human 
rights and associated standards. It contains Group-wide minimum standards for our entire 
workforce considering wages and salaries, working hours and rest periods, employment 
contracts as well as social protection. Besides the minimum standards it also describes 
the roles of the Labour Relations Cross-Brand Team, the TRATON SE Works council and 
the TRATON CHRO-Team. The execution of the strategy is monitored not only through the 
Speak up! whistleblower platform and the brand-respective whistleblower initiatives but 
also in SE Works Council meetings and dialogs and through the outcomes of our employee 
survey (StiBa). The strategy applies to the whole TRATON GROUP and is implemented at 
brand level. The most senior level at TRATON GROUP that is accountable for the it is the 
CHRO-Team of TRATON and the brands. To consider the interests of key stakeholders, the 
strategy has been aligned with the SE Works Council, the TRATON CEO, HR board members 
of the brands, labor relations representatives, and trade unions. The policy is available 
to other relevant stakeholders so that they are aware of the minimum standards and 
processes.
Actions and targets
The TRATON GROUP conducts regular risk analyses to identify, assess, and address poten-
tial negative impacts within its business operations and supply chain. These analyses 
prioritize areas such as workers’ well-being, workplace safety, and the prevention of 
 discrimination and adverse working conditions. Through these efforts, the company 
ensures timely and effective mitigation measures to uphold ethical standards and support 
sustainable practices.
The EU Taxonomy minimum safeguards require the TRATON GROUP to have in place 
effective processes, controls, and compliance measures regarding the core topics of 
human rights, including workers’ rights, bribery and corruption, taxation and fair competi-
tion. For more information regarding our EU Taxonomy disclosures, please refer to section 
“EU Taxonomy disclosures” of the combined management report. These safeguards are 
supported by mechanisms such as the Internal Control System ( ICS), which enable con-
tinuous monitoring and the identification of necessary actions when safeguards are not 
met. For more information regarding ICS and the risk management system, please refer 
to section “Risk management and internal controls over sustainability reporting”.
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The implementation of measures related to working conditions within the TRATON GROUP 
is overseen by the HR department. In 2024, the following key actions were taken regard-
ing working conditions of our own workforce. They all intend to prevent the potential 
negative impact of damage on own workers’ well-being from adverse working conditions, 
discrimination, and poor safety practices.
Regular Works Council meetings
The TRATON GROUP is committed to regular Works Council Meetings, which take place 
on a yearly basis. Together with the TRATON GROUP SE Works Council, alignments and 
monitoring of the “TRATON Strategy for working conditions and labor standards” is per -
formed with the aim of improving working conditions for all employees of the TRATON 
GROUP. TRATON supports the employee representatives and the corresponding commit-
tees, including funding for events, translation, interpreters, material preparation, and other 
subsidies. In addition, the Group is committed to providing the necessary human 
resources to support the committees, goals, and plans of the employee representatives 
and collective bargaining agreements.
Group talent development programs
The TRATON GROUP is fully committed to continuously developing its employees,  ensuring 
their motivation, necessary skills, and competencies, with a strong focus on daily learning. 
The goal is to enable self-driven and accessible learning throughout the TRATON GROUP, 
empowering the business in the present to be as successful as the future it envisions. In 
addition to brand-level learning initiatives, the Volkswagen Academy, and partnerships 
with external learning providers, the TRATON GROUP has offered talent development 
programs since 2017, covering each of the hierarchical levels. The Group talent develop-
ment programs are held annually or bi-annually and are adjusted to meet the evolving 
needs of the organization or to reflect fundamental changes, such as the implementation 
of our corporate values. The goal is to facilitate cross-brand collaboration among top 
talents, ensure visibility of talent at Group-level, and develop key skills aligned with the 
Group strategy. To track and assess the effectiveness of these programs, evaluations 
are gathered from participants on the program content, presenters, and the practical 
application of new knowledge in daily business. This feedback helps ensure the programs 
are impactful and aligned with the ongoing needs of the organization.
Annual employee survey (Stimmungsbarometer) 
TRATON GROUP made the decision to pause its annual employee survey “Stimmungs-
barometer (StiBa)” (see the section on “Management of corporate culture”) in 2024 to 
prepare for implementing a new Group-wide employee survey and tool that will be intro-
duced in 2025. This new survey will serve as a crucial method for capturing employee 
perspectives on workplace dynamics, team collaboration, and manager relationships. It 
provides an overall measure of employee engagement, offering insights from line 
 managers up to the TRATON GROUP level on what is working well and areas that need 
further development. This process aims to enable continuous improvement at both the 
Group- and organizational levels. Aligned with TRATON corporate values, TRATON Shared 
leadership principles, which are described in detail in the section on “Business conduct”, 
and our TRATON GROUP diversity and inclusion commitment, the new survey will be 
closely tracked from 2025 onward. To facilitate the development and implementation of 
this new survey, we provided both financial and personnel support through our HR and 
IT departments. The tracking of this action and its effective implementation is carried out 
by TRATON and the brands, which will follow up on the action plans derived from survey 
results.
Establishment of Group health and safety department to centralize coordination
To strengthen our group-wide health and safety measures, we are centralizing coordina-
tion through the newly established Group Health, Safety and Security department, which 
came into effect in April 2024. This Group function leads our efforts to unify and enhance 
the topic health and safety across all brands. Our immediate focus included appointing 
a Senior Expert to spearhead this initiative and developing a comprehensive TRATON 
GROUP health and safety policy for implementation in 2025. We completed a consolidated 
overview of existing brand policies by the end of 2024. A Group-wide working group has 
been established. Additionally, a collaborative platform for the brands was finalized and 
accessible by the end of 2024, enabling regular meetings and streamlined collaboration. 
Additionally, we are reviewing current brand structures to align with centralized steering 
and reporting, and piloting a new review process at MAN Truck & Bus Ankara. This coor-
dinated approach will ensure compliance with the German Supply Chain Due Diligence 
Act (LKSG) and the CSRD requirements and is designed to set a new standard for health 
and safety across the TRATON GROUP. To ensure the effectiveness of this approach, prog-
ress is reported regularly to TRATON’s CHRO. This reporting ensures that any necessary 
adjustments can be made promptly, keeping our health and safety standards aligned 
with TRATON’s strategy.
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For targets related to working conditions, please refer to the sections on “Management 
of equal treatment and opportunities for all” and “Management of corporate culture”. 
3.1.3. Metrics related to working conditions
Characteristics of the undertaking’s employees 
109,826 employees were employed by the TRATON GROUP at the end of the reporting 
year 2024.
In the reporting year, 10,271 employees left the TRATON GROUP. The turnover rate was 
9.4%. It is calculated by relating the number of departures to the average number of 
employees in the reporting year 2024. The basis of the calculation is the data from Decem-
ber of the previous year to December of the fiscal year of the employees of the reportable 
entities of the TRATON GROUP. The reference basis is the average number of employees 
during this period. The following groups are considered in the departures: employees 
who left TRATON due to resignation, retirement, death, or at their own request. For Scania, 
MAN and TRATON Financial Services departures to other TRATON GROUP entities are also 
considered due to technical system challenges.
All individuals with an active employment agreement involved in the value-added process 
of the reporting entity are included. All metrics reported in headcount here, reflect the 
number of the respective group of employees as of December 31 of the reporting year. 
Total number of employees by headcount, broken down by gender
Gender
As of December 
31, 2024
Female 22,229
Male 87,564
Other 0
Not reported 33
Total 109,826
Number of employees by headcount, broken down by country
Country
As of December 
31, 2024
Germany 21,239
Sweden 22,570
USA 15,378
Total number of full- and part-time employees and breakdowns by gender
Female Male Other
Not 
 disclosed Total
 2024 2024 2024 2024 2024
Number of employees  37 22,229 87,564 0 33 109,826
Number of permanent 
 employees 38 20,742 83,497 0 33 104,272
Number of temporary 
 employees 39 1,487 4,067 0 0 5,554
Number of non-guaranteed 
hours employees  40 0 0 0 0 0
37  All persons with an active employment contract involved in the value-added process of TRATON are included, 
such as top management, those in the passive phase of partial early retirement (ATZ), and apprentices. 
 Excluded are those on parental leave, marginal employment, and employees in academic training.
38  All those of the respective entity without an end date in their employment contract are counted as permanent 
employees.
39  All employees who do have a temporary contract that includes a time-limit are counted as temporary 
 employees.
40  Non-guaranteed hours employees are employed without a guarantee of a minimum or fixed number of 
 working hours.
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Characteristics of non-employees in the undertaking’s own workforce
As of December 31, 2024, there were a total of 5,127 non-employees in TRATON GROUP’s 
own workforce. Non-employees are personnel engaged for a limited period of time to 
perform the same work as TRATON GROUP employees. These personnel are not paid 
directly by TRATON and is therefore not classified as employees.
Collective bargaining coverage and social dialog
TRATON assesses the availability of collective bargaining coverage and social dialog. 
 Collective bargaining refers to negotiations between employers (or their organizations) 
and trade unions (or duly elected worker representatives) to determine working condi -
tions, terms of employment, and regulate relations between employers and workers or 
their organizations. A collective bargaining agreement is a written agreement resulting 
from these negotiations, covering conditions of employment such as payment and work-
ing hours, and potentially addressing topics like health and safety. The overall percentage 
of employees covered by collective bargaining agreements is 69% 41.
Percentage of total employees in the EEA covered by collective bargaining agreements  
and workers’ representatives
 Collective Bargaining Coverage  42 Social Dialog  43
Coverage Rate
Employees – EEA 
(for countries with > 50 empl. 
 representing > 10% total empl.)
Workplace representation (EEA only)  
(for countries with > 50 empl. 
 representing > 10% total empl.)
0–19%   
20–39%   
40–59%   
60–79%   
80–100% Germany, Sweden Germany, Sweden
Adequate wages
Not all employees received adequate wages in line with the applicable reference values 
during the reporting year. The table below accounts for the countries where some 
employees earn below the applicable adequate wage benchmark and the percentage 
41 Excluding International
42  Coverage includes all employees under a collective bargaining agreement, including those under voluntary 
extension (e.g., non-union members). An employee covered by multiple agreements is counted only once. 
In countries with trade unions, only employees covered by agreements between the employer and a trade 
union are considered.
43  Representatives of the workers duly elected and authorized are those freely elected by the workers, indepen-
dent of employer control, in accordance with national laws or collective agreements. Their functions do not 
overlap with trade union prerogatives and do not undermine the position of trade unions or their representa-
tives.
44  Within the EEA the ESRS-defined metric for an “adequate wage” is used, which is the minimum wage for the 
member state. If there is no minimum wage, the approximation prescribed by ESRS is applied. For Non-EEA 
countries, the living wage database by the WageIndicator Foundation is utilized, which provides a validated 
adequate wage for all countries outside the EEA.
45  Based on headcount as reported in table “Total number of employees by headcount, broken down by gender” 
(“Metrics related to working conditions”).
46 Other workers include workers in the value chain, if they work on TRATON sites.
of employees earning below this benchmark for each of those countries. In general, all 
employees are paid in line with local legal and, where applicable, existing collective 
 bargaining requirements. In Brazil, one employee is affected and in Morocco, six.
Countries with employees earning below the applicable adequate wage benchmark  
and  percentage of employees earning below the applicable benchmark
Country  44
Share of employees per country earning below the 
 applicable adequate wage benchmark 
Brazil 0.01%
Morocco 4.51%
Health and safety metrics
85% of our employees 45 are covered by a company health and safety management system 
based on legal requirements and/or recognized standards or guidelines. 
In the reporting year, there were zero fatalities in our own operations. Therefore, zero 
fatalities involved employees of the TRATON GROUP and zero fatalities involved other 
workers 46. 
In the reporting year, there were 2,951 work-related accidents, resulting in a rate of 
16.1 work- related accidents per 1,000,000 hours worked (TRIR).
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47  Targets related to gender representation in management, as outlined in this report, do not apply to TRATON US’s 
subsidiaries (e.g.  International Motors, etc.). Statements in this report apply only if they do not violate the 
 applicable law, including the laws and regulations of the United States of America. Our ability to achieve these 
and other goals, targets and aspirations described in this report, either at all or in a timely manner, is subject 
to a variety of factors, including evolving laws, regulations and other demands in the various jurisdictions in 
which we operate. We may update or rescind the goals, targets and commitments described in this report in 
the future as we deem necessary or appropriate.
3.1.4. Management of equal treatment and opportunities for all 
TRATON has several policies in place related to the potential negative impact on TRATON 
GROUP’s own workforce that would occur in case of discrimination in employment like 
unequal training, promotion opportunities, pay, and benefits. These policies are the 
TRATON GROUP diversity and inclusion commitment, the TRATON GROUP corporate val-
ues and the Policy statement on human rights. An action related to the representation 
of women in Group talent development programs has also been implemented to promote 
equal treatment and opportunities for all members of TRATON’s own workforce. The appli-
cation of these policies, commitments and programs, including the ones described in 
this section, is subject to applicable local law. Further actions that relate to equal treat -
ment and opportunities are regular Works Council meetings and the annual employee 
survey, which are already described in the previous section on “Management of working 
conditions”.
Policies
TRATON GROUP diversity and inclusion commitment
Diversity and inclusion at TRATON GROUP is a long-term strategic approach to ensure 
future success by developing our corporate culture through capturing and supporting 
the diversity of skills, experience, knowledge, and the perspectives of our most valuable 
asset — TRATON’s employees. TRATON does not tolerate discrimination on grounds of 
ethnic or national origin, sex, gender identity, religion, views, age, disability, sexual orien-
tation, skin color, political views, social background, or any other characteristics protected 
by law. TRATON embraces diversity, actively encourage inclusion, and create an environ-
ment that fosters each employee’s individuality in the interests of the Company. At 
TRATON GROUP, diversity and inclusion is viewed as central for success and crucial for 
reaching the goals as a company and as a responsible employer. The TRATON GROUP 
diversity and inclusion commitment is an essential component of the pillar “Responsible 
Company” of the TRATON Strategy and aligns with TRATON’s corporate values. Commit-
ments and actions are fundamentally anchored and effectively implemented through a 
set of strategies and measures across all our brands. To support this and ensure continuous 
best-practice sharing, TRATON established a Group diversity and inclusion Team with 
representatives from the management teams from each of the brands across the Group.
TRATON follows up on the success of our diversity and inclusion initiatives through rele -
vant key performance indicators such as the representation of women in management 
and the representation of women in management development. Additionally, a diversity 
and inclusion-Index was measured as part of the annual employee survey (StiBa). At the 
highest level, the TRATON SE Executive Board and the TRATON SE Works Council are 
accountable for the policy. The policy is available on the TRATON website and via the 
intranet. In light of our global operations and different legal and regulatory requirements 
and expectations across the different jurisdictions in which we operate, the applicability 
and use of these policies, commitments and programs, including the use of the index, is 
subject to, and may differ depending on, applicable local law.
TRATON GROUP corporate values 
Another policy related to the potential negative impact of discrimination in employment 
like unequal training, promotion opportunities, pay and benefits is the TRATON GROUP 
corporate values set. For further information, please refer to section “Management of 
corporate culture”.
Policy statement on human rights 
The Policy statement on human rights is based on internationally recognized instruments 
and is further detailed in section “Management of working conditions”.
Actions and targets
In 2024, the following key action and targets were set regarding equal treatment and 
opportunities for all for our own workforce  47. Together, they intend to prevent potential 
negative impacts effects from discrimination in employment like unequal training, 
 promotion opportunities, pay, and benefits.
Representation of women in Group talent development programs 
TRATON is committed to improving the representation of women in the Group talent 
development programs, with a particular focus on professionals, brand managers, brand 
executives, and Group executives, and has taken decisive action to achieve this goal. The 
groups efforts began in 2023 and continued throughout 2024, with a commitment to 
ongoing progress. To drive these improvements, we actively engage in communication 
and follow up with brand representatives to ensure a higher representation of women in 
these programs, subject to applicable local law.  
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For more details on the Group talent development programs, please refer to section 
“ Management of working conditions”.
By increasing the representation of women in the Group talent development programs, 
TRATON encourages the brands to promote women to higher management positions. 
This is closely aligned with the TRATON GROUP diversity and inclusion commitment and 
applies to all employees of the TRATON GROUP. TRATON’s targets for 2024 are to increase 
the share of women in the High Potential Challenge and Management Excellence Pro -
gram to 50%, in the Leading the Future Program to 35% and in the Executive Elite Program 
to 30%. The target setting was informed by the actual data of previous years since 2017 
and the women in management target set out below. Involved stakeholders include the 
CHROs who inform the brands via the CHRO meeting. TRATON has successfully met its 
targets for the HiPo, Management Excellence, and Leading the Future Programs for the 
cohorts starting in 2025, with the nomination process having taken place in 2024. As the 
Executive Elite Program follows a bi-annual cycle, there will be no cohort in 2025. 
In the course of our commitment, TRATON GROUP has set the target of achieving a 30% 
female management workforce by 2029, with an interim target of 20% by 2024. In light 
of our global operations, the applicability of this target is subject to applicable local law. 
The target is aligned with the TRATON GROUP’s diversity and inclusion commitment and 
applies to all employees of the TRATON GROUP. To define the target, TRATON relied on 
workforce data, discussions with internal experts, alignment with the Volkswagen Group, 
and involvement of the Group Works Council. Monitoring and reviewing the target is also 
a collaborative effort that involves TRATON and the Volkswagen Group.
3.1.5. Metrics related to equal treatment and opportunities for all
Diversity metrics
The metrics for addressing diversity include the gender distribution, both in number and 
percentage, at the top management level, as well as the distribution of employees by age 
group. 
Distribution of employees by age group
Number of employees 2024
Under 30 years 25,149
Percentage of employees under 30 years 23%
Between 30 and 50 years 58,365
Percentage of employees between 30 and 50 years 53%
Over 50 years 26,312
Percentage of employees over 50 years 24%
Gender distribution in number and percentage at top management level
Number of employees at top management level  48 2024
Female 7
% of total at top management level 16%
Male 37
% of total at top management level 84%
Other gender 0
% of total at top management level 0%
No data 0
% of total at top management level 0%
Total 44
48  Top management level is defined as the Volkswagen Group’s “TMK Group” (Top-Management Kreis Group).
  
