Årsredovisning 2025

327  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 
 
 
Levers addressing circularity 
Levers  Description 
Reducing resource consumption 
and waste 
 TRATON has committed to using resources more efficiently, minimizing the amount of waste generated, and ultimately reducing r esource 
consumption throughout the entire value chain. TRATON pays particular attention to the use phase of the vehicles it produce s and to its own business 
activities. At TRATON, waste prevention is a corporate value. The brands are constantly searching for more efficient ways to design and produce 
vehicles. By optimizing these processes, we aim to not only make our operations more s ustainable but also improve affordability for our customers. 
Reused, recycled, and renewable 
content 
 TRATON encourages its business partners to prioritize the use of recycled materials and to share recycled content data with t he TRATON GROUP on 
request. Through collaboration, the Group aims to source more sustainable materials and increase the share of re cycled and renewable content in 
TRATON’s products. Achieving this requires strong cross-functional efforts to incorporate reused parts and higher recycled material content into vehicle 
designs. Additionally, TRATON is exploring ways to improve the traceability of material composition across its brands. This initiative aims to support 
more transparent communication around product sustainability. 
Optimizing the lifetime and 
utilization rate 
 To advance lifetime and utilization rates, TRATON focuses on improving product longevity through enhanced durability and repa rability; increasing 
reuse through reconditioning and repurposing parts; and expanding remanufacturing and refurbishing services to  extend the life of components. These 
efforts primarily target the downstream part of the value chain of TRATON, aiming to reduce resource outflow by prolonging pr oduct life.  
A key aspect of the Group’s approach to circularity involves expanding circular services, including remanufacturing, repair, refurbishment, and 
reconditioning. To support these efforts, TRATON has prioritized scaling up remanufacturing services across bran ds through a dedicated cross-brand 
Remanufacturing Task Force. 
The ongoing development of the common modular platform, TMS, plays a significant role in supporting TRATON’s circularity agen da. It contributes to 
the circular economy by facilitating the reuse and refurbishment of standardized components such as engines, transmissions, and electronics. This 
alignment with circular principles enhances maintenance services, improves efficiency, and supports resource conservation.  
Business model and partnerships 
development 
 TRATON is committed to sourcing more renewable and recycled materials and scaling up circular services through essential coll aborations, within the 
Group, along the value chain and beyond.  
TRATON will work on developing further partnerships with suppliers, customers, governments, and even competitors to create a more circular 
transportation system and explore new business models, such as Product as a Service, in partnerships with others.  
Currently, the TRATON GROUP and its brands collaborate with multiple recycling partners in Europe. These partnerships are cru cial in advancing 
sustainable material recovery within TRATON operations. The main business model of the recyclers is to recover cr itical cathode-grade materials, like 
nickel, cobalt, and lithium. 
External advocacy is a key part of our partnership approach. The TRATON GROUP is convinced that the transition to a circular economy is imperative. 
 
Performance 
Resource inflows 
The total weight of vehicles produced by TRATON, including technical and biological materials, amounted to 2,260,894 tons in the reporting year, following 
2,450,218 tons in 2024. This figure is calculated based on either supplier-provided data on the weight of parts or by directly weighing the vehicles. The weight 
data is averaged for each product group and multiplied by the production volume to derive the total value.  
The weight of recycled materials was 557,193 tons, which corresponds to 24.6% of total material usage. In the previous year, the weight of recycled materials 
had been 608,653  tons (24.8%). The total weight of products is broken down into material groups, and the corresponding share of secondary materials  is 
applied. While brands calculate this in slightly different ways due to data availability, the overall approach follows the same principle of material classification

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328  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 
 
 
and reference vehicle analysis.2 The secondary material share is expected to be an accurate representation as the figure is based on industry data. Given the 
potential for a large range in the secondary material share of some materials, the lower percentage has been used for a conservative approach. To enhance 
accuracy in the future, plans are in place to actively request and collect information from suppliers on secondary material r ates when supplying a part to 
TRATON brands. 
Resource outflows 
Products and materials 
TRATON GROUP vehicles are designed and built to remain functional over a long period of time. Their longevity is further enhanced by regular maintenance 
and the repair or replacement of broken parts. However, there is currently no industry -wide standard or  average method for calculating the durability of 
heavy-duty vehicles. Additionally, the durability of such vehicles is influenced not only by their design and construction but also by downstream factors such 
as intensity of use, geographic conditions, and  the frequency of repairs and servicing. As a result, the TRATON GROUP is unable to provide a definitive 
durability figure for its products. 
The TRATON GROUP’s focus on high quality and low repair needs aims to enable the long durability of its vehicles during their  use phase, contributing to 
resource efficiency and sustainability. The exchange parts program is a cornerstone of this approach. I t enables the return of “old parts” by importers and 
national subsidiaries for industrial processing, remanufacturing, or refurbishment, making these components suitable for reuse in other vehicles within the 
Group. Parts that cannot be remanufactured or refurbished are replaced with brand-new components.  
As part of its commitment to circularity, the TRATON GROUP evaluates its vehicles to ensure compliance with international standards and advance sustain-
ability. A recyclability calculation conducted on two 12 -meter Citywide urban buses, one Inter ICE and on e BEV, using the guidelines set out in ISO 
22628:2002, showed a recyclability rate of 91% for both vehicles.  
Additionally, a study of the Group’s heavy-duty truck portfolio, including ICE models TGX, TGS, TGM, TGL, and the BEV truck model eTGS, revealed recyclability 
rates exceeding 85%.  
Waste 
The TRATON GROUP generates diverse waste streams across its production processes. A significant portion consists of scrap met al, metal filings, and met-
alworking fluids from machining operations. Paint waste is a major category, containing residues of organic solvents and other chemical components from 
vehicle painting. Additionally, casting sand from foundries and packaging materials such as cardboard, plastics, and wood are  common waste types. The 
 
2 Scania uses supplier data from the International Material Data System (IMDS) to classify material weights, according to the VDA 231-106 categories, per reference vehicle group. The total material weight is 
calculated by applying production volumes with the reference vehicle groups’ material usage. International and VWTB determine the weight of hotspot materials from purchasing data and supplier/engi-
neering data, respectively, in alignment with VDA 231-106. MAN, without access to granular IMDS data, calculates material distribution based on LCA analyses of reference vehicles. Secondary material shares 
for Scania, VWTB, and International are based on industry association data for metals (VDA categories 1-3), with non-metals assumed to have 0% secondary materials due to limited data availability. MAN has 
developed expert estimations, with supplier input, for hotspot material groups.

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329  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 
 
 
materials present in these waste streams include metals, oil, organic solvents, plastics, sand, and cardboard. Each material requires specific waste manage-
ment strategies to minimize environmental impact and comply with regulations.  
Waste streams and material management 
  2025  2024 
Total waste generated [t]1  524,419  359,415 
Total amount diverted from disposal – non-hazardous: 
 
   
Preparation for reuse [t]  2,328  8,585 
Recycling [t]  283,390  185,081 
Other recovery operations [t]  17,590  30,795 
Total amount directed to disposal – non-hazardous:     
Incineration [t]  8,789  1,954 
Landfill [t]  37,056  57,788 
Other disposal operation [t]  107,269  6,553 
Total amount of hazardous waste [t] 
 
67,996  68,659 
Total amount diverted from disposal - hazardous:     
Preparation for reuse [t]  2,364  4,558 
Recycling [t]  24,816  23,224 
Other recovery operations [t]  19,601  23,333 
Total amount directed to disposal - hazardous:     
Incineration [t]  9,388  1,369 
Landfill [t]  8,408  14,292 
Other disposal operation [t]  3,420  1,883 
Total amount of non-recycled waste [t] 
 
211,520  137,968 
Percentage of non-recycled waste [%]  40  38 
Total amount of radioactive waste [t]  0  0 
1 The increased volume of waste is due to construction activities at our sites

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330  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 
 
 
Pollution 
The TRATON GROUP is aware of the significant role that the transportation industry plays in environmental pollution. Minimizi ng negative environmental 
impacts is essential for protecting ecosystems and human health. The TRATON GROUP brands are working to continuously reduce pollutant emissions and 
phase out harmful substances. The Group -wide research and development teams are working to develop clean technologies and deploy innovative mate-
rials. This enables TRATON to lay the foundation for a successful transition to low-emission solutions and actively contribute to the transformation towards 
cleaner, more sustainable mobility. 
Through the DMA, TRATON identified an actual negative impact and a potential positive impact related to pollution of air, as well as a potential negative 
impact linked to substances of very high concern. No material impacts, risks, or opportunities for oth er sustainability matters were identified in relation to 
pollution, which is why they are not addressed further in this report.  
Impacts, risks and opportunities related to pollution 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Pollution of air  Actual negative impact  Medium- and long-term  Upstream, own operations, 
and downstream 
 Emissions from transportation and manufacturing release pollutants (e.g., 
particulates, nitrogen oxides) that degrade air quality and pose health risks 
 Potential positive impact  Medium-term  Upstream, own operations, 
and downstream 
 Reduction of air pollution by adopting cleaner technologies and systems to 
control emissions 
Substances of very high 
concern 
 Potential negative impact  Short-, medium- and long-
term 
 Own operations  Use of substances of very high concern can harm the environment, workers, 
and customers 
 
Approaches and policies 
As a global manufacturer of commercial vehicles, the TRATON GROUP is aware of its responsibility to reduce environmental impacts along the entire value 
chain. The following section outlines the Group’s approach to managing pollution. 
No policies or coordinated actions are currently in place at Group level that specifically relate to sustainability matters r elating to pollution. There are cur-
rently no plans to introduce such Group-wide policies. Responsibility for these topics lies with the individual brands of the TRATON GROUP. This decentral-
ized structure reflects the brand -specific approach to environmental management in the Group. The TRATON GROUP is assessing the need for a more 
harmonized approach to pollution management across its brands. 
Actions 
In the reporting period, the TRATON GROUP did not define any specific Group -wide actions or targets for combating environmental pollution. Nor are any 
activities or targets currently planned at Group level for the coming years. However, the TRATON brands c ontinued to pursue activities to reduce environ-
mental harm across their own operations in 2025. This included activities to mitigate pollution and implement robust systems to prevent and manage 
potential incidents and emergencies.

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331  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 
Pollution of air 
In 2025, the TRATON GROUP conducted a threshold analysis to identify which pollutants at its production sites exceed the thre sholds defined in the Euro-
pean Pollutant Release and Transfer Register (E-PRTR). 
Three groups of substances were identified whose emissions exceed the defined thresholds: non-methane volatile organic compounds (NMVOCs), nitrogen 
oxides (NOx/NO2), and benzene. 
The TRATON GROUP brands use local emission factors to calculate the pollutants emitted into the air. This approach supports a ccurate recording of emis-
sions and forms the basis for further actions to reduce environmental impacts.  
Pollution of air 
  2025  2024  
Changes over time 
(2024-2025)1 
NMVOC (t)2  993.9  1,165.6  –171.7 
NOx/NO2 (t)3  167.5  216.0  –48.5 
Benzene (t)4  6.3  5.5  +0.8 
1 The changes in the metrics are mainly due to changes in vehicle production and vehicle unit sales between the years. 
2 Volatile Organic Compounds (VOCs — from painting) are calculated from the material balance, with data provided from all production sites. The 
method analyses how many organic solvents are put into the production process, and this is compared with the outflows to air/water. Abatement incin-
erates the solvent, and, in these cases, it is measured to see how much is incinerated. 
3 Nitrogen oxides (NOx/NO2) are calculated at brand level using local emission factors. In combustion engine development emission factors have been 
determined from actual measurements of fuel used. The emission factors are calculated using the amount of fuel purchased, compared with the amount 
of fuel used and considering the type of engine. 
4 Benzene is measured in process ventilation. A sample is taken from several hours of product-based air flow and ventilation and extrapolated to an 
annual value. 
Substances of very high concern 
The TRATON GROUP uses the IMDS (International Material Data System) list of the European Automobile Manufacturers’ Association (ACEA) as the basis for 
managing substances of very high concern (SVHC). This is based on the candidate list of the European Chemicals Agency (ECHA).  
The TRATON GROUP and the operators at the sites of the individual brands always act in accordance with the applicable legal r equirements. The onsite 
technologies are approved by the competent authorities in accordance with these requirements. If SVHCs are used as substances or in mixtures during 
vehicle production, or if they become part of the “vehicle” product during the production process, they are subjected to indi vidual testing and approval by 
internal chemical management processes at brand level. No full quantitative analysis of SVHCs can currently be performed at either brand or Group level.  
There is no measurement method for recording the entire spectrum of all SVHCs, so no data can be collected on these emissions . Regarding the use of 
SVHCs in TRATON GROUP products, lead in starter batteries is by far the most significant substance. Lead acc ounts for approximately 98% of the total

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332  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 
 
 
amount of all SVHCs used in a typical truck. The total amount of lead in starter batteries sold by TRATON in 2025 was 23,922 tons (previous year: 24,780 tons)3. 
The data point “total amount of SVHCs leaving facilities as products” is not considered applicable for TRATON as only “vehicles sold” are considered accord-
ing to the product definition.  
Biodiversity 
Biodiversity is essential to the stability of ecosystems and the sustainability of global supply chains. Protecting this diversity is integral to responsible sourc-
ing, land use, and environmental stewardship. The TRATON GROUP is committed to minimizing its ecological footprint and supporting actions that preserve 
natural habitats, promote regenerative practices, and enhance resilience across the value chain. 
As a commercial vehicle manufacturer, the TRATON GROUP acknowledges that activities across its value chain can affect biodiversity and ecosystems. The 
TRATON GROUP has identified the sustainability matter of direct impact drivers of biodiversity loss as ma terial. No material impacts, risks, or opportunities 
were identified for other biodiversity-related sustainability matters and are therefore not addressed further in this report. The following section outlines the 
TRATON GROUP’s approach to managing material impacts related to biodiversity across the value chain. 
Impacts, risks and opportunities related to biodiversity 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Direct impact drivers of 
biodiversity loss 
 Potential negative impact  Long-term  Upstream and downstream  Support of activities that contribute to biodiversity 
loss 
 
Approaches and policies 
The Group is currently assessing its impacts as well as exposure to biodiversity -related risks and opportunities. TRATON Intends to integrate biodiversity 
considerations into the sustainability strategy in the future. At present, there are no specific poli cies addressing the direct drivers of biodiversity loss at 
Group level. However, the ECMS policy (see Decarbonization) oversees all environmental topics including biodiversity in own operations of TRATON. 
Actions 
As of the reporting period, the TRATON GROUP has not implemented targets or specific Group -wide actions to prevent or mitigate direct drivers of biodi-
versity loss, beyond the activities described under Decarbonization, Circularity, and Pollution. Given the interconnection between biodiversity loss, climate 
change, and pollution, all actions described in these areas contribute indirectly, however, to biodiversity protection. Furth ermore, resource use — particu-
larly the extraction of virgin raw mat erials — can significantly impact ecosystems. Therefore, activities aimed at reducing the consumption of primary re-
sources are considered relevant to biodiversity. 
 
