Årsredovisning 2025

268  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Independent auditor’s report 
To TRATON SE 
Report on the audit of the consolidated financial statements and of the group management report 
Opinions 
We have audited the consolidated financial statements of TRATON SE, Munich, and its subsidiaries (the Group or TRATON GROUP),  which comprise the 
income statement and statement of comprehensive income for the fiscal year from January 1 to December 31, 2025 and the balance sheet as at December 31, 
2025, statement of changes in equity and statement of cash flows for the fiscal year from January  1 to December 31, 2025, and notes to the consolidated 
financial statements, including material accounting policy information. In addition, we have audited the group management report of TRATON SE, which is 
combined with the Company’s management report (“group management report”), for the fiscal year from January  1 to December 31, 2025. In accordance 
with the German legal requirements, we have not audited the content of the parts of the group management report listed in the  appendix to the auditor’s 
report and the company information stated therein that is provided outside the annual report and is referenced in the group management report. 
In our opinion, on the basis of the knowledge obtained in the audit,  
– the accompanying consolidated financial statements comply, in all material respects, with the IFRS Accounting Standards as issued by the International 
Accounting Standards Board (IASB) (IFRS Accounting Standards) and adopted by the EU, and the additional r equirements of German commercial law 
pursuant to Sec. 315e (1) HGB [“Handelsgesetzbuch”: German Commercial Code] and, in compliance with these requirements, give a true and fair view of 
the assets, liabilities and financial position of the Group as at Dece mber 31, 2025 and of its financial performance for the fiscal year from January  1 to 
December 31, 2025, and 
– the accompanying group management report as a whole provides an appropriate view of the Group’s position. In all material respects, this group man-
agement report is consistent with the consolidated financial statements, complies with German legal requirements and appropriately presents the op-
portunities and risks of future development. We do not express an opinion o n the parts of the group management report listed in the appendix to the 
auditor’s report. 
Pursuant to Sec. 322 (3) Sentence 1 HGB, we declare that our audit has not led to any reservations relating to the legal comp liance of the consolidated 
financial statements and of the group management report. 
Basis for the opinions 
We conducted our audit of the consolidated financial statements and of the group management report in accordance with Sec. 31 7 HGB and the EU Audit 
Regulation (No. 537/2014, referred to subsequently as “EU Audit Regulation”) and in compliance with German G enerally Accepted Standards for Financial 
Statement Audits promulgated by the Institut der Wirtschaftsprüfer [Institute of Public Auditors in Germany] (IDW). Our respo nsibilities under those re-
quirements and principles are further described in the “Auditor ’s responsibilities for the audit of the consolidated financial statements and of the group 
management report” section of our auditor’s report. We are independent of the Group entities in accordance with the requireme nts of European law and

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269  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
German commercial and professional law as well as the International Ethics Standards Board for Accountants’ International Code of Ethics for Professional 
Accountants (including International Independence Standards) (IESBA Code), as applicable to audits of financial statements of public interest entities. We 
have also fulfilled our other German professional responsibilities in accordance with these requirements and the ISEBA Code. In addition, in accordance 
with Art. 10 (2) f) of the EU Audit Regulation, we declare that we have not provided non-audit services prohibited under Art. 5 (1) of the EU Audit Regulation. 
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinions on the consolidated financial state-
ments and on the group management report. 
Key audit matters in the audit of the consolidated financial statements 
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the consoli dated financial statements for 
the fiscal year from January 1 to December 31, 2025. These matters were addressed in the context of our audit of the consolidated financial statements as a 
whole, and in forming our opinion thereon; we do not provide a separate opinion on these matters. 
Below, we describe what we consider to be the key audit matters: 
Recoverability of goodwill 
Reasons why the matter was determined to be a key audit matter 
The result of the impairment testing of goodwill is highly dependent on the executive directors’ estimate of future cash flows and which discount rates they 
use. The recoverable amount of the cash-generating units is calculated on the basis of their value in use, applying discounted cash flow models. 
The ongoing transformation of the core business toward electromobility, the transition to autonomous vehicles, growing enviro nmental regulation and 
geopolitical developments lead to uncertainties that have to be factored into the estimation of market shares and margins for electric vehicles and the long-
term growth rates. There is also currently a delay in the rollout of electromobility. These estimates by the executive directors are subject to risk and may be 
revised in response to changes in environmental regulation and market conditions. 
In addition, the executive directors have scope for judgment in determining the cash-generating units for impairment testing, in determining the discount 
rates used and the long-term growth rates assumed. 
In view of the foregoing, the materiality of goodwill in relation to total assets, the complexity of its valuation and the ju dgment exercised during valuation, 
the impairment testing of goodwill was a key audit matter. 
Auditor’s response 
As part of our audit procedures, we discussed with management and assessed the identification of cash -generating units and the allocation of assets and 
liabilities to the respective cash-generating units on the basis of the internal reporting structure and the corresponding provisions of IAS 36.  
We analyzed the planning process established in the TRATON GROUP and tested the operating effectiveness of the controls imple mented therein. As a 
starting point, we compared the five-year operational plan of the TRATON GROUP and of the cash-generating units prepared by the executive directors and

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270  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
acknowledged by the Supervisory Board with the forecast figures in the underlying impairment tests. We discussed the key planning assumptions with the 
executive directors and compared them with past earnings and cash inflows to assess the planning accuracy. We based plausibility testing of the inputs for 
the impairment tests among other things on a comparison with general and industry -specific market expectations underlying the expected cash inflows. 
We also investigated the expectations regarding the devel opment of market shares for battery -electric vehicles, the effects on the planned investments 
and their indirect effects on the long-term cash inflows expected by the executive directors. 
We assessed the underlying valuation models for the determination of values in use calculated using the discounted cash flow model in terms of method-
ology and reperformed the calculations with the assistance of internal valuation specialists.  
We discussed the operational planning prepared by the executive directors in terms of the assumptions regarding the developme nt of sales markets, pro-
duction costs, margins and growth rates applied with the employees responsible for planning and compared it  with external information, particularly with 
market studies.  
Furthermore, we discussed and assessed the planning assumptions regarding the effects of climate change and the associated expansion of electromobil-
ity, particularly the existing uncertainties related to the estimation of market shares for electric vehicles and margins as well as long-term growth rates used 
for the planning.  
With respect to the rollforward from the medium-term plan to the long-term forecast, we assessed the plausibility of the assumed growth rates by compar-
ing them with observable data. To assess the discount rates and growth rates applied, we analyzed the inp uts used to determine them on the basis of 
publicly available information and obtained an understanding of the methods used with regard to the relevant requirements of IAS 36. We assessed the 
derivation of the capitalization rates, in particular by evaluating the composition of the peer groups used to determine the beta factors and comparing the 
country-specific parameters used by the TRATON GROUP on the current development of interest rates, market risk premiums and growth ra tes. We con-
sulted internal experts as part of this assessment.  
We assessed the sensitivity analyses performed by the Company and performed our own in order to estimate any potential impairment risk associated with 
a reasonably possible change in one of the significant assumptions. 
Our audit procedures did not lead to any reservations relating to the assessment of impairment testing of goodwill. 
Reference to related disclosures 
The Company’s disclosures regarding the relevant accounting principles for the recognition and measurement of goodwill are co ntained in sections “Esti-
mates and management’s judgment” and “8. Goodwill and impairment losses on assets” of the notes to the financial statements.

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271  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Capitalization and recoverability of development costs 
Reasons why the matter was determined to be a key audit matter 
Key criteria for capitalizing development costs are the ability to implement the development projects (including their techni cal feasibility, the intention to 
complete them and the ability to use them) as well as the realization of an expected future economic benefit. The complexity of research and development 
projects is mounting in view of the technological transformation of the TRATON GROUP and the resulting new development areas (including high invest-
ments in electromobility and autonomous driving). Ass essments of project feasibility are playing an ever greater role in this connection and entail the use 
of considerable judgment. 
Where capitalized development costs are not yet subject to amortization, they must be tested for impairment as part of the related cash-generating unit or, 
for corporate assets, as carrying amounts allocated to the individual cash -generating units on a proportionate basis, at least annually at the level of the 
brands defined as cash -generating units. The assumption of realizing future economic benefits and the result of testing the recoverability of capita lized 
development costs during the analyses and impairment tests performed are highly dependent on the executive directors’ estimate of future cash flows and 
which discount rates they use. The recoverable amount of the cash -generating units is calculated on the basis of their value in use, applying discount ed 
cash flow models. 
The ongoing transformation of the core business toward electromobility and digitalization as well as growing environmental regulation lead to uncertainties 
that have to be factored into the estimation of market shares and margins for electric vehicles and the long-term growth rates. There is also currently a delay 
in the rollout of electromobility. These estimates by the executive directors are subject to risk and may be revised in response to changes in environmental 
regulation and market conditions. 
In addition, the executive directors have scope for judgment in determining the cash-generating units for impairment testing, in determining the discount 
rates used and the long-term growth rates assumed. 
In light of the foregoing, the materiality of the capitalized development costs in relation to total assets, the total amount of research and development costs 
and the judgment exercised in the assessment of eligibility for capitalization and the valuation  process, the capitalization of development costs and the 
impairment test were a key audit matter. 
Auditor’s response 
During our audit, we examined the process for identifying the research and development costs, particularly with reference to the criteria for capitalization. 
In this connection, we carried out analytical audit procedures such as comparisons of project budg ets and capitalization rates, inspected documentation 
on project feasibility and tested the capitalized costs on a sample basis. We also assessed the future economic benefit crite rion for capitalization based on 
the assumptions regarding the cash inflows o f the cash-generating unit to which the capitalized development work is allocated. We also obtained an un-
derstanding of the executive directors’ estimate regarding changes in the useful lives applied and indicators for changes in value of individual projects. 
Moreover, we discussed with management and assessed the identification of cash-generating units and the allocation of capitalized development costs to 
the respective cash-generating unit on the basis of the internal reporting structure and the corresponding provisions of IAS 36.

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272  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
We analyzed the planning process established in the TRATON GROUP and tested the operating effectiveness of the controls imple mented therein. As a 
starting point, we compared the five-year operational plan of the TRATON GROUP and of the cash-generating units prepared by the executive directors and 
acknowledged by the Supervisory Board with the forecast figures in the underlying impairment tests. We discussed the key planning assumptions with the 
executive directors and compared them with past earnings and cash inflows to assess the planning accuracy. We based plausibility testing of the inputs for 
the impairment tests among other things on a comparison with general and industry -specific market expectations underlying the expected cash inflows. 
We also investigated the expectations regarding the development of market shares for battery -electric vehicles, the effects on the planned investments 
and their indirect effects on the long-term cash inflows expected by the executive directors. 
We assessed the underlying valuation models for the determination of values in use calculated using the discounted cash flow model in terms of method-
ology and reperformed the calculations with the assistance of internal valuation specialists.  
We discussed the operational planning prepared by the executive directors in terms of the assumptions regarding the developme nt of sales markets, pro-
duction costs and margins with the employees responsible for planning and compared it with external information, particularly with market studies.  
Furthermore, we discussed and assessed the planning assumptions regarding the effects of climate change and the associated expansion of electromobil-
ity, particularly the existing uncertainties related to the estimation of market shares for electric vehicles and margins as well as long-term growth rates used 
for the planning.  
With respect to the rollforward from the medium-term plan to the long-term forecast, we assessed the plausibility of the assumed growth rates by compar-
ing them with observable data. To assess the discount rates and growth rates applied, we analyzed the inp uts used to determine them on the basis of 
publicly available information and obtained an understanding of the methods used with regard to the relevant requirements of IAS 36. 
We assessed the derivation of the capitalization rates, in particular by evaluating the composition of the peer groups used to determine the beta factors and 
comparing the country-specific parameters used by the TRATON GROUP on the current development of i nterest rates, market risk premiums and growth 
rates. We consulted internal experts as part of this assessment. We assessed the sensitivity analyses performed by the Company and performed our own in 
order to estimate any potential impairment risk associated with a reasonably possible change in one of the significant assumptions. 
Our procedures did not lead to any reservations relating to the recognition and recoverability of the capitalized development costs. 
Reference to related disclosures 
The Company’s disclosures regarding the relevant accounting principles for the recognition and measurement of development costs are contained in sec-
tions “Estimates and management’s judgment” and “9. Intangible assets” of the notes to the financial statements.

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273  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Completeness and measurement of provisions for warranty obligations 
Reasons why the matter was determined to be a key audit matter 
Obligations for warranty claims are calculated on the basis of estimated warranty costs and remediation expenditure. Where un usual individual technical 
risks are anticipated, an individual assessment is made whether and, if so, to what extent measures are required to remediate them and provisions need to 
be recognized. 
In light of the amount of the provisions and the judgment exercised during valuation, the completeness and measurement of pro visions for warranty obli-
gations was a key audit matter. 
Auditor’s response 
With regard to the accounting for the provisions for warranty obligations, we examined the underlying processes for recording previous claims, calculating 
and valuing the estimated future warranty costs and recognizing the provisions, and tested controls in some areas. 
In light of the uncertainty in relation to the estimated future warranty costs, we assessed the underlying valuation assumpti ons, especially the expected 
claim rate per vehicle and the cost thereof, using analyses of historical data. Where there was a lack  of past experience, we obtained an understanding of 
the assumptions made by the executive directors and tested their plausibility using historical data for comparable items. Using the calculation bases derived 
from these historical data, we checked the estimated costs for expected claims per vehicle. To assess the completeness of the provisions, we also reconciled 
the number of sold vehicles used to recognize the provision with the sales volumes. We obtained an understanding of the method used for calculating the 
provisions, including the discounting, and reperformed the calculations. 
For significant individual technical risks, we assessed the expected incidence of technical faults and the calculation of exp ected costs per claim/vehicle 
using documentation on previous claims, inspecting resolutions passed by technical committees and hol ding discussions with the departments responsi-
ble. 
Our audit procedures did not lead to any reservations relating to the completeness and valuation of provisions for warranty obligations. 
Reference to related disclosures 
The Company’s disclosures regarding the recognition and measurement of provisions for warranty obligations are contained in s ection “25. Other provi-
sions” of the notes to the financial statements.

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274  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Accounting treatment of risks in connection with the EU antitrust proceedings 
Reasons why the matter was determined to be a key audit matter 
In 2011, the European Commission initiated fine proceedings on suspicion of breaches of European antitrust law in the Europea n truck sector. By decision 
dated 19 July 2016, the fine proceedings against MAN and four other European truck manufacturers (with the exception of Scania) were concluded in a final 
and unappealable settlement. While the other four truck manufacturers were fined, MAN’s fine was waived under the leniency pr ogram. Scania was fined 
approximately EUR 880.5m in a decision by the European Commission on 27 September 2017. The fine plus interest was paid in full in fiscal year 2022. 
Following the fine decision, a significant number of customers in various jurisdictions initiated or joined lawsuits against MAN and/or Scania, claiming 
damages for potentially excessive prices. The claims differ significantly in scope. Furthermore, some truck customer damages claims have been combined 
in class actions or through claim aggregators to which the truck customers assigned their respective damages claims. 
As part of our audit, we determined this to be a key audit matter because the risk assessment and the amount of the provision to cover the aforementioned 
risks from civil proceedings are subject to a high level of uncertainty and are influenced by estimate s and assumptions made by the executive directors 
with regard to the outcome of the proceedings. 
Auditor’s response  
As part of our audit procedures, we obtained an understanding of the process installed by the Group to deal with the facts of the civil lawsuits. We discussed 
with the executive directors and the Company’s legal department the estimates and assumptions mad e by the executive directors in connection with the 
current development and the reasons underlying these estimates and assumptions, and assessed them with the involvement of internal experts for antitrust 
law.  
We also discussed the development in the various countries arising from new judgments or additional claims with the executive directors and internal and 
external lawyers. In addition, we obtained quarterly confirmations from external lawyers and addressed the significant topics and developments in discus-
sions with the external lawyers. The significant results of various economic reports (party reports, court reports) were also explained to us in this context. For 
the discussions with the Company and the ext ernal lawyers, we also consulted relevant publications in the specialist literature and other sources such as 
databases. 
Where provisions were recognized and contingent liabilities disclosed for individual cases or in some countries, we reperform ed the calculations and 
checked the underlying assumptions against the confirmations from external lawyers and the corresponding settlement agreements. 
Our audit procedures did not lead to any reservations relating to the accounting treatment of the provision for civil law risks from EU antitrust proceedings. 
Reference to related disclosures 
The Company’s disclosures regarding the accounting treatment of risks in connection with the EU antitrust proceedings are contained in sections “25. Other 
provisions” and 32. Litigation/legal proceedings of the notes to the financial statements.