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3.1.6. Management of other work-related rights
The policies Information governance, handling personal data and data protection orga-
nization, and TRATON’s Guiding principles on trustworthy artificial intelligence (AI) relate 
to potential negative impacts on TRATON GROUP’s employees in case of excessive data 
access, lack of consent, or data leaks. In the reporting year, TRATON took a set of concrete 
actions to support the implementation of information governance. 
Policies
Information governance (Group policy)
The purpose of the policy Information governance is to establish standards, processes, 
roles, and requirements for information to meet global legal obligations, streamline infor-
mation management, and promote secure, efficient collaboration across the TRATON 
GROUP. Data privacy and protection are key elements, and the policy outlines guiding 
questions to ensure compliance during data transfers when anonymization of personal 
data is not possible. The policy’s effectiveness is monitored through regular meetings of 
an Information governance committee.
Handling personal data and data protection organization (Group policy)
This policy aims to enable the right use of personal data of natural persons, including 
employees, supply chain workers, business partners and affected communities, when 
processing it and thus support the digital transformation of the TRATON GROUP. It covers 
all processes in which personal data is collected, stored, organized, linked, transmitted, 
used, changed, read, destroyed, or otherwise processed. The policy sets principles for 
ethical and efficient personal data processing, focusing on legality, necessity, clarity, secu-
rity, and deletion of data. Material negative impacts are addressed through a series of 
binding measures that include maintaining comprehensive data processing records, 
implementing breach detection systems, establishing data protection risk management, 
and enforcing deletion and access control protocols. To track the effectiveness of the 
policy, reporting to the Truck Board is conducted twice a year, and monitoring takes place 
within a TRATON GROUP Privacy Forum.
The TRATON data protection organization supports business activities by ensuring data 
protection practices are legally compliant and practically implemented. Internal audits 
support these efforts by incorporating audit proposals from the data protection team into 
its annual audit program. Data protection officers are appointed by the management 
board of every brand in the TRATON GROUP that has the legal obligation to do so and are 
responsible for advising on data protection issues, monitoring compliance with regula -
tions, providing guidelines for the implementation of data protection and reporting on 
the Company’s data protection activities to the TRATON Board of Management and the 
Brand Spokesperson Data Protection. In case of notifiable personal data breaches, these 
would be reported to the authorities in due form and time. 
TRATON Guiding principles on trustworthy artificial intelligence 
The TRATON Guiding principles on trustworthy artificial intelligence ( AI) aim to ensure 
the responsible use of artificial intelligence in alignment with its commitment to sustain-
ability and ethical business practices. Three key principles have been defined: respect for 
human rights and fairness; safety through technical robustness and risk management; 
and transparency about AI’s usage in products and services. Monitoring of these princi-
ples’ implementation is integrated with TRATON’s broader policy management standards, 
and all other TRATON standards for example on quality, cybersecurity, and data protection 
requirements apply equally to AI systems to promote ongoing human oversight and 
accountability in AI systems.
The principles apply to the entire TRATON GROUP and are approved by the TRATON SE 
Executive Board. TRATON’s understanding of AI systems is aligned with the definitions of 
the EU AI Act, as well as the OECD AI policy observatory. As AI is a highly complex and 
dynamic technology, TRATON monitors political, legal, and social developments related 
to it and adjusts its principles as needed to align with these changes.
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Actions and targets
In 2024, the following key action was taken regarding other work-related rights of our 
own workforce. It intends to prevent the potential negative impact of privacy risks from 
excessive data access, lack of consent, and data leaks.
Implementation of the policy information governance (Group policy)
In mid-2024, the implementation of the Group policy Information governance started. 
The brands and our employees were supported in adapting the policy with a foundational 
framework to ensure clarity and consistency. While a guideline outlining key dos and 
don’ts was launched during the reporting year as part of this framework, this action will 
continue throughout 2025 with the development of additional guiding documents. To 
provide easy access to these materials, a dedicated website has been launched on the 
internal platform. The intended outcome is to ensure that the policies are fully imple -
mented at the brand level, creating a consistent approach to information governance 
across the entire organization. The policy’s effectiveness is monitored through regular 
meetings of an Information governance committee.
3.1.7. Metrics related to other work-related rights
Incidents, complaints, and severe human rights impacts
During the reporting year 2024, TRATON GROUP received 863 hints through the whistle-
blower channels. Of the cases that were categorized as potential violations, 19  49 cases 
were related to discrimination and harassment. 53  50 cases confirmed as violations were 
related to discrimination and harassment. 29 cases were categorized as potential viola -
tions concerned workforce issues outside of discrimination and harassment. 9 cases that 
were confirmed as violations related to workforce issues outside of discrimination and 
harassment. There have been no fines, sanctions, and compensation payments related 
to incidents and complaints about discrimination, including harassment. No 51 cases were 
submitted to the national contact points for multinational enterprises of the OECD in 
connection with workforce issues. 
During the reporting period, there were no 52 serious incidents related to human rights in 
connection with the workforce were reported through the whistleblower channels. There-
fore, no 53 cases were violations of the UN Guiding Principles on Business and Human 
Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD 
Guidelines for Multinational Enterprises. The fines, sanctions, and compensation payments 
related to these incidents amount to €0.
Additionally, the same methodology as above is used to measure the total amount of 
fines, penalties, and compensation for damages resulting from complaints. The total 
amount of fines, penalties, and compensation for severe human rights incidents is also 
tracked. Furthermore, based on the available data, the company did not have significant 
fines, penalties, or compensation for damages in an amount that requires a separate 
disclosure of those numbers in the financial statement.
3.2. Workers in the value chain
3.2.1. Process to remediate negative impacts and channels for value  
chain workers to raise concerns
To mitigate negative impacts on workers in the value chain, (for an overview of IROs refer 
to “Results of the double materiality assessment”), violations of the Code of Conduct for 
suppliers and business partners can be identified in the case of direct or indirect suppli-
ers through the Supply Chain Grievance Mechanism ( SCGM) as part of the complaint’s 
procedure and through on-side audits as part of the Sustainability Rating. If violations 
are found at direct suppliers, concrete measures should be defined to address these 
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49  The categorized cases are retrieved from the whistleblower system.
50  The confirmed cases are retrieved from the whistleblower system and sanctions reporting. The TRATON 
GROUP measures the total number of incidents of discrimination, including harassment and the number of 
complaints in its own workforce filed through channels to raise concerns, with the Group-wide reporting 
structure established by the Volkswagen Group in 2019. This structure requires each entity within the GROUP 
to document and report disciplinary measures and includes several clusters of causes and 4 categories of 
measures, with data points relevant for CSRD reporting (S1-17 103(a)). Notably, one cluster addresses discrimi-
nation, mobbing, and stalking, while another cluster focuses on sexual harassment. 
51  TRATON uses the OECD database as data source. The update frequency of this database is uncertain, there-
fore a case reported at the end of December may not be published on the website immediately.
52  The methodology described is also used to measure the number of severe human rights incidents connected 
to the workforce.
53  The methodology described is also used to measure the cases of non-compliance with the UN Guiding Princi-
ples, ILO Declaration, or OECD Guidelines.