3 The differences in the metrics are mainly due to changes in vehicle production and vehicle unit sales between the years.

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333  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 lack of specific targets and targeted actions is due to the current preparatory phase, in which the TRATON GROUP is focusing on developing fundamen-
tal structures for a systematic approach to biodiversity. 
The TRATON GROUP provided sector -specific data for the nature risk study conducted by the WWF. The study identified significant biodiversity impacts 
across the entire commercial vehicle value chain, from raw material extraction to vehicle production and us e. In addition, new risks associated with the 
transition to electric and alternative powertrains were identified, due in particular to increased demand for critical minerals such as lithium and rare earths. 
These findings mark an important step towards preparing targeted actions and integrating biodiversity aspects into environmental strategies in the future 
to address the impacts on biodiversity and encourage long-term ecological resilience. 
Performance 
The TRATON GROUP conducted an assessment to evaluate whether its production sites are located in or near biodiversity -sensitive areas. The evaluation 
included 32 sites involved in the manufacturing of vehicles, components, and assemblies. 
The TRATON GROUP has defined a radius of 4.5 km for the assessment of production sites located near biodiversity -sensitive areas on the basis of the 
Technical Instructions on Air Quality Control and in line with the industry standard in accordance with the  EU Taxonomy. This radius equates to the height 
of the tallest chimney multiplied by 50. The corresponding protected areas were analyzed by experts using the Kuyua software. 
The analysis revealed that 22 4 TRATON GROUP production sites (a total area of 1,489 ha) are situated within the 4.5 km radius of 7 2 protected areas. The 
status of over 500 protected areas was reviewed as part of this assessment. The evaluation considered protected habitats, species at risk, and those endan-
gered or critically endangered. 
Potential impacts and dependencies were identified using the online tool Exploring Natural Capital, Opportunities, Risks and Exposure (ENCORE). The eval-
uation looked at the sector’s potential impacts on vehicle production and identified the following relevant aspects:  
– Material dependencies: soil and sediment retention, water treatment, regulation of water flow, flood protection, and storm mitigation. 
– Material impacts: disruptions in the value chain (e.g., noise, light) and emissions of toxic and water pollutants. 
There are currently no plans for specific mitigation actions.  
Information on significant sites and biodiversity -sensitive areas, as well as activities and land use at sites near key biodiversity areas, can be found under 
Further information on biodiversity. 
 
4 The increase in the number of sites in or near KBAs compared with the previous year (19) is due to the construction of new sites.

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334  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 
 
 
Social 
Respect for human rights is a guiding principle for the TRATON GROUP and forms the foundation of its approach to social sustainability. This chapter outlines 
how the Group manages material impacts, risks, and opportunities related to four key areas: its ow n workforce, workers in the value chain, road safety, and 
affected communities. These disclosures are linked to the “Human Rights” joint impact area and reflect the Group’s ambition t o contribute to a just transi-
tion. 
Own workforce5  
The attractiveness and innovative strength of an organization is largely dependent on how well it recognizes and leverages the individual capabilities of its 
employees. Especially considering the dynamic shifts shaping today’s workplaces, diversity in empl oyees’ job profiles and qualifications is becoming in-
creasingly important. TRATON relies on qualified, motivated employees, and wants to offer its staff a safe and attractive working environment in which they 
can develop their full potential. In the DMA, the Group identified the following IROs related to its own workforce. 
Impacts, risks and opportunities related to own workforce 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Working conditions  Potential negative impact   Short-term   Own operations  Damage on own workers’ well-being from adverse 
working conditions, discrimination, and poor safety 
practices  
 Risk   Long-term   Own operations  Staff turnover, productivity loss, and safety issues in 
own workforce resulting from adverse working 
conditions 
Equal treatment and 
opportunities for all 
 Potential negative impact  Short-term  Own operations  Negative effects from discrimination in 
employment like unequal training, promotion 
opportunities, pay, and benefits 
 
The material impacts and risk relate to all employees. However, some groups in the TRATON workforce may be more vulnerable to  these risks due to eco-
nomic, political, and social processes of exclusion. These groups could therefore be disproportionately affe cted by the TRATON GROUP’s operations and 
value chain. Vulnerable groups of TRATON’s own workforce may be migrant workers, female workers, temporary workers, minority workers (e.g., linguistic, 
racial, or religious minority), juvenile workers, interns or apprentices, less technically literate groups, marginalized groups, low-income and low-skilled work-
ers with limited literacy. 
 
5 All statistics presented in this report represent an aggregate calculation for the entire TRATON GROUP. They do not reflect the specific figures for individual brands within the Group. In addition, targets 
related to gender representation in management, as outlined in this report, do not apply to TRATON’s US subsidiaries (e.g., International Motors, etc.). Statements in this report apply only if they do not 
violate the applicable law, including the laws and regulations of the United States of America. The ability to achieve these and other goals, targets and aspirations described in this report, either at all or in a 
timely manner, is subject to a variety of factors, including evolving laws, regulations and other demands in the various jurisdictions in which TRATON operates. TRATON may update or rescind the goals, 
targets and commitments described in this report in the future as TRATON deems necessary or appropriate.

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335  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 
 
 
Additionally, the human rights salience assessment (see Stakeholder engagement) has enabled TRATON to identify certain groups within its workforce who 
may be at greater risk of harm, with particular attention given to vulnerable groups. 
The risk analysis of the TRATON GROUP’s own business areas (see Report on opportunities and risks ) has neither identified a risk of incidents of forced or 
compulsory labor nor a risk of incidents of child labor. Therefore, no specific types of operations, countries, or geographies are considered at significant risk. 
Nevertheless, due to the global activities of TRATON, the Group operates in countries with significant social, political, or economic instability, conflict regions, 
or high-risk areas, among others. Such an environment, despite all efforts, could complicate the TRATON GROUP’s commitment to complying with interna-
tional standards around the world. 
Approaches and policies 
General approach to people and culture management 
TRATON’s purpose is: “Transforming Transportation Together. For a sustainable world“. This requires a team of dedicated and passionate individuals working 
collaboratively across the entire TRATON GROUP towards a common objective. The TRATON GROUP employer value proposition (EVP), “be part of some-
thing bigger,” reflects this sentiment. 
The culture foundation of the TRATON GROUP’s corporate values and TRATON’s shared leadership principles (see Corporate culture) provides the necessary 
support for this purpose and EVP. 
Employee representation 
The TRATON GROUP attaches great importance to the participation of its employees and their representatives. Decisions and activities to manage impacts 
are therefore aligned with the perspectives of TRATON’s workforce. This engagement takes place mainly with employee representatives. 
Employee representatives are involved in various bodies at the TRATON GROUP. One such is the TRATON Supervisory Board, which is made up of an equal 
number of shareholder and employee representatives and, hence, enables equal say from both groups in decision-making.  
At Group level, TRATON has two forums  — the Group Works Council ( Konzernbetriebsrat) and the SE Works Council  — that are designed to enable the 
multinational involvement of employee representatives in the European Union. As part of an additional agreement with the SE W orks Council, TRATON 
enables participants to be invited from outside the European Union so that employee representatives from locations around the world can take part in the 
meetings. TRATON conducts at least five SE Works Council meetings and four Group Works Council meetings per year to enable effective communication 
and collaboration across the organization. In addition, the Executive Board and the employee representatives established an e conomic committee held 
twice a year for information on economic matters at the level of the SE Works Council. Subcommittees hold several meetings to discuss matters related to 
Group Industrial Functions.

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336  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 
 
 
Frameworks for employee engagement 
The rights of TRATON’s European employees are governed by the SE Participation Agreement as defined under section 2 (3) and ( 4) of the Act on the 
participation of the employees in a European community (SEBG), in member states of the European Union, and the  European Economic Area. The Chief 
Human Resources Officers (CHROs) and the Group Labor Relations department are responsible for enabling employee engagement on an operational level. 
The strategy on labor standards and working conditions (see table on Policies addressing own workforce ) defines common principles and standards for 
TRATON employees. Further internal agreements include the SE Participation Agreement and the Business and Human Rights Commitment. External com-
mitments comprise e.g., the TRATON Modern Slavery and Human Trafficking Statement, and the commitment to the United Nations Global Compact. Each 
brand is responsible for ensuring execution and compliance with these standards and agreements and is autonomous in shaping t heir individual work 
environment and framework for execution. 
The TRATON GROUP tracks compliance with labor standards through monitoring tools and reporting, such as the reporting for CSR D, for the SE Works 
Council meetings and dialog with the SE Works Council, (e.g., country reports), the TRATON Speak up! Whistleblo wer portal or brand -respective whistle-
blower initiatives, as well as surveys (e.g., annual employee survey). These surveys as well as the SE Works Council meetings are used to assess the effective-
ness of employee engagement. 
At the Group Works Council level, TRATON has established over 20 work agreements covering several topics, including the prope r use of Group -wide IT 
systems and measures to protect employees. At the international level, the Group has implemented several agr eements that enable the involvement of 
employee representatives in decision-making processes. During SE Works Council meetings, a variety of local issues are directly addressed and directed to 
the appropriate individuals within various brands. 
The TRATON GROUP has several initiatives in place to gain insight into the perspectives of people in its own workforce who ma y be particularly vulnerable 
and/or marginalized and to improve inclusion. For instance, the TRATON GROUP has a strategic initiative to improve the engagement of underrepresented 
groups of employees. The SE Works Council representatives for severely disabled employees met twice in the reporting year. Th e TRATON GROUP works 
together to find solutions for integrating people with disabilities into working life by offering them suitable jobs, work aids, or appropriate support measures. 
Frameworks for human rights 
The TRATON GROUP integrates human rights into its compliance management system and respects all applicable regulations in for ce to protect human 
rights as a fundamental and general requirement throughout the world. This is stressed in internal regulations and in the due diligence processes described 
below, where TRATON strives to involve relevant stakeholders. 
TRATON is committed to complying with applicable national and international human rights legislations and, hence, acknowledges the International Bill of 
Human Rights and ha s joined the UN Global Compact where TRATON recognizes the commitment to its principles regarding human rights and environ-
mental protection. TRATON further strives to operate in line with the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multi-
national Enterprises, and international labor standards such as the  International Labour Organization (ILO) Declaration on Fundamental Principles and 
Rights at Work. Furthermore, TRATON acknowledges the following conventions and uses them to guide its actions, where applicab le within the countries 
in which it operates:

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337  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 
 
 
– Minamata Convention on Mercury 
– Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal 
– Stockholm Convention on Persistent Organic Pollutants 
TRATON considers these international conventions and declarations as the basis of its commitment and the way in which business should be conducted. 
As described in the Codes of Conduct (for both the one for Employees as well as the one for Suppliers and Business Partners, see the section on Sustainability 
governance), the TRATON GROUP rejects all kinds of forced or compulsory labor as well as modern slavery and human trafficking. This includes work carried 
out involuntarily due to intimidation, penalty, violence by security forces, or threat of being disadvantaged. Employment relationships are based on voluntary 
participation and can be terminated at any time by the employees of their own free will and within a reasonable period of not ice. The TRATON GROUP 
assumes responsibility for the health and safety of its employ ees and the continuous improvement of their work environment. Child labor is prohibited 
across the entire TRATON GROUP. The ILO determines the minimum age for employment, which must be adhered to. 
The Group has defined clear responsibilities within the organization in the human rights risk management system. Moreover, th e TRATON Human Rights 
Committee (HRC) is a multidisciplinary committee that monitors and tracks the implementation of human rights’  due diligence obligations in the Group. 
The HRC meets regularly and reports directly to the Executive Board. Such reports include the results of risk analysis, the e ffectiveness of preventive and 
remedial measures, and relevant findings from  the complaints procedure. Further, employees are trained on the Code of Conduct for Employees in web -
based and face-to-face training. Moreover, employees receive specific training on business and human rights to provide guidance and raise aware ness of 
the Group’s corporate responsibility for this topic (see Corporate culture). They can address questions on human rights, e.g., via the TRATON Compliance 
helpdesk and receive information on human rights through various communication formats. In addition to general preventive measures, TRATON continu-
ously evaluates and implements measures addressing identified risks. 
The TRATON human rights approach encompasses not only the working conditions of the Group’s own workforce, but also those of workers in the value 
chain. Also covered are other material matters, such as other work -related rights of workers in the value chai n, equal treatment, and opportunities for the 
Group’s own workforce, and affected communities’ economic, social, and cultural rights. 
Human rights risk management 
A central element of the human rights management is the risk analysis. For TRATON’s own operations, an abstract risk analysis was first carried out in 2024. 
Based on the analysis of external sources such as industry studies and country risk indices, abstra ct human rights and environmental risks were identified. 
All relevant entities of the TRATON GROUP were assigned to one of three risk categories. The subsequent concrete risk analysi s included the validation of 
the identified abstract risks and the determination of concrete risks. Following a risk-based approach, risk workshops as well as questionnaires and individ-
ual interviews with topic managers and subject matter experts were used to identify, prioritize, and validate risks. To deepe n its understanding of selected 
risk areas, TRATON began in 2025 to supplement the risk assessment in its own operations by initiating specific “deep-dive” projects. The results of the risk 
assessment are analyzed in the context of our human rights management system and the implemented human rights measures, where potential gaps are 
being addressed by additional measures and controls, if needed.