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275  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Other information 
The Supervisory Board is responsible for the Report of the Supervisory Board in the 2025 Annual Report. The executive directors and the Supervisory Board 
are responsible for the declaration pursuant to Sec. 161 AktG [“Aktiengesetz”: German Stock Corporatio n Act] on the German Corporate Governance Code, 
which is part of the Corporate Governance Statement , and for the Remuneration Report pursuant to Sec. 162 AktG . In all other respects, the executive 
directors are responsible for the other information. The other information comprises the parts of the annual report listed in the appendix. 
Our opinions on the consolidated financial statements and on the group management report do not cover the other information, and consequently we do 
not express an opinion or any other form of assurance conclusion thereon. 
In connection with our audit, our responsibility is to read the other information and, in so doing, to consider whether the other information 
– is materially inconsistent with the consolidated financial statements, with the group management report or our knowledge obtained in the audit, or 
– otherwise appears to be materially misstated. 
Responsibilities of the executive directors and the Supervisory Board for the consolidated financial statements and the group man-
agement report 
The executive directors are responsible for the preparation of the consolidated financial statements that comply, in all mate rial respects, with the IFRS 
Accounting Standards as adopted by the EU and the additional requirements of German commercial law pursuant to Sec. 315e (1) HGB, and that the consol-
idated financial statements, in compliance with these requirements, give a true and fair view of the assets, liabilities, financial position and financial perfor-
mance of the Group. In addition, the executive directors are responsible for such internal control as they have determined necessary to enable the prepara-
tion of consolidated financial statements that are free from material misstatement, whether due to fraud (i.e., fraudulent fi nancial reporting and 
misappropriation of assets) or error. 
In preparing the consolidated financial statements, the executive directors are responsible for assessing the Group’s ability to continue as a going concern. 
They also have the responsibility for disclosing, as applicable, matters related to going concern.  In addition, they are responsible for financial reporting 
based on the going concern basis of accounting unless there is an intention to liquidate the Group or to cease operations, or there is no realistic alternative 
but to do so. 
Furthermore, the executive directors are responsible for the preparation of the group management report that, as a whole, provides an appropriate view of 
the Group’s position and is, in all material respects, consistent with the consolidated financial stat ements, complies with German legal requirements, and 
appropriately presents the opportunities and risks of future development. In addition, the executive directors are responsibl e for such arrangements and 
measures (systems) as they have considered necessary to enable the preparation of a group management report that is in accordance with the applicable 
German legal requirements, and to be able to provide sufficient appropriate evidence for the assertions in the group management report. 
The Supervisory Board is responsible for overseeing the Group’s financial reporting process for the preparation of the consol idated financial statements 
and of the group management report.

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276  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Auditor’s responsibilities for the audit of the consolidated financial statements and of the group management report 
Our objectives are to obtain reasonable assurance about whether the consolidated financial statements as a whole are free fro m material misstatement, 
whether due to fraud or error, and whether the group management report as a whole provides an appropriate view of the Group’s position and, in all material 
respects, is consistent with the consolidated financial statements and the knowledge obtained in the audit, complies with the  German legal requirements 
and appropriately presents the opportunities and risks  of future development, as well as to issue an auditor’s report that includes our opinions on the 
consolidated financial statements and on the group management report. 
Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with Sec. 317 HGB and the EU Audit Regu-
lation and in compliance with German Generally Accepted Standards for Financial Statement Audits promulga ted by the Institut der Wirtschaftsprüfer 
(IDW) will always detect a material misstatement. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, 
they could reasonably be expected to influence the eco nomic decisions of users taken on the basis of these consolidated financial statements and this 
group management report. 
We exercise professional judgment and maintain professional skepticism throughout the audit. We also: 
– Identify and assess the risks of material misstatement of the consolidated financial statements and of the group management r eport, whether due to 
fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that  is sufficient and appropriate to provide a 
basis for our opinions. The risk of not detecting a material misstatement resulting from fraud is higher than the risk of not detecting a material misstate-
ment resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. 
– Obtain an understanding of internal control relevant to the audit of the consolidated financial statements and of arrangement s and measures relevant 
to the audit of the group management report in order to design audit procedures that are appropriate in the  circumstances, but not for the purpose of 
expressing an opinion on the effectiveness of the Group’s internal control and of such arrangements and measures. 
– Evaluate the appropriateness of accounting policies used by the executive directors and the reasonableness of estimates made by the executive direc-
tors and related disclosures. 
– Conclude on the appropriateness of the executive directors’ use of the going concern basis of accounting and, based on the au dit evidence obtained, 
whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Group’s ability to continue as a going concern. 
If we conclude that a material uncertainty exists, we are required to draw attention in the auditor’s report to the related d isclosures in the consolidated 
financial statements and in the group management report or, if such disclosures are inadequate, to modify our respective opinions. Our conclusions are 
based on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may cause t he Group to cease to be 
able to continue as a going concern. 
– Evaluate the overall presentation, structure and content of the consolidated financial statements, including the disclosures,  and whether the consoli-
dated financial statements present the underlying transactions and events in a manner that the consolidated  financial statements give a true and fair 
view of the assets, liabilities, financial position and financial performance of the Group in compliance with the IFRS Accounting Standards as adopted by 
the EU and the additional requirements of German commercial law pursuant to Sec. 315e (1) HGB.

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277  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
– Plan and perform the audit of the consolidated financial statements to obtain sufficient appropriate audit evidence regarding the financial information 
of the entities or business units within the Group to express opinions on the consolidated financial sta tements and on the group management report. 
We are responsible for the direction, supervision and review of the work performed for the group audit. We remain solely resp onsible for our audit 
opinions. 
– Evaluate the consistency of the group management report with the consolidated financial statements, its conformity with [German] law, and the view of 
the Group’s position it provides. 
– Perform audit procedures on the prospective information presented by the executive directors in the group management report. On the basis of suffi-
cient appropriate audit evidence we evaluate, in particular, the significant assumptions used by the executive  directors as a basis for the prospective 
information, and evaluate the proper derivation of the prospective information from these assumptions. We do not express a se parate opinion on the 
prospective information and on the assumptions used as a basis. There is a substantial unavoidable risk that future events will differ materially from the 
prospective information. 
We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit a nd significant audit 
findings, including any significant deficiencies in internal control that we identify during our audit. 
We also provide those charged with governance with a statement that we have complied with the relevant independence requirements, and communicate 
with them all relationships and other matters that may reasonably be thought to bear on our independence and where applicable, the related safeguards. 
From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the con-
solidated financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditor’s report unless law or 
regulation precludes public disclosure about the matter. 
Other legal and regulatory requirements 
Report on the assurance on the electronic rendering of the consolidated financial statements and the group management report prepared for publication 
purposes in accordance with Sec. 317 (3a) HGB 
Opinion 
We have performed assurance work in accordance with Sec. 317 (3a) HGB to obtain reasonable assurance about whether the rendering of the consolidated 
financial statements and the group management report (hereinafter the “ESEF documents”) contained in the file TRATON_SE_KA_ZLB_ESEF_2025-12-31.zip 
and prepared for publication purposes complies in all material respects with the requirements of Sec. 328 (1) HGB for the electronic reporting format (“ESEF 
format”). In accordance with German legal requirements, thi s assurance work extends only to the conversion of the information contained in the consoli-
dated financial statements and the group management report into the ESEF format and therefore relates neither to the information contained within these 
renderings nor to any other information contained in the file identified above. 
In our opinion, the rendering of the consolidated financial statements and the group management report contained in the file identified above and prepared 
for publication purposes complies in all material respects with the requirements of Sec. 328 (1) HGB for the electronic reporting format. Beyond this assur-
ance opinion and our audit opinions on the accompanying consolidated financial statements and the accompanying group manageme nt report for the

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278  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
fiscal year from January 1 to December 31, 2025 contained in the “Report on the audit of the consolidated financial statements and of the group management 
report” above, we do not express any assurance opinion on the information contained within these renderings or on the other information contained in the 
file identified above. 
Basis for the opinion  
We conducted our assurance work on the rendering of the consolidated financial statements and the group management report con tained in the file 
identified above in accordance with Sec. 317 (3a) HGB and the IDW Assurance Standard: Assurance on the Electroni c Rendering of Financial Statements 
and Management Reports Prepared for Publication Purposes in Accordance with Sec. 317 (3a) HGB (IDW AsS 410 (06.2022)) and the  International Standard 
on Assurance Engagements 3000 (Revised). Our responsibility in accordan ce therewith is further described in the “Group auditor’s responsibilities for the 
assurance work on the ESEF documents” section. Our audit firm applies the IDW Standard on Quality Management 1: Requirements for Quality Management 
in the Audit Firm (IDW QMS 1 (09.2022)). 
Responsibilities of the executive directors and the Supervisory Board for the ESEF documents 
The executive directors of the Company are responsible for the preparation of the ESEF documents including the electronic ren dering of the consolidated 
financial statements and the group management report in accordance with Sec. 328 (1) Sentence 4 No. 1 HG B and for the tagging of the consolidated 
financial statements in accordance with Sec. 328 (1) Sentence 4 No. 2 HGB. 
In addition, the executive directors of the Company are responsible for such internal control as they have determined necessa ry to enable the preparation 
of ESEF documents that are free from material intentional or unintentional non -compliance with the req uirements of Sec. 328 (1) HGB for the electronic 
reporting format. 
The Supervisory Board is responsible for overseeing the process for preparing the ESEF documents as part of the financial rep orting process. 
Group auditor’s responsibilities for the assurance work on the ESEF documents  
Our objective is to obtain reasonable assurance about whether the ESEF documents are free from material intentional or uninte ntional non-compliance 
with the requirements of Sec. 328 (1) HGB. We exercise professional judgment and maintain professional skept icism throughout the assurance work. We 
also: 
– Identify and assess the risks of material intentional or unintentional non -compliance with the requirements of Sec. 328 (1) HGB, design and perform 
assurance procedures responsive to those risks, and obtain assurance evidence that is sufficient and appropr iate to provide a basis for our assurance 
opinion. 
– Obtain an understanding of internal control relevant to the assurance on the ESEF documents in order to design assurance proc edures that are appro-
priate in the circumstances, but not for the purpose of expressing an assurance opinion on the effectiveness of these controls. 
– Evaluate the technical validity of the ESEF documents, i.e., whether the file containing the ESEF documents meets the require ments of Commission 
Delegated Regulation (EU) 2019/815, in the version in force at the date of the financial statements, on the technical specification for this file. 
– Evaluate whether the ESEF documents enable an XHTML rendering with content equivalent to the audited consolidated financial statements and to the 
audited group management report.

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279  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
– Evaluate whether the tagging of the ESEF documents with Inline XBRL technology (iXBRL) in accordance with the requirements of  Arts. 4 and 6 of 
Commission Delegated Regulation (EU) 2019/815, in the version in force at the date of the financial statements, e nables an appropriate and complete 
machine-readable XBRL copy of the XHTML rendering. 
Further information pursuant to Art. 10 of the EU Audit Regulation 
We were elected as group auditor by the Annual General Meeting on 14 May 2025. We were engaged by the Supervisory Board on 21  July 2025. We have 
been the group auditor of TRATON SE without interruption since fiscal year 2020. 
We declare that the opinions expressed in this auditor’s report are consistent with the additional report to the Audit Committee pursuant to Art. 11 of the EU 
Audit Regulation (long-form audit report). 
In addition to the financial statement audit, we have provided to Group entities the following services that are not disclosed individually in the consolidated 
financial statements or in the group management report: 
– Issuance of comfort letters for TRATON SE in connection with the EUR 18b European Medium Term Notes (EMTN) Program 
– Audit of the remuneration report in accordance with Sec. 162 AktG 
– Voluntary audits or reviews of annual financial statements 
– GRI 207 – TRATON Tax Transparency Report: voluntary assurance engagement on the income tax-related sustainability reporting 
– Limited assurance engagement on the EU Taxonomy disclosures 
– Training on the topic of “Regulatory ESG update” for the Supervisory Board 
– Project-based analysis of CSRD readiness and EU Taxonomy readiness 
– EMIR assurance engagement pursuant to Sec. 20 WpHG [“Wertpapierhandelsgesetz”: German Securities Trading Act] 
– Services in connection with enforcement procedures 
Other matter – use of the auditor’s report 
Our auditor’s report must always be read together with the audited consolidated financial statements and the audited group ma nagement report as well 
as the assured ESEF documents. The consolidated financial statements and the group management report conver ted to the ESEF format – including the 
versions to be published in the Unternehmensregister [German Company Register] – are merely electronic renderings of the audited consolidated financial 
statements and the audited group management report and do not tak e their place. In particular, the ESEF report and our assurance opinion contained 
therein are to be used solely together with the assured ESEF documents made available in electronic form.

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To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
German Public Auditor responsible for the engagement 
The German Public Auditor responsible for the engagement is Steffen Maurer. 
Appendix to the auditor’s report: 
1. Parts of the group management report whose content is unaudited 
We have not audited the content of the following parts of the group management report: 
– The Corporate Governance Statement contained in the section “Supplemental Information on Fiscal Year 2025” of the group management report 
– The EU Taxonomy disclosures contained in the section “Nonfinancial Group Statement” of the group management report 
Furthermore, we have not audited the content of the following disclosures extraneous to management reports. Disclosures extra neous to management 
reports are such disclosures that are not required pursuant to Secs. 315, 315a HGB or Secs. 315b to 315d HGB or GAS 20. 
– The section “Appropriateness and effectiveness of risk management” contained in the section “Report on Expected Developments,  Opportunities, and 
Risks,” subsection “2. Report on opportunities and risks” of the group management report.  
2. Further other information 
The other information also comprises other parts to be included in the annual report, of which we obtained a copy prior to is suing this auditor’s report, in 
particular the sections: 
– Section 1 To Our Shareholders 
– Section 4 Responsibility Statement 
– Section 5 Sustainability Report 
– Section 6 Further Information (containing the Remuneration Report) 
but not the consolidated financial statements, not the group management report disclosures whose content is audited and not our auditor’s report thereon.