===== SIDA 280 =====

violations systematically and transparently. When selecting and designing measures, 
special care is taken to ensure that they are specifically defined and appropriate. The 
measures are defined by the SCGM experts and communicated to the affected suppliers. 
Measures implemented by the supplier can include, but are not limited to audits, policies, 
and certifications. The violations found during an on-site audit are mapped out in corrective 
action plans and must be dealt with by the suppliers. 
TRATON empowers and upskills its suppliers in executing corrective actions, fostering a 
collaborative environment where both short- and long-term improvements are achieved 
to effectively address violations. Suppliers are actively involved in the development of 
these actions in dialogue with SCGM experts and/or auditors. This allows action to be 
taken to stop or minimize the breach. In particular, the selection and design of appropriate 
measures weights up the effort associated with the specific violation and the affected 
persons in the relevant local context. If necessary, an escalation process can be initiated, 
in which it is possible to block the suppliers. 
The basic procedure for checking the effectiveness of the measures implemented by the 
supplier as a result of an on-site audit is carried out by the auditor or the responsible brand 
expert as a part of desktop review or by a further on-site audit. In cases where direct 
suppliers do not implement the defined measures or do not implement them completely, 
the supplier goes through the intended steps in a multi-stage escalation process. As part 
of the escalation process, if the measures are not implemented effectively within the 
specified period, a new on-site audit can be ordered or, if necessary, the business relation-
ships can be temporarily suspended. This temporary suspension means that the supplier 
is blocked from re-awarding. If, upon re-examination of the action plan by the SCGM 
auditor or subject matter expert, it is determined that it does not lead to a termination of 
the breach, the supplier will remain barred from new business. Finally, the current and 
upcoming orders from the supplier can be verified based on the evidence.
TRATON values confidential, relevant tip-offs from business partners, customers, and other 
third parties. In the event of specific indications of potential misconduct by employees 
of TRATON, or of the business partner or its business partners in turn in the context of 
collaboration with TRATON, TRATON offers all stakeholders the option of reporting such 
misconduct to the TRATON whistleblowing system. 
TRATON’s general approach to addressing negative impacts via the whistleblower system 
as well as mechanisms in place to protect its users against retaliation is outlined in section 
“Management of TRATON’s grievance mechanism”. As our complaint channels are avail-
able to the public, they are also accessible for all value chain workers as well as affected 
communities. To prevent and detect negative impacts on value chain workers specifically, 
TRATON requires its business partners to establish a grievance mechanism adequate to 
their business via the Code of Conduct for suppliers and business partners. The mecha-
nism allows for concerns related to business ethics, human rights, or the environment 
to be raised by both their own employees as well as other potentially affected people 
anonymously, confidentially, and without fear of retaliation. TRATON’s Code of Conduct 
for suppliers and business partners further demands business partners to provide their 
employees with unhindered access to the whistleblowing system implemented by 
TRATON and not perform any actions that obstruct, block or impede access. Business 
partners undertake contractually to pass on these obligations to their suppliers and 
to ensure, to the extent possible and reasonable, that the obligations are passed on in 
the supply chain. Detailed information on how issues raised are monitored and how the 
 effectiveness of the whistleblower system is ensured are presented in the sections on 
“Metrics related to other work-related rights” and “Management of TRATON’s grievance 
mechanism”.
As of now, TRATON has not adopted a general process to engage with workers in the value 
chain about impacts.
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3.2.2. Management of working conditions and other work-related rights 
of workers in the value chain
Policies
Two of TRATON’s Group policies – the Policy statement on human rights and the Code of 
Conduct for suppliers and business partners – relate to the potential negative impacts of 
adverse working conditions, occupational health and safety issues, and denial of freedom 
of association on workers in the value chain as well as the potential employment of under-
age workers and the use of forced labor within the value chain. Both policies are also 
relevant in the context of the risk of reputational damage, legal risks, and operational 
disruptions than can arise from involvement in child and forced labor cases. 
TRATON GROUP’s Policy statement on human rights is applicable to our own workforce 
as well as to workers in the value chain and is described in section “Management of 
working conditions”. TRATON’s Code of Conduct for suppliers and business partners is 
further detailed in section “Management of relationships with suppliers” and essentially 
covers all material IROs related to the following topics: working hours, fair wages, work-life 
balance, health and safety measures, freedom of association, and collective bargaining.
Actions and targets 
The Responsible Supply Chain System (Re SC System) provides Group-wide applicable 
standard actions to mitigate significant potential negative impacts and manage any 
 significant risks that arise in relation to workers in the value chain. These negative impacts 
are specifically potential negative impacts of adverse working conditions, occupational 
health and safety issues, and denial of freedom of association on workers in the value 
chain as well as potential employment of underage workers and the use of forced labor 
within the value chain. The corresponding material risks include reputational damage, 
legal risks, and operational disruptions can arise from involvement in child and forced 
labor cases.
Sustainability Rating
The Sustainability Rating (S-Rating) is used to check suppliers’ sustainability performance 
and identify opportunities for continuous improvement. By tying sustainability perfor -
mance directly to eligibility for being awarded contracts of a certain volume and higher, 
together with the Volkswagen Group we are aiming to send a signal to our suppliers and 
partners to encourage collaboration to allow sustainability aspects to permeate the  supply 
chain. The primary objective is not to exclude suppliers from the supply chain, but rather 
to empower suppliers whose performance is not yet satisfactory to achieve the rating.
The S-Rating is an established process in the brands of the TRATON GROUP, which started 
as early as 2019 at MAN, Scania and VWTB. The tool is used to review the sustainability 
performance of suppliers with a high sustainability risk in the areas of environment, social 
affairs, and integrity and to mitigate risks. The review as part of the S-Rating is carried out 
on a risk-based and event-driven basis before a new contract is awarded using a multi-
stage process. In an initial step, a risk exposure is determined from a combination of a 
country risk and the supplier’s corporate processes and guidelines. In addition, the com-
panies with insufficient sustainability performance can be subjected to audits. TRATON 
draws on data from a specialized service provider to determine the country risk. The Group 
uses a standardized self-assessment questionnaire to review the requirements for cor -
porate processes and supplier guidelines. Since 2022, the S-Rating has been mandatory 
as a minimum requirement for supplier locations in the scope with ten or more employ-
ees. The result of the S-Rating is divided into three rating categories: Suppliers with an 
A or B rating fulfill our requirements to a sufficient extent and are therefore eligible to 
be awarded contracts. A and B ratings are considered positive ratings. If a supplier does 
not meet the requirements for compliance with sustainability standards (C rating), it is 
 generally not eligible to be awarded a contract. This provides a direct incentive for 
 suppliers to improve their sustainability performance.
By the end of the reporting year 2024, 3,135 S-Ratings were available for suppliers. Of 
these suppliers, 1,774 have an A rating. Six suppliers have a C rating and are therefore 
currently not eligible to be awarded contracts. Suppliers who do not meet our require -
ments for compliance with our sustainability standards are also ineligible.
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In addition, the sustainability performance of suppliers is assessed on a risk basis and at 
times with the help of audits. If suppliers pass this audit with a score of less than 100%, 
they receive improvement measures. If the score is below 80%, these measures are 
recorded in a plan. Their implementation is agreed with the supplier and followed up on. 
Depending on the measure, the supplier must implement the plan within six months at 
the latest. If the supplier receives an audit result of less than 60%, a new audit is carried 
out following the implementation of the action plan. The audit result affects the S-Rating 
category and can consequently lead to a C rating. With a C rating, a supplier is generally 
no longer eligible to be awarded. Following Volkswagen’s Group-wide target, the TRATON 
brands’ goal is that over 95% of our direct suppliers have a positive S-Rating (meaning a 
rating of A or B) based on turnover by 2040. As part of the strategy development process, 
the goal was formulated by a cross-divisional working group at Volkswagen Group, for 
which part of the TRATON GROUP brands were consulted. Workers in the value chain were 
not involved either directly or indirectly through representatives. S-Rating coordination 
is handled by procurement sustainability.
This goal of continuously improving the sustainability performance of suppliers is aimed 
at reducing both the negative impacts TRATON has identified as material and the asso -
ciated material risk. As an interim goal, TRATON GROUP has, together with the Volkswagen 
Group, the target of achieving a positive S-Rating for 85% of our direct suppliers by 2025, 
based on turnover. The achievement of the target and the analysis of significant changes 
at suppliers are tracked independently by the brands. Since the target was set, no changes 
have been made to the target itself or to the methodology on which the target is based.
Sustainability training for employees in procurement
Sustainability is an integral part of the skills profile for employees in procurement. 
 Systematic training of our employees is essential for improving sustainability in the  supply 
chain. In 2024, training courses on sustainability for procurement were performed by the 
brands and attended more than 363 times worldwide.
Sustainability training for suppliers 
To enable continuous supplier development, the TRATON GROUP brands in collaboration 
with Volkswagen Group conduct topic-specific sustainability training and workshops with 
suppliers at selected locations or online and offer web-based trainings. In the reporting 
period, 733 suppliers were trained accordingly. In-depth human rights training has also 
been available for suppliers since 2023. The training includes legally required aspects 
such as training on child labor, forced labor, and discrimination. Since 2023, the training 
has been systematically rolled out to suppliers with a high sustainability risk. Correspond-
ing activities were continued in 2024. In addition to the training courses, through TRATON 
provides current suppliers with an e-learning module on sustainability in eight languages.
Due diligence checks for suppliers
TRATON continuously conducts due diligence checks for suppliers, also throughout the 
reporting period. Through the brands, the company reserves  the right to verify compli-
ance of suppliers with sustainability requirements of the Code of Conduct for suppliers 
and business partners regularly, randomly, or for specific events.
This can be done, for example, by means of a risk assessment of the relevant supplier’s 
area of responsibility, a self-assessment by the supplier and when necessary, by deploying 
experts locally for an on-site assessment. An on-site assessment of this nature is only 
carried out in the presence of representatives of the business partner during regular 
working hours and in accordance with applicable laws, in particular regarding data pro -
tection. The supplier takes measures that give the TRATON GROUP, through the brands, 
the right to carry out similar assessments of their business partners if this is necessary 
for the fulfilment of legal obligations.
If sustainability risks are identified during pre-contractual assessments, the resulting 
measures, if any, shall be included in a corrective action plan that will be followed up 
during the supplier onboarding process. In this case, the supplier is obliged upon entering 
into the contract to assess any determined or imminent violation of the sustainability 
requirements in its own business area or in its supply chain within a reasonable period and 
to address any such non-compliance at no additional cost to TRATON. The results of pre- 
contractual sustainability compliance assessments are a key factor in contract awarding.
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Should a violation of the sustainability requirements by the supplier occur or be imminent, 
the TRATON GROUP is entitled to take prompt measures to prevent or minimize the extent 
of such violation. In such instances, the supplier is obligated to take measures to prevent, 
stop, or minimize the extent of such violation. The supplier can be required to participate 
in one or more training formats of Volkswagen Group, if participation in the training may 
lead to the termination or minimization of the violation. If the nature of the violation is 
such that it cannot be terminated in the foreseeable future, the business partner prepares 
and implements a plan (including a specific schedule) to stop or minimize the violation 
without undue delay. If required by law, the TRATON GROUP shall be involved in the prepa-
ration of the plan.
Raw Materials Due Diligence Management System
Regarding the responsible sourcing of raw materials, TRATON in collaboration with 
Volkswagen Group follows the approach on the five steps of the OECD Due Diligence 
Guidance for Responsible Business Conduct and the requirements of the OECD Due 
Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected 
and High-Risk Areas. Since 2020, TRATON brands have been represented in the 
Volkswagen Group management system. The brands that have assessed the potential, 
have implemented a raw materials due diligence management system based on the 
OECD. It serves to identify, assess, and mitigate actual and potential human rights risks 
in our upstream raw materials supply chains. In the reporting year 2024, a new review 
and assessment of the 18 raw materials identified as particularly risky was carried out by 
Volkswagen Group. The TRATON GROUP brands were represented during the assessment. 
These include the battery raw materials cobalt, lithium, nickel, and natural graphite, the 
conflict minerals tin, tungsten, tantalum, and gold (3 TG) as well as aluminum, copper, 
leather, mica, steel, natural rubber, platinum group metals, rare earth elements, cotton, 
and magnesium.
With this risk-based approach, the company prioritizes its activities based on the severity 
and likelihood of the infringement and the Company’s ability to influence it. TRATON also 
systematically uses the Volkswagen Group structure to develop and implement specific 
preventive and mitigative measures, the effectiveness of which the Company reviews. As 
part of the management system, new reporting structures and toolkits were developed 
and existing instruments such as the Supply Chain Grievance Mechanism were integrated 
into the brands of the TRATON GROUP. In partnership with Volkswagen Group, the TRATON 
GROUP brands continuously adapt and enhance new measures based on the outcomes 
of the due diligence process.
In addition to the actions described above as part of the ReSC System, TRATON performed 
the following action. 
Human rights salience assessment  
To understand the TRATON GROUP’s human rights and social risk profile and increase 
the readiness and ability of the key decision-makers to consider human rights in the 
 Company’s sustainability and business strategy, TRATON GROUP commissioned an exter-
nal consultancy to conduct a human rights salience assessment in 2024. The salience 
assessment identifies and prioritizes human rights risks from the perspective of rights-
holders prior to any company’s management effort. It covers the TRATON GROUP’s full 
value chain across its brands including the Company’s own operations, supply chain, 
distribution, and sales networks, as well as customers and end-users. The salience 
assessment methodology on negative impacts is aligned with the United Nations Guid-
ing  Principles on Business and Human Rights considering the four criteria of scope, scale, 
remediability, and likelihood. In total, 18 salient human rights risks and impacts were 
identified, which can be split in the three categories labor and workforce; product, 
 customer and end-users; and cross cutting and emerging themes.
The human rights salience assessment served as a basis for the DMA and will inform 
further actions around managing IROs related to value chain workers. As a next step, in 
2025, the TRATON GROUP will start a new human rights program. 
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3.3. Affected communities
3.3.1. Processes for engaging with affected communities
TRATON’s general approach to addressing negative impacts via the grievance mechanism 
as well as our mechanisms in place to protect its users against retaliation is laid out in the 
section on “Management of TRATON’s grievance mechanism”. 
Besides the grievance mechanism, which is accessible to everyone, the TRATON GROUP 
has not adopted a general process to engage with affected communities as of now. 
However, this will be covered by a newly introduced human rights program, which is 
based on the human rights salience assessment conducted in 2024.
TRATON respects the human rights of affected communities in the same manner as 
TRATON respects the human rights of its own workforce and value chain workers. There-
fore, the Group’s risk analysis addresses negative impacts to local communities and 
indige nous people that may be caused by the own business operations or the suppliers 
of TRATON. Similarly, cases of regulatory violations with negative impact on local commu-
nities and indigenous people that are caused by misconduct of employees or suppliers 
of the Group can be addressed in the relevant channels of the TRATON complaints pro-
cedure. An approach to address impact on local communities and indigenous people 
that is not attributed to either suppliers or employees’ misconduct is currently under 
development. During 2024, to best knowledge, no confirmed cases were reported of 
non-respect of the UN Guiding Principles on Business and Human Rights, ILO Declaration 
on Fundamental Principles and Rights at Work, OECD Guidelines for Multinational 
 Enterprises nor cases of severe human rights issues and incidents connected to affected 
communities.
Further aspects of the management of impacts and risks related to affected communities 
are described in section “TRATON’s grievance mechanism”. The processes described in 
section “Management of working conditions” for identifying appropriate action for 
 negative impacts are implemented across TRATON GROUP’s operations and supply chain.
3.3.2. Management of health and safety of affected communities
Protecting the health and safety of communities is especially important for communities 
near TRATON’s operations or supply chain and communities affected by crimes and illegal 
activities potentially facilitated by TRATON’s vehicles. Alongside the Code of Conduct for 
suppliers and business partners (see the section on “Management of relationships with 
suppliers”) and the accompanying actions, TRATON has an export control policy in place. 
Together, these put into practice the commitment of the TRATON GROUP to adhere to all 
applicable export control laws and regulations across the jurisdictions and regimes where 
it operates. 
The Code of Conduct for suppliers and business partners also relates to the legal and 
reputational risks and operational disruptions from implication in human rights violations, 
which is also partially addressed by the CAHRA project, as described below. The Policy 
statement on human rights (see the section on “Management of working conditions”) 
also relates to this risk. Additionally, the Code of Conduct for suppliers and business part-
ners requires suppliers and business partners to respect the rights of local communities 