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338  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 
TRATON has implemented several policies that provide guidance for managing the IROs related to its own workforce. These policies also outline fundamen-
tal principles for the actions. 
The TRATON Policy Statement on Human Rights, the TRATON Strategy on Working Conditions and Labor Standards, the OHS Group Pol icy as well as the 
Code of Conduct for Employees relate to the identified potential negative impact and risk related to the working conditions of TRATON’s own workforce. 
Furthermore, TRATON has several policies in place related to the potential negative impact on the TRATON GROUP’s own workforc e that would occur in 
case of discrimination in employment like unequal training, promotion opportunities, pay, and benefits. Apart  from the Code of Conduct for Employees, 
these policies are the TRATON GROUP Diversity & Inclusion commitment, the TRATON GROUP corporate values, and the TRATON Polic y Statement on Hu-
man Rights. 
The aforementioned policies are described in detail in the Policies addressing own workforce table below. Exceptions are the Code of Conduct for Employees 
and the TRATON GROUP’s corporate values, which are presented in the Sustainability governance section and in the Policies addressing corporate culture 
table in the Corporate culture chapter. 
Policies addressing own workforce 
Name of policy  Key contents and objective  Scope  
Responsible organizational level 
and monitoring process  
Availability of the policy 
for stakeholders  Further Information 
TRATON Policy 
Statement on Human 
Rights 
 The Policy Statement on Human Rights 
outlines the principles on how TRATON wants 
to live up to its commitment to comply with 
applicable national and international human 
rights legislation. It applies to all TRATON 
companies worldwide and is based on 
internationally recognized tools. The principles 
shall be incorporated and inherent in our 
systems and processes. 
 TRATON GROUP 
and its value 
chain 
 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 management of 
TRATON GROUP entities is 
responsible for implementing the 
actions and requirements defined in 
this commitment in their entities. 
 Access via intranet and 
website 
 The policy is based on the UN 
Guiding Principles on 
Business and Human Rights, 
as well as other international 
instruments such as the 
International Labour 
Organization (ILO) 
Declaration on Fundamental 
Principles and Rights at 
Work. 
TRATON Strategy on 
Working Conditions 
and Labor Standards 
 This strategy aims to secure fair working 
conditions and labor standards and is based on 
the TRATON Policy Statement on Human 
Rights and associated standards. It contains 
Group-wide minimum standards for our entire 
workforce considering wages and salaries, 
working hours and rest periods, employment 
contracts as well as social protection. Besides 
the minimum standards, it also describes the 
roles of the Labor Relations Cross-Brand Team, 
the TRATON SE Works council, and the 
TRATON CHRO Team. 
 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. 
 Access via intranet  The policy is based on the 
International Labour 
Standards. To consider the 
interests of key stakeholders, 
the strategy has been aligned 
with the SE Works Council, 
the TRATON CEO, HR board 
members of the brands, labor 
relations representatives, and 
trade unions.

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339  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 
 
 
Name of policy  Key contents and objective  Scope  
Responsible organizational level 
and monitoring process  
Availability of the policy 
for stakeholders  Further Information 
TRATON GROUP OHS 
Policy 
 A Group policy for occupational health and 
safety (OHS) was aligned with all TRATON 
brands and will enter into force in 2026. 
The TRATON GROUP’s goal is to provide safe 
and healthy workplaces to prevent work-
related injury and ill health, and to promote a 
safety and health culture and well-being at 
work. 
The purpose of this policy is to establish holistic 
and effective management of OHS matters in 
the TRATON GROUP. 
 TRATON GROUP  The most senior level at the TRATON 
GROUP that is accountable for this 
policy is the Executive Board. 
 Access via intranet   
TRATON GROUP 
Diversity & Inclusion 
commitment 
 TRATON does not tolerate discrimination on 
grounds of ethnic or national origin, sex, 
gender identity, religion, views, age, disability, 
sexual orientation, skin color, political views, 
social background, or any other characteristics 
protected by law. TRATON embraces diversity, 
actively encourages inclusion, and creates an 
environment that fosters each employee’s 
individuality in the interests of the Group. At 
the TRATON GROUP, diversity and inclusion is 
viewed as central to success and crucial for 
reaching the goals as a company and as a 
responsible employer. The TRATON GROUP 
Diversity and Inclusion commitment is an 
essential component of the “Responsible 
Company” pillar of the TRATON Strategy and 
aligns with the Group’s corporate values. 
Commitments and actions are fundamentally 
anchored through a set of strategies and 
measures across all brands. 
Diversity and inclusion at the TRATON GROUP 
is a long-term strategic approach to safeguard 
future success. TRATON encourages a 
corporate culture that supports the diversity of 
skills, experience, knowledge, and the 
perspectives of the most valuable asset — the 
Group’s employees. 
 TRATON GROUP  The most senior level at the TRATON 
GROUP that is accountable for this 
policy is the Executive Board. 
To support development in line with 
the Diversity & Inclusion 
commitment and enable 
continuous strategic Group 
initiatives and best-practice sharing, 
TRATON established a Group 
diversity and inclusion working 
party with representatives from 
each of the brands across the 
TRATON GROUP. 
TRATON follows up on the success 
of diversity and inclusion initiatives 
through relevant key performance 
indicators such as the 
representation of women in 
management and the 
representation of women in 
management development. 
 Access via intranet and 
website (link: 
https://traton.com/ 
dam/jcr:961d4ca4- 
b778-4b29-8bd8-762e0 
c495427/230221%20%20 
TRATON%20Group%20 
Diversity%20Inclusion%20 
Commitment%20-%20EN 
%20-%20final.pdf)

===== SIDA 340 =====

340  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 
The following section outlines the measures and processes in place to manage material impacts, risks, and opportunities related to own workforce, including 
regular risk analyses, monitoring, and compliance mechanisms to provide a safe, fair, and supportive workplace. 
The TRATON GROUP conducts regular risk analyses to identify, assess, and address potential negative impacts within its busine ss operations and supply 
chain. These analyses prioritize areas such as workers’ well -being, workplace safety, and the prevention of discrimination and adverse working conditions. 
This ensures that timely and effective mitigation measures are taken to uphold ethical standards and support sustainable prac tices. 
The implementation of measures related to working conditions within the TRATON GROUP is overseen by the Group Human Resources  (HR) department. 
In 2025, the following actions were taken regarding working conditions of our own workforce. Regular works counci l meetings, updating the annual em-
ployee survey (MyVoice), and central coordination by the Group Health, Safety, and Security department aim to prevent potenti al negative impacts on the 
well-being of our own workforce due to adverse working conditions, discrimination, and poor safety practices, as well as related identified risks. The actions 
listed in the table below relate to the sustainability matters equal treatment, working conditions, and equal opportunities. 
Actions related to own workforce 
Actions  Description and time horizon  Scope  
Target in 
place  Overall progress in 2025 and how we track effectiveness 
Regular Works 
Council meetings 
 Works Council Meetings take place regularly throughout the year. 
The TRATON Strategy on Working Conditions and Labor Standards 
is coordinated and monitored in collaboration with the Group Works 
Council. Its aim is to improve working conditions for all employees 
of the TRATON GROUP. TRATON supports the employee 
representatives and the corresponding committees, including 
funding for events, translation, interpreters, material preparation, 
and other subsidies. In addition, the Group provides the necessary 
human resources to support the committees, goals, and plans of the 
employee representatives and collective bargaining agreements. 
 European 
entities 
 No  Ongoing process, meeting frequency set by each Works Council 
Group talent 
development 
programs 
 The TRATON GROUP is committed to continuously developing its 
employees to promote their motivation, necessary skills, and 
competencies, with a strong focus on daily learning. The goal is to 
enable self-driven and accessible learning throughout the TRATON 
GROUP, empowering the business in the present to be as successful 
as the future it envisions. In addition to brand-level learning 
initiatives, the Volkswagen Academy, and partnerships with external 
learning providers, the TRATON GROUP has offered talent 
development programs since 2017, covering each of the hierarchical 
levels. The Group talent development programs are held annually or 
bi-annually and are adjusted to meet the evolving needs of the 
organization or to reflect fundamental changes, such as the 
implementation of TRATON’s corporate values. 
 TRATON 
GROUP 
 Yes  The goal is to facilitate cross-brand collaboration among top talents, 
ensure the visibility of talents at Group level, and develop key skills 
aligned with the Group strategy. To track and assess the 
effectiveness of these programs, evaluations are gathered from 
participants on the program content, presenters, and the practical 
application of new knowledge in daily business. This feedback helps 
ensure the programs are aligned with the ongoing needs of the 
organization.

===== SIDA 341 =====

341  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  Description and time horizon  Scope  
Target in 
place  Overall progress in 2025 and how we track effectiveness 
Representation of 
women in Group 
talent development 
programs 
 TRATON endeavors to improve the representation of women in the 
Group talent development programs, with a particular focus on 
professionals, brand managers, brand executives, and Group 
executives, and has taken decisive action to achieve this goal. The 
Group’s initiatives began in 2023 and continued throughout 2025, 
with a commitment to ongoing progress. To drive these 
improvements, we actively engage in communication and follow up 
with brand representatives. 
 TRATON 
GROUP 
 Yes  For more details on the target and progress, see the section on 
Performance below. 
Annual Employee 
Survey (MyVoice) 
 This new employee survey will serve as a crucial method for 
gathering employee views on workplace dynamics, team 
collaboration, and manager relationships. It will provide an overall 
assessment of employee engagement, offering insights from line 
managers up to the TRATON GROUP level on what is working well 
and areas that need further development. This process aims to 
enable continuous improvement at both team and organizational 
levels. Aligned with the TRATON GROUP’s corporate values, TRATON 
Shared leadership principles, which are described in detail in the 
section on Corporate Culture, and the TRATON GROUP Diversity & 
Inclusion commitment, the new survey will be closely tracked from 
2026 onward. 
 TRATON 
GROUP 
 No  The TRATON GROUP made the decision to pause its annual 
employee survey “Stimmungsbarometer”(StiBa) from 2024 to 
prepare for implementing a new group-wide employee survey and 
tool called MyVoice. It was planned to be introduced in 2025 and 
has been postponed to 2026. To facilitate the development and 
implementation of this new survey, both financial and personnel 
support was provided through the HR and IT departments. The 
tracking of this action and its effective implementation is carried out 
by TRATON and the brands, which will follow up on the action plans 
derived from survey results. Each TRATON brand defined its own 
initiatives for 2025, as the Group survey will not be introduced until 
2026. 
D&I Strategy  In 2025, a cross-brand working group updated and sharpened the 
existing diversity and inclusion (D&I) approach based on the 
Diversity & Inclusion Commitment. It thereby established a strategy 
framework that can be also used by the brands and that shows the 
link between strategy and operational initiatives. D&I is an 
important part of company culture and the new D&I strategy also 
shows a clear link to the TRATON Corporate Culture Frameworks. 
 TRATON 
GROUP 
 No  The D&I Strategy was developed and adopted during fall 2025. 
Continuous monitoring of target achievement is carried out by the 
CHROs. The TRATON GROUP shared targets, and future initiatives 
will be updated and steered within the HR Governance model. 
Central coordination 
via Group Health, 
Safety and Security 
department 
 To strengthen group-wide health and safety management, TRATON 
centralized its coordination in a new Group Health, Safety and 
Security department. This Group function leads efforts to unify and 
enhance the topic of health and safety across all brands. This 
coordinated approach is designed to set a new standard for health 
and safety across the TRATON GROUP. 
 TRATON 
GROUP 
 No  A senior expert was appointed with a coordinating function and a 
TRATON GROUP health and safety policy was developed. The policy 
will enter into force in 2026. A collaborative platform for the brands 
supports regular meetings and streamlined collaboration. The 
current brand structures were reviewed and an internal audit with a 
focus on corporate governance and reporting at the level of TRATON 
SE and in two brands was initiated. In addition, an internal process 
to review occupational health and safety (OHS) was established. To 
monitor the effectiveness of OHS approach, progress is reported 
regularly to the CHRO. This reporting enables any necessary 
adjustments to be made, keeping health and safety standards 
aligned with the strategy.

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342  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 
Characteristics of the undertaking’s employees  
112,123 (previous year: 109,826) employees were employed by the TRATON GROUP at the end of 2025.6 
In the reporting year, 9,022 (previous year: 10,271) employees left the TRATON GROUP. The turnover rate was 8.1% (previous ye ar: 9.4%). It is calculated by 
relating the number of departures to the average number of employees in the reporting year. The basis of the calculation is the data from December of the 
previous year to December of the fiscal year of the reportable entities of the Group. The reference basis is the average numb er of employees during this 
period. The following groups are considered in the departures: employees who left TRATON due to dismissal, retirement, death, or at their own request. For 
Scania and MAN, departures to TRATON GROUP entities are included in the total departure numbers. This is due to technical challenges in the system, which 
does not record transfers between TRATON GROUP entities. 
All individuals with an active employment relationship involved in the value -adding process of the TRATON GROUP are included. All metrics are reported 
as headcount in this section and reflect the number of the respective group of employees as of December 31 of the reporting year. 
Number of employees by headcount, broken down by gender 
Gender  
As of December 
31, 2025  
As of December 
31, 2024 
Female  22,923  22,229 
Male  89,170  87,564 
Other  2  0 
Not disclosed  28  33 
Total  112,123  109,826 
 
Number of employees by headcount, broken down by country 
Country1 
 As of December 
31, 2025  
As of December 
31, 2024 
Germany  21,292  21,239 
Sweden  22,688  22,570 
USA  14,386  15,378 
1 Only countries with more than 10% of total headcount mentioned 
 
6 In the Human Resources section of the Annual Financial Statements, the total workforce is also reported as headcount, but based on the annual average. By contrast, the headcount reported in the sus-
tainability report reflects the total workforce as of December 31, 2025.