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To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
3. Company information outside the annual report referenced in the group management report 
The group management report contains cross -references to webpages of the Group and the Group companies. We have not audited the content of the 
information to which these cross-references refer.” 
Munich, February 17, 2026 
EY GmbH & Co. KG 
Wirtschaftsprüfungsgesellschaft 
 
Dr. Janze   Maurer 
Wirtschaftsprüfer   Wirtschaftsprüfer 
[German Public Auditor] [German Public Auditor]

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282  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Assurance report of the independent German public auditor  
on a limited assurance engagement  
To TRATON SE, Munich 
Assurance conclusion 
We have conducted a limited assurance engagement on the disclosures in section EU -Taxonomy disclosures of the Combined Management Report of 
TRATON SE to fulfill the requirements of Art. 8 of Regulation (EU) 2020/852 (“non-financial disclosures”) for the fiscal year from January 1, 2025, to December 
31, 2025. 
Based on the procedures performed and the evidence obtained, nothing has come to our attention that causes us to believe that  the accompanying non-
financial disclosures for the fiscal year from January 1, 2025, to December 31, 2025, are not prepared, in all material respects, in accordance with the require-
ments of Art. 8 of Regulation (EU) 2020/852 and the supplementary criteria presented by the executive directors of the Company. 
Basis for the assurance conclusion 
We conducted our assurance engagement in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised ): Assurance En-
gagements Other Than Audits or Reviews of Historical Financial Information issued by the International Auditing and Assurance Standards Board (IAASB).  
The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonabl e assurance engagement. 
Consequently, the level of assurance obtained is substantially lower than the assurance that would have bee n obtained had a reasonable assurance en-
gagement been performed. 
Our responsibilities under ISAE 3000 (Revised) are further described in the section “German public auditor’s responsibilities for the assurance engagement 
on the non-financial disclosures.”  
We are independent of the Company in accordance with the requirements of European law and German commercial and professional law, and we have 
fulfilled our other German professional responsibilities in accordance with these requirements. Our audit firm has applied the requirements for a system of 
quality control as set forth in the IDW Quality Management Standard issued by the Institut der Wirtschaftsprüfer [Institute o f Public Auditors in Germany] 
(IDW): Requirements for Quality Management in the Audit Firm (IDW QMS 1 (09.2022)) and International Standard on Quality Management (ISQM) 1 issued 
by the IAASB. We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our assurance conclusion.

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To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Responsibilities of the executive directors and the supervisory board for the non-financial disclosures 
The executive directors are responsible for the preparation of the non -financial disclosures in accordance with the applicable German legal and European 
requirements as well as with the supplementary criteria presented by the executive directors of the Com pany and for designing, implementing and main-
taining such internal control that they have considered necessary to enable the preparation of non -financial disclosures in accordance with these require-
ments that are free from material misstatement, whether due to fraud (i.e., fraudulent non-financial reporting) or error.  
This responsibility of the executive directors includes selecting and applying appropriate reporting policies for preparing t he non-financial disclosures, as 
well as making assumptions and estimates and ascertaining forward-looking information for individual sustainability-related disclosures.  
The supervisory board is responsible for overseeing the process for the preparation of the non -financial disclosures. 
Inherent limitations in preparing the non-financial disclosures  
The applicable German legal and European requirements contain wording and terms that are subject to considerable interpretati on uncertainties and for 
which no authoritative, comprehensive interpretations have yet been published. Therefore, the executive di rectors have disclosed their interpretations of 
such wording and terms in section DNSH criteria of the non -financial disclosures. The executive directors are responsible for the reasonableness of these 
interpretations. As such wording and terms may be interpreted differently by regulators or courts, the legality of measurements or evaluations of sustaina-
bility matters based on these interpretations is uncertain. 
These inherent limitations also affect the assurance engagement on the non-financial disclosures. 
German public auditor’s responsibilities for the assurance engagement on the non-financial disclosures 
Our objective is to express a limited assurance conclusion, based on the assurance engagement we have conducted, on whether any matters have come to 
our attention that cause us to believe that the non-financial disclosures have not been prepared, in all material respects, in accordance with the applicable 
German legal and European requirements and the supplementary criteria presented by the Company’s executive directors, and to issue an assurance report 
that includes our assurance conclusion on the non-financial disclosures.  
As part of a limited assurance engagement in accordance with ISAE 3000 (Revised), we exercise professional judgment and maint ain professional skepti-
cism. We also: 
– Obtain an understanding of the process for identifying the taxonomy-eligible and taxonomy-aligned economic activities and the corresponding disclo-
sures in the non-financial-disclosures and of the internal controls relating to this process. 
– Identify disclosures where a material misstatement due to fraud or error is likely to arise, design and perform procedures to  address these disclosures 
and obtain limited assurance to support the assurance conclusion. The risk of not detecting a material misstatement resulting from fraud is higher than 
the risk of not detecting a material misstatement resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations 
or the override of internal control. In addition, the  risk of not detecting a material misstatement in information obtained from sources not within the

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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Company’s control (value chain information) is ordinarily higher than the risk of not detecting a material misstatement in in formation obtained from 
sources within the Company’s control, as both the Company’s executive directors and we as practitioners are  ordinarily subject to restrictions on direct 
access to the sources of the value chain information. 
– Consider the forward -looking information, including the appropriateness of the underlying assumptions. There is a substantial unavoidable risk tha t 
future events will differ materially from the forward-looking information. 
Summary of the procedures performed by the German public auditor  
A limited assurance engagement involves the performance of procedures to obtain evidence about the sustainability information . The nature, timing and 
extent of the selected procedures are subject to our professional judgment. 
In performing our limited assurance engagement, we:  
– Evaluated the suitability of the criteria as a whole presented by the executive directors in the non-financial disclosures. 
– Inquired of the executive directors and relevant employees involved in the preparation of the non -financial disclosures about the preparation process 
and about the internal controls relating to this process.  
– Evaluated the reporting policies used by the executive directors to prepare the non-financial disclosures. 
– Performed analytical procedures and made inquiries about the disclosures on the taxonomy-eligible and taxonomy-aligned economic activities. 
– Performed selective testing and obtained evidence relating to the collection and reporting of the disclosures on taxonomy -eligible and taxonomy -
aligned economic activities. 
– Considered the implementation of key management requirements, processes and data collection requirements through site visits to the selected loca-
tions. 
– Reconciled selected disclosures with the corresponding disclosures in the [annual / consolidated] financial statements and th e [group] management 
report. 
– Considered the presentation of the information in the non-financial disclosures. 
Restriction of use 
We draw attention to the fact that the assurance engagement was conducted for the Company’s purposes and that the assurance report is intended solely 
to inform the Company about the result of the assurance engagement. As a result, it may not be suitable fo r another purpose than the aforementioned. 
Accordingly, the assurance report is not intended to be used by third parties for making (financial) decisions based on it. Our responsibility is to the Company 
alone. We do not accept any responsibility to third parties. Our assurance conclusion is not modified in this respect.

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285  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
General Engagement Terms and Liability 
The “General Engagement Terms for Wirtschaftsprüferinnen, Wirtschaftsprüfer and Wirtschaftsprüfungsgesellschaften [German Public Auditors and Public 
Audit Firms]” dated January 1, 2024, which are attached to this report, are applicable to this engagement and also govern our relations with third parties i n 
the context of this engagement (ey-idw-aab-en-2024.pdf).  
In addition, please refer to the liability provisions contained there in no. 9 and to the exclusion of liability towards third parties. We accept no responsibility, 
liability or other obligations towards third parties unless we have concluded a written agr eement to the contrary with the respective third party or liability 
cannot effectively be precluded.  
We make express reference to the fact that we will not update the assurance report to reflect events or circumstances arising  after it was issued, unless 
required to do so by law. It is the sole responsibility of anyone taking note of the summarized result  of our work contained in this report to decide whether 
and in what way this result is useful or suitable for their purposes and to supplement, verify or update it by means of their own review procedures. 
Stuttgart, February 17, 2026 
EY GmbH & Co. KG  
Wirtschaftsprüfungsgesellschaft 
 
Maurer   Hinderer 
Wirtschaftsprüfer  Wirtschaftsprüfer 
[German Public Auditor] [German Public Auditor]

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5
SUSTAINABILITY 
REPORT
General Information 287
Environmental 308
Social 334
Governance 361
Notes to the Sustainability Report 376

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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
SUSTAINABILITY REPORT 
General Information 
Basis for preparation 
The Corporate Sustainability Reporting Directive (CSRD) was not transposed into national law in Germany in 2025. Nevertheless , TRATON has voluntarily 
prepared a sustainability report on a consolidated basis for the 2025 financial year. This report is not p art of the combined management report and is 
therefore not audited and not fully compliant with European Sustainability Reporting Standards (ESRS). However, in our opinio n, it largely fulfills the re-
quirements of reporting in accordance with ESRS. The refe rence table (see References) provides an overview of where disclosure requirements can be 
found in the report. 
To support transparency and ensure year-over-year comparisons, quantitative data from the previous reporting period is included where available. As in the 
previous year, TRATON reports key metrics to the Volkswagen Group, which are reviewed by a financial auditor in context of the preparation of their non -
financial statement. 
Basis of consolidation 
The scope of consolidation generally aligns with that of the consolidated financial statements and is determined based on financial reporting requirements, 
impact materiality, and activities under operational control. The following adjustments were made for the gathering of data related to environmental infor-
mation and information on governance: 
Environmental standards: Data is gathered primarily for the fully consolidated companies. There are no associated companies o ver which TRATON has 
operational control. Consequently, environmental data (Scope 1 and 2 emissions) for these entities is not reported. TRATON has a joint venture that operates 
within Scania’s production network. However, the associated environmental emissions cannot be reliably reported separately. F or this reason, they are in-
cluded in the overall reporting for the Group. 
Governance standard: The disclosures under corruption and bribery in the Governance section take all controlled companies with active employees or 
purchasing activities into account. 
For the preparation of this sustainability report, both the upstream and downstream value chain were considered when assessin g the impacts, risks, and 
opportunities beyond the Group’s own business area.

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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Uncertainties and estimates 
Preparation of ESG performance data requires the application of estimations in some areas, which affects the reported data. These estimates are grounded 
in historical experience, expert input, external benchmarks, and internal expertise, and are made with due consideration of the circumstances. The method 
descriptions provide further detail on the inherent uncertainties and estimation processes. To mitigate the risk of reporting  inaccuracies, particularly in 
areas subject to estimation, internal controls and validation procedures are in place. 
The estimates reported in the previous year are updated accordingly if actual data becomes available for the previous reporting period. 
Business model and value chain 
Business model 
TRATON’s business model is centered on the research and development, production, and distribution of commercial vehicles, including trucks, buses, light 
commercial vehicles, and related services. TRATON comprises the Scania, MAN, International, and Volkswa gen Truck & Bus brands, thereby addressing a 
diverse range of customers. In addition, the TRATON GROUP offers a large number of financial services to its customers.  
In the reporting period, the Group continued its efforts to shift investments from diesel powertrains to alternative drive sy stems in line with TRATON’s 
sustainability-related strategy and ambition. The TRATON brands are continuing to expand their product and service portfolio and supporting their custom-
ers in switching to battery-electric vehicles (BEVs). This contributes to making TRATON’s business model and strategy resilient against the material impacts 
and risks identified in the double materiality ana lysis (DMA). The most significant customer groups are logistics and transportation companies, public 
transport authorities, and retailers. 
For further information on TRATON’s business model and the brands’ positioning, see the section on Key Information of the TRATON GROUP  of the Com-
bined Management Report. 
Value chain 
The TRATON GROUP has a highly diversified value chain. It includes upstream processes, also referred to as supply chain, own operations, and downstream 
processes. Both upstream and downstream process steps of this value chain are integrated vertically into TRATON’s own operations, in addition to the core 
business.

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Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
The TRATON value chain

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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Upstream 
The upstream value chain includes the extraction of raw materials and the production of components and parts. TRATON maintains close relationships with 
a large number of suppliers globally who play a key role in the provision of raw materials and intermediate products. 
Core business/own operations  
TRATON operates its own production facilities and assembly plants globally in which essential components such as powertrains, transmissions, and chassis 
are produced, and complete vehicles are assembled. The core business includes the central activities of  development, manufacturing, logistics, and sales 
of vehicles as well as related services.  
Development 
In the development phase, TRATON conducts research and development activities in advanced technologies and innovative designs. 
Manufacturing 
Production takes place in production facilities spread across key geographies.  
Logistics 
Efficient logistics processes ensure integration of all steps, from purchasing to production and delivery.  
Sales 
Sales are carried out via a global dealer or distributor network. Parts of the TRATON dealer and distribution network are cap tive. Through the TRATON 
Financial Services segment, customers can also benefit from financing solutions. 
Downstream 
Product use 
In the downstream value chain, the use phase and the associated services play a central role. The dealers and service partners offer maintenance and repair 
services, as well as digital services.  
End-of-Life  
The focus here is on the end of the products’ service life. This now also includes remanufacturing. In the future, battery re cycling is also expected to play a 
role. 
As depicted in the value chain description, TRATON relies on various inputs such as raw materials, components, technology, sk illed labor, and financial 
resources sourced globally. These inputs are secured through strategic supplier relationships, expenditu res for research and development, talent acquisi-
tion, and robust financial management. Promoting innovations is also an aspect of the approach to achieving and maintaining c ompetitive advantages in 
the respective markets.

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 Combined  
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Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
The products of the TRATON GROUP, commercial vehicles and innovative technologies, offer valuable advantages to a broad range of global stakeholders. 
Customers gain from reliable, cost-efficient vehicles that enhance their operations. Investors benefit from strong financial performance, market leadership, 
and growth driven by continuous innovation. Through the Group’s investment in low and zero emission technologies, stakeholders as well as wider society 
and the environment benefit from reduced environmenta l impact. The TRATON GROUP thereby further supports its customers in meeting their sustaina-
bility goals and regulatory compliance. For more details on the locations of our material impacts, risks and opportunities (I ROs) within the TRATON value 
chain, refer to the graphic Overview of material topics in the Material topics of TRATON section. 
For further information on the TRATON GROUP’s business activities, refer to the Business activities and organization section. 
In general, none of the TRATON GROUP’s products or services are banned in certain markets. Nevertheless, they may fall under existing sanctions or em-
bargoes, with which the Group strictly complies in line with applicable laws, regulations, and internal policies (see Affected communities). 
Sustainability strategy  
At TRATON, the commitment to sustainability is firmly anchored in the strategy and corporate values. The Group’s purpose is: “Transforming Transportation 
Together. For a sustainable world”. This is a commitment to building a profitable company by developing transportation solutions that meet the needs of a 
sustainable society.  
Responsible Company 
The strategic focus of the TRATON GROUP, known as the TRATON Way Forward (see To Our Shareholders), is based on a long -term vision for proactively 
navigating the transformation of the transportation and logistics sector. A part of this strategy is the pillar Responsible C ompany, which serves as the cor-
nerstone of the Group’s ambition to act sustainably, ethically, and with a clear sense of accountability. Through this strategic focus, the Group strives to meet 
environmental goals, to foster responsible engagement with employees, customers, suppliers, and partners, and to ensure that responsibility underpins 
every decision. Together with its brands, TRATON is committed to a shared purpose: a central objective is to deliver value no t only to customers but also to 
society — across the entire product life cycle. 
The Responsible Company pillar also drives the cultivation of an inclusive and people -oriented corporate culture. TRATON recognizes diversity in a broad 
sense, valuing differences in personal experience, education, and perspective. Upholding ethical governance principles is equally critical to this strategy, as 
the Group seeks to embed integrity and transparency throughout its organizational processes. By focusing on joint impact areas, the TRATON GROUP aims 
to deepen its commitment and accelerate progress towards becoming an even more responsible and sustainability-driven Group.