to decent living conditions, including their rights to land, access to water, and other  natural 
resources, as well as their right to practice their culture. The Policy Statement on human 
rights sets out further principles that TRATON adheres to in the context of human rights 
contributing to mitigating potential negative impacts in this context.
Policies
Export control (Group policy)
The policy describes export control, a top-down process that regulates trade and payment 
flows related to individuals, organizations, funds, items, services, and technical support, 
as well as sanctioned countries and critical end-uses. Each local brand company involved 
in exports must appoint an Export Control Officer in line with the governance structure 
provided by the Central Brand Export Control function. Additionally, all TRATON GROUP 
companies nominate a member of the management board or board of directors to be 
chief export control officer and responsible for foreign trade and export control matters. 
The policy defines the framework for each Group company to implement an Internal 
Compliance Program (ICP) including export control self-assessments as described below. 
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The TRATON GROUP Export Control department supports companies to ensure the effec-
tiveness of the policy requirements, as well as national, EU, and US regulations, and informs 
the Volkswagen Export Control department annually. Where needed, qualified external 
parties may be considered to conduct reviews and audits. Corrective actions to adopt the 
export control operations or the ICP according to the findings of the review will be jointly 
defined and monitored by the respective brand and/or TRATON GROUP company. All 
TRATON GROUP companies and their employees must comply with this policy. In cases 
where country-specific laws are stricter, those laws are prioritized.
Actions and targets
In 2024, the following key actions were set in this topic.
Internal Compliance Program and export control self-assessment
The TRATON Export control policy defines a framework and requires TRATON brands and 
companies to establish an ICP, thereby ensuring compliance with international legal 
requirements arising from international trade regulations such as US Export Administra-
tion Regulation (EAR), the EC Dual-Use Regulation, and other national export control laws. 
The ICP is an inhouse manual detailing the organization of the export controls and descrip-
tion of internal procedures put in place to deal with export controls and comply with trade 
restrictions. The scope and extent of the ICP need tailoring to the commercial activities 
of the specific company and depend on various factors including the size, structure, scope 
of business, and customer portfolio. Further, to identify export control requirements and 
as part of the ICP, Group companies are required to conduct continuous export control 
self-assessments to identify and mitigate risks. These assessments help evaluate the 
effectiveness of procedures and internal controls in place, ensuring improvement and 
alignment with evolving legal requirements (e.g., in the field of sanctions). Where needed, 
qualified external parties may be considered to conduct reviews and audits. Corrective 
actions to adopt the export control operations according to the findings of the review are 
monitored by the respective brand and/or TRATON GROUP company.
The self-assessment must be continuously repeated to re-evaluate the implemented 
measures, changes in the legal situation, and risk factors. The repetition of self-assessments 
is based on identified risk profiles. The ICP, the self-assessment, together with other export 
control documentation, form the basis for the reviews and audits that ensure the effec -
tiveness of the Export Control policy and accompanying actions. All brands and companies 
in scope have implemented and are continuously developing training to ensure that 
stakeholders across various departments clearly understand their role and how they are 
expected to contribute to the export control process.
Project to conflict-affected and high-risk areas (CAHRA)
To address negative impacts on affected communities in conflict-affected and high-risk 
areas (CAHRA) caused by our own operations and those of our business partners, TRATON 
is currently developing a heightened human rights due diligence approach ( CAHRA 
 project). This project will start in 2025 and aims to focus on sales and end-use related risks. 
It will not only facilitate risk mapping for sales and end-use risks, but also develop a due 
diligence process for CAHRAs. Additionally, this action aligns with our identified risks and 
material topics related to upholding International Standards in CAHRA. The scope of this 
action extends to business partners in our downstream value chain that are located in or 
sell to CAHRAs. In this context, input from this project could help to better understand 
the adverse impact of a certain complaint, should it not reach the complaints procedure. 
The implementation of measures related to affected communities is overseen by the 
Sustainability department. Through their personnel and financial resources, these depart-
ments continuously address the key impacts and contribute to achieving the established 
goals. No targets related to the sustainability matter of the health and safety of affected 
communities were determined for the reporting period as this topic only became mate-
rial for TRATON in 2024. 
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3.3.3. Management of road safety and privacy
During the DMA, TRATON identified a potential negative and a positive impact related to 
road safety and privacy. The product safety and conformity policy and accompanying 
monitoring actions relate to the potential negative impacts on the health and safety of 
users, passenger and pedestrians that may result from product defects, or quality issues 
and data privacy violations from information gathered in vehicles. They also relate to the 
potential positive impact of enhanced data security and road safety, which can encourage 
privacy-conscious and safe driving behaviours.
The policies Information governance, Handling personal data and data protection 
 organization and the TRATON Guiding principles on trustworthy artificial intelligence, as 
outlined in section “Management of other work-related rights” alongside relevant related 
actions, also relate to both of these impacts by providing comprehensive guidelines for 
handling personal data.
Policies
Product safety and conformity (Group policy)
As a leading commercial vehicles manufacturer, the TRATON GROUP strives to manufac-
ture products of the highest possible quality. However, sustained success is possible only 
if integrity — in other words, activities conforming to statutory requirements and driven 
by a commitment to values – forms the basis for day-to-day activities. For this reason, the 
TRATON GROUP is not only required by law to observe duties but is also committed to 
complying with the statutory and administrative rules and regulations as well as other 
legally binding standards applicable to its products. It further maintains a system for 
active and passive product surveillance monitoring for the products that it releases on 
the market. Finally, TRATON aims to avert hazards and danger to life and limb arising from 
such products as far as it is reasonably able to do so.
The policy product safety and conformity established uniform standards for the TRATON 
GROUP by closely aligning with the Volkswagen Group’s policy. It stipulates that TRATON 
entities bringing products to market adhere to the organizational and procedural frame-
works and aims to ensure that in the field identified risks against safety and/or conformity 
are detected, assessed, and appropriately mitigated. Additionally, the policy specifies 
multi-brand collaboration among the TRATON brands. It sets consistent, Group-wide 
 standards in accordance with the TRATON GROUP’s module and component strategy, 
facilitating the coordination of necessary measures across the companies within the 
TRATON GROUP.
Actions and targets
The following key action are taken regarding road safety. Regular internal audits are 
 conducted to ensure that all actions required by the product safety and conformity policy 
are complied with and effective. To this end, at least 5% of the new cases of suspicion of 
non-conformity or lack of safety added since the last audit should be audited in each 
calendar year.
Monitoring and management of product safety and conformity
The brands of the TRATON GROUP placing products on the market are committed to 
maintaining robust systems for both active and passive surveillance of products released 
on the market to prevent potential hazards. As soon as indications of potentially safety 
and/or conformity-relevant deviations are identified, this information must be immediately 
subjected to a more detailed technical analysis and, if necessary, a risk assessment to 
introduce any necessary measures. For managing such procedures, designated committees 
are installed within the brands. No specific measurable targets with respect to the defined 
affected communities have been established yet due to the need for further internal 
evaluations.
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4. Business conduct
Business conduct is a decisive factor for the long-term success of the TRATON GROUP. It 
significantly influences relationships with customers, employees, suppliers, and other 
stakeholders. Ethical and responsible business conduct is therefore essential to 
strengthen the trust of various parties and build a positive reputation for TRATON in the 
industry. The TRATON GROUP’s ongoing membership and active participation in initiatives, 
such as Transparency International Deutschland e.V., UN Global Compact, German Institute 
for Compliance (Deutsches Institut für Compliance), and Alliance for Integrity (Allianz für 
Integrität) demonstrate its unwavering commitment to conducting business with integ-
rity, ethics, and compliance. The matters that were identified as material for the TRATON 
GROUP in the context of business conduct are: corporate culture, corruption and bribery, 
management of relationships with suppliers including payment practices, political 
engagement, and protection of whistleblowers. For the topic of animal welfare, no material 
impacts, risks or opportunities were identified, hence the topic is not addressed further 
in this report.
4.1. Corporate culture 
4.1.1. Management of corporate culture
Policies
To maintain a responsible business conduct and implement TRATON’s sustainability strate-
gies in line with its corporate values, several Group policies guide the Group’s effort. They 
relate to the potential negative impact of disengagement of employees, lack of employee 
empowerment and motivation, potential unethical behavior from weak corporate culture, 
the risk of reduced productivity, decreased efficiency and higher employee turnover, the 
potential positive impact on employees by cultivating a corporate culture that aligns with 
the Group’s values and purpose, and the material opportunity to improve productivity 
and competitiveness and reduced turnover costs. 
Code of Conduct for employees (Group policy)
The TRATON GROUP Code of Conduct for employees is the ethical and value-based central 
guideline for acting with integrity and in compliance with the rules in our Group. It serves 
as a binding framework for all employees of all functions in all TRATON GROUP companies 
— all over the world. The Code of Conduct for employees covers a wide range of topics, 
including ethical leadership, human rights, occupational health and safety, prohibition 
of corruption, product compliance, IT security, and environmental protection. All topics 
of the section Business conduct are also governed by the Code of Conduct for employees. 
The decisions taken in all areas of work and in all roles must be in accordance with the 
corporate values and comply with applicable national and international laws, regulations, 
and internal voluntary commitments. 
TRATON corporate culture frameworks
Three frameworks further shape the corporate culture of TRATON: TRATON GROUP 
 corporate values, TRATON GROUP thinking model, and TRATON GROUP shared leadership 
principles. Together they form a system at TRATON in which all components rely on each 
other. They apply to the entire TRATON GROUP and are accessible for all affected stake -
holder, our employees, via the intranet. The most senior level at the TRATON GROUP that 
is accountable for these policies is the Executive Board. The policies are reviewed and 
updated if necessary. They do not align with relevant internationally recognized instru-
ments.
TRATON GROUP corporate values
The TRATON GROUP corporate values provide the frame for how business is conducted 
in the Group. This is based on the firm conviction that there is a close connection between 
the results and the way in which all employees, managers and the Executive Board behave, 
think and make decisions. That is why the TRATON GROUP commits to five corporate 
values: Customer first, Respect, Team Spirit, Responsibility, and Elimination of Waste. 
These values are applicable to the whole Group and underline its purpose: Transforming 
Transportation Together. For a sustainable world. Although the TRATON GROUP finds its 
strength in the different perspectives within the Group, it is crucial that the full business 
potential is used and the Group exploits its advantages to create value for clients and 
society. Hence, the TRATON GROUP has stepped up collaboration between its brands 
through workstreams to successfully implement its strategy and realize common projects. 
As there are many overlaps between the corporate values and the corresponding stake-
holders, the interests of the stakeholders were not only considered but fundamental when 
developing the policy.
4. Business conduct
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Customer First
RespectElimination 
of Waste
Team SpiritResponsibility
TRATON
Corporate Values
TRATON GROUP thinking model
The TRATON GROUP thinking model is a framework that describes how everyone involved 
learns, adapts, and evolves. It connects the TRATON GROUP corporate values with the 
Group’s results — and back again — to create a real-time and relevant organizational 
learning system. This ensures that everyone involved in the development of methods has 
the same vision, even if they are not in direct contact with each other. The TRATON GROUP 
thinking model not only links corporate values and results, but also integrates principles 
and methods into the strategy. It describes how principles are translated into methods 
and how knowledge is learnt and preserve within the company. To foster the Group-wide 
implementation of the Group thinking model, a cross-brand human resources workstream 
has been established developing a shared training concept. 
Thinking Model
Thinking Model
Principles
Methods
Results
Corporate Values
TRATON GROUP shared leadership principles
The TRATON GROUP shared leadership principles capture how TRATON thinks about great 
leadership. Principles are rooted in TRATON’s corporate values, because it matters how 
we achieve business results. Each leadership principle serves all TRATON GROUP corporate 
values and describes a core idea that shapes the methods. The shared leadership principles 
help to avoid misunderstandings and unnecessary conflicts by defining good leadership. 
By adhering to the shared leadership principles, employees follow certain standards and 
methods that strengthen TRATON’s external image. TRATON pursues three leadership 
principles : (1) own today, shape tomorrow, (2) start with trust, build together, and (3) dare 
to try, manage the risk. The shared leadership principles were developed this year and 
implemented through various communication measures as well as the Top 400 Leaders 
Workshop held in June 2024.
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Actions and targets 
In 2024, the following key actions and targets were set regarding corporate culture.
Corporate value roll-out
The TRATON GROUP is actively rolling out and strengthening its corporate values across 
all its brands, ensuring the seamless integration of these values throughout the entire 
organization. The implementation started in 2024 and will be continued beyond the 
reporting period. Each brand and Group function needs to set up a system with training, 
promotion schemes, recruitment processes, leadership principles, and similar, that 
ensures that the corporate values are lived throughout the organization. This is supported 
by a tool-based process, which consists of seven sessions taking approximately ten hours 
per employee to complete. The expected outcome is to support the development of the 
TRATON GROUP’s culture and to create awareness of the TRATON GROUP corporate values 
among all employees. This will help shape actions and new behaviors that are aligned 
with the values, ultimately contributing to a positive work environment and a strong 
Group culture. In the reporting period, 12,672 employees of TRATON GROUP participated 
in the corporate value training.
Collaboration tools
Two tools are available to employees via TRATON’s intranet: The collaboration toolbox and 
the culture kit. These tools serve as an implementation aid for corporate culture concepts 
and are promoted throughout talent development programs, training, and working 
groups. They were developed in 2022 and have been continuously updated. In the report-
ing year, for example, tools regarding diversity and inclusion were added. 
Role Model Program
The Role Model Program, is based on our corporate values and supports the culture 
change within the entire TRATON GROUP by reinforcing an open and trustful culture, as 
well as reducing silo thinking. For 2024, we set the target of 75% implementation rate for 
the Role Model Program throughout the Group. We achieved this target with a 82% imple-
mentation rate for the year 2024. The targets are based on managers’ completion of their 
individual target. Employees with a management function were required to set a good 
example by implementing at least two activities by the end of 2024 to reach 100%. 
 Managers who made a status change in the second half of the year were only required to 
implement and document one activity in this timeframe. In total, 6,222 managers par -
ticipated in the Role Model Program in 2024. Several functions of TRATON’s Human 
Resources department were involved in setting the target to ensure it is aligned with 
relevant policies, programs, and other goals.
Talent development programs 
Another action significantly strengthening the application of the TRATON corporate  values 
and beliefs reflected in the Groups corporate culture are the talent development pro -
grams, which are described in the section on “Management of working conditions”.
Annual employee survey 
In previous years, an annual employee survey called Stimmungsbarometer (StiBa) was 
conducted to obtain feedback on employees’ experiences and review how the corporate 
culture is developing. This year, this process was paused as the TRATON GROUP is currently 
developing a new tool covering all brands that will be introduced in 2025. The annual 
employee survey will further support the evaluation of the success of Business Conduct 
implementation and serves as a guidance for actions in the area of governance (see the 
section on “Management of working conditions”).
Tone from the top statements
Regular tone from the top statements addressing TRATON’s own workforce by members 
the Executive Board and of the management demonstrate the importance of compliance 
and commitment to ethical and compliant behavior. Such statements appear through 
various channels such as quotes in training and communication material and keynotes 
at compliance events. A clear tone from the corporate leadership encourages a com-
pliance culture throughout the TRATON GROUP and demonstrates TRATON GROUP’s 
commitment to internal and external stakeholders.
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54 Excluding Scania due to technical system challenges
Code of Conduct training
In order to support employees in applying the Code of Conduct for employees, we offer 
Code of Conduct training for all employees of the TRATON GROUP. All indirect employees 
receive a mandatory web-based training. For this training, we aimed at a 100% completion 
rate throughout the reporting year. In the reporting period, 94% of the target group 
completed the web-based training. 54 The completion gap can be explained by regular 
fluctuation, that is, employees joining or leaving the Company during the training period.
4.2. Prevention and detection of corruption and bribery 
4.2.1. Management of prevention and detection of corruption and bribery
The TRATON GROUP’s general procedures to prevent, detect, and address allegations or 
incidents of corruption and bribery include, amongst others, the implementation of 
Group-wide policies (see section on “Sustainability management process”), conduct of 
due diligence checks (see section “Management of relationships with suppliers”), anti-
corruption training and communications as described below, and the whistleblower 