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343  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 
 
 
Number of employees by headcount, broken down by gender and employment relationship 
 
 Female  Male  Other  Not disclosed  Total 
 2025  2024  2025  2024  2025  2024  2025  2024  2025  2024 
Number of employees1  22,923  22,229  89,170  87,564  2  0  28  33  112,123  109,826 
Number of permanent employees  21,928  20,742  86,222  83,497  2  0  28  33  108,180  104,272 
Number of temporary employees  995  1,487  2,948  4,067  0  0  0  0  3,943  5,554 
Number of non-guaranteed hours 
employees2 
 
0  0  0  0  0  0  0  0  0  0 
1 All persons with an active employment relationship involved in the value-adding process of TRATON are included, such as top management, those in the passive phase of partial early retirement (ATZ), and 
apprentices. Excluded are all forms of dormant employment, such as employees on parental leave as well as marginal employment, employees in academic training temporary external personnel and self-
employed individuals. 
2 Non-guaranteed hours employees are employed without a guarantee of a minimum or fixed number of working hours. 
Characteristics of non-employees in the undertaking’s own workforce 
As of December 31, 2025, there were a total of 5,335 (previous year: 5,127) non -employees in the TRATON GROUP’s own workforce. Non-employees include 
temporary external personnel and self-employed people. Temporary external personnel refers to personnel in an employment relationship with a temporary 
employment agency, who are only employed for a limited period and perform the same work as the company’s employees. These personnel are not paid 
directly by TRATON and are therefore not considered employees. Self -employed people work independently to operate business or professional activities 
themselves, as opposed to working for an employer. 
Collective bargaining coverage and social dialog 
TRATON surveys coverage by collective bargaining agreements and social dialog. Collective bargaining refers to negotiations between employers (or their 
organizations) and trade unions (or duly elected worker representatives) to determine working conditions , terms of employment, and regulate relations 
between employers and workers or their organizations. A collective bargaining agreement is a written agreement resulting from these negotiations, cover-
ing conditions of employment such as payment and working hours, and potentially addressing topics like health and safety. In the reporting year, the overall 
percentage of employees covered by collective bargaining agreements was 67% (previous year: 69%7). 
 
7 Excluding International

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344  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 
 
 
Percentage of total employees in the European Economic Area (EEA) covered by collective bargaining agreements and workers’ representatives 
  Collective Bargaining Coverage1  Social Dialog2 
Coverage Rate 
 
Employees – EEA  
(for countries with > 50 employees 
representing > 10% total number of 
employees)  
Workplace representation 
– EEA  
(for countries with > 50 employees 
representing > 10% total number of 
employees) 
  2025  2024  2025  2024 
0 to 19%         
20 to 39%         
40 to 59%         
60 to 79%         
80 to 100%  Germany, Sweden  Germany, Sweden  Germany, Sweden  Germany, Sweden 
1 Coverage includes all employees under a collective bargaining agreement, including those under voluntary extension (e.g., non-union members). An employee covered by multiple agreements is counted 
only once. In countries with trade unions, only employees covered by agreements between the employer and a trade union are considered. 
2 Representatives of the workers duly elected and authorized are those freely elected by the workers, independent of employer control, in accordance with national laws or collective agreements. Their 
functions do not overlap with trade union prerogatives and do not undermine the position of trade unions or their representatives. 
Adequate wages 
To assess whether employees are being paid an adequate wage, an annual reference value is used as a benchmark. Within the EEA , the minimum wage 
serves as the reference value, while outside the EEA the living wage is applied. The source for the reference values is WageIndicator. This is a global research 
initiative that collects and publishes data on wages, cost of living, and labor market conditions. It provides living wage be nchmarks to help organizations 
ensure fair and adequate pay. If there is no applicable minimum wage in an EEA country, comparative values are used that are not lower than the minimum 
wage of a socio-economically similar neighboring country. Almost all employees of the TRATON GROUP received remuneration above the applicable refer-
ence values. In countries where the reference values referred to above were not reached, a case-by-case review was conducted with regard to existing local 
collective bargaining agreements. If the case-by-case review showed compliance with existing local collective bargaining requirements, those employees 
are considered to be adequately remunerated . In Singapore, there are no local collective bargaining requirements within the TRATON GROUP and 19% of 
the workforce (10 employees) fall below the reference value applied. All employees were remunerated in line with existing local legal requirements. 
Representation of women in Group talent development programs (target) 
By increasing the representation of women in the Group talent development programs, TRATON encourages the brands to promote w omen to higher 
management positions based on objective criteria. This is closely connected to the TRATON GROUP diversity and inclusion commitment. The Group’s targets 
for 2025 were to increase the share of women in the High Potential Challenge and Management Excellence Program to 50% and in the Leading the Future 
Program to 35%. The target setting was informed by the actual data of pr evious years since 2017 and the women in management target set out below. The 
CHROs were involved in target setting and inform the brands via the CHRO meeting. TRATON successfully met its targets for the High Potential Challenge, 
Management Excellence, and Leading the Future Programs for the cohorts starting in 2025. Since the Executive Elite Program (EEP) generally follows a two-
year cycle, there was no cohort in 2025, and the EEP will also be paused temporarily in 2026. This is an ongoing goal, and th e proportion of women in the 
talent development program cohorts applies to each respective year, meaning that there is no base value or year.

===== SIDA 345 =====

345  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 
 
 
Representation of women in management (target) 
In the context of the commitment, the TRATON GROUP has set the target of achieving a 28% female management workforce by 2029, with an interim target 
of 24.8% by 2025. TRATON has fulfilled this interim target. In 2025, the TRATON GROUP reassessed its Women in Management target path in light of organ-
izational changes and applicable regulatory requirements for US entities. Updated brand forecasts led the TRATON GROUP to adjust its target for 2029 from 
30% to 28%. The revised goal reiterates the continued commitment to fostering an inclusive working environment. The women in management target 
includes Group Executives, Brand Executives, and Brand Managers and the objective is to increase the proportion of women in a ll three management 
groups. The target is closely connected to the TRATON GROUP diversity and inclusion commitment. To define the target, TRATON relied on workforce data, 
discussions with internal experts, alignment with the Volkswagen Group, and involvement of the Group Works Council. Monitoring and reviewing the target 
is also a collaborative effort that involves TRATON and the Volkswagen Group. 
Diversity metrics 
The following tables show the distribution of employees by age group and gender at the highest management level (by number and percentage). 
Distribution of employees by age group 
Number of employees  2025  2024 
Under 30 years  24,198  25,149 
Percentage of employees under 30 years   22%  23% 
Between 30 and 50 years  60,374  58,365 
Percentage of employees between 30 and 50 years  54%  53% 
Over 50 years  27,551  26,312 
Percentage of employees over 50 years   25%  24%

===== SIDA 346 =====

346  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 
 
 
Gender distribution in number and percentage at top management level 
Number of employees at top management level1  2025  2024 
Female  8  7 
% of total at top management level   18%  16% 
Male  36  37 
% of total at top management level  82%  84% 
Other  0  0 
% of total at top management level  0%  0% 
Not disclosed  0  0 
% of total at top management level  0%  0% 
Total   44  44 
1 Top management level is defined as the Volkswagen Group’s “TMK Group” (Top-Management Kreis Group). 
Health and safety metrics 
84% of employees8 are covered by a company health and safety management system based on legal requirements and/or recognized standards or guide-
lines. In the reporting year, there was one fatality in TRATON’s own operations. 9 This fatality involved a non-employee. Therefore, no fatalities involved em-
ployees of the TRATON GROUP and no fatalities involved other workers.10 In the reporting year, there were 3,331 reportable work-related accidents involving 
employees of the TRATON GROUP, resulting in a rate of 17.8 work-related accidents per 1,000,000 hours worked (TRIR). 
Incidents, complaints, and severe human rights impacts 
During the reporting year, the TRATON GROUP received 1,169 (previous year: 863) hints through the whistleblower channels. The number of reported cases 
has risen compared with the prior-year period, as expected, due to awareness campaigns and whistleblower protection laws in force within Europe. Of these 
cases, six (previous year: 53 11) cases were confirmed as violations related to discrimination and harassment. 13 cases (previous year: nine) cases were con-
firmed as violations related to workforce issues outside of discrimination and harassment. As in the previous year, there wer e no fines, sanctions, or com-
pensation payments related to incidents and complaints about discrimination, including harassment. No (previous year: 0) case s12 were submitted to the 
national contact points for multinational enterprises of the OECD in connection with workforce issues. 
 
8 Based on headcount as reported in table “Number of employees by headcount, broken down by gender.” 
9 The reporting of fatalities resulting from work-related accidents complies with the Group-wide process for reporting fatal accidents and serious incidents. 
10 Other workers include workers in the value chain, if they work on TRATON sites. 
11 The confirmed cases are retrieved from the whistleblower system. In contrast to the 2024 reporting period, reporting in 2025 was based exclusively on the whistleblower system; disciplinary statistics were 
no longer factored into the reporting. The TRATON GROUP measures the total number of incidents of discrimination, including harassment and the number of complaints in its own workforce filed through 
channels to raise concerns, with the Group-wide reporting structure established by the Volkswagen Group in 2019.  
12 TRATON uses the OECD database as data source. The update frequency of this database is uncertain, therefore a case reported at the end of December may not be published on the website immediately.

===== SIDA 347 =====

347  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 
 
 
As in the previous year, during the reporting period, there were no 13 serious incidents related to human rights in connection with the workforce that were 
reported through the whistleblower channels. Therefore, no 14 cases were violations of the UN Guiding Principles on Business and Human Rights, the ILO 
Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises. The fines, sa nctions, and compensation 
payments related to these incidents amount to €0 (previous year: €0). 
Additionally, the same methodology as above is used to measure the total amount of fines, penalties, and compensation for dam ages resulting from com-
plaints. The total amount of fines, penalties, and compensation for severe human rights incidents is also tracked. 
Furthermore, based on the available data, the TRATON GROUP did not face significant fines, penalties, or compensation for dam ages in an amount that 
requires a separate disclosure of those numbers in the consolidated financial statement. 
During the reporting period, one  infringement of human rights protected by the German Supply Chain Due Diligence Act 15 (Lieferkettensorg-
faltspflichtengesetz, LkSG) with regard to the workforce of suppliers in the upstream and downstream value chain was identified (previous year: none). The 
infringement concerned the prohibition on disregarding occupational safety. 
Workers in the value chain 
The TRATON GROUP recognizes its responsibility to uphold labor rights and ethical standards throughout its supply chain. This  section details the Group’s 
policies, risk assessments, and grievance mechanisms related to value chain workers. In the DMA, TRATON identified the following IROs related to workers 
in its value chain.  
Impacts, risks and opportunities related to workers in the value chain 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Working conditions  Potential negative impact  Short-term  Upstream  Impact of adverse working conditions, occupational health and safety 
issues, and denial of freedom of association on workers in the value chain 
Other work-related rights  Potential negative impact  Short-term  Upstream  Potential employment of underage workers and the use of forced labor 
within the value chain 
These IROs are strongly connected to the “Responsible Company” pillar of the TRATON Way Forward strategy and the joint impact  area of human rights. 
Based on the human rights salience assessment, TRATON developed an understanding of how particular value chain workers may be at greater risk of harm.  
The material negative impacts on affected communities identified in the DMA are widespread and do not pertain to specific incidents or business relation-
ships. In the DMA and based on the results of the human rights salience assessment, only workers in the upstream value chain were identified to be poten-
tially impacted materially, with workers in the raw materials supply chain at greater risk of being negatively impacted. Amon g these, the following 
 
13 The methodology described is also used to measure the number of severe human rights incidents connected to the workforce. 
14 The methodology described is also used to measure the cases of non-compliance with the UN Guiding Principles, ILO Declaration, or OECD Guidelines. 
15 The German Act on Corporate Due Diligence Obligations in Supply Chains

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 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
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 Further 
Information 
 
 
particularly vulnerable groups were identified: migrant workers, temporary workers, female workers, trade unions and workers’ representatives, minors, low-
income and low-skilled workers with limited literacy, and individuals from minority ethnic, religious, or language groups. In general, raw material mining in 
certain regions is more at risk of child and forced labor, particularly in cobalt mining sites in the Democratic Republic of the Congo. For more details on the 
human rights salience assessment, see the section on Stakeholder engagement. 
Approaches and policies 
The Group policies — Policy Statement on Human Rights and Code of Conduct for Suppliers and Business Partners  — relate to the potential negative im-
pacts identified within the value chain.  
The TRATON GROUP’s Policy Statement on Human Rights is applicable to own workforce as well as to workers in the value chain a nd is described in the 
section Own workforce. The Group’s Code of Conduct for Suppliers and Business Partners is further detailed in the section Sustainability governance and 
essentially covers all material IROs related to the following topics: elimination of child labor and protection of minors, el imination of forced labor, working 
hours, fair wages, work-life balance, health and safety measures, freedom of association, and collective bargaining. 
Processes for identifying, addressing, and monitoring supplier violations 
To mitigate negative impacts on workers in the value chain, violations of the Code of Conduct for Suppliers and Business Part ners can be identified in the 
case of direct or indirect suppliers through the Supply Chain Grievance Mechanism (SCGM) as part of the complaints procedure and the sustainability rating 
(for more details, refer to the table below describing Actions). In both cases, on-site audits can be used.  
TRATON empowers and upskills its suppliers and business partners in executing corrective actions to effectively address violations and fosters a collabora-
tive environment where both short - and long-term improvements are achieved. Suppliers are actively inv olved in the development of these actions with 
SCGM experts and/or auditors. This allows action to be taken to stop or minimize the breach. In particular, the selection and design of appropriate measures 
weighs up the effort associated with the specific violation and the affected persons in the relevant local context. If necessary, an escalation process can be 
initiated, in which it is possible to block the supplier or business partner.  
The check of the effectiveness of the measures implemented by the supplier or business partner as a result of an on -site audit is carried out by the auditor 
or the responsible brand expert as part of a desktop review or by a further on -site audit. In cases  where a direct supplier or a business partner fails to 
implement the defined measures or does not implement them completely, the defined steps of a multi -stage escalation process are followed. As part of 
this process, if the measures are not implemented e ffectively within the specified period, a new on -site audit can be ordered or, if necessary, the business 
relationships can be suspended. This temporary suspension means that the supplier or business partner is blocked from being r e-awarded a contract. If,  
upon re-examination of the action plan by the auditor or subject matter expert, it is determined that the supplier or business partne r has not corrected the 
violation, the supplier will remain barred from new business. Finally, current and upcoming orders  from the supplier or business partner can be verified 
based on the evidence. 
In the event of specific indications of potential misconduct by employees of TRATON, a business partner, or its business part ners in turn in the context of 
collaboration with TRATON, the Group offers all stakeholders the option of reporting such misconduct  via the TRATON whistleblower system. The Group’s 
approach to addressing negative impacts via the whistleblower system as well as mechanisms in place to protect its users against retaliation is outlined in