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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Joint impact areas 
The TRATON GROUP’s sustainability management approach outlines how TRATON translates its sustainability purpose and ambitions  into action and re-
sults.  
TRATON welcomes the Paris Climate Agreement as a guiding principle for the future. Our commitment is to move steadily towards alignment with the Paris 
Climate Agreement — driven by innovation and collaboration. This ambition is rooted in the recognition that road freight today contributes to a noticeable 
share of energy related greenhouse gas (GHG) emissions. To align road freight transportation with the Paris Climate Agreement, deep and fast reduction is 
needed. This requires the adoption and harmonization  of stricter fuel economy standards and incentives, and infrastructure for zero -emission vehicles. A 
significant increase in renewable electricity supply and advancements in battery technology for truck electrification are necessary for the electrification of 
commercial vehicles. To achieve this, the commitment of all major transportation companies and commercial vehicle manufacture rs, the pooling of re-
sources, and cooperation with industry partners are crucial in order to drive forward decarbonization and strengthen the industry. 
Increased resource consumption contributes to climate change as well as biodiversity loss and pollution. Also, here the transportation sector is a significant 
contributor. The Earth’s resources cannot sustain current consumption rates, leading to societal inequality and higher costs. Urgent measures and regula-
tory frameworks are needed to curb resource exploitation. Transitioning to a circular economy, especially in wealthier countries, could reduce resource use, 
improve well-being, and stimulate economic growth. 
TRATON adopts a transformative approach to sustainability. This implies fundamental changes to products and services all the way to relationships with 
suppliers, customers, and partners, while ensuring relevance in the transition in the different parts of the world. The TRATON GROUP is active in shaping 
strategies, practices, and collaborations to shoulder our responsibility for the systemic changes needed. However, these sustainability-related goals are not 
limited to any specific supplier, customer group, or geographical area, thus a broad and inclusive approach to driving transformation is adopted. For TRATON 
to stay focused and use the resources in a manner that creates the most effect, three joint impact areas have been identified : decarbonization, circularity, 
and human rights. They allow TRATON to address these areas in an integrated and efficient way, based on the sustainability management model. With the 
joint impact areas, TRATON aims to drive sustainable transportation solutions and create lasting value for people and the planet.

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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Joint impact area commitments 
 
Decarbonization: TRATON is committed to the Paris Climate Agreement to reduce greenhouse gas emissions across the company’s entire value chain. 
A substantial portion of global greenhouse gas (GHG) emissions originate from the transportation sector. TRATON is working to wards being part of the 
solution and strives to play an important role in the decarbonization of the commercial vehicle sector. Rec ognizing that almost all the Group’s value chain 
emissions stem from the use phase of its products, TRATON is focusing on electrification as the most impactful lever to decarbonization. The Group aims to 
offer high-performance BEVs and complementary services such as charging solutions and financing options. At the same time, TRATON keeps improving 
the energy efficiency of vehicles using internal combustion engines. By forming partnerships and advocating supportive regula tions, the Group facilitates 
access to new technologies and infrastructure. 
Circularity: Commitment to decoupling the use of resources from the company’s growth. 
Circularity reduces reliance on finite natural resources, ensuring a more sustainable development throughout the vehicle life cycle. Circularity means more 
for the TRATON GROUP than merely reducing negative impacts. It is about fundamentally rethinking processes and enhancing their design. The systematic 
introduction of circular principles is geared toward accelerating innovation and developing new products, services, and busin ess models. This is linked to 
the goals of reducing or completely avoiding the us e of new materials and creating a more sustainable customer offering that is tailored to future market 
requirements. Electrification of vehicles not only lowers emissions, it also reduces the resources used within the value chai n. By forming partnerships a nd 
advocating appropriate regulations, the TRATON GROUP wants to play its part in bringing about systemic change.

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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Human rights: Commitment to human rights and ensuring an equitable transition. 
The Group has taken steps to manage its own human rights impact. Further work is aimed at understanding the impact in its own  operations and value 
chain, including the social dimension of the green transition. TRATON will place a strong focus on the supply chain and work closely with partners to create 
a transparent, responsible, and resilient value chain.  
Stakeholder engagement 
As a global organization, the activities of the TRATON GROUP impact many individuals. Engaging with stakeholders is essential to identify key areas for the 
Group strategy and anticipate evolving expectations. TRATON sees stakeholder engagement as its duty to systematically and continuously interact with 
various stakeholders, actively listen to their perspectives, and incorporate their feedback into our own strategy and business model. The goal is to — within 
the legal framework — maintain an open, constructive dialog with all stakeholder groups. 
To facilitate decision-making processes at the TRATON GROUP, the following key stakeholder groups were identified as being of particular relevance in the 
context of sustainability: customers, employees, society and media, investors, science and experts, bu siness partners and suppliers including value chain 
workers, politics and associations, NGOs and NPOs, as well as residents and communities and local authorities. 
Engagement with these stakeholder groups is designed to foster open dialog, build trust through a variety of processes such a s feedback mechanisms, 
collaborative initiatives, and transparent communication channels. For example, our European employees are engaged through the TRATON GROUP Works 
Council, ensuring a continuous exchange of perspectives across different regions. Investors are kept informed and involved th rough the Annual General 
Meeting, Investor Calls, and Capital Markets Days. These platforms offer transparency and the opportunity to explain strategic priorities. In general, surveys 
and partnerships are used to gather insights and share knowledge across stakeholder groups, while active participation in all iances and networks fosters 
the exchange of expertise and innovative solutions. By integrating stakeholder perspectives into decision-making and maintaining open, ongoing commu-
nication, TRATON ensures that its strategies are both inclusive and aligned with evolving societal and environmental pri orities. The frequency of engage-
ment with stakeholders depends on the stakeholder group and engagement format. Some formats are conducted regularly while others depend on specific 
political, societal, or economic events. The purpose of these actions is to maintain an exchange in both directions and generate insights into the interests 
and views of stakeholder groups. These in return inform the strategy process and subsequently contribute to any changes made to continuous development 
of the TRATON business model through the responsible functions, working groups, and committees. Thereby, ultimately also the highest-level management 
bodies of the Group are informed about the views and interests of stakeholders. 
This process ensures that the sustainability strategy, accompanying processes, and guidelines are directly informed by stakeh olders’ interests in sustaina-
bility matters. TRATON has the ambition to further elaborate guidance and actions of sustainability management, which will be  informed by stakeholder 
engagement processes performed by the responsible function. The integration of stakeholder expectations into the DMA process is described in the section 
on Methodology and process. 
A human rights salience assessment from 2024 provided key insights into the interests, views, and rights of the TRATON workfo rce, value chain workers, 
and affected communities. The salience assessment focused on the areas that are affected by the Group’s b usiness model, highlighting opportunities for 
mitigating the negative impacts as well as creating value for people and society. It also serves as a base to further develop the sustainability strategy and

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 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
specifically the joint impact area of human rights, which ensures the reflection of views, interests, and rights of employees, supply chain workers, (see Work-
ers in the value chain) and affected communities in the strategy (see Road safety and Affected communities).  
Beyond its contribution to material IRO evaluation, the human rights salience assessment also indirectly shaped TRATON’s sustainability strategy and busi-
ness model. As this salience assessment was done on a cursory level, and there have been no major chang es to the business model or operations of the 
company in 2025, we have continued to use the human rights salience assessment from 2024. 
Material impacts, risks and opportunities and their interaction with strategy and business model 
The TRATON GROUP has established strategic and operational foundations to adapt its business model in response to climate-related risks and opportuni-
ties. As part of its decarbonization strategy, the TRATON GROUP has defined actions that were implemented i n 2025 and will continue to be implemented 
in the future. Details are described in the Decarbonization section. While measurable impacts are not yet available for the reporting year, these measures 
are designed to increase internal awareness and readiness across the Group. 
The TRATON GROUP continuously monitors regulatory developments, technological trends, and stakeholder expectations to ensure its strategy remains 
compliant and responsive. These include regular review and adjustment of its sustainability measures, investme nt planning, and operational processes. 
These mechanisms enable the Group to flexibly align its business model with evolving climate transition pathways and commerci al vehicle sector require-
ments. 
In 2025, the TRATON GROUP identified material IROs through its DMA. These IROs are integrated into the Group’s strategy and business model through 
structured governance and sustainability processes. The following section outlines the current and anticipated effects of the se IROs, the Group’s planned 
responses, and how these impacts affect people and the environment across the value chain. 
In the reporting period, three material risks (see Decarbonization, Own workforce, and Corporate culture) were identified through the DMA, none of which 
had material negative or positive impacts on the TRATON GROUP’s financial position.  
Looking ahead, TRATON anticipates that initiatives related to decarbonization and circularity may influence future investment decisions and product devel-
opment. Additionally, regulatory changes and evolving stakeholder expectations are expected to increase  the relevance of certain IROs over time. Key 
strategic levers include, among others, electrification, renewable energy sourcing, reducing resource consumption and waste, and human rights due dili-
gence. The tracking of progress and the establishment of targets are currently managed at brand level rather than at Group level.  
Material impacts identified by the TRATON GROUP affect both people and the environment across the entire value chain. These i mpacts are considered in 
the Group’s strategic planning and are integrated into the sustainability strategy. From a people perspect ive, the Group takes health and safety risks for 
employees and value chain workers into account. Managing these impacts is fundamental to TRATON’s business model: safe and fa ir working conditions 
underpin a skilled workforce, which is essential for competi tiveness and innovation (see Own workforce – Approaches and policies). Material risks such as 
staff turnover and safety issues are addressed through Group -wide policies and targeted actions (see Own workforce — Actions). Thus, workforce impacts 
are embedded in TRATON’s sustainability governance and strategic decision -making (see Sustainability governance and Double materiality assessment).

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and Independent  
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 Sustainability 
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 Further 
Information 
 
 
Road safety also plays a key role: it protects the lives and health of road users and supports the safe transportation of commercial goods. For TRATON, road 
safety means taking social and economic responsibility. It is therefore an integral part of vehicle development. 
There are also human rights concerns related to sourcing, as well as community impacts arising from operations and product us e. From an environmental 
perspective, the TRATON GROUP is aware that the use of its products, the consumption of resources, the environmental impacts associated with production 
and logistics, and waste generation can lead to greenhouse gas emissions and potentially contribute to biodiversity loss. These material impacts are closely 
connected to the company’s sustainability strategy, which prioritizes decarbonization, circularity, and human rights. Insights from the DMA inform product 
innovation, supply chain management, and stakeholder engagement. Impact assessments are conducted across short-, medium-, and long-term planning 
horizons to ensure that strategic decisions are aligned with the sustainability goals.  
Sustainability governance 
Sustainability management process 
In the TRATON GROUP, the management and oversight of IROs are embedded in a structured and cross -functional governance framework to ensure ac-
countability, integration, and continuous improvement across all brands and internal functions. 
Dedicated controls and procedures for managing IROs: TRATON applies a Sustainability Management Model consisting of five interconnected steps that 
guide the identification, management, and integration of IROs: 
1. Prioritize and Commit:  Material IROs are identified through stakeholder engagement and materiality assessments. These inform strategic commit-
ments and action plans at both Group and brand levels. Actions, requirements, and targets are defined based on identified pri orities. These are aligned 
with global frameworks such as the Science Based Targets initiative (SBTi), with validated climate goals already in place for  Scania and MAN. Feedback 
loops enable adjustments and improvements based on the insights gained. 
2. Plan: Dedicated controls and procedures guide the definition of targeted actions, requirements and objectives. These are tailored to both brand-specific 
and Group-wide needs, ensuring alignment with strategic sustainability goals. The Group’s management accompanies sustainability target-setting and 
its progress through weekly meetings of the Sustainability Leadership Group, which includes the Chief Sustainability Officer and sustainability managers 
from each brand. Cross -functional collaboration on joint im pact areas — Decarbonization, Circularity, and Human Rights  — serves to guide resource 
allocation and the strategic focus. 
3. Integrate: Sustainability considerations are embedded into operational and strategic decision -making across all functions — such as product develop-
ment, procurement, HR, and strategy — ensuring that IROs are managed as part of core business activities. 
4. Monitor and Learn: Governance structures within each function support continuous learning and performance tracking. Brand-level governance struc-
tures ensure sustainability targets are contextually relevant and operationally embedded. Monitoring mechanisms within each f unction track progress 
against defined targets and feed into Group -level reporting and strategy refinement. This integrated and collaborative approach ensures that IROs are 
not siloed but are part of the transformation of TRATON towards sustainable transportation.  
5. Enable Communication: Transparent internal and external communication reinforces credibility and stakeholder trust. This includes reporting mecha-
nisms that support open dialog and accountability across the organization.

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and Independent  
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 Sustainability 
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 Further 
Information 
 
 
Management of sustainability issues and IROs identified in the DMA is organized through various committees, working groups, and reporting streams. This 
is designed to ensure a coordinated approach and the involvement of all relevant parties. The central Su stainability function at TRATON reports directly to 
the Chief Executive Officer and the other Executive Board members via the TRATON Sustainability Board and is responsible for coordinating sustainability 
management at TRATON. Developing TRATON’s sustainab ility strategy is a cross -functional task with responsibilities embedded both in several central 
TRATON functions and at the level of the brands. 
– The TRATON Sustainability Board (TSB) consists of the Executive Board, the Chief Purchasing Officer, the Head of Production &  Logistics, the Chief Sus-
tainability Officer of the TRATON GROUP, the Heads of Sustainability of the brands and the TRATON GROUP’s Head of ESG. The TSB sets the direction 
and ambition level and approves commitments, group targets, and binding regulations. It also monitors how the IROs identified  through the DMA are 
managed. New initiatives, actions and commitments, as well as the DMA, receive final approval from the TSB and at the level of each brand. The TSB held 
four meetings in 2025 and approved in particular the material impact, risks, and opportunities of the DMA. The outcomes of th e TSB were documented 
through meeting minutes, signed by the CEO and the Chief Sustainability Officer. 
– The Sustainability Leadership Group (SLG) consists of the Heads of Sustainability at the TRATON GROUP and all brands. The SLG  acts as the responsible 
interface to the brand sustainability functions. It aligns decisions with relevant Group, entity, and bran d functions and can approve non -binding docu-
ments. The SLG is responsible for all materials developed for the TSB, informing the TSB, and implementing the decisions made by the TSB. Progress and 
deviations are monitored on a regular basis, both on Group an d brand level. Each brand within the TRATON GROUP is solely responsible for the imple-
mentation of approved initiatives at the brand level. 
– The Group Sustainability Alignment Meeting (GSAM) consists of the Heads of Sustainability at the TRATON GROUP and all brands and relevant repre-
sentatives of TRATON functions. All commitments, action areas, targets, binding, and non -binding regulations are aligned in GSAM before being pre-
sented to the TSB. These decisions are then communicated during TRATON Sustainability Network Meetings, which occur quarterly . These meetings 
serve as an instrument to share information on sustainability topics within the Group. Further communication is shared through relevant channels such 
as the intranet.

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Management Report 
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Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Committees and processes for sustainability management 
 
Responsibility for sustainability also lies with the Executive Board, while the Supervisory Board monitors the activities. Un der German law, the Executive 
Board and Supervisory Board are obliged to conduct an evaluation of all relevant aspects, including sustainability aspects, when making business decisions. 
This ensures that all factors are taken into consideration and that decisions are made with the utmost care and diligence. Fa ilure to do so might result in 
liability risks, as decisions made without proper evaluation might be deemed faulty. The Executive Board is committed to upholding these rules and making 
informed decisions that benefit TRATON SE and its stakeholders. Fundamental cornerstones of corporate governance, such as the  Code of Conduct for 
Employees and related procedures, are created and supervised respectively with their involvement. In addition, the Audit Committee is regularly informed 
about the progress of CSRD reporting. The Chairman of the Audit Committee then reports directly to the S upervisory Board based on the discussions and 
outcomes of these meetings.  
In addition to the sustainability management structure, the Governance, Risk, and Compliance (GRC) organization plays a criti cal role in ensuring integrity 
across the TRATON GROUP. Managed by the Head of GRC/Chief Compliance Officer, the organization repor ts directly to the Chairman of the Executive 
Board and the Audit Committee. The GRC organization oversees compliance, integrity, risk management, and data protection throughout the Group.