 system (see section “TRATON’s grievance mechanism”). Furthermore, the TRATON GROUP 
Compliance department provides advice on compliance- and integrity-related questions, 
e.g., via the Compliance Helpdesk that employees can phone or e-mail. Internal control 
systems (ICSs) are integrated into the business processes to help ensure that the TRATON 
GROUP’s financial and non-finacial data is reliable, operations are effective and efficient, 
and activities comply with applicable laws and regulations. Findings from detective 
 measures are used to identify additional preventive compliance measures. Furthermore, 
independence is assured as investigations are conducted by independent investigation 
offices and investigation units. The Chief Compliance Officer (CCO) of TRATON SE reports 
topics to the Compliance Board three times a year and to the Truck Board once a year. 
Further, the CCO reports quarterly to the Audit Committee.
Policies 
Several policies manage the prevention and detection of corruption and bribery and relate 
to the potential negative impact of corruption weakening governance, harming environ-
mental initiatives, and fostering unfair competition. These policies are: Antitrust compliance, 
Business partner due diligence, Prevention of money laundering and terrorism financing, 
Donations and sponsoring, and Handling gifts, hospitality and invitations to events and 
conflicts of interest. Further, the Code of Conduct for employees (see the section on 
“ Management of corporate culture”), Code of Conduct for suppliers and  business part-
ners (see the section on “Management of relationships with suppliers”) and Internal 
investigations (see the section on “Management of TRATON’s grievance  mechanism”) 
also relate to these IROs. These policies are communicated to our employees via an 
 internal news channel on a regular basis, are available on the intranet, and are part of 
the compliance training programs.
Antitrust compliance (Group policy) 
Antitrust laws protect free and fair competition, thus preventing anti-competitive prac -
tices to the detriment of customers and other market participants. Hence, the TRATON 
GROUP commits itself without restriction to free and fair competition and does not tol -
erate violations of antitrust regulations. For this reason, the Antitrust compliance policy 
has been developed. It provides guidelines on how to deal with areas that are relevant in 
terms of antitrust regulations, when dealing with competitors, customers, and suppliers 
and in cases when a company dominates the market. The Compliance department at 
TRATON is responsible for conducting trainings and other awareness measures, address-
ing questions related to the policy, and providing advice on potential antitrust infringe -
ments. In addition, the Legal department provides legal advice, particularly in the course 
of merger control proceedings. 
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Business partner due diligence (Group policy)
The TRATON GROUP strives to work with partners that follow the same high ethical 
 principles of conduct to which we adhere. The Business partner due diligence policy 
relates to the risk of working with business partners lacking integrity by providing guid-
ance on engaging with business partners, evaluating third parties using the business 
partner approval tool, concluding contracts, documenting, and archiving information, 
and establishing payment and remuneration frameworks. The policy governs the man -
datory use of the Business Partner Approval Tool (BPA Tool), a web-based application that 
supports the assessment of the business partner’s integrity and provides approval work-
flows. The effectiveness of the policy is reviewed via quality assessments of due diligence 
checks conducted in the BPA Tool. Additionally, internal controls check whether all busi-
ness partner contracts have gone through the due diligence process. The policy applies 
to the engagement of business partners that have an intermediary and representative 
function. This includes importers, dealers, resellers, authorized service partners, body -
builders, and many more. The same rules for checking the integrity of these business 
partners are valid for all TRATON GROUP entities. The business partner’s integrity check 
utilizes the Corruption Perception Index (CPI), created by Transparency International.
Prevention of money laundering and terrorism financing (Group policy)
This Policy implements the German law on the tracing of profits from serious crimes 
(Money Laundering Act (GwG)) and also takes into account other money laundering laws 
that oblige companies in other countries to take measures to prevent money laundering 
and terrorist financing. It further defines roles and responsibilities, explains red flags and 
the prohibition of cash payments above a certain threshold as well as obligations in the 
event of any suspicion of money laundering or terrorism financing. In case a TRATON 
GROUP employee becomes aware of any potential or factual money laundering suspicion 
in connection with a transaction or business relationship, the employee must report this 
immediately to the responsible Compliance department. The Compliance department 
assesses the facts of the case, if necessary, with the support of the responsible TRATON 
GROUP employee, and decides whether there is indeed a money laundering suspicion. 
If required, the Compliance department assures that a suspicion notification to the 
 relevant authorities is made and that the relevant stakeholders are informed accordingly. 
In addition, the TRATON GROUP employee is informed of the result of the analysis and 
advised on the next steps, if appropriate. 
Donations and sponsoring (Group policy)
The TRATON SE and the brands support selected institutions and projects with donations 
and sponsoring measures. The Donations and sponsoring Group policy ensures that those 
donations and sponsoring measures are implemented in line with legal provisions and 
in compliance with the TRATON GROUP’s integrity standards by stating admissible areas 
of support, (in)admissible donations and sponsoring measures as well as additional 
 process rules and thresholds. To monitor compliance with and effectiveness of the policy, 
benefits in the form of donations and sponsoring measures must be documented and 
archived by the responsible donations or sponsorship manager of the brands. Any direct 
or indirect financial or in-kind political contributions are prohibited by this policy.
Handling gifts, hospitality and invitations to events and conflicts of interest 
(Group policy)
The TRATON Policy on handling gifts, hospitality, invitation to events and conflicts of inter-
est lays down binding instructions on how to handle benefits granted to natural persons 
or legal entities, including criteria for determining the appropriateness of benefits to 
prevent corrupt behavior. Furthermore, this policy establishes rules for handling conflicts 
of interests, particularly in connection with the granting and acceptance of benefits. While 
the policy applies to TRATON employees, it affects several stakeholders in the value chain 
such as business partners, suppliers and customers.
Actions and targets
In 2024, the following key actions and targets were set regarding prevention and detection 
of corruption and bribery.
Anti-corruption training
All TRATON GROUP employees receive training on the Code of Conduct for employees, 
which includes education on anti-corruption (see the section on “Management of cor -
porate culture”). In addition, employees who are exposed to higher corruption risks due 
to their role and responsibilities at the TRATON GROUP have to complete the web-based 
anti-corruption training, which also includes content on anti-bribery. These include, in 
particular, all managers and employees who are in contact with third parties and public 
officials. The training explains the term corruption in general and covers topics, such as 
dealing with public officials, gifts, hospitality and invitations, donations and sponsorships, 
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55  The percentage of at-risk functions covered by training programs is calculated by dividing the number of 
training participants by the number of employees in the target group. Numbers from Scania are not included 
for 2024 reporting as they are currently updating their tracking system. This datapoint reveals the participa-
tion rate in training sessions focused on Anti-Money Laundering (AML) and Anti-Corruption (AC). According to 
ESRS, functions at risk are identified based on their specific tasks and responsibilities.
and conflicts of interest. Employees in the target group must complete the training every 
three years. TRATON GROUP aims at a 100% completion rate of the mandatory anti-  
corruption training. In the reporting period, 86% 55 of employees in the target group com-
pleted the anti-corruption training. The completion gap is mainly due to employee 
 fluctuation. 
Further, the Anti-money laundering and terrorism financing training is a web-based train-
ing for employees who are exposed to higher money laundering risks and could become 
aware of suspicious transactions. These are e.g. employees involved in payment services 
or with direct contact to third parties. In a three-year interval, they are trained on the 
respective policy, the risks of money laundering, red flags, and how to act when they 
suspect money laundering. TRATON GROUP aims at a 100% completion rate of the man-
datory anti-money laundering training. In the reporting period, 52%  55 of employees in 
the target group completed the training on money laundering and terrorism financing. 
The completion gap is mainly due to the rollout of the updated web-based training in the 
fourth quarter at MAN and TRATON-Holding, which led to a low completion rate at the 
end of the financial year. Furthermore, International conducts its training on a campaign 
basis, with the new campaign launching in early 2025.
In addition to web-based training, the TRATON GROUP offers face-to-face compliance 
trainings on a risk-based approach. Participating in corruption training is mandatory for 
all levels. Board members and local gatekeepers participate in an additional Code of 
Conduct training since they act as role models and are exposed to higher risks due to 
their responsibilities. The format is a one-off, face-to-face training. Based on case studies, 
topics such as “fair and free competition”, “gifts, hospitality and invitations”, “conflicts of 
interest”, “donations, sponsoring and charity”, “human rights and environmental protection”, 
and “product conformity and product safety” are discussed. The compliance training 
program including the anti-corruption trainings and related goals are developed in coor-
dination with the TRATON SE Works Council. 
Compliance helpdesk 
The Compliance helpdesk is a service accessible to all TRATON GROUP employees via 
phone and email, providing guidance on a variety of compliance-related inquiries, topics, 
and requests. These may pertain to questions or uncertainties regarding the Code of 
Conduct for employees, the Group policy on handling gifts, hospitality and invitations to 
events and conflicts of interest, the Group policy on internal investigations, the Group 
policy on antitrust compliance, and the Group policy on the prevention of money launder-
ing and terrorism financing and other compliance topics. The Compliance helpdesk serves 
as a point of contact for two purposes: First, to address inquiries aimed at preventing 
policy violations, and second, to report potential misconduct by employees. In the latter 
scenario, the matter is referred to the TRATON Investigation Office.
4.2.2. Incidents of corruption or bribery
During the reporting period 2024, no criminal convictions were identified within the 
TRATON GROUP for breaches of anti-corruption and anti-bribery laws. Convictions for 
corruption and bribery include criminal convictions of a legal entity within the TRATON 
GROUP as well as criminal convictions concerning such legal entities’ employees. Therefore, 
the TRATON GROUP incurred no fines as part of convictions for a violation of corruption 
and bribery laws including anti-money laundering in the year 2024.
To learn from identified breaches in procedures and standards of anti-corruption and 
anti-bribery, the TRATON GROUP perfoms a root cause analysis. A better understanding 
of the underlying cause of a problem helps to identify potential improvement measures 
that reduce the likelihood of the problem reoccurring.
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4.3. TRATON’s grievance mechanism
4.3.1. Management of TRATON’s grievance mechanism
Integrity and compliant conduct in line with statutory regulations, internal policies, as 
well as the principles laid down in the Code of Conduct for employees and the Code of 
Conduct for suppliers and business partners are of the highest priority for the TRATON 
GROUP. To avoid or minimize the risk of potential violations by employees, suppliers, 
business partners, or other external parties related to TRATON, it is crucial to identify these 
at an early stage. They need to be clarified, stopped, and disciplinary measures need to 
be applied where necessary. That is why the TRATON GROUP is operating an independent, 
impartial, and confidential whistleblower system that provides various channels for 
employees, business partners, and external parties to report potential violations. 
The potential negative impact resulting from stakeholders not having accessible channels 
to raise their concerns, as well as the potential positive impact that occurs when creating 
a speak-up culture within the Group relate to the internal investigations policy and the 
complaints procedure. They are implemented through two actions, in particular, the Speak 
up! whistleblower portal and regular internal and external compliance audits. The target 
of 100% completion rate of Code of Conduct training also relates to these IROs and the 
general sustainability matter of protection of whistleblowers.
Policies
Internal investigations (Group policy)
The internal investigations policy regulates how hints regarding potential violations are 
being handled. Violations are all intentional or negligent violations of regulations of appli-
cable law (e.g., statutory laws, regulations) or internal company regulations (especially 
violations of the Code of Conduct for employees or employment contractual obligations) 
by employees committed in connection with, or based upon, their employment by the 
TRATON GROUP. It describes the TRATON GROUP’s commitment and process to conse -
quently follow up on potential violations, such as corrupt behavior. Standards are set such 
as general procedural rules for implementing and executing internal investigation pro -
cesses in the TRATON GROUP and the competencies, responsibilities, and cooperation 
requirements to be established within the Group are defined. 
Investigating units or the TRATON Investigation Office conduct the internal investigation. 
TRATON GROUP brands may implement a brand Investigation Office hub in accordance 
with the Group policy. The effectiveness of the policy is measured via the tracking of 
incoming hints, regular reporting, audits and through an IT-based case management 
system which documents and archives hints on violations and their processing including 
the results in compliance with relevant data protection regulations. 
Complaints procedure 
The TRATON GROUP’s complaints procedure is an important part of safeguarding our 
corporate values and beliefs and serves to identify potential risks and violations to remedy 
them. It describes generally applicable principles for handling reports of potential risks 
or violations in the TRATON GROUP and across the associated supply chains. Anyone within 
the TRATON GROUP and along its supply chain can submit a report or complaint about 
potential risks or violations. The TRATON Investigation Office operates the internal and 
external reporting channels. The TRATON GROUP ensures that reports of potential viola-
tions by TRATON GROUP employees and business partners along the supply chain are 
handled properly. 
The effectiveness of the complaints procedure is measured via the tracking of incoming 
hints, regular reporting, and audits.The complaints procedure is publicly available on 
TRATON’s website. It aligns with internationally recognized instruments by complying 
with the legal requirements for a whistleblower system in accordance with the EU Whistle-
blower Protection Act. The Head of Investigations is responsible for the implementation 
of the policy at TRATON. In addition to the here described policies, the Code of Conduct 
for suppliers and business partners further regulates the protection of whistleblowers.
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Actions and targets
In 2024, the following key actions and targets were set regarding TRATON’s grievance 
mechanism.
Whistleblower portals 
The TRATON GROUP whistleblower portals are accessible 24/7 in several languages for 
whistleblowers of the TRATON GROUP workforce to report any potential violations e.g. 
white-collar crime, corruption, antitrust law and data protection concerns. It also allows 
for reporting of violations and risks related to human rights and environmental obligations, 
as well as other internal and statutory regulations. Besides, the whistleblower portal can 
be used by both direct and indirect suppliers, to report violations of the Code of Conduct 
for suppliers and business partners as well as violations of environmental laws and human 
rights. Even if the reporters’ preferred language is not offered in the reporting channel, 
whistleblowers can use any language to submit their report. Our whistleblowing portal 
is operated by a third-party, who hosts the portal on external, certified servers (located in 
Germany), allowing whistleblowers to address hints to us on an anonymous, non-traceable 
basis. Besides the electronic Speak up! whistleblower portal, internal or external reports 
of misconduct can be directed towards the contacts within the TRATON Investigation 
Office by post or e-mail, the 24/7 Volkswagen whistleblower hotline, and the ombuds-
persons of the Volkswagen Group.
Upon receiving a hint, the TRATON Investigation Office checks for substantiated informa-
tion and categorizes the hint based on its severity and investigates if applicable. The Office 
is dedicated to investigating potentially serious violations that could significantly impact 
the interests of the TRATON GROUP, particularly in terms of reputation or financial inter-
ests, or that could significantly violate the ethical values of the TRATON GROUP or one of 
its brands. In the event of a confirmed serious violation, the TRATON Investigation Office 
will present the outcome, along with appropriate disciplinary measures, to a Disciplinary 
Committee consisting of several functions. The Disciplinary Committee is chaired by the 
Chief Compliance Officer of TRATON SE and further comprised of the Chief Human 
Resources Officer, the Chief Audit Executive, the HR Coordinator of TRATON SE for cases 
concerning employees of TRATON SE. For cases concerning employees of a TRATON 
GROUP brand, the respective members of the brand are included.  Furthermore, the Head 
of the TRATON Investigation Office provides reports to the TRATON Chief Compliance 
Officer on selective cases on a regular basis and as needed. 
The whistleblower system is designed to protect whistleblowers, the persons concerned, 
and equivalent individuals. Equivalent Individuals are all persons who confidentially sup-
port a whistleblower in reporting a hint in a work-related context. Discrimination against 
them is itself considered a serious violation. The investigation process is based on proce-
dural principles, which include confidentiality, the need-to-know principle, and objectivity. 
The presumption of innocence applies to all persons concerned, as defined in the Internal 
Investigations Policy.
Information about the whistleblower system is available on both the TRATON GROUP 
website and intranet. Regular and engaging communication measures and initiatives 
are carried out to raise awareness. In addition, TRATON conducts training sessions — further 
mainly described in the section on “Management of corporate culture” — that are oblig-
atory for all direct and indirect employees, including Board members, and cover information 
on the TRATON GROUP whistleblower system. For key contact points (KCPs) of the whistle-
blower system, specialized training is available. These KCPs are departments that potentially 
encounter the process of reporting, investigating, and sanctioning employee misconduct. 
Regular internal and external compliance reports
To help ensure compliance with corporate governance, while also increasing corporate 
transparency and accountability across the TRATON GROUP, regular internal reporting 
related to GRC is provided to various boards and committees, including the Audit Com -
mittee, Truck Board, Compliance Board, Human Rights Committee, and Sustainability Board. 
External GRC-related reporting is also conducted, such as communication on TRATON’s 
website, reports to relevant authorities and to the TRATON GROUP’s investors. GRC-related 
reporting is submitted to Volkswagen through its digital compliance reporting tool.
  