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 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
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 Sustainability 
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 Further 
Information 
 
 
the section TRATON’s grievance mechanism. As the complaint channels are available to the public, they are also accessible for all value chain workers as 
well as affected communities. To prevent and detect negative impacts on value chain workers specifically, TRATON requires its suppliers and business part-
ners to establish a grievance mechanism adequate to their business via the Code of Conduct for Suppliers and Business Partner s. The mechanism allows 
for concerns related to business ethics, human rights, or the environment to be raised by both th eir own employees as well as other potentially affected 
people anonymously, confidentially, and without fear of retaliation. The Group’s Code of Conduct for Suppliers and Business P artners further demands 
suppliers and business partners provide their emplo yees with unhindered access to the whistleblower system implemented by TRATON and not perform 
any actions that obstruct, block, or impede access. Suppliers and business partners undertake contractually to pass these obl igations on to their suppliers 
and to ensure, to the extent possible and reasonable, that the obligations are passed on further in the supply chain. Detailed infor mation on how topics 
addressed are monitored and how the effectiveness of the whistleblower system is ensured is presented in the section TRATON’s grievance mechanism. 
As of now, TRATON has not adopted a process to engage directly with workers in the value chain about impacts. Until a process is in place, TRATON integrates 
value-chain workers’ perspectives through external research including reports, papers, and articles  from Non-Governmental Organizations (NGOs), media, 
and other reputable organizations/experts, reflecting affected persons’ perspectives and voices. 
Actions 
Responsible supply chain system 
The TRATON approach to managing supplier relationships largely relies on the Responsible Supply Chain System (ReSC system), which includes preventive 
actions including confirmation of the Code of Conduct for Suppliers and Business Partners, the sustainability rating (S-Rating), training courses for suppliers, 
and the human rights focus system (HRFS), as well as mitigation and remedial action such as the supply chain grievance mechanism (SCGM). In the context 
of the responsible supply chain system policy and  incorporated actions, such as the raw materials due diligence management system (RMDDMS) and the 
HRFS incorporating supplier audits, TRATON, together with the Volkswagen Group has developed an understanding of the extent t o which workers with 
certain char acteristics and workers who work in a specific environment, or perform certain activities may be more affected by impacts. As  the Code of 
Conduct for Suppliers and Business Partners is a standard measure of the ReSC system, the actions relate to the same I ROs as the Code of Conduct for 
Suppliers and Business Partners and therefore cover both sustainability matters, namely working conditions and other work-related rights of workers in the 
value chain.  
The ReSC system includes the following elements, which build on each other: 
– Risk analysis: A regular risk analysis is used to identify potential negative impacts on workers at supplier level. The processes for analyzing risk represent 
the first step of the ReSC system. Based on the risk class determined for certain business models and countrie s, the supplier is assigned a package of 
actions to prevent and mitigate the potential negative impacts identified to enable it to be eligible for the award of contracts. 
– Standard measures: These preventive and reactive actions include confirmation of the Code of Conduct for Suppliers and Business Partners by dire ct 
suppliers, the Supply Chain Grievance Mechanism (SCGM), media screening, the S-Rating, and training for suppliers and employees. 
– Deep-dive measures: These include the human rights focus system (HRFS), the raw materials due diligence management system (RMDDMS), and col-
laboration with external partners to progress the sustainability policy in the supply chain.

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Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
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 Further 
Information

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 Responsibility Statement 
and Independent  
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 Further 
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Actions related to workers in the value chain 
Action  Description and time horizon  Scope  Target in place  
Overall progress in 2025 and 
how we track effectiveness 
Standard measure 
Supply Chain Grievance 
Mechanism  
(SCGM) 
 The SCGM was implemented as part of the ReSC system to systematically 
process reports of risks or violations. It is used to process hints of violations 
of the Code of Conduct for Suppliers and Business Partners by the TRATON 
GROUP’s direct or indirect suppliers. Part of this may also include the 
definition of (remedial) actions once the facts of the case have been 
established and the corresponding conclusions have been made, i.e., via 
ad hoc on-site audits. These audits can identify gaps in supplier 
performance as well as risks at indirect suppliers’ sites that need to be 
mitigated through the direct supplier. The mechanism is available via the 
channels of the Volkswagen Group, the TRATON GROUP, or TRATON brand 
whistleblower systems and is open to all potentially affected stakeholders. 
 Direct and 
indirect suppliers 
Upstream and 
downstream 
supply chain 
 No target has been set 
because it is currently not 
possible to define a 
measurable and verifiable 
target due to the qualitative 
nature of this topic. 
 Supplier-specific measures, 
defined during audits or 
through the SCGM (e.g., 
following up on reports of 
violations) and implemented 
by the supplier, are assessed 
for effectiveness by auditors or 
case handlers. This is carried 
out through methods such as 
desktop reviews or on-site 
follow-up audits. 
Standard measure 
Media screening 
 The TRATON GROUP brands, either directly or through Volkswagen Group 
Procurement Sustainability, carry out continuous and risk-based media 
screening of relevant suppliers1 using a software tool. If the tool identifies 
indications of possible breaches of the Code of Conduct for Suppliers and 
Business Partners by suppliers in the upstream and downstream value 
chain, these are reviewed and, if necessary, processed in the SCGM. The 
media screening can identify potential breaches even if there is no direct 
report in the whistleblower system, or no findings are made in supplier 
audits. This enables these cases to be processed by the SCGM, and where 
necessary, remedial action to be taken. 
 Direct and 
indirect suppliers 
Upstream and 
downstream 
supply chain 
 No target has been set 
because it is currently not 
possible to define a 
measurable and verifiable 
target due to the qualitative 
nature of this topic. 
 In the case of media screening, 
it was not feasible to define 
suitable indicators to 
determine the effectiveness of 
this measure. 
Standard measure 
S-Rating 
 The S-Rating is an established process in the brands of the TRATON 
GROUP. This standardized instrument is used to assess the degree to 
which direct suppliers with high sustainability risks and a corresponding 
company size comply with Volkswagen’s Group sustainability 
requirements. It is closely linked to the requirements of the Code of 
Conduct for Suppliers and Business Partners. 
The goal is to create transparency, verify compliance with Volkswagen’s 
Group sustainability standards, identify potential areas for improvement, 
and provide incentives for sustainable corporate governance. 
In 2025, the S-Rating process was fundamentally revised and reintroduced 
under the name “S-Rating 2.0.” 
The new evaluation logic distinguishes between positive and negative S-
Ratings: 
Positive S-Rating: The supplier meets the sustainability requirements and 
is eligible for contract awards. A positive S-Rating is intended to 
demonstrate that a direct supplier, by meeting the minimum criteria of the 
S-Rating, has the capacity to mitigate or avoid potential negative impacts 
on the working conditions of its own employees, and to eliminate actual 
negative impacts on working conditions and other labor-related rights. 
Negative S-Rating: The supplier has not yet submitted the necessary 
documentation or has violated sustainability requirements of the TRATON 
GROUP. A negative S-Rating generally means the supplier is not eligible 
for contract awards and serves as a targeted incentive to improve 
sustainability performance and promote responsible business practices. 
The evaluation is risk-based and event-related, conducted before each 
new contract award. It is based on a risk analysis that considers 
 Direct suppliers 
Upstream and 
downstream 
supply chain 
 Long-term goal: By 2040, more 
than 95% of relevant 
Volkswagen Group direct 
suppliers, based on turnover, 
should have a positive S-
Rating. 
Interim goal: For the reporting 
year 2025, an interim target of 
85% for the Volkswagen Group 
was defined. 
TRATON brands are 
contributing to this target, but 
a target feasible specifically for 
commercial vehicles is 
currently being evaluated. 
The target is directly linked to 
the Group’s sustainability 
goals, as a positive S-Rating 
shows that suppliers meet 
sustainability requirements 
and thereby reduce or avoid 
negative impacts on working 
conditions and work-related 
rights. The interim target was 
defined by a cross-functional 
working group based on 
feasibility analyses and 
internal benchmarking. 
 The target has not been 
adjusted since the goal was 
defined. The underlying 
methodology for calculating 
the associated KPI was revised 
and updated as part of the 
introduction of S-Rating 2.0, 
expanding the supplier base 
covered and the assessment 
logic. This methodological 
change improves transparency 
and harmonization across 
brands, but affects 
comparability with previous 
evaluations. The revised 
method for calculating the KPI 
will be implemented gradually 
to ensure consistency across all 
brands. Performance is 
continuously monitored at 
brand level using internal 
systems that aggregate 
supplier S-Rating data. 
Although no direct employee 
integration into tracking has 
been established, the system 
takes supplier feedback and 
audit results into account when 
assessing effectiveness. The

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 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
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 Further 
Information 
 
 
environmental, social, and integrity aspects. TRATON draws on data from a 
specialized service provider to determine the country risk. 
Supplier evaluation begins with a Self-Assessment Questionnaire (SAQ), 
which captures documented processes, management systems, and 
relevant documents. These responses are validated by external service 
providers and typically adjusted based on country risk. Based on the SAQ 
responses, suppliers receive recommendations to improve their processes 
and regulatory frameworks. 
For certain companies, an audit (on-site inspection) by selected service 
providers may also be required. If discrepancies are found, the supplier 
must develop and implement an action plan. The effectiveness of these 
measures is reviewed by auditors, for example, through desktop reviews or 
follow-up audits. 
Audits are conducted based on risk. If the supplier receives a score below 
100 points, they are issued a Corrective Actions Plan (CAP). The required 
actions are documented in the CAP, jointly agreed upon with the supplier, 
and subsequently monitored. If a supplier receives an audit result of less 
than 50 points, a follow-up audit will be conducted after the CAP has been 
implemented. 
In addition to SAQ and audits, other instruments — such as the SCGM or 
specification-specific requirements (e.g., through RMDDMS) — influence 
the S-Rating and thus the supplier’s eligibility for contract awards. 
Workers in the supply chain or 
their representatives were not 
directly involved in the target-
setting process. 
results are regularly reviewed 
and analyzed for significant 
trends to support targeted 
supplier outreach and 
improvements. In 2025, the 
share of supplier sales revenue 
with a positive S-Rating at 
TRATON was 85%. As 2025 is 
the first year using the revised 
methodology, the reporting 
year serves as the baseline for 
future tracking. 
Standard measure 
Sustainability training for 
employees in procurement 
 Sustainability is an integral part of the skills profile for employees in 
procurement, deeply embedded not only in individual competencies 
related to the core focus areas of sustainable procurement, but also in the 
organizational culture. Systematic training of TRATON’s employees is 
essential for improving sustainability in the supply chain. 
 TRATON GROUP 
buyers globally 
 No specific target has been 
defined at this stage due to 
ongoing data validation and 
evolving standards. The focus 
is on continuously enhancing 
the internal training portfolio. 
 In 2025, training courses on 
sustainability for procurement 
were performed by the brands 
and attended more than 1,817 
(previous year: 363 attendees) 
times worldwide. The 
significant increase is primarily 
attributable to major training 
events at MAN and Scania. To 
date, no monitoring of 
effectiveness in relation to 
working conditions and other 
work-related rights has been 
implemented. 
Standard measure 
Sustainability training for 
suppliers 
 To enable continuous supplier development, the TRATON GROUP brands 
in collaboration with Volkswagen Group conduct topic-specific 
sustainability training and workshops with suppliers at selected locations 
or online. They also offer web-based training courses, including on S-rating 
and the Code of Conduct for Suppliers and Business Partners. Since 2023, 
an in-depth human rights training has been rolled out to suppliers with a 
high sustainability risk. The training includes legally required aspects such 
as training on child labor, forced labor, and discrimination. In addition to 
the training courses, TRATON provides current suppliers with an e-learning 
module on sustainability in eight languages. 
 Direct suppliers 
Upstream supply 
chain 
 No specific target has been 
defined at this stage due to 
ongoing data validation and 
evolving standards. The 
priority is to continuously 
enhance the external training 
portfolio. 
 In 2025, 600 (previous year: 
733) suppliers were trained 
accordingly. To date, no 
monitoring of effectiveness in 
relation to working conditions 
and other work-related rights 
has been implemented. 
Deep-dive measures 
Raw materials due diligence 
management system  
(RMDDMS) 
 Regarding the responsible sourcing of raw materials, TRATON as part of 
the Volkswagen Group RMDDMS follows the approach on the five steps of 
the OECD Due Diligence Guidance for Responsible Business Conduct and 
the requirements of the OECD Due Diligence Guidance for Responsible 
Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.  
This management system serves to identify, assess, and implement 
mitigation actions. In total, it currently covers 18 raw materials. These 
include the battery raw materials cobalt, lithium, nickel, and graphite, the 
 Direct and 
indirect suppliers 
Upstream supply 
chain 
 No target has been set 
because it is currently not 
possible to define a 
measurable and verifiable 
target due to the qualitative 
nature of this topic. 
 In the RMDDMS, measures are 
considered effective if they 
help improve living conditions 
or protect the environment. 
Each measure is assigned a 
timeline and success indicators 
upon selection, with results 
feeding into the annual risk