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299  TRATON GROUP 2025 Annual Report 
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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Overarching management policies for sustainability 
The TRATON GROUP has overarching policies that provide a foundation for the overall management processes and apply to all sustainability matters. These 
policies ensure a consistent and integrated approach to decision-making on material sustainability measures across the TRATON GROUP. The overarching 
policies are outlined in the following sections. In addition to this, the TRATON GROUP has policies that relate to specific sustainability matters. These topic-
specific policies are presented in detail in the relevant sections on the topics within this sustainability report. 
General management process for TRATON GROUP policies 
TRATON has implemented a process for developing, implementing, and monitoring policies on Group -level. This process applies to all Group policies de-
scribed throughout the report, which are clearly labeled as such. Where policies other than Group policies are described, such as guidelines or frameworks, 
their individual management processes are described. 
Group policies regulate substantial topics, thereby protecting employees and the organization, avoiding risks, but also securing the Group’s reputation and 
assets. Topics that do not relate to any of these categories may be managed through other types of policies or processes. 
From 2025 and based on the new TRATON GROUP policy Policy Management, it is possible and intended to have common TRATON GROUP policies applying 
to all TRATON brands and entities. Policy Management requires the mandatory involvement of all brands based on a co -creation approach. The respective 
brand topic owners contribute their brands’ perspectives and coordinate with stakeholders within their brands. 
Once a new Group policy has been created and checked regarding applicable quality standards, it is submitted to the TRATON Policy Committee to conclude 
sufficient involvement of the brands and fulfillment of quality standards. This preapproval qualifies fo r requesting final approval by TRATON SE Executive 
Board, which is the most senior level accountable for the implementation of the policy. After approval, the policy coordinato rs ensure publication via the 
TRATON intranet. The policy coordinators submit the approved policy documents to their equivalents at brand or entity level and request implementation 
within a given time frame. If needed for safeguarding the implementation or compliance, training and guidance are provided fo r relevant target groups of 
the policies. If applicable, the brands’ policy coordinators publish equivalent policies on the respective topic and  report the implementation status to 
TRATON quarterly.  
In place of the general policies of the TRATON GROUP, corporate policies that apply exclusively to TRATON SE may be issued. These define minimum stan-
dards and requirements for TRATON brands and companies. The TRATON brands implement requirements by issuing own governing documents or adopt-
ing the TRATON SE company policy. Brands can also issue further brand-governing documents that apply to their subsidiaries in case of need. 
Guided by Policy Management, policy owners must regularly review their TRATON GROUP policies to evaluate whether they need to  be updated. Further-
more, they must assess the need for an amendment of existing regulations or the introduction of new ones as soo n as relevant parameters change. The 
Group’s corporate audit department conducts audits of topics or processes based on its assessments and planning. It utilizes applicable policies and related 
governing documents for such audits.  
As of the reporting date, the policies for policy management, internal investigations, and sustainability management had been  adopted as Group policies 
of TRATON. The revision of further policies for inclusion in the Group standards of TRATON is currently in preparation.

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Management Report 
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Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Overarching policies 
Name of policy  Key contents and objective  Scope  
Responsible organizational level 
and monitoring process  
Availability of the policy 
for stakeholders 
TRATON sustainability 
management  
(Group policy) 
 In 2024, the TRATON GROUP started developing the TRATON 
sustainability management Group policy, which was approved by the 
Executive Board in October 2025. Its purpose is to enable the TRATON 
GROUP to translate its sustainability purpose and ambitions into action 
and results. The policy enables TRATON to set its own ambitions and 
priorities while also meeting stakeholders’ expectations and requirements. 
This policy defines the sustainability management model, the governance 
structure, and the roles and responsibilities for ensuring cross-brand 
collaboration at TRATON in terms of sustainability. In line with the nature 
of the policy, TRATON’s sustainability management has neither a defined 
ambition level nor a reference period against which progress can be 
benchmarked. 
 TRATON GROUP  The most senior level at the 
TRATON GROUP that is 
accountable for this policy is the 
Chief Sustainability Officer. 
TRATON does not currently track 
the effectiveness of this policy, 
though the policy provides a 
foundation for actionable impact 
and integration. 
 Access via intranet 
TRATON sustainability 
management 
(guideline) 
 The TRATON GROUP’s sustainability management is designed to drive 
transformative change by embedding sustainability into core business 
practices. It begins with Prioritize and Commit, where the organization 
identifies its most critical impacts and risks through ongoing engagement 
with stakeholders and the DMA. Once these priorities are clear, TRATON 
makes concrete commitments to act. The next phase, Plan, focuses on 
defining targeted actions, requirements, and objectives that are tailored to 
both brand-specific and Group-wide needs — helping ensure that planned 
efforts align with strategic sustainability goals. In the Integrate phase, 
TRATON moves from intention to action by embedding these 
commitments into daily operations, empowering teams across the 
organization to make decisions that uphold these sustainability ambitions. 
Progress is tracked through Monitor and Learn, relying on existing 
governance structures and the TRATON Sustainability Board to assess 
performance, extract lessons, and refine strategies. Finally, Enable 
Communication reinforces transparency and trust, with open internal and 
external reporting — including a sustainability report — serving as a 
cornerstone of credible management. Together, these five pillars form a 
resilient system that not only advances sustainability but unlocks its 
capacity for deep, systemic transformation. In line with the nature of the 
policy, TRATON’s sustainability management guideline has neither a 
defined ambition level nor a reference period against which progress can 
be benchmarked. 
 TRATON GROUP  The most senior level at the 
TRATON GROUP that is 
accountable for the guideline is the 
Chief Sustainability Officer. 
TRATON does not currently track 
the effectiveness of this guideline, 
though the guideline provides a 
foundation for actionable impact 
and integration. 
 Access via intranet 
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 the Group. It serves as a binding framework for all 
employees of all functions in all TRATON GROUP entities 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 Governance in this 
sustainability report 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. The Code of Conduct for Employees addresses human 
 TRATON GROUP  The most senior level at the 
TRATON GROUP that is 
accountable for this policy is the 
Executive Board. 
The Code of Conduct for 
Employees is monitored within the 
standard processes of the Group. 
 Accessible via the 
TRATON GROUP 
website. The brand-
specific versions are 
available on the relevant 
brand websites.

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and Independent  
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 Sustainability 
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 Further 
Information 
 
 
Name of policy  Key contents and objective  Scope  
Responsible organizational level 
and monitoring process  
Availability of the policy 
for stakeholders 
rights, including human trafficking and the use of forced or child labor. 
Each brand has their brand-specific version observing local requirements. 
Code of Conduct for 
Suppliers and Business 
Partners (Group policy) 
 The policy is considered the basis for successful execution of business 
relations between the TRATON GROUP and its partners. 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, 
amongst others 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 Partners, the TRATON 
GROUP has defined its expectations as well as requirements regarding the 
conduct of Suppliers and Business Partners in their corporate activities. 
The sustainability requirements in the Code of Conduct for Suppliers and 
Business Partners are based on various international standards, including 
the UN Global Compact, OECD Guidelines, ILO conventions, and the 
Guiding Principles of the Drive Sustainability Initiative. The TRATON 
GROUP also adheres to internationally agreed standards such as the 
Universal Declaration of Human Rights. The Code of Conduct for suppliers 
and business partners addresses the safety of workers, human trafficking, 
and the use of forced labor or child labor. No ambition level has been 
defined. Each brand has their brand-specific version observing local 
requirements. 
 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. 
 The most senior level at the 
TRATON GROUP that is 
accountable for this policy is the 
Executive Board. To monitor the 
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, such as risk 
assessments or self-assessments by 
the business partner, before 
awarding a new contract and 
throughout the business 
relationship. Some of the related 
actions are described in section 
Responsible supply chain system 
 Accessible via the 
TRATON GROUP 
website. The brand-
specific versions are 
available on the relevant 
brand websites. 
 
Double materiality assessment 
General approach to the double materiality assessment 
The sustainability reporting of the TRATON GROUP is grounded in a DMA aligned with the ESRS requirements. In 2025, the TRATON  GROUP updated its 
DMA. It was carried out at Group-level and in close collaboration with all brands, iterating between Group and brand materiality to come to an aligned result. 
The DMA was approved in line with TRATON’s sustainability governance. This ensured review and verification across all hierarc hical levels. Following the 
review by the Sustainability Leadership Group, it was presented to the Group Sustainability Alignment meeting before its approval by the TRATON Sustain-
ability Board. In the coming years, work will continue towards further maturing and refining the assessment in line with best  practices and new guidance 
across our sustainability topics. The IROs identified as material to the operations and value chain of TRATON have been mapped agains t the disclosure 
requirements listed in the topical ESRS to identify required information for the reporting in 2025. For material I ROs covered by a topical standard, the 
information is disclosed in line with ESRS, while for entity-specific topics, the minimum disclosure requirements are used as a basis for reporting on policies, 
actions, targets, and metrics. For the index of ESRS disclosure requirements covered by this sustainability report, see the section on Disclosure requirements 
covered in the TRATON GROUP Annual Report 2025.

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 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
The updated DMA did not result in any significant change. However, it led to changes to the material topics that are part of the environmental, social, and 
governance standard. This shift is primarily due to an increased materiality threshold compared to t he previous year. More details can be found in section 
Methodology in this section. Material sustainability topics, which comprise further sub -topics, are detailed along with their respective IROs in the Environ-
mental, Social, and Governance sections of this report.  
Material topics of TRATON 
In its DMA, the TRATON GROUP identified and assessed the impacts on the environment and society, as well as the sustainabilit y-related financial risks to 
which it is exposed and the opportunities it leverages. In total, 24 IROs have been assessed as material, comprising four positive impacts, 17 negative impacts, 
three risks, and no opportunities. The outcome of the DMA is shown in the figure below, Overview of material topics.

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Overview of material topics

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304  TRATON GROUP 2025 Annual Report 
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and Independent  
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 Further 
Information 
 
 
For environmental topics, the DMA confirmed that decarbonization, circularity, pollution, and biodiversity and ecosystems are  material to TRATON. Within 
decarbonization, two sub-topics were identified as having material impacts — one within climate change mitigation and another within energy. The assess-
ment of physical climate -related impacts on the company’s assets was informed by a comprehensive analysis conducted across multiple time horizons, 
evaluating the potential effects of climate change. In additi on, a transitional risk related to climate change mitigation was recognized. Other than in the 
previous year, climate change adaptation did not qualify as material.  
Regarding circularity, the DMA identified three distinct impacts: one related to resource inflows, one concerning resource outflows, and one associated with 
waste.  
In the area of pollution, three material impacts were recognized: two pertaining to pollution of air and one to substances of very high concern (SVHC). In the 
previous year, pollution of water as well as microplastics were also identified as material. However, following the reassessment conducted during the report-
ing year’s DMA, it has been determined that, while these issues continue to play a role, they do not qualify as material topics for TRATON.  
Within the topic of biodiversity and ecosystems, a single impact was identified, linked to direct drivers of biodiversity loss.  
For social topics, the assessment reconfirmed that own workforce, workers in the value chain, and affected communities are material to the TRATON GROUP. 
Most of the material topics in these categories are relevant in terms of their impact. However, employe e turnover, productivity losses, and safety issues 
among its own workforce due to adverse working conditions also pose a significant risk to TRATON. For the entity-specific topic of road safety, two impacts 
were identified as material in the DMA: injuries resulting from accidents on the road from our products as a material negative impact and increased safety 
features and driver training as a material positive impact. The sub-topic other work-related rights and privacy did not qualify as a material topic in the 2025 
DMA reassessment, unlike last year. 
For governance topics, the DMA confirmed the categories corporate culture, corruption and bribery, protection of whistleblowers as well as political en-
gagement to be material. However, based on the reporting year’s DMA reassessment, it has been concluded that although managing supplier relationships, 
including payment practices, remains a relevant consideration, it does not meet the threshold for materiality for TRATON.  
Most of the material topics are material from an impact perspective, with only the financial risk of reduced productivity, de creased efficiency, and higher 
employee turnover fostered by a negative corporate culture identified as material. In light of the global operations of the TRATON GROUP and its role as a 
global commercial-vehicle provider, this list is not exhaustive. It highlights the areas in which TRATON may have the greatest impact on people  and the 
environment, as well as the areas in which we are exposed to the most significant financial risks or opportunities.

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305  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Methodology and process 
Methodology 
The TRATON GROUP conducted a DMA across its operations and value chain, integrating both internal and external stakeholder pe rspectives. The process 
included desktop research, expert workshops, and stakeholder engagement through interviews. Internal stakeh olders included cross -functional experts 
from sustainability, decarbonization, and governance teams across the Group. External perspectives were integrated through desktop research and analysis 
of relevant reports and articles. Material IROs were evaluated  using a structured scoring model based on likelihood, severity, and financial magnitude. In 
2024, the TRATON GROUP adopted a conservative approach to the DMA as part of its first ESRS reporting cycle. Following a thorough benchmarking exercise 
with industry peers, consultation with external experts, and consideration of evolving legislative requirements, TRATON decided in the r eporting year to 
raise the materiality threshold. This adjustment reflects a more focused and robust assessment, enabling the TRATO N GROUP to concentrate on the most 
significant sustainability topics. The rise of the threshold did not lead to changes in the DMA process itself. 
No IROs were identified for end-users due to the Group’s B2B model providing logistics services to customers who are not consumers/end-users as defined 
in the ESRS. 
To ensure the reliability of the analysis, strict control mechanisms were introduced: Documentation was stored securely, access was restricted, and complete 
traceability was ensured. Additionally, the results were validated through plausibility checks, ben chmarking against previous assessments and industry 
peers, and expert reviews. This approach ensures that the sustainability strategy of the TRATON GROUP is both stakeholder-informed and data-driven. 
Description of the process to identify and assess material impacts, risks and opportunities 
To assess the materiality of potential and actual impacts, an impact risk score was calculated based on likelihood and severity. The likelihood of each impact 
was rated from 2 to 10, with 2 being unlikely and 10 being a very likely or actual impact. The se verity resulted from the average value of scale, scope, and in 
the case of negative effects, remediability. The severity assessment levels were 0, 2, 3, 5, and 10, with 10 being the most s evere factor (i.e., very high scale, 
global/total scope, and not remediable/reversible). In general, an impact was considered material if the product of its severity and likelihood yielded a risk 
score above 25 — an increase from last year’s threshold of 20.  
To determine financial materiality of potential risks and opportunities for the TRATON GROUP, the likelihood factor described  above, as well as the magni-
tude — amount of the potential loss from a risk or gain from an opportunity  — of the financial impact a nd the severity of the reputational effect were as-
sessed. Magnitude is generally measured as the amount of potential loss from a risk or potential gain from an opportunity. Magnitude and reputation effect 
were assessed in combination, whereby the magnitude had five (0, 1, 3, 5, and 10) and the reputation effect had four evaluation levels (0, 1, 5, and 10). However, 
with a weighting of 75%, the magnitude was significantly more decisive for the assessment of materiality than the reputationa l effect. The sum o f the two 
factors was multiplied by the likelihood factor and the result ultimately determined the materiality. Financial materiality was determined when the analysis 
produced a risk score above 25, reflecting an increase from the previous year’s threshold of 20. In general, areas with a greater positive and negative impact 
on the environment and people are also more likely to represent higher financial risks and opportunities for the TRATON GROUP . Following the evaluation 
of which scores require further input through the confidence score, impact and financial materiality scores were compared.