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4.4. Political engagement
4.4.1. Management of political engagement
The policies TRATON Code of Conduct for employees, Donations and sponsoring, Public 
affairs one-voice policy, state aid and grant register, as well as Handling gifts, hospitality 
and invitations to events and conflicts of interest, relate to the potential negative impact 
associated with opaque political involvement, which could threaten a vivid democracy 
and well-informed decision-making within the TRATON GROUP. There is no process in 
place for tracking these policies’ effectiveness as violations of the policy would be handled 
in the regular compliance and investigation processes described throughout this section. 
Regarding the sustainability matter of political engagement, no relevant actions and 
targets are reported for 2024 as the potential negative impact is already well regulated 
by TRATON GROUP policies and procedures, as well as by the legislation to which the 
Group adheres strictly.
Policies
Public affairs one-voice-policy, state aid and grant register (Group policy) 
This policy explains the fundamental procedure of the work process between the TRATON 
Public Affairs department, the brands, and companies. Regarding handling public affairs 
in the Group, the TRATON brands act independently and on their own responsibility but 
aligned with the TRATON Public Affairs department according to the policy. The key 
 content of the policy includes a framework for lobbying, the one-voice-policy, the dotted 
line principle, an explanation of group relevance as well as principles and obligations the 
TRATON GROUP and its brands must follow. Additionally, the application and handling 
process of state-aid and grant register is addressed and explained. 
TRATON Public Affairs directly reports to the Volkswagen Group Public Affairs department, 
which then prepares an annual report on the state aid and grant register applied for and 
received in the EU by the Volkswagen Group and its brands and companies. The necessary 
data is provided by state aid coordinators or financial responsible for installing adequate 
processes for the appropriate and proper application and handling of state aid and grant 
register. Furthermore, the Volkswagen Group Public Affairs department must be informed 
about the relevant activities of the brands and companies to support the implementation 
of suitable processes. To identify and track risks arising from the receipt of state aid and 
grant register, brands and companies are obliged to install processes to identify and avoid 
project-specific risks. In the event of imminent reputational damage or legal conse -
quences for TRATON SE or the Volkswagen Group, coordination with the departments of 
Volkswagen Group Public Affairs and TRATON Public Affairs takes place at an early stage. 
4.2.2. Political influence and lobbying activities
TRATON SE is registered in the German lobby register for the representation of interests 
vis-à-vis the German Parliament and the Federal Government under registration number 
R001565. The TRATON Public Affairs department is in direct (with politicians) and indirect 
(via associations, NGOs, other stakeholders) contact to decision-makers. The TRATON 
GROUP’s responsibilities for monitoring lobbying activities are set out in the TRATON Code 
of Conduct for employees and other Group policies (Donations and sponsoring, Public 
affairs one-voice-policy, state aid and grant register as well as Handling gifts, hospitality 
and invitations to events and conflicts of interest). The TRATON SE Executive Board is 
responsible for approving these regulations.
The way of political engagement strictly pursues the goals of the TRATON Way Forward 
strategy. Main topics of the TRATON GROUP’s lobbying activities include enabling con-
ditions for the ramp-up of battery electric commercial vehicles and the development of 
a charging infrastructure. These topics directly interact with the IROs related to the 
 sustainability matters climate change mitigation and energy. When electric transporta-
tion costs are comparable to fossil fuel transports and the necessary charging infrastruc-
ture is in place, choosing to go electric becomes straightforward for the customers of 
TRATON GROUP. Further topics of our lobbying activities encompass labor regulations, 
international trade, energy policies, digitalization, public finance, taxes and duties, urban 
development, climate and resource protection, transportation policies, science, research, 
and technology.
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4.5. Supplier relationships and payment practices
4.5.1. Management of relationships with suppliers
TRATON’s management of supplier relationships fundamentally builds on the Code of 
Conduct for suppliers and business partners. Besides a variety of other sustainability 
matters highlighted throughout this report, it also relates to the potential positive impact 
of fair payments, which builds suppliers, improving loyalty, collaboration, and innovation. 
The TRATON GROUP currently does not have Group-wide policies or initiatives specifically 
addressing late payments. The brands continue to manage their payment practices inde-
pendently. 
Policies
Code of Conduct for suppliers and business partners (Group policy)
As the TRATON GROUP’s suppliers and business partners play a significant role in the 
Group’s business success, TRATON expects them to act responsibly, particularly in the 
areas of human rights, health and safety at work, tax and trade compliance, environmental 
protection, and anti-corruption. In the Code of Conduct for suppliers and business part -
ners, the TRATON GROUP has defined its expectations as well as requirements regarding 
the attitude and conduct of suppliers and business partners in their corporate activities. 
The policy is considered the basis for successful execution of business relations between 
the TRATON GROUP and its partners. Moreover, the Code of Conduct for suppliers and 
business partners applies to all suppliers (i.e., all contracting parties that supply the 
TRATON GROUP with goods, materials, or services) as well as to sales and service partners 
and other B2B partners who do business with the TRATON GROUP.
Our sustainability requirements are based on various international standards, including 
the UN Global Compact, OECD Guidelines, ILO conventions, and the Guiding Principles 
of the Drive Sustainability Initiative. TRATON GROUP also adheres to internationally 
agreed standards such as the Universal Declaration of Human Rights. As such, the Code 
of  Conduct for suppliers and business partners addresses the safety of workers, human 
trafficking, the use of forced labor, or child labor. Precarious work (i.e., use of workers on 
short-term or limited hours contracts, workers employed via third parties, sub-contracting 
to third parties, or use of informal workers) is not explicitly addressed.
To monitor effectiveness of the policy, the TRATON GROUP brands reserve the right to 
verify compliance with sustainability requirements regularly, randomly, or for specific 
events and using appropriate and adequate means before awarding a new contract and 
throughout the business relationship. The related actions are described below.
The Code of Conduct for suppliers and business partners is publicly available on the 
TRATON GROUP website. 
Actions and targets
In 2024, the following key action and targets were set regarding relationships with 
 suppliers.
Responsible supply chain system
The TRATON approach to managing supplier relationships largely relies on the Responsible 
Supply Chain System (ReSC System), applicable to the whole Volkswagen Group, which 
provides standard actions and targets to mitigate significant potential negative impacts 
and manage any significant risks that arise in relation to workers in the value chain. Addi-
tionally, TRATON assesses compliance of suppliers with sustainability requirements of 
the Code of Conduct for suppliers and business partners through regular due diligence 
checks. A detailed description of these actions is provided in section “ Management of 
working conditions of workers in the value chain”.
4.5.2. Payment practices
On average, the TRATON GROUP takes 44 days to pay invoices (from the start date of the 
contractual or statutory payment term). This figure was calculated for the TRATON GROUP 
using the following definition of Days Payable Outstanding (DPO):
Payables at 31.12.
×365
Annual turnover
  