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Financial Statements 
 Responsibility Statement 
and Independent  
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 Further 
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conflict minerals tin, tungsten, tantalum, and gold (3TG), and aluminum, 
copper, leather, mica, steel, natural rubber, platinum group metals, rare 
earths, cotton, and magnesium. 
With this risk-based approach, the TRATON GROUP, as part of the 
Volkswagen Group, prioritizes its activities based on the severity and 
likelihood of the infringement and the ability to influence it. Audits are one 
of the key tools used to assess risks in the upstream supply chains and 
identify mitigation measures. They are utilized alongside other tools used 
for raw material due diligence and help promote transparency, 
compliance, and a culture of continuous improvement and dialog 
throughout the supply chain. 
RMDDMS mitigation measures are implemented by TRATON brands in a 
way that corresponds to their business. Some TRATON brands implement 
additional measures tailored to their specific supply chain risks and 
sustainability goals. 
analysis for 18 high-risk raw 
materials. To date, no 
monitoring of effectiveness in 
relation to working conditions 
and other work-related rights 
has been implemented. 
Deep-dive measure 
Human rights focus system 
(HRFS) 
 Within the sustainable supplier management, TRATON as part of the 
Volkswagen Group is also involved in protecting groups of people who 
may be affected by negative impacts along the upstream and downstream 
supply chain. To achieve greater impact here, Volkswagen Group 
introduced the HRFS. TRATON brands as part of Volkswagen Group use the 
HRFS in a way that corresponds to their business to identify topics that 
may be associated with human rights and environmental risks. These 
topics require more in-depth analysis and are continuously addressed. The 
tools and actions implemented in the HRFS are intended to minimize and 
stop identified negative impacts on value chain workers. Simultaneously, 
the aim is to promote positive impacts on these workers.  
 Direct suppliers 
Upstream and 
downstream 
supply chain 
 No target has been set 
because it is currently not 
possible to define a 
measurable and verifiable 
target due to the qualitative 
nature of this topic.  
 As of the reporting year, no 
measurement for tracking the 
effectiveness is in place. 
Human rights salience 
assessment (not part of the 
ReSC system) 
 To understand the TRATON GROUP’s human rights and social risk profile 
and increase the readiness and ability of the key decision-makers to 
consider human rights in TRATON’s sustainability and business strategy, 
the TRATON GROUP commissioned an external consultancy to conduct a 
human rights salience assessment in 2023-2024. The salience assessment 
identifies and prioritizes human rights risks from the perspective of 
rightsholders prior to any management effort. It covers the TRATON 
GROUP’s value chain across its brands including TRATON’s own 
operations, supply chain, distribution, and sales networks, as well as 
customers and end-users. The salience assessment methodology on 
negative impacts is aligned with the United Nations Guiding Principles on 
Business and Human Rights considering the four criteria of scope, scale, 
remediability, and likelihood. In total, 18 salient human rights risks and 
impacts were identified, which can be split into the three categories labor 
and workforce; product, customer, and end-users; and cross cutting and 
emerging themes. 
 Upstream and 
downstream 
supply chain 
TRATON GROUP  
 No target has been set 
because it is not possible to 
define a measurable and 
verifiable target due to the 
qualitative nature of this topic. 
 The human rights salience 
assessment served as a basis 
for the DMA and will inform 
further actions around 
managing IROs related to value 
chain workers. As a next step, 
the TRATON GROUP will start a 
new human rights program. In 
2025, no measurement for 
tracking the effectiveness was 
in place. 
1 The relevance of a supplier for media screening results from factors including the procurement volume or the risk exposure derived from the type of product or service.

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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Road safety  
Countless people come into contact with the TRATON GROUP’s products and services on a daily basis. TRATON gives the highest priority to the security and 
safety of its products. Through the DMA, the company identified potential negative and positive impacts related to the entity -specific issue of road safety. 
The following section outlines the approach of the TRATON GROUP to managing material impacts related to road safety across the value chain. 
Impacts, risks and opportunities related to road safety 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Road Safety (entity-specific 
sub-topic) 
 Potential negative impact  Short-term  Downstream  Impact of traffic accidents on road users. 
 Potential positive impact  Short-term  Downstream  Increasing safety features in the products and promoting safe road use. 
 
Approaches and policies 
The TRATON GROUP Policy on Product Safety and Conformity is related to the potential negative impact on people from traffic accidents and the potential 
positive impact by increasing the safety features in products and promoting safe road use. The Policy pl ays a key role, especially in ensuring the personal 
safety of customers, the environment, and society in general. It is strongly aligned with the corresponding Volkswagen Group policy and sets consistent 
standards across the Group to meet legal requirement s and fulfill the TRATON GROUP’s commitment to responsible product stewardship. A system for 
actively and passively monitoring products placed on the market must be maintained, and any risks associated with these produ cts must be prevented as 
far as reasonably possible. 
Road safety policy 
Name of policy  Key contents and objective  Scope  
Responsible 
organizational level and 
monitoring process  
Availability of the policy 
for stakeholders 
Product Safety 
and Conformity 
(Group policy) 
 The Product Safety and Conformity policy established consistent standards for the TRATON 
GROUP. It is closely aligned with the Volkswagen Group’s policy. It stipulates that TRATON 
entities bringing products to market adhere to the organizational and procedural frameworks 
and aims to ensure that in-the-field identified risks against safety and/or conformity are 
detected, assessed, and appropriately mitigated.  
Additionally, the policy specifies multi-brand collaboration among the TRATON brands. It sets 
consistent, Group-wide standards in accordance with the TRATON GROUP’s module and 
component strategy, facilitating the coordination of necessary measures across t he entities 
within the TRATON GROUP. As a commercial vehicle manufacturer, TRATON strives to 
manufacture products of the highest possible quality. However, sustained success is possible 
only if integrity — in other words, activities conforming to statutory requirements and driven 
by a commitment to values — forms the basis for day-to-day activities. It further maintains a 
system for active and passive product surveillance monitoring for the products that it releases 
on the market. Finally, TRATON aims to avert hazards and danger to life and limb arising from 
such products as far as it is reasonably able to do so. 
 TRATON GROUP  The monitoring process for 
this policy is described in 
detail in the following in 
the Actions related to road 
safety table. 
 Access via intranet

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Process for Safety-Conformity-Related Matters 
If a case has the potential to be safety- and/or conformity relevant, the Product Safety Committee at the respective manufacturing entity must be consulted 
in accordance with Group regulations. The Product Safety department then determines the necessary an d appropriate actions to restore the safety and 
conformity of products on the market. These actions may include recall campaigns, workshop service actions, warranty extensions, or production halts. 
Any indications of safety- and/or conformity relevant issues identified through passive or active product monitoring are analyzed in detail. Once the Product 
Safety Committee approves a measure, its implementation is initiated and coordinated by the respec tive brand’s field quality and service organization, 
which reports to the Product Safety Committee on timing and progress. 
The effectiveness of each measure is tracked through ongoing product monitoring and evaluated based on the implementation rate. 
All decisions and measures approved by the Product Safety Committee are binding for all relevant departments. The Product Saf ety Committee office 
monitors the timely execution of these measures and, when necessary, reports the status back to the Committee.  This includes input from departments 
such as Technical Development and Production, and considers factors like frequency of occurrence, root cause, affected components, and other impacted 
Group models. 
Cybersecurity Management System 
The brands use a variety of automotive management systems for motor vehicles to address the cybersecurity of their vehicles. 
Potential risks are analyzed during development and mitigated using appropriate state -of-the-art solutions. Tests uncover remaining weak spots and help 
to close them before starting production. 
To effectively respond to new cybersecurity risks, ongoing risk assessments are maintained by the brands and different monitoring procedures were imple-
mented. Continuous monitoring includes internal sources, like the analysis of vehicle data, and external sources, like the screening of the web by a threat 
intelligence service provider. These measures enable the brands to detect new cybersecurity vulnerabilities and cyberattacks on TRATON GROUP products 
(also known as incidents). Vulnerability and incident management processes on brand and VW Group level ensure an appropriate and prompt response.  
If necessary, suitable countermeasures will be rolled out in the field via the known channels like over-the-air updates or field campaigns.

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 Combined  
Management Report 
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Financial Statements 
 Responsibility Statement 
and Independent  
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 Further 
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Actions 
The following actions highlight the TRATON GROUP’s ambition regarding road safety.  
Actions related to road safety 
Action   Description and time horizon  Scope  Target in place  
Overall progress in 2025 and how we track 
effectiveness 
Monitoring and 
management of product 
safety and conformity 
 The brands of the TRATON GROUP placing products on the market are 
committed to maintaining robust systems for both active and passive 
surveillance of products released on the market to prevent potential 
hazards. As soon as indications of potential safety and/or conformity-
relevant deviations are identified, this information must be immediately 
subjected to a more detailed technical analysis and, if necessary, a risk 
assessment to introduce any necessary measures. For managing such 
procedures, designated committees are installed within the brands. This is 
a recurring action. 
 TRATON GROUP  No  Regular internal audits are conducted to 
ensure that all actions required by the 
product safety and conformity policy are 
complied with and effective. To this end, at 
least 5% of the new cases of suspicion of non-
conformity or lack of safety added since the 
last audit should be audited in each calendar 
year. 
Scania Zone   Scania Zone is a position-based service for vehicles that allows geographic 
conditions to be set to restrict speed in certain areas. It is managed in 
Scania’s digital ecosystem My Scania and the applications Scania Driver app 
and Scania Fleet app. 
 Scania’s L, P, G, R 
and S cabs as well 
as the CrewCab 
models 
 No   
Fédération Internationale 
de l’Automobile (FIA) Road 
Safety Index.  
 As part of Scania’s ambition to drive the shift towards zero accidents, Scania 
has completed the first three steps of the FIA Road Safety Index — Value 
Chain Analysis, Commitment, and Footprint — initially focusing on Scania’s 
global functions and the operations in Sweden. This is an important step in 
measuring how well Scania aligns with its ambition.  
 TRATON GROUP 
operations in 
Sweden 
 No  Scania received a 3-star rating, the highest 
rating awarded by a third-party certification 
body. This makes Scania one of the world’s 
leading companies and the first heavy-duty 
vehicle manufacturer to receive this award.

===== SIDA 357 =====

357 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 
Affected communities 
The TRATON GROUP recognizes that its vehicles and operations can influence the lives of people. This section outlines how the  Group manages impacts 
related to affected community rights and vehicle misuse, in line with the joint impact area human rights.  
Impacts, risks, and opportunities related to affected communities 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Communities’ economic, 
social and cultural rights 
 Potential negative impact  Short-term  Upstream, own operations, and downstream   Harm due to inadequate protection of communities’ 
rights and vehicle misuse. 
Aside from the DMA, the Human Rights Salience Assessment was conducted for various groups of rightsholders. One of these grou ps is the local commu-
nities in the vicinity of TRATON’s sites and along TRATON’s supply chain that may be impacted by activities such as production or raw material extraction. 
Affected communities in the scope of this report are all communities affected by material IROs. The following were identified  as affected communities in 
this context: 
The material negative impacts on affected communities identified in the DMA are widespread and do not pertain to specific incidents or business relation-
ships. The identified risk of legal and reputational harm and operational disruptions from implication in human rights violations may arise from dependen-
cies of the TRATON GROUP on communities located near its operations or within its supply chain, potentially leading to disrup tions that affect business 
continuity and local stakeholder relations. The material impacts in the area of product misuse are reflected in the TRATON project on conflict -affected and 
high-risk areas (CAHRA).
1. Rightsholders affected by crimes and illegal activities facilitated by the Group’s vehicles, such as illegal logging, mining, robberies, terrorist attacks, 
kidnapping, or human trafficking. These persons may experience impacts on their health, standard of living, personal safety, and life. In conflict zones, 
misuse of the TRATON GROUP’s vehicles may exacerbate these impacts, while in authoritarian states, it could affect political expression and personal 
liberty. 
2. Rightsholders in communities near TRATON operations or along the supply chain may face impacts from activities like mining.
3. Primary users of the Group’s vehicles, such as drivers, may have their privacy impacted if smart systems collect data like location history or health
information without consent. This also applies to connected devices and vehicle cameras. 
4. Drivers and passengers of TRATON vehicles may experience impacts on their right to health, safety, and life if there are accidents associated with poor 
product or road safety. Other rightsholders that may be involved in accidents with TRATON vehicles, such as pedestrians or passengers in other vehicles, 
may also experience impacts on health, safety, and life.

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358  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 
The Group’s approach to addressing negative impacts via the grievance mechanism as well as mechanisms in place to protect its  users against retaliation 
is laid out in the section on TRATON’s grievance mechanism.  
Besides the grievance mechanism, which is accessible to everyone, the TRATON GROUP has not adopted a process to engage with a ffected communities 
as of now. Until a process is in place, TRATON integrates communities’ perspectives through external research i ncluding reports, papers, and articles from 
NGOs, media, and other reputable organizations/experts, reflecting rightsholders’ perspectives and voices. 
TRATON respects the human rights of affected communities in the same manner as TRATON respects the human rights of its own wo rkforce and value 
chain workers, striving to ensure that its internal mechanism and principles are in line with the UN Guiding Prin ciples on Business and Human Rights, ILO 
Declaration, and OECD Guidelines. This approach is important for communities near the Group’s operations or supply chain and communities affected by 
crimes and illegal activities potentially facilitated by the Group’s vehicles. Therefore, the Group’s risk analysis addresses negative impacts on local commu-
nities that may be caused by own business operations or TRATON’s suppliers. Similarly, cases of regulatory violations with negative impact on local commu-
nities that are caused by misconduct of employees or suppliers of the Group can be addressed via the relevant channels contained within t he TRATON 
complaints procedure. 
The Code of Conduct for Suppliers and Business Partners (see section Sustainability governance) requires suppliers and business partners to respect the 
rights of local communities to decent living conditions, including their rights to land, access to water, and other natural r esources, as well as their right to 
practice their culture. The Policy Statement on Human Rights sets out further principles that TRATON adheres to in the context of human rights, contributing 
to mitigating potential negative impacts in this context.