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306  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Interfaces between DMA and Enterprise Risk Management (ERM) have been defined to combine information gained through both proc esses. The IROs 
identified in the DMA are used as input for the ERM process and the results of the ERM process are considered when updating the DMA. 
Double materiality at a glance 
 
In the assessment of IROs, time horizons as per ESRS 1 are applied by TRATON, short -term being the reporting year and medium-term covering one to five 
years. Long-term emerging impacts and risks (beyond five years) have also been identified by TRATON. Some of these, such as negative impacts of climate 
change, are also material in the longer term, but since impacts are already apparent, these have been included as short-term IROs.

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307  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Additional considerations to the double materiality assessment 
Beyond the DMA process for identifying and assessing IROs, for some topical standards additional aspects were considered. 
For the identification of IROs and dependencies related to water and marine resources, as well as biodiversity and ecosystems , the TRATON GROUP used 
input from the study conducted by WWF Sweden (World Wildlife Fund) (see Biodiversity). The TRATON GROUP conducted a human rights salience assess-
ment in 2024, which was considered during the DMA to assess the impact on human rights across the entire value chain.  
Beyond the process for identifying and assessing IROs, the TRATON GROUP has not conducted a structured and complete screening of its assets, sites, and 
business activities to identify IROs related to decarbonization, circularity, pollution, or water and marine resources across its value chain. However, an analysis 
of the physical climate risks for our own business activities was carried out under a worst-case scenario (SSP5-8.5). It was conducted in accordance with the 
EU Taxonomy requirements and did not f ully meet the ESRS requirements (see EU Taxonomy). Potential risks in the supply chain cannot be ruled out, as 
this area is not covered by the EU Taxonomy climate risk analysis. Additionally, the current analysis does not include any transition risks.

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308  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Environmental 
Environmental responsibility is a key component of the TRATON GROUP’s sustainability strategy. This section covers four key areas — decarbonization and 
the circular economy as joint impact areas, as well as pollution and biodiversity. It also highlights ho w the Group is striving to achieve a resource -efficient, 
low-emission future. 
Decarbonization 
The TRATON Way Forward strategy (see To Our Shareholders) emphasizes our commitment to sustainability. It serves as a catalyst for change within a global 
industrial and transportation ecosystem undergoing critical transformation. This is reflected through the joint impact area o f decarbonization, through 
which TRATON aims to transform the business model and product design to reduce GHG emissions across the value chain.  
Aligned with this strategy and regulatory requirements, the TRATON GROUP is committed to playing an active role in shaping th e future of transportation 
by driving innovation in cleaner, sustainable mobility solutions. This includes not only reducing emissi ons but also setting new standards for efficiency, 
safety, and circularity in the transportation sector. Achieving these goals requires close collaboration with governments, bu sinesses, customers, and other 
stakeholders. Stringent regulations in the EU are already driving change, and TRATON is advocating for market conditions that support the decarbonization 
of global transportation.  
As of the reporting period, the TRATON GROUP has not yet performed a comprehensive climate resilience analysis. The Group is in a preparatory phase 
focused on establishing the necessary foundations for a structured approach to climate resilience.  
As part of the DMA, TRATON identified material negative impacts and risks in the areas of climate change mitigation and energ y. The following section 
explains the Group’s approach to managing these impacts, in particular related to decarbonization across the entire value chain.  
Impacts, risks and opportunities related to decarbonization 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Climate change mitigation  Actual negative impact   Short-term   Upstream, own operations, and downstream  Significant contribution to climate change, 
especially the use phase of our products 
 Risk   Medium-term   Upstream, own operations, and downstream  Financial risks to business linked to CO2 penalties, 
insufficient BEV volumes and loss of market share 
Energy  Actual negative impact  Long-term  Upstream, own operations, and downstream  Reliance on fossil fuels contributing to climate 
change

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309  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Approaches and policies 
Material IROs that specifically relate to climate change mitigation and energy are managed through the policies described below.  
The TRATON sustainability management policy and the TRATON sustainability management guideline, in conjunction with the sustainability management 
process (see also the Sustainability management process), refer to climate-related financial transition risks for the business in connection with CO2 penalties, 
insufficient BEV volumes, and market share losses. These policies, as well as the Code of Conduct for Suppliers and Business Partners, further relate to the 
actual negative impacts of the transportation industry as a substantial contributor to climate change, especially through the use phase of the Group’s 
products.  
The TRATON GROUP’s Code of Conduct for Suppliers and Business Partners, as well as the respective codes of the brands, encourages the implementation 
of effective measures to reduce air emissions — particularly GHG — that pose risks to human health and the environment. To enhance product and service 
performance, partners are expected to actively reduce emissions along the value chain, for example through greater use of fos sil-free energy. On request, 
suppliers who supply TRATON directly or via the TRATON brands provide product-level data on energy consumption (MWh) and GHG emissions (Scope 1, 2, 
and 3, in CO2-equivalents), enabling the Group to improve its environmental indicators. Partners are further encouraged to adopt science-based targets and 
renewable energy goals aligned with the Paris Climate Agreement, and to commit to a carbon-neutral economy by 2050. Additional details on the Code of 
Conduct for Suppliers and Business Partners can be found below and in the section on Overarching policies. 
Two frameworks further shape TRATON’s decarbonization: The Environmental Compliance Management System (ECMS), which covers al l environmental 
sustainability matters, including decarbonization, circularity, pollution, and biodiversity and, therefore, relates to all environmental IROs, as well as the guide-
lines for renewable and fossil -free electricity, which relate to the actual negative impact of reliance on fossil fuels that is contributing to climate chan ge. 
Both frameworks apply to the entire TRATON GROUP  and are accessible to all affected stakeholders, our employees, via the intranet, or via distribution. 
Further details on the policies can be found in the table below.

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310  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Policies addressing decarbonization 
Name of policy  Key contents and objective  Scope  
Responsible organizational 
level and monitoring process  
Availability of the policy 
for stakeholders  Further Information 
ECMS  
(Group policy) 
 The ECMS directs all TRATON GROUP entities to address 
environmental management through all stages of their 
operations and the life cycle of their products and services with 
the goal of minimizing the environmental impact. By integrating 
compliance aspects into environmental management, the 
TRATON GROUP ensures conformity with applicable regulations, 
uncovers possible misconduct, and prevents it in the future. The 
policy defines the minimum requirements for operating 
organizations to implement the ECMS, while providing flexibility 
to tailor these requirements to the brands’ specific business 
needs. It outlines what is necessary for effective environmental 
compliance management, without prescribing how it should be 
carried out. In this way, it empowers each organization, 
regardless of size, location, range of activities, or degree of 
regulation, to identify, assess, and manage environmental 
aspects and risks. 
The ECMS ambition level is 100% coverage of all TRATON entities 
within the Group’s general compliance framework. The reference 
period for measuring progress is 2022. 
In line with the risk-based approach, this Group policy is divided 
into nine core premises: leadership and commitment; 
responsibility and accountability; compliance obligations; 
managing environmental aspects, risks, and opportunities; 
improving performance; awareness and competence; 
stakeholder dialog; evaluating performance; and managing non-
compliance. 
 TRATON 
GROUP 
 The most senior level at the 
TRATON GROUP that is 
accountable for this policy is 
the Executive Board. The policy 
is reviewed and updated if 
necessary. The effectiveness of 
the ECMS is tracked by 
evaluating risks, incidents, and 
audit findings from both 
internal and external audits 
conducted under ISO 
14001:2015. These findings are 
reported annually by the 
brands and subsequently 
presented to the Executive 
Board as part of the annual 
management review. 
 Access via intranet  This policy is aligned with 
internationally recognized 
standards, e.g., the ISO 
14001:2015 and ISO 
19011:2018, to enhance 
environmental compliance 
across the life cycle of 
products and services. 
Guidelines for 
renewable and 
fossil free 
electricity 
 The guidelines for renewable and fossil-free electricity outline the 
commitment of the TRATON GROUP to reducing GHG emissions 
by transitioning to renewable and fossil-free electricity sources 
throughout the value chain. Renewable electricity sources such 
as wind, solar, sustainable hydropower, certified biomass, 
geothermal, and marine energy are preferable. While nuclear 
power is considered a fossil-free option, it is only acceptable 
when renewable options are unavailable due to business, 
infrastructural, or regulatory constraints. The policy prioritizes on-
site electricity generation, followed by off-site generation 
through investments in renewable projects and contractual 
solutions for renewable energy procurement. Wherever possible, 
electricity from renewable sources should be sourced within the 
same interconnected grid, enhancing the local impact and 
reliability of renewable electricity use. Exceptions are made only 
when renewable energy sources are inaccessible, in which case 
nuclear power may be temporarily used with prior consultation 
from the TRATON Energy department. 
The policy does not provide for either a fixed ambition level or a 
reference period for measuring progress. 
 
 TRATON 
GROUP 
 The most senior level at the 
TRATON GROUP that is 
accountable for the guidelines 
is the Chief Sustainability 
Officer of TRATON GROUP. 
The guidelines are reviewed 
and updated if necessary. For 
monitoring purposes and to 
track the effectiveness of these 
guidelines, a uniform reporting 
system is planned for all sites 
across the brands and the 
entire TRATON GROUP. 
Compliance and transparency 
are ensured through third-party 
audits, which also prevent 
double counting of renewable 
energy attributes. 
 These guidelines are 
distributed to all TRATON 
brands and are scheduled 
for integration into the 
Group’s overarching 
sustainability 
documentation. 
 The criteria for 
implementation of these 
guidelines are aligned with 
Scope 2 Guidance of the 
GHG Protocol and the 
Technical Criteria of the 
Renewable Energy 
Initiative RE100. To support 
implementation, 
particularly for regional 
operational units, the 
TRATON GROUP 
Sustainability department 
offers direct guidance on 
selecting and procuring 
renewable and fossil-free 
electricity.

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311  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Actions 
In the reporting period, the TRATON GROUP did not define concrete Group -wide actions, targets, or a climate transition action plan. The primary reason is 
that the Group is in a preparatory phase focused on establishing the necessary foundations for effecti ve decarbonization. This involves identifying the key 
decarbonization levers — strategic mechanisms that outline the pathways for addressing decarbonization — across brands and operations, which is essen-
tial for setting realistic, fact-based targets. TRATON prioritizes building a robust plan that will enable credible, actionable, and measurable targets in subse-
quent reporting periods. There is currently no defined scope of application, binding timeframe, or monitoring for the defined levers. 
GHG footprint of the TRATON GROUP 
 
TRATON developed forecasts for GHG emissions from its own operations (Scope 1 and 2) and the vehicle use phase (Scope 3, Category 11). The analysis shows 
that emissions from the use phase account for the predominant share of total emissions, at about 97%. In light of this, the electrification of the product 
portfolio is the key pathway to reducing emissions. A detailed breakdown of total emissions reveals that 76% are attributable to the use phase of trucks, 8% 
to the use of buses, 1% to the use of va ns, and 12% to the use of external engines in customer applications. Conversely, emissions from own operations 
represent only 0.1% of the total, with supply chain activities contributing 2%.

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312  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Although the footprint from its own operations is comparatively small (0.1%), TRATON is committed to reducing it. Emissions a re systematically measured 
across all sites, with individual roadmaps developed for each brand. 
Levers addressing decarbonization in own operations 
Levers  Description 
Renewable electricity  Most of the TRATON GROUP’s European production sites are already utilizing electricity from 
renewable energy sources. The remaining sites are evaluated to transition to renewable 
energy sources in the coming years. 
Electrification and renewable heat  When it comes to electrification and the supply of renewable heat, there are various 
considerations for replacing the existing fossil energy sources. Depending on local 
requirements, geothermal energy, biogas, or hydrogen are being considered. A timeframe by 
which all locations of TRATON will be converted to renewable energy sources for heat supply 
has yet to be defined. 
Electrification and fuel switching  In addition, the electrification and transition to alternative fuels for the own fleet of the 
TRATON GROUP is being driven forward. 
 
About 97% of the TRATON GROUP’s CO 2 emissions occur during the use phase of its products. To address this, the company focuses on three key levers: 
battery-electric vehicles (BEVs) as the primary and most effective means to decarbonize product use, energy -efficient internal combustion engines (ICEs), 
and solutions based on biofuel and biogas for transitional and external applications. These technologies form the foundation of TRATON’s strategy to reduce 
use-phase emissions. 
Levers addressing decarbonization in the use phase 
Levers  Description 
BEV production  The TRATON GROUP has been accelerating its investment in the development and 
production of BEVs to reduce reliance on diesel engines. TRATON is introducing a large range 
of battery-electric trucks and buses to the market, with a focus on long-haul electric solutions 
equipped with fast-charging capabilities.  
The TRATON GROUP further aims to lower the total cost of ownership for electric trucks and 
buses. The brands offer consulting services to fleet operators, helping them evaluate the 
operational savings BEVs can deliver, including reductions in maintenance and fuel costs. 
Improving energy efficiency of internal 
combustion engine vehicles 
 By enhancing the efficiency of ICEs, the TRATON GROUP reduces fuel consumption and GHG 
emissions as it transitions to full electrification. The TRATON GROUP is developing innovative 
combustion technologies to achieve better fuel consumption and lower emissions. Advanced 
engineering and leveraging digital solutions to monitor and adjust engine performance in 
real time, optimizing fuel use based on load and topography, results in more efficient energy 
use and minimized emissions. These innovations enable the TRATON GROUP to deliver 
immediate emission reductions through enhanced ICE vehicle efficiency while advancing 
toward a fully electric future. 
Enabling use of renewable fuels  To enable the use of renewable fuels, the TRATON GROUP is making its vehicles’ engines 
compatible with renewable fuels, such as biodiesel and biogas, which can achieve lower CO 2 
emissions compared to traditional diesel if sustainably sourced biofuels are used.

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313  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
The supply chain accounts for approximately 2% of the TRATON GROUP’s total CO 2 emissions. As part of its decarbonization strategy, the company is in-
creasing the use of recycled materials in manufacturing processes. The Group is working with suppliers to reduce emissions fr om hot spot materials that 
together represent the majority of material-related emissions. Hotspot materials, identified through Life Cycle Assessment (LCA) at the vehicle level, account 
for up to 80% of supply chain carbon emissions, primarily from steel, aluminum, cast iron, and battery cells. In the course of reducing its emissions, TRATON 
is targeting high-impact areas identified through LCAs. 
Levers addressing decarbonization in the supply chain 
Levers  Description 
Use of recycled content in hot spot materials   Recycled materials require significantly less energy to produce compared to virgin materials. 
By integrating these materials into TRATON’s manufacturing processes, the Group directly 
reduces the embedded carbon in its vehicles. Furthermore, recycled content reduces the 
need for resource extraction, minimizes waste, and creates a more resilient and sustainable 
supply chain. 
Sourcing of materials produced with 
renewable energy 
 The production of batteries, steel, aluminum, and cast iron is energy-intensive. By sourcing 
materials produced with renewable energy, the TRATON GROUP can substantially reduce the 
embedded carbon in its materials. 
 