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The standard payment terms vary between each brand from 30 up to 120 days. The 
conditions of the brands and companies in the markets and regions relevant to the 
TRATON GROUP show different payment terms, each in compliance with national legal 
requirements as well as voluntary commitments. The standard payment terms generally 
apply to all suppliers, but individual deviations as part of a negotiated supplier contract 
are possible. There is no standard deviation for a specific group of suppliers. The brands 
within the TRATON GROUP offer supply chain financing programs for suppliers.
As of December 31, 2024, the TRATON GROUP in Germany has an insignificant number of 
pending court dunning procedures due to payment delays, against which no objections 
have been raised yet. In the exceptional case that legal proceedings arise due to payment 
delays, these cases are handled by the Legal departments of TRATON and its brands.
   
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5. Annex
Reference Table
ESRS Disclosure  Requirement Reference
ESRS 2 BP-1 General basis for preparation of the sustainability statement 1.1.Basis for preparation of the sustainability statement
ESRS 2 BP-2 Disclosures in relation to specific circumstances 1.1. Basis for preparation of the sustainability statement
ESRS 2 GOV-1 The role of the administrative, management and supervisory bodies 1.3.2. Sustainability management process 
“Corporate Governance Statement”
ESRS 2 GOV-2 Information provided to and sustainability matters addressed by the 
undertaking’s administrative, management and supervisory bodies
1.3.2. Sustainability management process
ESRS 2 GOV-3 Integration of sustainability-related performance in incentive schemes 1.3.3. Integration of sustainability-related performance in incentive schemes
“Remuneration report”
ESRS 2 GOV-4 Statement on due diligence 1.3.4. Statement on due diligence
ESRS 2 GOV-5 Risk management and internal controls over sustainability reporting 1.3.5. Risk management and internal controls over sustainability reporting
“Report on Expected Developments, Opportunities, and Risks”
ESRS 2 SBM-1  56 Strategy, business model and value chain 1.4.1. Strategy, business model, and value chain
ESRS 2 SBM-2 Interests and views of stakeholders 1.4.2. Stakeholder engagement
ESRS 2 SBM-3  56 Material impacts, risks and opportunities and their interaction with 
strategy and business model
1.4.3. Material impacts, risks and opportunities and their interaction with strategy and business model
ESRS 2 IRO-1 Description of the process to identify and assess material impacts, 
risks and opportunities
1.2.1. Processes to identify and assess material impacts, risks and opportunities
1.2.2. Results of the double materiality assessment
ESRS 2 IRO-2 Disclosure Requirements in ESRS covered by the undertaking’s 
sustainability statement
5. Annex
ESRS 2 MDR-P Policies adopted to manage material sustainability matters 1.3.2. Sustainability management process – Overarching management policies and concepts for 
sustainability
ESRS 2 MDR-T Tracking effectiveness of policies and actions through targets 1.3.2. Sustainability management process – Overarching management policies and concepts for 
sustainability
E1 ESRS2 GOV-3 Integration of sustainability-related performance in incentive schemes 1.3.3. Integration of sustainability-related performance in incentive schemes
“Remuneration report”
E1 ESRS 2 IRO-1  56 Description of the processes to identify and assess material impacts, 
risks and opportunities
1.2.1. Processes to identify and assess material impacts, risks and opportunities – Climate-related 
scenario analysis
E1-1 Transition plan for climate change mitigation 2.1.1. Management of climate change – Actions and targets
E1 ESRS 2 SBM-3  56 Material impacts, risks and opportunities and their interaction with 
strategy and business model
1.4.3. Material impacts, risks and opportunities and their interaction with strategy and business model – 
Resilience analysis
E1-2 Policies related to climate change mitigation and adaptation 2.1.1. Management of climate change – Policies
E1 ESRS 2 MDR-P  56 Policies adopted to manage material sustainability matters 2.1.1. Management of climate change – Policies
56 Disclosure requirement incomplete
5. Annex
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Reference Table
ESRS Disclosure  Requirement Reference
E1-3 Actions and resources in relation to climate change policies 2.1.1. Management of climate change – Actions and targets
E1 ESRS 2 MDR-A Actions and resources in relation to material sustainability matters 2.1.1. Management of climate change – Actions and targets
E1-4 Targets related to climate change mitigation and adaptation 2.1.1. Management of climate change – Actions and targets
E1 ESRS 2 MDR-T  56 Tracking effectiveness of policies and actions through targets 2.1.1. Management of climate change
E1-5 Energy consumption and mix 2.1.2. Metrics related to climate change – Energy consumption and mix
E1-6  56 Gross Scopes 1, 2, 3 and Total GHG emissions 2.1.2. Metrics related to climate change – GHG emissions
E1 ESRS 2 MDR-M Metrics in relation to material sustainability matters 2.1.2. Metrics related to climate change
E1-7 GHG removals and GHG mitigation projects financed through carbon credits 2.1.2. Metrics related to climate change – GHG emissions
E1-8 Internal carbon pricing 2.1.2. Metrics related to climate change – GHG emissions
E1-9 Anticipated financial effects from material physical and transition risks and 
potential climate-related opportunities
TRATON uses the option to phase-in this disclosure requirement in line with ESRS 1 Appendix C
E2 ESRS 2 IRO-1 Description of the processes to identify and assess material impacts, 
risks and opportunities
1.2.1. Processes to identify and assess material impacts, risks and opportunities
E2-1 Policies related to pollution 2.2.1. Management of pollution
E2 ESRS 2 MDR-P  56 Policies adopted to manage material sustainability matters 2.2.1. Management of pollution
E2-2 Actions and resources related to pollution 2.2.1. Management of pollution
E2 ESRS 2 MDR-A Actions and resources in relation to material sustainability matters 2.2.1. Management of pollution
E2-3 Targets related to pollution 2.2.1. Management of pollution
E2 ESRS 2 MDR-T  56 Tracking effectiveness of policies and actions through targets 2.2.1. Management of pollution
E2-4 Pollution of air, water and soil 2.2.2. Metrics related to pollution – Pollution of air
E2-5 Substances of concern and substances of very high concern 2.2.2. Metrics related to pollution – Substances of very high concern
E2 ESRS 2 MDR-M Metrics in relation to material sustainability matters 2.2.2. Metrics related to pollution
E2-6 Anticipated financial effects from material pollution-related risks 
and opportunities
TRATON uses the option to phase-in this disclosure requirement in line with ESRS 1 Appendix C
E3 ESRS 2 IRO-1 Description of the processes to identify and assess material impacts,  
risks and opportunities
1.2.1. Processes to identify and assess material impacts, risks and opportunities
E3-1 Policies related to water and marine resources 2.3.1. Management of water
E3 ESRS 2 MDR-P Policies adopted to manage material sustainability matters 2.3.1. Management of water
56 Disclosure requirement incomplete
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Reference Table
ESRS Disclosure  Requirement Reference
E3-2 Actions and resources related to water and marine resources 2.3.1. Management of water
E3 ESRS 2 MDR-A  56 Actions and resources in relation to material sustainability matters 2.3.1. Management of water
E3-3 Targets related to water and marine resources 2.3.1. Management of water
E3 ESRS 2 MDR-T  56 Tracking effectiveness of policies and actions through targets 2.3.1. Management of water
E3-4 Water consumption 2.3.2. Metrics related to water – Water consumption
E3 ESRS 2 MDR-M Metrics in relation to material sustainability matters 2.3.2. Metrics related to water
E3-5 Anticipated financial effects from material water and marine resources-
related risks and opportunities
TRATON uses the option to phase-in this disclosure requirement in line with ESRS 1 Appendix C
E4-1 56 Transition plan and consideration of biodiversity and ecosystems in strategy 
and business model
1.4.3. Material impacts, risks and opportunities and their interaction with strategy and business model – 
Resilience analysis
E4 SBM-3 Material impacts, risks and opportunities and their interaction with strategy 
and business model
2.4.1. Management of biodiversity and ecosystems
E4 ESRS 2 IRO-1  56 Description of the processes to identify and assess material impacts, 
risks and opportunities
1.2.1. Processes to identify and assess material impacts, risks and opportunities
E4-2 Policies related to biodiversity and ecosystems 2.4.1. Management of biodiversity and ecosystems
E4 ESRS 2 MDR-P  56 Policies adopted to manage material sustainability matters 2.4.1. Management of biodiversity and ecosystems
E4-3 56 Actions and resources related to biodiversity and ecosystems 2.4.1. Management of biodiversity and ecosystems – Actions
E4 ESRS 2 MDR-A  56 Actions and resources in relation to material sustainability matters 2.4.1. Management of biodiversity and ecosystems – Actions
E4-4 Targets related to biodiversity and ecosystems 2.4.1. Management of biodiversity and ecosystems
E4 ESRS 2 MDR-T  56 Tracking effectiveness of policies and actions through targets 2.4.1. Management of biodiversity and ecosystems
E4-5 Impact metrics related to biodiversity and ecosystems change 2.4.1. Management of biodiversity and ecosystems
E4 ESRS 2 MDR-M Metrics in relation to material sustainability matters 2.4.1. Management of biodiversity and ecosystems
E4-6 Financial effects from material biodiversity and ecosystem-related risks 
and opportunities
TRATON uses the option to phase-in this disclosure requirement in line with ESRS 1 Appendix C
E5 ESRS 2 IRO-1 Description of the processes to identify and assess material impacts, 
risks and opportunities
1.2.1. Processes to identify and assess material impacts, risks and opportunities
E5-1 Policies related to resource use and circular economy 2.5.1. Management of resource use and circular economy – Policies
E5 ESRS 2 MDR-P Policies adopted to manage material sustainability matters 2.5.1. Management of resource use and circular economy – Policies
56 Disclosure requirement incomplete
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===== SIDA 301 =====

Reference Table
ESRS Disclosure  Requirement Reference
E5-2 Actions and resources related to resource use and circular economy 2.5.1. Management of resource use and circular economy – Actions and targets
E5 ESRS 2 MDR-A  56 Actions and resources in relation to material sustainability matters 2.5.1. Management of resource use and circular economy – Actions and targets
E5-3 Targets related to resource use and circular economy 2.5.1. Management of resource use and circular economy – Actions and targets
E5 ESRS 2 MDR-T  56 Tracking effectiveness of policies and actions through targets 2.5.1. Management of resource use and circular economy
E5-4 Resource inflows 2.5.2. Metrics related to resource use and circular economy – Resource inflows
E5-5 Resource outflows 2.5.2. Metrics related to resource use and circular economy – Resource ouflows
E5 ESRS 2 MDR-M Metrics in relation to material sustainability matters 2.5.2. Metrics related to resource use and circular economy
E5-6 Anticipated financial effects from material resource use and circular 
economy-related risks and opportunities
TRATON uses the option to phase-in this disclosure requirement in line with ESRS 1 Appendix C
S1 ESRS 2 SBM-2 Interests and views of stakeholders 1.4.2. Stakeholder engagement
S1 ESRS 2 SBM-3 Material impacts, risks and opportunities and their interaction with 
strategy and business model
1.4.3. Material impacts, risks and opportunities and their interaction with strategy and business model – 
Own workforce
S1-1 Policies related to own workforce 3.1.1. Process for engaging with own workers and workers’ representatives 
3.1.2. Management of working conditions
3.1.4. Management of equal treatment and opportunities for all
3.1.6. Management of other work-related rights
4.1.1. Management of corporate culture
4.3.1. Management of TRATON’s grievance mechanism
S1 ESRS 2 MDR-P Policies adopted to manage material sustainability matters 3.1.2. Management of working conditions
3.1.4. Management of equal treatment and opportunities for all
3.1.6. Management of other work-related rights
S1-2 Processes for engaging with own workforce and workers’ representatives 
about impacts
3.1.1. Process for engaging with own workers and workers’ representatives 
3.1.2. Management of working conditions – Policies
S1-3 Processes to remediate negative impacts and channels for own workforce 
to raise concerns
3.1.1. Process for engaging with own workers and workers’ representatives
S1-4 Taking action on material impacts on own workforce, and approaches to 
managing material risks and pursuing material opportunities related to own 
workforce, and effectiveness of those actions
3.1.2. Management of working conditions – Actions and targets
3.1.4. Management of equal treatment and opportunities for all – Actions and targets
3.1.6. Management of other work-related rights – Actions and targets
S1 ESRS 2 MDR-A Actions and resources in relation to material sustainability matters 3.1.2. Management of working conditions – Actions and targets
3.1.4. Management of equal treatment and opportunities for all – Actions and targets
3.1.6. Management of other work-related rights – Actions and targets
S1-5 Targets related to managing material negative impacts, advancing positive 
impacts, and managing material risks and opportunities
3.1.2. Management of working conditions – Actions and targets
3.1.4. Management of equal treatment and opportunities for all – Actions and targets
3.1.6. Management of other work-related rights – Actions and targets
56 Disclosure requirement incomplete
301
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Independent Auditor’s Reports
Combined Management Report Sustainability StatementTo Our Shareholders

===== SIDA 302 =====

Reference Table
ESRS Disclosure  Requirement Reference
S1 ESRS 2 MDR-T Tracking effectiveness of policies and actions through targets 3.1.2. Management of working conditions
3.1.4. Management of equal treatment and opportunities for all
3.1.6. Management of other work-related rights
S1-6 Characteristics of the undertaking’s employees 3.1.3. Metrics related to working conditions – Characteristics of the undertaking’s employees
S1-7 56 Characteristics of non-employees in the undertaking’s own workforce 3.1.3. Metrics related to working conditions – Characteristics of non-employees in the undertaking’s own 
workforce
S1-8 56 Collective bargaining coverage and social dialogue 3.1.3. Metrics related to working conditions – Collective bargaining coverage and social dialog
S1-9 Diversity metrics 3.1.5. Metrics related to equal treatment and opportunities for all – Diversity metrics
S1-10 Adequate wages 3.1.3. Metrics related to working conditions – Adequate wages
S1-11 Social protection TRATON uses the option to phase-in this disclosure requirement in line with ESRS 1 Appendix C
S1-12 Persons with disabilities TRATON uses the option to phase-in this disclosure requirement in line with ESRS 1 Appendix C
S1-13 Training and skills development metrics TRATON uses the option to phase-in this disclosure requirement in line with ESRS 1 Appendix C
S1-14 Health and safety metrics 3.1.5. Metrics related to working conditions – Health and safety metrics
S1-15 Work-life balance metrics  TRATON uses the option to phase-in this disclosure requirement in line with ESRS 1 Appendix C
S1-16 56 Remuneration metrics (pay gap and total remuneration) -
S1-17 56 Incidents, complaints and severe human rights impacts 3.1.7. Metrics related to other work-related rights – Incidents, complaints and severe human rights impacts
S1 ESRS 2 MDR-M Metrics in relation to material sustainability matters 3.1.3. Metrics related to working conditions
3.1.5. Metrics related to equal treatment and opportunities for all
3.1.7. Metrics related to other work-related rights
S2 ESRS 2 SBM-2 Interests and views of stakeholders 1.4.2. Stakeholder engagement
S2 ESRS 2 SBM-3 Material impacts, risks and opportunities and their interaction with 
strategy and business model
1.4.3. Material impacts, risks and opportunities and their interaction with strategy and business model – 
Workers in the value chain
S2-1 Policies related to value chain workers 3.1.2. Management of working conditions – Actions and targets
3.2.1. Process to remediate negative impacts and channels for value chain workers to raise concerns
3.2.2. Management of working conditions and other work-related rights of workers in the value chain – 
Policies
S2 ESRS 2 MDR-P Policies adopted to manage material sustainability matters 3.2.2. Management of working conditions and other work-related rights of workers in the value chain – 
Policies
S2-2 Processes for engaging with value chain workers about impacts 3.2.1. Process to remediate negative impacts and channels for value chain workers to raise concerns
56 Disclosure requirement incomplete
302
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Combined Management Report Sustainability StatementTo Our Shareholders

===== SIDA 303 =====

56 Disclosure requirement incomplete
Reference Table
ESRS Disclosure  Requirement Reference
S2-3 Processes to remediate negative impacts and channels for value chain 
workers to raise concerns
3.1.1. Process for engaging with own workers and workers’ representatives  
3.2.1. Process to remediate negative impacts and channels for value chain workers to raise concerns
S2-4 Taking action on material impacts on value chain workers, and approaches to 
managing material risks and pursuing material opportunities related to value 
chain workers, and effectiveness of those actions
3.2.2. Management of working conditions and other work-related rights of workers in the value chain – 
Actions and targets
S2 ESRS 2 MDR-A Actions and resources in relation to material sustainability matters 3.2.2. Management of working conditions and other work-related rights of workers in the value chain – 
Actions and targets
S2-5 Targets related to managing material negative impacts, advancing positive 
impacts, and managing material risks and opportunities
3.2.2. Management of working conditions and other work-related rights of workers in the value chain – 
Actions and targets
S2 ESRS 2 MDR-T Tracking effectiveness of policies and actions through targets 3.2.2. Management of working conditions and other work-related rights of workers in the value chain
S3 ESRS 2 SBM-2 Interests and views of stakeholders 1.4.2. Stakeholder engagement
S3 ESRS SBM-3 Material impacts, risks and opportunities and their interaction with 
strategy and business model
1.4.3. Material impacts, risks and opportunities and their interaction with strategy and business model – 
Affected communities
S3-1 Policies related to affected communities 3.1.2. Management of working conditions – Actions and targets
3.3.1. Processes for engaging with affected communities
3.3.2. Management of health and safety of affected communities
3.3.3. Management of road safety and privacy
S3 ESRS 2 MDR-P Policies adopted to manage material sustainability matters 3.3.2. Management of health and safety of affected communities – Policies
3.3.3. Management of road safety and privacy – Policies
S3-2 56 Processes for engaging with affected communities about impacts 3.3.1. Processes for engaging with affected communities
S3-3 Processes to remediate negative impacts and channels for affected 
communities to raise concerns
3.1.1. Process for engaging with own workers and workers’ representatives 
3.3.1. Processes for engaging with affected communities
4.1.1. Management of corporate culture
S3-4  56 Taking action on material impacts on affected communities, and approaches 
to managing material risks and pursuing material opportunities related to 
affected communities, and effectiveness of those actions
3.3.1. Processes for engaging with affected communities
3.3.2. Management of health and safety of affected communities
3.3.3. Management of road safety and privacy
S3 ESRS 2 MDR-A  56 Actions and resources in relation to material sustainability matters 3.3.2. Management of health and safety of affected communities  – Actions and targets
3.3.3. Management of road safety and privacy – Actions and targets
S3-5 56 Targets related to managing material negative impacts, advancing positive 
impacts, and managing material risks and opportunities
3.3.2. Management of health and safety of affected communities   
3.3.3. Management of road safety and privacy
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===== SIDA 304 =====