===== SIDA 359 =====

359 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 
Policy addressing affected communities 
Name of policy  Key contents and objective  Scope  
Responsible organizational level 
and monitoring process  
Availability of the 
policy for 
stakeholders 
Export Control Policy  TRATON GROUP  Each local brand entity involved in 
exports must appoint an Export 
Control Officer in line with the 
governance structure provided by 
the Central Brand Export Control 
function. Additionally, all TRATON 
GROUP entities nominate a 
member of their respective 
management board or board of 
directors to be Chief Export Control 
Officer and responsible for foreign 
trade and export control matters. 
The policy defines the framework 
for each Group entity to implement 
an Internal Compliance Program 
(ICP) including export control self-
assessments as described in the 
table Actions addressing affected 
communities 
 Access via 
intranet 
 The policy serves as the overarching framework for all Group entities. It defines the 
Group’s responsibilities and principles for complying with export control and 
sanctions requirements, and assigns clear accountability for their implementation. 
As export control laws and regulations inherently incorporate human rights 
considerations by prohibiting exports that could contribute to repression, conflict, or 
violations of international law, the Group integrates human rights protection by 
restricting sales to sanctioned countries, high-risk end-users, and conflict regions. 
These measures ensure products are used solely for legitimate civilian purposes and 
prevent potential misuse of products. 
Under the framework of the Group policy, each entity must designate appropriate 
governance and accountability (e.g., an export control function with defined 
reporting lines), perform risk-based classification of products, software, and 
technology, conduct screening of transactions and business partners, determine 
licensing needs, maintain records, and provide role-appropriate training and 
awareness. 
Brand- or country-specific procedures, work instructions, and process descriptions 
supplement this policy, provided they meet or exceed its requirements. 
The TRATON GROUP Export Control department supports the Group entities in 
ensuring compliance with this policy as well as with national, EU, and US regulations. 
Entities report to their respective Export Control function, these to the TRATON 
Export Control function. Moreover, reporting is annually taken to the Volkswagen 
Export Control department. Where necessary, qualified external parties may be 
considered to conduct reviews and audits. Corrective actions required to adapt 
export control operations or the Internal Compliance Program (ICP) based on review 
findings will be jointly defined and monitored by the respective brand and/or 
TRATON GROUP entity. All TRATON GROUP entities and their employees are 
required to comply with this policy.

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360  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 
The table below outlines the actions addressing affected communities taken in 2025. 
Actions addressing affected communities 
Action   Description and time horizon  Scope  Target in place  
Overall progress in 2025 and how we track 
effectiveness 
Project to conflict-affected 
and high-risk areas 
(CAHRA) 
 To address negative impacts on affected communities in conflict-
affected and high-risk areas (CAHRA) caused by our own operations 
and those of business partners, TRATON develops its heightened 
human rights due diligence approach (CAHRA) project. Additionally, 
this action aligns with identified impacts and material topics related to 
upholding international standards in CAHRA. The scope of this action 
extends to business partners in the downstream value chain that are 
located in or sell to CAHRAs. In this context, input from this project 
could help to better understand the adverse impact of certain 
complaints related to CAHRAs.  
 Downstream  No target has 
been set because 
it is currently not 
possible to define 
a meaningful and 
measurable 
target due to the 
qualitative nature 
of this topic. 
 This project started in 2025 and aims to focus on sales 
and end-use related risks. The project facilitates risk 
mapping for sales and end-use risks. A due diligence 
process for CAHRAs is to be developed. 
Internal Compliance 
Program and export 
control self-assessment 
 The TRATON Export Control Policy establishes a binding framework 
and requires all TRATON brands and entities to implement an Internal 
Compliance Program (ICP) to ensure adherence to international legal 
requirements arising from trade regulations, including the U.S. Export 
Administration Regulations (EAR), the EU Dual-Use Regulation, and 
other applicable national export control laws. 
The ICP serves as the overarching framework for the Group. It defines 
the Group’s responsibilities and principles for complying with export 
control and sanctions requirements, and assigns clear accountability 
for their implementation. The scope and level of detail of each ICP shall 
be tailored to the commercial activities of the respective entity and will 
depend on factors such as its size, structure, scope of business, and 
customer portfolio. 
 TRATON 
GROUP 
 No target has 
been set because 
it is currently not 
possible to define 
a meaningful and 
measurable 
target due to the 
qualitative nature 
of this topic. 
 To identify export control requirements and as part of 
the ICP, Group entities are required to conduct 
continuous export control self-assessments to identify 
and mitigate risks. These assessments help evaluate 
the effectiveness of procedures and controls in place, 
ensuring improvement and alignment with evolving 
legal requirements (e.g., in the field of sanctions). 
Where necessary, qualified external parties may be 
considered to conduct reviews and audits. Corrective 
actions to adopt the export control operations 
according to the findings of the review are monitored 
by the respective brand and/or TRATON GROUP 
entity. 
 
Performance 
In 2025, no confirmed cases were reported of non -respect of the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental 
Principles and Rights at Work, OECD Guidelines for Multinational Enterprises, nor cases of severe human rights issues and incidents connected to affected 
communities. 
Further aspects of the management of impacts and risks related to affected communities are described in section TRATON’s grievance mechanism. The 
processes described in the section Own workforce for identifying appropriate action for negative impacts are implemented across the TRATON GROUP’s 
operations and supply chain. 
No specific measurable targets with respect to the defined affected communities have yet been established due to the need for further internal evaluation.

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361  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 
 
 
Governance 
Business conduct is a decisive factor in ensuring the long -term success of the TRATON GROUP. It significantly influences relationships with customers, 
employees, suppliers, and other stakeholders. Ethical and responsible corporate governance is therefore o f paramount importance. The TRATON GROUP’s 
ongoing membership and active participation in initiatives such as Transparency International Deutschland e.V., UN Global Com pact, German Institute for 
Compliance (Deutsches Institut für Compliance), and Alliance for Integrity (Allianz für Integrität) demonstrate its unwavering commitment to conducting 
business with integrity, ethics, and compliance.  
The sustainability matters that were identified as material for TRATON in the context of business conduct are: corporate cult ure, corruption and bribery, 
protection of whistleblowers, and political engagement. For the topics of management of relationships with suppliers including payment practices, and 
animal welfare, no material impacts, risks, or opportunities were identified, hence the topics are not addressed further in this report. 
Corporate culture 
The TRATON GROUP regards its corporate culture as a vital foundation for success and a driver of fostering collaboration across the entire organization. The 
following table shows the material IROs related to corporate culture for TRATON. 
Impacts, risks and opportunities related to corporate culture 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Corporate culture  Potential negative impact  Short-term  Own operations  Disengagement of employees, lack of employee 
empowerment and motivation, potential unethical 
behavior from weak corporate culture.  
 Risk  Short-term  Own operations and downstream  Reduced productivity, decreased efficiency, and 
higher employee turnover fostered by a negative 
corporate culture.

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362  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 
To maintain responsible business conduct and implement the sustainability strategy of TRATON in line with its corporate value s, several Group policies 
guide the Group’s efforts. They all relate to both the risk described in the IRO table above and the potential negative impact.  
The TRATON GROUP’s values and principles are anchored in the overarching Code of Conduct for Employees, which shapes the corporate culture. It covers 
a wide range of topics, including ethical leadership and prohibition of corruption, as well as TRATON’s co rporate values. Detailed information on our Code 
of Conduct for Employees can be found in the section on Sustainability governance. 
TRATON corporate culture frameworks 
Three frameworks further shape our corporate culture: TRATON GROUP corporate values, TRATON GROUP thinking model, and TRATON GROUP shared 
leadership principles. Together they form a system in which all components are interdependent.

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363  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 corporate culture 
Name of policy  Key contents and objective  Scope  
Responsible 
organizational level and 
monitoring process  
Availability of the policy for 
stakeholders 
TRATON GROUP 
corporate values 
 The TRATON GROUP corporate values provide the framework for how business is 
conducted in the Group. This is based on the firm conviction that there is a close 
connection between the results and the way in which all employees, managers, and the 
Executive Board behave, think, and make decisions. That is why the TRATON GROUP is 
committed to five corporate values: Customer First, Respect, Team Spirit, Responsibility, 
and Elimination of Waste (see figure below). These values underline its purpose 
“Transforming Transportation Together. For a sustainable world“. Although the TRATON 
GROUP finds its strength in the different perspectives within the Group, it is crucial that the 
full business potential be achieved and that the Group leverage its advantages to create 
value for clients and society. Hence, the TRATON GROUP has stepped up collaboration 
between its brands through work groups to successfully implement its strategy and realize 
joint projects. 
 TRATON GROUP  The most senior level at 
the TRATON GROUP that is 
accountable for this policy 
is the Executive Board. The 
framework is reviewed and 
updated if necessary. 
 Access via intranet and website 
For more details, see the 
”Actions addressing corporate 
culture” table below under 
“Corporate value roll-out.” 
TRATON GROUP 
thinking model 
 The TRATON GROUP thinking model is a framework that describes how everyone involved 
learns, adapts, and evolves. It connects the TRATON GROUP corporate values with the 
Group’s results — and back again — to create a real-time and relevant organizational 
learning system, as shown in the figure below. This ensures that everyone involved in the 
development of methods has the same vision, even if they are not in direct contact with 
each other. The TRATON GROUP thinking model not only links corporate values and results 
but also integrates principles and methods into the strategy. It describes how principles are 
translated into methods and how knowledge is learned and preserved within the Group.  
 TRATON GROUP  The most senior level at 
the TRATON GROUP that is 
accountable for this policy 
is the Executive Board. The 
framework is reviewed and 
updated if necessary. 
 Access via intranet 
TRATON GROUP 
shared leadership 
principles 
 The TRATON GROUP shared leadership principles capture how TRATON regards great 
leadership. Principles are rooted in the Group’s corporate values because it matters how we 
achieve business results. Each leadership principle serves all TRATON GROUP corporate 
values and describes a core idea that shapes the methods, connections, and dependencies 
described at greater length in the thinking model. The shared leadership principles help to 
avoid misunderstandings and unnecessary conflicts by defining good leadership. By 
adhering to the shared leadership principles, employees follow certain standards and 
methods that strengthen the Group’s external image. TRATON pursues three leadership 
principles: (1) own today, shape tomorrow, (2) start with trust, build together, and (3) dare to 
try, manage the risk. The shared leadership principles were developed in 2024 and 
implemented through various communication measures within the Group brands.  
 TRATON GROUP  The most senior level at 
the TRATON GROUP that is 
accountable for this policy 
is the Executive Board. The 
framework is reviewed and 
updated if necessary. 
 Access via intranet

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364  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

===== SIDA 365 =====

365  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 2025, the Group took several actions to engage the corporate culture. The key actions focus on the implementation of the c orporate culture framework 
and are presented in the table below.  
Actions addressing corporate culture 
Action  Description and time horizon  Scope  Target in place  
Overall progress in 2025 and how we track 
effectiveness 
Corporate value 
roll out 
 The TRATON GROUP is actively rolling out and strengthening its corporate values 
across all its brands, ensuring the seamless integration of these values throughout 
the organization. The implementation started in 2024 and continued in 2025. This is 
supported by a tool-based process, which consists of seven team sessions taking 
approximately ten hours per employee to complete. Each brand and Group function 
further needs to set up a system to implement the values in training, promotion 
schemes, and HR processes such as recruitment and similar to ensure that the 
corporate values are put into practice throughout the organization. The expected 
outcome is to support the development of the TRATON GROUP’s culture and to 
create awareness of the TRATON GROUP corporate values among all employees. 
 TRATON 
GROUP 
 See Role model 
Program in the 
section 
“Performance” 
below. 
 This will help shape actions and new behaviors 
that are aligned with the corporate values, 
ultimately contributing to a positive work 
environment and a strong Group culture. By 
November 2025 inclusive, 20,406 employees of 
TRATON GROUP (previous year: 12,672) had 
participated in the corporate value training. 
Operationalization 
of The TRATON 
Way  
 In 2025, the TRATON GROUP initiated the operationalization of “The TRATON Way” 
across all brands and Group functions. These activities build on the TRATON GROUP 
Thinking Model, core values, and shared leadership principles, and aims to embed a 
shared mindset and way of working, enabling continuous improvement throughout 
the organization. The Executive Board endorsed four main principles “continuous 
improvements,” “right from me,” “normal situation,” and “demand driven” — as the 
foundation for this cultural alignment. Group functions were tasked with defining 
functional principles and visualizing their interpretation of “The TRATON Way” using a 
common shape and color scheme, while brands embarked on a validation journey to 
adapt and implement these principles. The initiative is coordinated by brand CEOs 
and functional leads. This cultural anchoring supports TRATON’s transformation goals 
and strengthens its identity as a unified yet diverse organization. 
 TRATON 
GROUP 
 No  The operationalization of “The TRATON Way” has 
led to increased clarity and consistency in 
decision-making and collaboration across 
functions. The definition of functional principles 
has been started in key areas such as HR, R&D, 
and Communications, and is being integrated 
into leadership development, onboarding, and 
change enablement programs. Effectiveness is 
tracked through feedback loops, workflow 
alignment sessions, and the adoption of shared 
practices in strategic projects. 
Collaboration 
tools 
 Two tools are available to employees via the Group’s intranet: Team collaboration 
toolbox and culture kit. These tools serve as an implementation aid for corporate 
culture frameworks and are promoted throughout talent development programs, 
training, and working groups. 
 TRATON 
GROUP 
 No  The collaboration tools are continuously 
updated. 
Change 
management 
 Good change management drives the TRATON strategy forward. Using change 
management for change initiatives embodies the TRATON GROUP core values, 
putting people in the center, and preparing the transformation. In 2025, a cross-brand 
working group aligned shared concepts, developed a joint training portfolio and a 
new change management page on the intranet The Tube. Implementation will 
continue in 2026. 
 TRATON 
GROUP 
 No  This will help shape actions and new behaviors 
that are aligned with the values and leadership 
principles, ultimately contributing to a positive 
work environment and a strong Group culture. 
Tone from the top 
statements 
 Regular tone from the top statements addressing the Group’s own workforce by 
members of the Executive Board and management demonstrate the importance of 
compliance and commitment to ethical and compliant behavior. Such statements 
appear through various channels such as quotes in training and communication 
material and keynotes at compliance events. A clear tone from the corporate 
leadership encourages a compliance culture throughout the TRATON GROUP and 
demonstrates the commitment to internal and external stakeholders. 
 TRATON 
GROUP 
 No

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366  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 
 
 
Talent development programs  
Another action significantly strengthening the application of the TRATON corporate values and beliefs reflected in the Group’ s corporate culture are the 
talent development programs, which are described in the section on Own workforce. 
Annual employee survey  
In previous years, an annual employee survey called Stimmungsbarometer (StiBa) was conducted to obtain feedback on employees’ experiences and review 
how the corporate culture is developing. In the reporting year, this process was paused as the TRATON GROUP is developing and  implementing a new 
employee survey process and tool called MyVoice, covering all brands. The new annual employee survey will help evaluate the success of business conduct 
implementation and serve to guide actions in the area of governance. In 2025, each TRATON brand decided on its own initiatives as the new MyVoice survey 
will be introduced in 2026. 
Performance 
In 2025, the following targets were set regarding corporate culture. 
Role Model Program 
The Role Model Program is based on TRATON’s corporate values and supports the culture change within the entire TRATON GROUP by reinforcing an open 
and trustful culture, as well as reducing silo thinking. For 2025, we set the target of a 75% implementation rate for the Role Model Program throughout the 
Group. The target was exceeded with a 76% (previous year: 82%) implementation rate. The targets are based on managers’ comple tion of their individual 
targets. Managers with a leadership function were required to set a good example by implementing at least two activities by the end of 2025 to reach 100%. 
Managers who made a status change in the second half of the year were only required to implement and document one activity in  this timeframe. In total, 
6,039 (previous year: 6,222) managers participated in the Role Model Program in 2025. Several functions from the TRATON GROUP’s People & Culture were 
involved in setting the targets, meaning that the Role Model Program is aligned with relevant policies, programs, and other goals of TRATON. 
Prevention and detection of corruption and bribery  
TRATON promotes ethical conduct and compliance across its own operations and value chain. This section outlines TRATON’s appr oach to preventing and 
detecting corruption and bribery, including relevant policies, training, and internal procedures that support transparency and integrity. 
Impacts, risks and opportunities related to corruption and bribery 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Corruption and bribery  Potential negative impact  Short-term  Upstream, own operations, and downstream  Corruption can weaken governance, harm 
environmental initiatives, and foster unfair 
competition.