The Group is collaborating with stakeholders across and beyond its value chain to accelerate the transformation to electric mobility. This includes expanding 
charging infrastructure through initiatives like Milence and TRATON Charging Solutions, which aim to make public charging for heavy-duty vehicles acces-
sible across the entire EU. For long -haul and heavy -duty applications, a robust charging network is essential. These activities are supported by strategic 
partnerships, direct investments, and the development of new technologies. Together, these initiatives are paving the way for a more sustainable future in 
transport.  
Levers addressing decarbonization via partnerships 
Levers  Description  
Partnerships for charging infrastructure  TRATON Charging Solutions focuses on simplifying access to the charging infrastructure by providing reliable charging services for 
commercial vehicle operators. The network currently comprises around 150 locations and over 400 charging points across 19 Eur opean 
countries. TRATON Charging Solutions partnered with Hubject in 2023 to align EU charging data standards, enhancing network usability for 
fleet operators and enabling global scalability. 
Additionally, the TRATON GROUP, in partnership with Daimler Truck and Volvo Group, has launched a high -performance charging network in 
Europe through their joint venture, Milence. Joint investments of €500 million have been allocated to install high-performance charging 
points along all major TEN-T corridors — the long-distance, multimodal transportation axes of Europe’s TransEuropean Transport Network, 
helping to ensure that infrastructure development aligns with customer needs and market development. Milence opened its first charging 
hub in the Netherlands in 2023. In 2024, additional hubs were launched in Belgium, Germany, France, and Sweden, followed by I taly, the UK, 
and Spain in 2025. As of 2025, Milence had over 30 operational sites across Europe. Despite growing regulatory support, charging 
infrastructure remains a critical bottleneck to the adoption of EVs. 
Green corridors: together with partners, TRATON develops green corridors — dedicated routes for battery-electric heavy-duty vehicles 
supported by robust charging infrastructure and renewable energy. TRATON launched a pilot project in Brazil and set up a stro ng ecosystem 
of partners supplying the full range of expertise. Further green corridor projects are pl anned in Mexico, Kenya, Poland, and Australia, among 
other countries.

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314  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
In the reporting year, TRATON continued to allocate resources toward reducing CO2 emissions, including investments in battery production, transformation 
of manufacturing lines, and workforce development. These initiatives support the expansion of TRATON’s electrified commercial vehicle portfolio and reflect 
the TRATON GROUP’s strategic commitment to sustainable transportation solutions. The electrification of the product portfolio is the primary contributor 
to decarbonization, which is reflected in the OpEx and CapEx plan. 
In 2025, investments of €51 3 million (previous year: €56 3 million)1 were made for decarbonization -related initiatives. Looking ahead, the Group plans to 
invest an additional €3.1 billion between 2026 and 2030, with a significant share directed toward use-phase decarbonization levers.   
 
1 The metric for 2024 has been updated due to a small adjustment to the underlying allocation methodology.

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315  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Performance 
Energy consumption and mix 
  2025  20241 
Total energy consumption (MWh) 
 
2,388,588  2,439,717 
Total fossil energy consumption (MWh)2 
 
1,309,127  1,372,865 
Fuel consumption from coal and coal products (MWh)  321  293 
Fuel consumption from crude oil and petroleum products (MWh)  408,587  444,787 
Fuel consumption from natural gas (MWh)  569,144  521,875 
Fuel consumption from other fossil sources (MWh)  1,757  3,066 
Consumption of purchased or acquired electricity, heat, steam, and cooling from fossil 
sources (MWh) 
 
329,317  402,844 
Share of fossil sources in total energy consumption (%)  55  56 
Energy consumption from nuclear sources (MWh)  33,368  34,068 
Shares of consumption from nuclear sources in total energy consumption (%)   1  1 
Total renewable energy consumption (MWh)  1,046,094  1,032,784 
Fuel consumption from renewable sources (MWh)3  74,739  80,396 
Consumption of purchased or acquired electricity, heat, steam and cooling from renewable 
sources (MWh) 
 
941,749  925,389 
Consumption of self-generated non-fuel renewable energy (MWh)4  29,606  26,999 
Share of renewable sources in total energy consumption (%)  44  42 
Non-renewable energy production (MWh)5  45,870  4,259 
Renewable energy production (MWh)6  48,226  43,880 
Total energy consumption from activities in high climate impact sectors (MWh)  2,388,588  2,439,717 
1 In addition to the update based on the availability of actual data, the metrics for 2024 were adjusted due to structural changes. 
2 Further disaggregation specifies how much energy is used from coal and coal products, crude oil, and petroleum products, natural gas, other fossil sources or purchased or acquired electricity, heat, steam, 
or cooling from fossil sources. 
3 The data on energy consumption from biomass (including industrial and municipal waste of biological origin), biofuels, biogas, and hydrogen from renewable sources is directly derived from the respec-
tive invoices. 
4 The TRATON GROUP consumes only self-generated, non-fuel renewable solar energy. Meter readings specify the amount produced, consumed, and sold. 
5 Energy production from combined heat and power plants driven by gas burning, and electricity production from diesel burning in test engines and diesel generators. 
6 Energy production from renewable sources, primarily from solar panels for TRATON, and from biomass pellets, calculated using conversion factors based on invoices detailing the mass (kg) of pellets 
purchased or from meters in burning stations if mass data is unavailable.

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316  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
The energy intensity of TRATON is reported as total energy consumption in megawatt hours (MWh) per million euros ( € million) of sales revenue from 
activities in high climate impact sectors. All TRATON GROUP activities are considered to fall within high climate impact sect ors as the Group’s main eco-
nomic activity is the manufacture of commercial vehicles and engines (NACE Code 29.10: Manufacture of motor vehicles). The only exception is financial 
services, which are classified under NACE Section K (Financial  and insurance activities: divisions 64 –66) and therefore not considered high climate impact 
sectors.  
Compared with the previous year, financial services are now excluded from the scope. The prior -period comparative figure was modified accordingly to 
comply with the new methodology. In 2024, total energy consumption from activities in high climate impact sectors of the TRATON GROUP was 53.6 MWh 
per € million of revenue, while in the reporting year this figure is 57.1 MWh per € million. The revenue used to calculate energy intensity, corresponding to 
the Group’s total sales revenue from activities in high climate impact sectors, was €45,541 million in 2024 and €41,864 million in 2025. 
To track and manage energy consumption, environmental coordinators at each brand collect energy usage invoices and record them in their brand-specific 
environmental IT systems. These invoices detail the amount of energy consumed from fossil and renewable sources. The consumption of nuclear energy is 
estimated by multiplying the energy consumption from fossil sources with the country-specific percentage of nuclear energy in the grid, provided from the 
World Nuclear Performance Report. The data in the table above is based on a combination of actual data and estimates. In particular, consumption data for 
the fourth quarter was not yet fully available at the time of reporting and was therefore calculated using established estimation methods.

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317  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
GHG emissions 
GHG emissions (in tCO2eq) 
  2025  20241 
Scope 1 GHG emissions      
Gross Scope 1 greenhouse gas emissions (tCO2eq)  232,441  231,219 
Percentage of Scope 2 GHG emissions from regulated emission trading schemes (%) 2  7  7 
Scope 2 GHG emissions     
Gross location-based Scope 2 greenhouse gas emissions (tCO 2eq)  320,688  323,810 
Gross market-based Scope 2 greenhouse gas emissions (tCO 2eq)3  105,188  138,025 
Scope 1 & 2 GHG emissions (market-based)  337,628  369,244 
Significant scope 3 GHG emissions     
Total gross indirect (Scope 3) GHG emissions (tCO2eq)  305,749,409  359,148,382 
Purchased goods and services (tCO2eq)4  6,818,270  7,324,861 
Capital goods (tCO2eq)5  684,440  654,381 
Fuel and energy-related activities (tCO2eq)6  111,173  121,322 
Upstream transportation and distribution (tCO2eq)7  846,222  1,133,269 
Waste generated in operations (tCO2eq)8  593,407  397,038 
Business travel (tCO2eq)9  80,938  86,700 
Employee commuting (tCO2eq)10  60,436  61,619 
Upstream leased assets (tCO2eq)11  –  – 
Downstream transportation (tCO2eq)12  –  – 
Processing of sold products (CO2eq)13  199,587  197,938 
Use of sold products (tCO2eq)14  295,593,530  348,263,895 
End-of-life treatment of sold products (tCO 2eq)15  465,374  606,022 
Downstream leased assets (tCO2eq)16  –  – 
Franchises (tCO2eq)17  287,139  292,358 
Investments (tCO2eq)18  8,893  8,981 
Total GHG emissions     
Total GHG emissions (location-based) (tCO2eq)  306,302,538  359,703,411 
Total GHG emissions (market-based) (tCO2eq)  306,087,037  359,517,627 
1 In addition to the update based on the availability of actual data, the metrics for 2024 were adjusted due to structural changes. 
2 Percentage is calculated with an online tool from the German Emissions Trading Authority (DEHSt) at the Federal Environment Agency. 
3 Location-based emission factors were used for individual sites for which no market-based emission factors are available.

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318  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
4 Purchased goods = volume of vehicle and components * weight of vehicle and components * kgCO2eq per reference vehicle or components. Purchased 
services (IT, supplies, packaging, sales marketing) are scoped out due to their minimal impact (<1%). Scania groups similar products together into refer-
ence groups, using production volumes and an in-house Material Data System (SMDS) with external Life Cycle Assessment (LCA) data. International 
groups similar products together into reference groups, based on the number of vehicles sold, and uses external LCA data. MAN applies LCAs for vehicle 
categories using sales data, average weight calculations, and expert estimates. VWTB calculates emissions from component volumes, applying Ecoin-
vent emission factors based on engineering calculations. 
5 Capital goods = monetary input * emission factor. Monetary input based on values from Financial Accounting and Cash Transaction System (FACTS). 
Emission factors are used from GHG protocol. Factors are converted into kgCO2/€ based on world bank data and adjusted for inflation based on the 
German Federal Office for statistics. For International, ClimatePartner calculates this datapoint. 
6 Fuel and energy-related activities = Sum of (emission factor for fuel type * fuel consumption for fuel type). The emission factors are taken from 
Volkswagen AG’s internal manual. Additional emission factors are taken from Sphera’s LCA for Experts database. MAN and International use emission 
factors from VDA (German Association of the Automotive Industry). VWTB uses emission factors from Ecoinvent, the International Energy Agency (IEA), 
and the Brazilian Ministry of Energy. The amount of fuel is derived from consumption data and differentiated by fuel type. 
7 Scania and VWTB apply an activity-based calculation method. MAN employs a cost-based approach. Scania and MAN rely on emission factors from the 
Global Logistics Emission Council (GLEC). VWTB uses emission factors from the Department for Environment, Food & Rural Affairs (DEFRA) and the 
Brazilian GHG Protocol Program (PBGHGP). ClimatePartner calculates this data point for International. 
8 Waste generated in operations = Sum of (waste outflow * corresponding emission factor). Scania, MAN and International use emission factors from LCA 
for Experts and the internal manual from Volkswagen AG. Due to the different type of waste operations in South America, VWTB uses emission factors 
from the IPCC. 
9 Flight, train, and car data is collected separately at brand level and multiplied with the respective emission factors. MAN gets its data from BCD Travel 
standard reports for flight emissions. Car rental providers report data on the total annual orders of rented cars. Emissions from train travel are set to zero 
as Deutsche Bahn reports zero CO2 usage. Scania receives its emissions stemming from flight travel from BCD Travel reports. No emissions from train 
transportation are reported for Scania. VWTB calculates the emissions based on emission factors from DEFRA 2021 for flights and from PBGHGP for cars. 
No trains are used in VWTB. ClimatePartner calculates this datapoint for International. 
10 Commuting emissions = Σ number of employees per region * distances * modal split * emission factors. The number of employees is split into regions 
(Europe, North America, South America, Africa, Asia/Pacific, Australia) and direct (production)/indirect (non-production) sector. VWTB uses a calcula-
tion based on primary data since its employees’ main method of commuting is the chartered bus fleet hired by the VWTB. 
11 Upstream leased assets, primarily consisting of vehicles and buildings, are reported under Scope 1 and Scope 2 emissions, as their operational emis-
sions can be determined. 
12 Reported under upstream transportation and distribution. 
13 Only rigids are included in the processing calculation. The emissions are estimated by assuming the processing emissions per vehicle are the same as 
the production emissions per vehicle. Scope 1 and 2 emissions are divided by the total number of vehicles sold/produced and then multiplied by the 
number of rigids sold/produced. 
14 See Scope 3: Methods, assumptions, and emission factors 
15 End-of-life treatment of sold products =Scania and MAN have developed internal life cycle assessment (LCA) models to produce intensity factors 
estimating CO2 emissions associated with end-of-life treatment per kilogram of product group. These intensity factors are then multiplied by the total 
weight of each product group to calculate total end-of-life greenhouse gas (GHG) emissions. International and VWTB follow the model developed by 
Scania. 
16 Reported under use of sold products. 
17 Scania and MAN franchise emissions are calculated based on the average Scope 1 and Scope 2 emissions of a typical commercial site. VWTB and 
International do not have any commercial sites in scope for CSRD. 
18 Scania calculate this datapoint in two steps. Investments are prioritized by importance, selecting the top ten for evaluation. Scope 1 and 2 emissions 
are then calculated based on Scania’s equity interest in these companies, using the formula: Emissions * Interest. Emission data is obtained from the 
companies’ environmental reports or, if not available, through questionnaires sent to the companies. MAN has fewer than ten investments and therefore 
includes all investments in its calculation. VWTB and International do not provide financial resources to external companies.

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319  TRATON GROUP 2025 Annual Report 
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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
The TRATON GROUP annually calculates its greenhouse gas emissions using the Scope 1 to 3 inventory, in accordance with the gu idelines of the interna-
tionally recognized GHG Protocol and the ESRS.  
Scope 1 and 2: Methods, assumptions, and emission factors 
Currently, Scope 1 and Scope 2 emissions are calculated by the brands and aggregated at Group level. 
For Scope 1 emissions, the following emission factors are used: Scania and VWTB apply the Intergovernmental Panel on Climate Change (IPCC) Guidelines. 
MAN relies on the German Association of the Automotive Industry (VDA) guidelines for facilities, as well as the Life Cycle Assessment (LCA) for Experts 
Software and the Joint Research Centre (JRC)  — of the European Commission and its JEC Consortium for vehicles. International uses factors from the Cli-
mate Registry.  
Scope 2 GHG emissions are calculated using both location -based and market-based approaches in alignment with Scope 2 Guidance of the GHG Protocol. 
For US sites, Environmental Protection Agency (EPA) emission factors are applied. For non -US sites, emission factors provided by the International Energy 
Agency (IEA) are used. Regarding the types of contractual instruments used for energy purchases tied to Scope 2 emissions, the TRATON GROUP identifies 
renewable energy purchases based on available contractual instruments recorded in each brand’s environmental management system. Energy with a valid 
instrument is classified as renewable, while energy without documentation is treated as non -renewable. The TRATON GROUP records the following types 
of contractual instruments for renewable energy purchases: Guarantee of Origin (GO), International Renewable Energy Certificate (I -REC), Tradable Instru-
ments for Global Renewables (TIGR), Non-Fungible Digital Certificate (NFD), and Green Electricity Certificate (GEC). All contractual instruments recorded by 
the TRATON GROUP represent unbundled guarantees of origin for renewable energies; no bundled electricity purchases from renew able energies were 
recorded for the reporting year. The share of contractual instruments is calculated as the proportion of purchased electricity, heat, steam, and cooling from 
renewable sources in relation to total purchased energy, reported at TRATON GROUP level. The percentage of contractual instru ments in 2025 was 74.1% 
(previous year: 69.7%). 
Scope 3: Methods, assumptions, and emission factors 
For the reporting year, emissions are covered for all 15 Scope 3 categories, with methodologies and assumptions detailed in an internally maintained hand-
book that is updated annually. However, emissions of some categories are reported together with other categories. Upstream leased assets, primarily vehi-
cles and buildings, are accounted for under Scope 1 and Scope 2 emissions as TRATON has operational control over these assets. Downstream transportation 
and distribution are classified under upstream transpo rtation and distribution (Scope 3 Category 4) as all TRATON brands, except VWTB, outsource these 
services. To maintain a standardized reporting framework, VWTB’s separately calculated data is manually integrated into Scope 3 Category 4. Downstream 
leased assets are reported under Scope 3 Category 11 as CO2-equivalent emissions for all vehicles during their use phase are calculated and included in this 
category, irrespective of whether the vehicles are sold or leased. The emission factors used for calculating Scope 3 emissions are specific to each brand and 
Scope 3 category.  
Emissions from the use phase of sold products represent the major share of the emissions balance sheet of the TRATON GROUP. T he calculation of these 
emissions is divided into two methods based on the product category. The first method applies to the produc t category of trucks and buses, while the 
second method applies to the product category of power solutions and external engines. To calculate emissions for trucks and buses, variables such as the 
number of vehicles, energy consumption, well-to-wheel GHG emission factors, and the driven distance are considered. Each brand applies the same general