Reference Table
ESRS Disclosure  Requirement Reference
S3 ESRS 2 MDR-T  56 Tracking effectiveness of policies and actions through targets 3.3.2. Management of health and safety of affected communities
3.3.2. Management of road safety and privacy
G1 ESRS 2 GOV-1 The role of the administrative, management and supervisory bodies 1.3.2. Sustainability management process 
“Corporate Governance Statement”
G1 ESRS 2 IRO-1 Description of the processes to identify and assess material impacts, 
risks and opportunities
1.2.1. Processes to identify and assess material impacts, risks and opportunities
G1-1 Business conduct policies and corporate culture 4.1.1. Management of corporate culture
4.3.1. Management of TRATON’s grievance mechanism – Actions and targets
G1-2 Management of relationships with suppliers 3.2.2. Management of working conditions and other work-related rights of workers in the value chain – 
Actions and targets
4.5.1. Management of relationships with suppliers
G1-3 Prevention and detection of corruption and bribery 4.2.1. Management of prevention and detection of corruption and bribery
G1-4 Incidents of corruption or bribery 4.2.2. Incidents of corruption or bribery
G1-5 Political influence and lobbying activities 4.4.2. Political influence and lobbying activities
G1-6 Payment practices 4.5.2. Payment practices
G1 ESRS 2 MDR-P Policies adopted to manage material sustainability matters 4.1.1. Management of corporate culture – Policies
4.2.1. Management of prevention and detection of corruption and bribery – Policies
4.3.1. Management of TRATON’s grievance mechanism – Policies
4.4.1. Management of political engagement
4.5.1. Management of relationships with suppliers – Policies
G1 ESRS 2 MDR-A Actions and resources in relation to material sustainability matters 4.1.1. Management of corporate culture – Actions and targets
4.2.1. Management of prevention and detection of corruption and bribery – Actions and targets
4.3.1. Management of TRATON’s grievance mechanism – Actions and targets
4.4.1. Management of political engagement
4.5.1. Management of relationships with suppliers – Actions and targets
G1 ESRS 2 MDR-T  56 Tracking effectiveness of policies and actions through targets 4.1.1. Management of corporate culture
4.2.1. Management of prevention and detection of corruption and bribery
4.3.1. Management of TRATON’s grievance mechanism
4.4.1. Management of political engagement
4.5.1. Management of relationships with suppliers
G1 ESRS 2 MDR-M Metrics in relation to material sustainability matters 4.2.2. Incidents of corruption or bribery
56 Disclosure requirement incomplete
   
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===== SIDA 305 =====

Disclosure of significant sites and biodiversity-sensitive areas 
Brand Country Location/city Sitename Location/SiteCode
Scania France Angers Basses vallées angevines, aval de la rivière Mayenne et prairies de la Baumette FR5200630
Scania Sweden Lulea Gammelstadsviken SE0820042
Scania Netherlands Meppel Olde Maten & Veerslootlanden NL2003063
De Wieden NL3009004
Scania Brazil Sao Paulo Área De Proteção Ambiental Haras São Bernardo 555682085
Scania Poland Slupsk Dolina Słupi PLH220052
Scania Sweden Södertällje Brosjön SE0110115
Lina SE0110164
Scania Netherlands Zwolle Uiterwaarden Zwarte Water en Vecht NL9902003
Rijntakken NL2014038
MAN Truck & Bus Poland Krakow Puszcza Niepołomicka PLB120002
MAN Truck & Bus Germany München Gräben und Niedermoorreste im Dachauer Moos DE7734301
Allacher Forst und Angerlohe DE7734302
MAN Truck & Bus Germany Nürnberg Tiergarten Nürnberg mit Schmausenbuck DE6532372
Rednitztal in Nürnberg DE6632371
Nürnberger Reichswald DE6533471
MAN Truck & Bus South Africa Pinetown Krantzkloof Nature Reserve 26031
New Germany Nature Reserve 555571042
Marion Wood Nature Reserve 555571041
MAN Truck & Bus Germany Salzgitter Heerter See DE3828401
Uroczyska Lasów Starachowickich PLH260038
Ostoja Sieradowicka PLH260031
MAN Truck & Bus Slovakia Banovce Rokoš SKUEV0128
MAN Truck & Bus Slovakia Banovce Strážovské vrchy SKCHVU028
Volkswagen Truck and Bus Brazil Resende Refúgio De Vida Silvestre Estadual Da Lagoa Da Turfeira 555682323
INTERNATIONAL United States Huntsville Dallas W. Fanning Nature Preserve 258 Old Jim Williams Rd SW, Huntsville, AL 35824
Wheeler National Wildlife Refuge 34.627877, -86.753455
INTERNATIONAL United States San Antonio Mitchell Lake 29.280676, -98.490558
Cassin Lake 29.301112, -98.458457
Medina River 29.265685, -98.486560
San Antonio Missions National Historical Park 29.305421, -98.451557
INTERNATIONAL United States Springfield Mad River 40.015899, -83.822472
Cedar Bog Nature Preserve Cedar Bog Nature Preserve, 980 Woodburn Rd, Urbana, OH 43078
INTERNATIONAL United States Tulsa Oxley Nature Center 6700 Mohawk Blvd, Tulsa, OK 74115
305
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Combined Management Report Sustainability StatementTo Our Shareholders

===== SIDA 306 =====

Barcelona, Spain
FURTHER  
INFORMATION
Remuneration Report 307
Independent Auditor’s Report 331
Financial Calendar 332
Glossary 333
Five-Year Overview 335
Publication Details 337
6

===== SIDA 307 =====

FURTHER INFORMATION
Remuneration Report
Section 162 of the Aktiengesetz (AktG — German Stock Corporation Act) requires the 
Executive Board and Supervisory Board of TRATON SE to prepare a clear, readily under -
standable report on the remuneration of members of the Executive Board and the Super-
visory Board. In this report, we explain the principles of the remuneration system for the 
Executive Board and Supervisory Board. The Remuneration Report also presents the 
individual remuneration broken down by component for current and former members 
of the Executive Board and Supervisory Board of TRATON SE.
Executive Board remuneration
Business performance in the year under review 
The TRATON GROUP had a successful fiscal year 2024. The performance of the TRATON 
GROUP’s most important truck and bus markets varied greatly in fiscal year 2024 and 
was  slightly down overall. Despite a slight year-on-year decline in unit sales, the 
TRATON GROUP reported a slight year-on-year increase in sales revenue to approximately 
€47.5  billion in fiscal year 2024. Among other things, this increase in sales revenue was 
due to a favorable market and product mix as well as better unit price enforcement. Sales 
revenue even grew significantly year-on-year in the TRATON Financial Services segment. 
Overall, business performance in fiscal year 2024 was largely in line with or slightly 
exceeded the ranges forecast for the fiscal year.
Principles of Executive Board remuneration
The remuneration of the members of the Executive Board is based on the revised remu-
neration system for the Executive Board (“remuneration system”) adopted by the Super-
visory Board effective from January 1, 2024, which largely corresponds to the remuneration 
system already adopted on December 16, 2020, and effective from January 1, 2021, and 
most recently approved by the Annual General Meeting on June 9, 2022. The Annual 
General Meeting approved the remuneration system on June 13, 2024, with 97.98% of the 
votes cast. The remuneration system implements the requirements of the AktG in the 
version as amended by ARUG II and takes account of the recommendations of the German 
Corporate Governance Code (the Code) as amended on April 28, 2022 (entered into force 
on June 27, 2022). The Supervisory Board reviews the remuneration system at its reason-
able discretion at regular intervals, but at least every four years.
In the course of revising the remuneration system, the Supervisory Board decided to 
replace the financial performance target of return on investment ( ROI) by the financial 
performance target of net cash flow of the TRATON Operations business area ( NCF) in 
order to better reflect the interests of the capital markets. Net cash flow is a core perfor -
mance indicator that is used to measure earnings power, the ability to make investments, 
and to pay dividends, and is therefore highly relevant for the capital markets. TRATON SE 
reports the net cash flow of the TRATON Operations business area in the condensed 
statement of cash flows in the Combined Management Report. In addition, the Super -
visory Board adjusted the profit bonus cap from 180% to 200%. The ESG factor generally 
considers the opinion index ESG factor for the Social subtarget. The Supervisory Board 
was given the option to suspend the opinion index ESG factor in fiscal years 2024 and 
2025, as the underlying measurement methodologies are being optimized and recali -
brated. Instead, the new gender index1, which is linked to the development of the propor-
tion of women in management positions in TRATON GROUP companies and contributes 
to the advancement of women in the TRATON GROUP, will be used for fiscal years 2024 
and 2025. In the performance share plan, the maximum target achievement for the earn-
ings per share (EPS) target was increased from 150% to 175%, and the cap on the payment 
amount under the performance share plan was increased from the current 200% to 250% 
to reflect the development of the share price. The remuneration of the members of the 
Executive Board is also capped under the revised remuneration system. To reflect current 
market conditions, the maximum remuneration for all regular members of the Executive 
Board will in future be a standard amount of €5,000 thousand gross, and €8,500 thousand 
gross for the Chair of the Executive Board. The Supervisory Board also decided that the 
Chair of the Executive Board may in future be granted fringe benefits in the form of an 
annual flat-rate fringe benefit allowance. 
The remuneration system applies to all members of the Executive Board with new or 
extended employment contracts from the date of the 2024 Annual General Meeting. For 
the members of the Executive Board who were already in office prior to December 16, 
2020, the remuneration system applied until their contract was renewed and with the 
proviso that the performance share plan would continue to have a performance period 
of three years. This no longer applied to any active members of the Executive Board in 
fiscal year 2024. A performance share plan with a four-year performance period has also 
been in place for Mr. Levin and Mr. Cortes since fiscal year 2024.
Remuneration Report
1  The calculation and application of the gender index is subject to applicable local law. 
307
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===== SIDA 308 =====

The level of the Executive Board remuneration should be appropriate and attractive in 
the context of the Company’s national and international peer group. Criteria include the 
tasks of the individual Executive Board member, their personal performance, the eco -
nomic situation, and the performance of and outlook for the Company, as well as how 
customary the remuneration is when measured against the peer group. In this context, 
comparative studies on remuneration are conducted on a regular basis. The Supervisory 
Board increased the remuneration of the members of the Executive Board appropriately 
as of January 1, 2024. When revising the remuneration system, adjusting the remuneration 
amounts and defining the targets, the Supervisory Board was supported by a leading 
independent external remuneration consultant. 
The Executive Board and Supervisory Board reported in detail on the remuneration of 
the Executive Board and Supervisory Board in fiscal year 2023 in the 2023 Remuneration 
Report. The Annual General Meeting approved the 2023 Remuneration Report on June 
13, 2024, with 99.36% of the votes cast. Comments from investors were taken into consid-
eration when preparing the Remuneration Report for fiscal year 2024, for example, the 
tables showing remuneration granted and owed more clearly presented the minimum and 
maximum achievable amounts for the short-term and long-term variable remuneration of 
the members of the Executive Board.
The following provides an overview of the remuneration system for the Executive Board 
that was applicable in fiscal year 2024 before discussing the remuneration components 
in the same reporting period.
Overview of the remuneration components
The following table provides an overview of the components of the remuneration system 
applicable to the members of the Executive Board for fiscal year 2024. It also provides an 
overview of the composition of the individual remuneration components and explains 
the targets, especially in respect of how the remuneration is intended to foster the 
 Company’s long-term development. 
308
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Independent Auditor’s Reports
Combined Management Report Further InformationTo Our Shareholders

===== SIDA 309 =====

2024 Executive Board remuneration system
Component Composition Target
Fixed remuneration components   
Base salary Twelve equal installments payable at month-end The base remuneration and fringe 
 benefits are intended to reflect the 
tasks and responsibility of the Executive 
Board members, provide a basic 
 income, and prevent them from taking 
 inappropriate risks.
Fringe benefits In particular:
 – Private use of the first company car; second and third company cars with fuel cards in return for payment of a monthly flat fee ; 
private use of the driver pool to an appropriate extent
 – Allowance toward health and long-term care insurance and retirement provision
 – Accident insurance
 – Installation and private use of security measures
 – Medical check-up for managers
 – Inclusion in D&O and criminal legal expenses insurance
 – Benefits in the event of death
 – Possible payment of tax consulting costs
Modified fringe benefits for Executive Board members who are also members of the Executive Board of a foreign subsidiary:
 – Executive Board members who are also members of the Executive Board of a foreign subsidiary do not receive their fringe 
benefits from TRATON SE but from the respective foreign subsidiary. 
 – These Executive Board members are only entitled to modified fringe benefits from TRATON SE, i.e., they are included in the 
D&O and criminal legal expenses insurance, they are entitled to benefits in the event of death, and, under certain circumstances , 
to the payment of tax consulting costs.
The Chair of the Executive Board receives an annual flat-rate fringe benefit allowance from which the benefits used by 
 TRATON SE or a foreign subsidiary are deducted. Any residual amount is paid out to the Chair of the Executive Board. 
Occupational 
retirement provision
 – Retirement, disability, and surviving dependents’ benefits
 – In principle, upon reaching the age of 65 (earlier claims are possible)
 – Defined contribution system dependent on the performance of certain fund indices
 – Annual contribution of 40% of the contractually agreed annual base salary
 – Executive Board members who are also members of the Executive Board of a foreign subsidiary do not currently receive 
 occupational retirement provision from TRATON SE but from the respective foreign subsidiary.
The occupational retirement provision 
is intended to provide Executive Board 
members with an adequate pension 
when they retire. 
309
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===== SIDA 310 =====