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320  TRATON GROUP 2025 Annual Report 
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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
formula by multiplying the values but, due to deviations in product portfolios, each brand calculates the total emissions individually with differently grouped 
vehicle classes. Scania uses its production volume while MAN, International, and VWTB use sales volumes. Scania’s and MAN’s energy consumption values 
are derived by collecting operational data sent from vehicles and are extrapolated based on vehicle group average. The monitored truck fleet is assumed to 
be representative of all vehicles. MAN also use s certificate-based estimates for vehicles that do not deliver operating data. Due to lack of operational data, 
VWTB uses engineering tests and estimations. International collects telematic data and average data when available for each vehicle group. Estimates are 
also used for vehicle groups with no or minimal real-world data available such as vans and BEVs. Scania and MAN derive values of driven distance based on 
a Scania/MAN investigation carried out in 2022 -2023. International sets a value based on shar es of lifetime driven distance per year in percent (profile 
derived from service data). VWTB uses engineering judgement to estimate driven distance. TRATON uses dynamic emission factors  by combining estima-
tions of driven distance shares per year with forec asted emission factors. CO2eq from AdBlue, N 2O, and CH4 are also accounted for in the emission factors. 
Scania applies a well-to-wheel (WtW) factor based on the energy carrier (diesel, gas, electricity), year, and the geographic segment. MAN aggregates differ-
ent geographic groups by energy use share and translates it up once over 80% of total energy is accounted for. In the case of  BEVs, the total energy is 
accounted for in its entirety. VWTB and International are in alignment with Scania’s WtW emission fac tor calculation and data source. Scania and MAN 
calculate CO2eq emissions from external engines by multiplying the estimated lifetime CO2eq emissions per unit by the corresponding number of external 
engines sold. International and VWTB do not sell external engines and therefore do not report emissions for this category. 
Primary data in scope 3 reporting 
When primary data from value chain partners is unavailable for Scope 3 emissions, assumptions, average values, and estimation s are used to approximate 
the emissions. Currently, individual brands within the TRATON GROUP calculate their Scope 3 emissions ind ependently, and the results are subsequently 
aggregated on the Group level. This decentralized approach leads to discrepancies in the individual Scope 3 subcategories, as brands differ, for example, in 
the availability of primary data and the choice of emi ssion factors. Further details on methodological discrepancies can be found in the footnotes to the 
table on Scope 3 disclosures. Applying industry-wide, average emission factors does not account for individual measures taken by specific suppliers, which 
further underscores the challenges of the current approach. There is currently no recognized or standardized method for indica ting the share of primary 
data in Scope 3 as well as measuring the extent of scope 3 GHG emissions measured using inputs from specific activities within the upstream or downstream 
value chain. Recognizing these limitations, TRATON is committed to improving data accuracy and consistency by aligning calcul ation methods across the 
Group. This initiative aims to reduce measurement uncertainty and enhance the reliability of reported emissions data in the future. 
Biogenic carbon emissions 
  2025  2024 
Biogenic CO2 emissions from the combustion or biodegradation of biomass in Scope 1 GHG 
emissions (tCO2eq) 
 
13,605  15,045 
Biogenic CO2 emissions from the combustion or biodegradation of biomass in Scope 2 GHG 
emissions (tCO2eq) 
 
18,643  22,517 
Biogenic CO2 emissions from the combustion or biodegradation of biomass occurring in 
the upstream and downstream value chain under Scope 3 GHG emissions (tCO 2eq) 
 
18,079,249  20,892,806

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Management Report 
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Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
The biogenic CO2 emissions resulting from combustion or biodegradation of biomass are displayed in the table above, categorized by their exclu sion from 
Scope 1, Scope 2, and Scope 3 GHG emissions across the value chain. For reporting, each brand used different emission factors to calculate biogenic Scope 1 
emissions: Scania and VWTB used emission factors from the IPCC Guidelines, while International used those from the Climate Registry. MAN uses emission 
factors from the German Association of the Automotive Industry (VDA) for emissions from facilities and Sphera’s LCA for Experts and JEC emission factors 
for vehicle emissions. For Scope 2 emissions, all brands apply VDA emission factors, which include detailed disclosures on th e biogenic share of fuels used 
in electricity and heat generation. These factors reflect the biomass content specific to each country, allowing the separate identification of biogenic CO 2 
emissions. For Scope 3 emissions, all brands use emission factors from Sphera LCA for Experts. 
GHG emissions intensity 
The table below presents the total GHG emissions calculated using both the location -based and market-based methods, relative to the TRATON GROUP’s 
total net revenue. The net revenue of the TRATON GROUP amounted to €44,052 million in 2025. 
GHG intensity based on net revenue1 
  2025  2024 
Total GHG emissions (location-based) per sales revenue (tCO2eq/€ million)  6,953  7,577 
Total GHG emissions (market-based) per sales revenue (tCO2eq/€ million)  6,948  7,573 
1 To calculate the greenhouse gas (GHG) emissions intensity of TRATON GROUP, the “Sales revenue” line item as reported in the Consolidated Financial Statement is used (see 1. Sales revenue). 
Further information on GHG reporting 
The changes in the metrics are mainly due to changes in vehicle production and vehicle unit sales between the years. The calculations for gross Scopes 1, 2, 
3, and total GHG emissions were not independently validated by an external body. However, recognized methodologies, reporting frameworks, and emission 
factors provided by external organizations such as ClimatePartner, the German Emissions Trading Authority (DEHSt), and other industry-standard references 
were used. However, this does not constitute external validation or confirmation. 
Currently, there are no active carbon removal or storage initiatives integrated into TRATON’s business activities or supply chain. Additionally, no formalized 
internal carbon pricing schemes are currently in place within the TRATON GROUP’s business operations. 
Circularity 
The TRATON GROUP considers circularity as a core component of its sustainability strategy and a joint impact area. In light of the sharp rise in raw material 
consumption, which according to the United Nations’ Global Resource Outlook 2024 is damaging the c limate, biodiversity, and the environment, TRATON 
sees circularity strategies not only as an ecological imperative, but also as an economic opportunity. The TRATON GROUP is wo rking with its brands on a 
circular economy policy that outlines the strategic transition from a linear value chain to a circular life cycle model.

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322  TRATON GROUP 2025 Annual Report 
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Management Report 
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Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
The approach is rooted in a life cycle mindset and considers circular materials, the company’s own business activities, services, and end -of-life processes. 
Four levers have been defined to operationalize circular business approaches: reducing resource consumption and waste; increasing reused, recycled, and 
renewable content in products; op timizing vehicle lifetime and utilization through circular design and services and integrating circularity into business 
models and partnerships.  
Commitments in the Circularity joint impact area 
 
The TRATON GROUP has firmly anchored circularity principles in its governance structure: TRATON’s Sustainability Board makes key decisions and desig-
nates sponsors to drive integration across business processes. This shared commitment across all brands make s circularity a collective responsibility for a 
sustainable transportation ecosystem. Particularly in the case of resource-intensive commercial vehicles, circularity in design is crucial to reducing environ-
mental impacts and ensuring value retention across  the entire life cycle. TRATON is committed to using secondary materials and closed material cycles to 
reduce dependency on finite resources and minimize end-of-life waste.

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323  TRATON GROUP 2025 Annual Report 
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Shareholders 
 Combined  
Management Report 
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Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
As part of the DMA, the Group identified an actual negative impact related to resource inflows, as well as potential negative impacts associated with resource 
outflows and waste. The following section outlines the approach of the TRATON GROUP to managing material impacts related to circularity across the value 
chain. 
Impacts, risks and opportunities related to circularity 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Resources inflows, including 
resource use  
 Actual negative impact  Short-term  Upstream  High virgin and non-renewable resource consumption 
Resource outflows related to 
products and services  
 Potential negative impact  Short-term  Downstream  The improper disposal or recycling of vehicles can contribute to 
landfill waste, increased resource outflows, and the loss of 
valuable resources. 
Waste  Potential negative impact  Short-term  Own operations  Landfill waste and contribution to resource scarcity caused by 
significant waste generation 
 
Approaches and policies 
As a global manufacturer of commercial vehicles, the TRATON GROUP acknowledges its responsibility to foster circularity. Whil e TRATON does not have a 
standalone circular economy policy, the Group is working on aligning circularity efforts to guide decision-making and support the integration of circularity 
across the value chain.  
TRATON circular business model 
TRATON’s circular business model covers the entire life cycle of commercial vehicles. It pursues renewable practices for products, components, and mate-
rials to reduce resource consumption, prolong service life, and minimize environmental impact — from initial design to end-of-life.

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Management Report 
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Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
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 Further 
Information 
 
 
The TRATON GROUP’s circular business model 
 
Circularity begins at the design and engineering stage. As part of the product development process, the TRATON GROUP is working on a common guideline 
for ecodesign, including circular design, to support engineering decisions. This guideline contains princi ples such as circular design, modularity, remanu-
facturing, and material reuse. Each element contributes to reducing resource consumption and extending product life cycles. 
By implementing these principles, the TRATON GROUP is strengthening its competitiveness: it is unlocking potential for sales revenue growth, reducing 
costs for circular services, and preparing for upcoming legal requirements  — in particular, standards for circular designs and end -of-life return and disas-
sembly. At the same time, TRATON is building core competencies for circularity and improving access to green financing. The increased use of recycled and 
renewable components enhances recyclability and promotes the sustainability of vehicles.

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 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
The TRATON Modular System (TMS) acts as a central key element by standardizing components across brands, supporting reuse, enabling scalable reman-
ufacturing processes, simplifying maintenance, and optimizing resource utilization throughout the entire vehicle life cycle. 
TRATON’s service network plays a role in implementing circular practices throughout the use phase of the vehicles. These incl ude repairs of key systems, 
such as drivetrains, to extend vehicle life and enable second -life applications. Remanufacturing plays a central role, by rebuilding components to their 
original specifications. In addition, digital services such as predictive maintenance and fleet optimization could further ex tend vehicle usage and reduce 
environmental impact. TRATON brand Scania supports end-of-life management for heavy-duty commercial vehicles by providing data for disassembly. This 
data includes guidelines for safe draining and disposal of hazardous materials. At the same time, this increases occupational safety.  
Resource inflows of materials and products 
The TRATON GROUP recognizes the increasing complexity of global supply chains and the rising demand for strategic raw materials driven by the transition 
to e-mobility. TRATON is committed to closely monitoring the sourcing of these materials, ensuring comp liance with human rights standards and ethical 
practices throughout the supply chain. For more information, refer to the section Workers in the value chain – Approaches and policies. 
Circularity in products and materials 
The TRATON GROUP is focused on minimizing resource and energy consumption. Initial measures have prioritized batteries, steel , aluminum, and plastics 
as a decarbonization approach. These initiatives lay the foundation for further advancing the Group’s join t impact area and exploring innovative business 
models. 
High-voltage batteries and other key components such as electric drive systems are becoming part of the circular economy due to statutory requirements. 
The raw materials they contain are playing an increasingly important role in climate change mitigation. These materials are not only valuable but also critical 
for ensuring resource security. Maintaining these materials in the circular economy supports the decoupling of production fro m virgin raw material de-
pendency while safeguarding access to resources. Fu rthermore, the extraction and use of these raw materials are associated with emissions and other 
environmental impacts. By reusing battery -grade materials, the TRATON GROUP can mitigate these effects, which could contribute to a reduction in the 
overall CO2 footprint.  
Given the increasing complexity of supply chains and the geopolitical and material availability challenges of recent years, T RATON recognizes the need to 
develop an efficient, Group-wide strategy for material security. This is not yet an active strategy, b ut the plan is to establish a comprehensive raw material 
procurement process aimed at securing critical and strategic raw materials for key components. This approach focuses on strategically relevant raw material 
groups to define, assess, and implement security scenarios. These groups may include battery materials, rare earth elements (REEs), platinum group mate-
rials (PGMs), semiconductor materials, tin, tantalum, tungsten, and gold (3TGs), and mica (a silicate mineral widely used in electronics and industrial appli-
cations). Other critical resources such as magnesium, aluminum, plastics, and copper will also be considered.

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326  TRATON GROUP 2025 Annual Report 
To Our 
Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Policies 
In the DMA, the sustainability matters of resource inflows, resource outflows, and waste were identified as material for the TRATON GROUP. Material impacts 
that specifically relate to these sustainability matters are managed through the policies described below. 
The TRATON sustainability management policy and TRATON sustainability management guideline, in conjunction with the sustainability manag ement 
process, relate to the potential negative impact of landfill waste and contribution to resource scarcity caused by significan t waste generation. The same 
policies and the Code of Conduct for Suppliers and Business Partners address the actual negative impact of high virgin and no n-renewable resource con-
sumption, which is substantial in the transportation supply chain d ue to the reliance on non -renewable resources. Furthermore, the Code of Conduct for 
Suppliers and Business Partners addresses the potential negative impact of improper disposal or recycling of vehicles, which can contribute to landfill 
waste, increased res ource outflows, and the loss of valuable resources. Further information on the above -mentioned policies is available in the section 
Overarching policies. 
Resource efficiency is a fundamental aspect of the Code of Conduct for Suppliers and Business Partners. Partners are expected  to minimize waste, reuse 
resources, recycle materials, and dispose of residuals, including hazardous waste and wastewater, safely and sustainably. These practices should apply across 
development, production, product use, and end -of-life recycling, in compliance with international standards, such as the Basel Convention, and relevant 
local laws. Where technically and economically feasible, partners should use secondary materials, know the recycled content of their products, and provide 
this data to TRATON when requested. They are also encouraged to support circular systems by closing material loops, extending  product lifespans, and 
improving utilization.  
Actions 
In the reporting period, the TRATON GROUP did not yet define concrete Group-wide actions or targets  and does not track the effectiveness of its policies  
for circularity.  
The primary reason is that the Group is in a preparatory phase focused on establishing the necessary foundations for a Group -wide circularity approach. 
This includes identifying key circularity levers across brands and business areas. This is essential for setting realistic, fact-based targets. Circularity levers are 
strategic mechanisms that outline the main pathways for addressing circularity, such as reducing resource consumption, prioritization of the use of recycled 
materials, and optimizing the lifeti me and utilization rate of TRATON’s products. There is currently no defined scope of application, binding timeframe, or 
monitoring for the defined levers. 
The levers are directly aligned with IROs identified in TRATON’s DMA. The sustainability matter of waste aligns with the key lever of reducing resource 
consumption and waste. The three additional key levers align with the sustainability matters of resource inflows, including resource use, and the aspects of 
resource outflows related to products and services. The specific levers are further detailed in the following section, providing a view of their implementation 
and contribution to mitigating negative impacts and enhancing long-term value creation.

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