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367  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 
The TRATON GROUP’s procedures to prevent, detect, and address allegations or incidents of corruption and bribery include, amo ngst others, the imple-
mentation of Group -wide policies (see Sustainability management process ), conduct of due diligence checks (see Workers in the value chain ), anti - 
corruption training and communications as described below, and the whistleblower system (see TRATON’s grievance mechanism ). Furthermore, the 
TRATON GROUP Compliance department provides advice on compliance- and integrity-related questions, e.g., via the Compliance Helpdesk that employees 
can phone or email. Internal control systems (ICSs) are integrated into the business pro cesses to help ensure that the TRATON GROUP’s financial and non -
financial data is reliable, operations are effective and efficient, and activities comply with applicable laws and regulations. Findings from detective measures 
are used to identify additional  preventive compliance measures. Furthermore, independence is assured as investigations are conducted by independent 
investigation offices and investigation units. The Chief Compliance Officer (CCO) of TRATON SE reports topics to the Complian ce Board three times a year 
and to the Executive Board once a year. Further, the CCO reports quarterly to the Audit Committee. 
Several policies manage the prevention and detection of corruption and bribery and relate to the potential negative impact of corruption, such as weakening 
governance, harming environmental initiatives, and fostering unfair competition. These policies are: Antitrust compliance, Business partner due diligence, 
Prevention of money laundering and terrorism financing, Donations and sponsoring, and Handling gifts, hospitality and invitat ions to events, and conflicts 
of interest. Further, the Code of Conduct for Employees, Code of Conduct for Suppliers and Business Partners (see Sustainability governance) and Internal 
investigations (see TRATON’s grievance mechanism) also relate to this IRO.

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368  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 corruption and bribery 
Name of policy  Key contents and objective  Scope  
Responsible organizational 
level and monitoring process  
Availability of the policy 
for stakeholders 
Antitrust 
compliance  
 Antitrust laws protect free and fair competition, thus preventing anti-competitive practices 
to the detriment of customers and other market participants. Hence, the TRATON GROUP 
commits itself without restriction to free and fair competition and does not tolerate 
violations of antitrust regulations. For this reason, the Antitrust compliance policy has been 
developed. It provides guidelines on how to address relevant areas in terms of antitrust 
regulations, when interacting with competitors, customers, and suppliers, and in cases 
where a company dominates the market. The Compliance department at TRATON is 
responsible for conducting training and other awareness measures, addressing questions 
related to the policy, and providing advice on potential antitrust infringements. In addition, 
the Legal department provides legal advice, particularly in the course of merger control 
proceedings. 
 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. 
 Access via intranet and 
communicated in 
compliance training 
Business partner 
due diligence 
(Group policy) 
 The TRATON GROUP strives to work with partners that follow the same high ethical 
principles of conduct to which we adhere. The Business partner due diligence policy relates 
to the risk of working with business partners lacking integrity by providing guidance on 
engaging with business partners, evaluating third parties using the business partner 
approval tool, concluding contracts, documenting, and archiving information, and 
establishing payment and remuneration frameworks. The policy governs the mandatory 
use of the Business Partner Approval Tool (BPA Tool), a web-based application that 
supports the assessment of the business partner’s integrity and provides approval 
workflows. The effectiveness of the policy is reviewed via quality assessments of due 
diligence checks conducted in the BPA Tool. Additionally, internal controls check whether 
all business partner contracts have gone through the due diligence process. The policy 
applies to the engagement of business partners that have an intermediary and 
representative function. This includes importers, dealers, resellers, authorized service 
partners, bodybuilders, and many more. The same rules for checking the integrity of these 
business partners are valid for all TRATON GROUP entities. The business partner’s int egrity 
check utilizes the Corruption Perception Index (CPI), created by Transparency International.  
 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. 
 Access via intranet and 
communicated in 
compliance training 
Prevention of 
money 
laundering and 
terrorism 
financing (Group 
policy)  
 This Policy describes measures to prevent money laundering and terrorist financing as 
required by international applicable money laundering regulations. It further defines roles 
and responsibilities, explains red flags and the prohibition of cash payments above a 
certain threshold as well as obligations in the event of any suspicion of money laundering 
or terrorism financing. In case a TRATON GROUP employee becomes suspicious of any 
potential or factual money laundering in connection with a transaction or business 
relationship, the employee must report this immediately to the Compliance department 
responsible. It assesses the facts of the case, if necessary, with the support of the TRATON 
GROUP employee responsible, and decides whether there is indeed suspected money 
laundering. If required, the Compliance department ensures that the relevant authorities 
and the relevant stakeholders are informed accordingly. In addition, the TRATON GROUP 
employee is informed of the outcome of the analysis and advised on the next steps, if 
appropriate. 
 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. 
 Access via intranet and 
communicated in 
compliance training

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Shareholders 
 Combined  
Management Report 
 Consolidated  
Financial Statements 
 Responsibility Statement 
and Independent  
Auditor’s Reports 
 Sustainability 
Report 
 Further 
Information 
 
 
Name of policy  Key contents and objective  Scope  
Responsible organizational 
level and monitoring process  
Availability of the policy 
for stakeholders 
Policy for 
donations and 
sponsorships  
 TRATON supports selected institutions and projects with donations and sponsoring 
measures. The Donations and sponsoring Group policy ensures that donations and 
sponsoring measures are implemented in line with applicable legal provisions and in 
compliance with the TRATON GROUP’s integrity standards by stating admissible areas of 
support, (in)admissible donations, and sponsoring measures as well as additional process 
rules and thresholds. This policy prohibits any financial or in-kind political contributions, 
whether direct or indirect. 
 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. To monitor 
compliance with and 
effectiveness of the policy, 
benefits in the form of 
donations and sponsoring 
measures must be documented 
and archived by the responsible 
donations or sponsorship 
manager of the brands. 
 Access via intranet and 
communicated in 
compliance training 
Policy for gifts, 
hospitality and 
invitations to 
events and 
conflicts of 
interest (Group 
policy)  
 This policy lays down binding instructions on how to handle benefits granted to natural 
persons or legal entities, including criteria for determining the appropriateness of benefits 
to prevent corrupt behavior. Furthermore, this policy establishes rules for handling conflicts 
of interests. While the policy applies to TRATON employees, it affects several stakeholders 
in the value chain such as business partners, suppliers, and customers. 
 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. 
 Access via intranet and 
communicated in 
compliance training 
 
Actions 
In 2025, the following action was taken in relation to the prevention of corruption and bribery. 
Action addressing the prevention of corruption and bribery 
Action  Description and time horizon  Scope  Target in place  
Overall progress in 2025 and how we 
track effectiveness 
Compliance 
helpdesk 
 The Compliance helpdesk is a service accessible to all TRATON GROUP employees via 
phone and email, providing guidance on a variety of compliance-related inquiries, 
topics, and requests. These may pertain to questions or uncertainties regarding the 
Code of Conduct for Employees, the Policy on handling gifts, hospitality and 
invitations to events, and conflicts of interest, the Group policy on internal 
investigations, the Policy on antitrust compliance, and the Policy on the prevention of 
money laundering and terrorism financing, and other compliance topics. The 
Compliance helpdesk serves as a point of contact for two purposes: first, to address 
inquiries aimed at preventing policy violations, and second, to report potential 
misconduct by employees. In the latter scenario, the matter is referred to the TRATON 
Central Investigation Office. 
 TRATON 
GROUP 
 The target below related to 
the Code of Conduct 
training is connected to 
the compliance helpdesk. 
During the training, 
employees are informed of 
the service.  
 This is a recurring action. Quarterly 
management reports on the number 
and types of compliance-related 
inquiries across all compliance areas.

===== SIDA 370 =====

370  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 
In 2025, the following targets were set regarding the prevention and detection of corruption and bribery. 
Code of Conduct training 
To support employees in applying the Code of Conduct for Employees, Code of Conduct training is offered to all employees of t he TRATON GROUP. All 
employees, except for production and service personnel, are required to complete a web-based training course. For this training, we aimed at a 100% com-
pletion rate throughout the reporting year. 
In the reporting period, 80% (previous year: 94% 16) of the target group completed the web -based training. The difference can be explained by regular em-
ployee turnover, i.e., employees joining and leaving during the training period, as well as the continuing transition to the newly created Group R&D depart-
ment. 
Anti-corruption training 
All TRATON GROUP employees receive training on the Code of Conduct for Employees, which includes education on anti-corruption. In addition, all employ-
ees of the TRATON GROUP, except for production and service personnel, must complete the web-based anti-corruption training, which also includes specific 
anti-bribery content. The training program defines corruption in general and covers topics such as dealing with public officials, gifts, hospitality and invita-
tions, donations and sponsorships, and conflicts o f interest. Employees in the target group must complete the training every three years. The TRATON 
GROUP aims at a 100% completion rate of mandatory anti -corruption training. In 2025, 79% (previous year: 86% 17) of employees in the target group com-
pleted anti-corruption training. The difference is primarily attributable to employee turnover and the transition to the newly created Group R&D department. 
Further, the anti -money laundering and terrorism financing training is a web -based training program for employees who are exposed to higher money 
laundering risks and could become aware of suspicious transactions. These include employees involved in payment services or with direct contact to third 
parties. In a three-year interval, they are trained on the respective policy, the risks of money laundering, red flags, and how to act when they suspect money 
laundering. The TRATON GROUP aims at a 100% completion rate of mandatory anti-money laundering training. In 2025, 73% (previous year: 52%) of employ-
ees in the target group completed the training on money laundering and terrorism financing. The difference is primarily attributable to employee turnover 
and the transition to the newly created Group R&D department. 
In addition to web-based training, the TRATON GROUP offers face-to-face compliance training on a risk-based approach. Participating in corruption training 
is mandatory for all levels. Board members and relevant management functions participate in an additi onal Code of Conduct for Employees training since 
they act as role models and are exposed to higher risks due to their responsibilities. The format is a one -off, face-to-face training session. Based on case 
studies, topics such as fair and free competition, gifts, hospitality, and invitations, conflicts of interest, donations, sponsoring, and charity, and human rights 
 
16 Does not include Scania due to technical system challenges. 
17 The percentage of at-risk functions covered by training programs is calculated by dividing the number of training participants by the number of employees in the target group. Numbers from Scania are 
not included for 2024 reporting as the tracking system was simultaneously updated. This datapoint reveals the participation rate in training sessions focused on Anti-Money Laundering (AML) and Anti-
Corruption (AC). According to ESRS, functions at risk are identified based on their specific tasks and responsibilities.

===== SIDA 371 =====

371  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 
 
 
and environmental protection are discussed. The compliance training program including the anti -corruption training and related target have been dis-
cussed with the TRATON SE Works Council. 
Metrics related to corruption or bribery 
In 2025, no criminal convictions were identified within the TRATON GROUP for breaches of anti -corruption or anti-bribery laws. Convictions for corruption 
and bribery include criminal convictions of a legal entity within the TRATON GROUP. Therefore, the TRATON GROUP incurred no fines as part of convictions 
for a violation of corruption and bribery laws including anti-money laundering in 2025. 
To continuously improve its framework for combating corruption and bribery, the TRATON GROUP is implementing targeted measures designed to prevent, 
detect, and effectively address potential risks. These include root cause analyses for identified violations as well as proactive modifications and optimizations 
of processes and standards. 
TRATON’s grievance mechanism 
TRATON provides centralized channels for employees and external stakeholders to report concerns related to ethical conduct, c ompliance, and human 
rights. Through the DMA, TRATON identified a potential positive impact related to the protection of whistleblowers. 
Impacts, risks and opportunities related to the grievance mechanism 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Protection of 
whistleblowers 
 Potential positive impact  Short-term  Upstream and own operations  Implementing robust speak-up channels promotes 
trust and a transparent culture. 
 
Approaches and policies 
Integrity and compliant conduct in line with applicable statutory regulations, internal policies, as well as the principles laid down in the Code of Conduct for 
Employees and the Code of Conduct for Suppliers and Business Partners are of the highest priority for the TRATON GROUP. To avoid potential violations by 
employees, suppliers, business partners, or other external parties related to TRATON, or minimize the possibility of violations, it is crucial to identify these at 
an early stage. That is why the TRATON GROUP maintains an independent, impartial, and confidential whistleblower system that provides multiple channels 
for employees, business partners, and external parties to report potential violations.  
The potential positive impact that occurs when implementing robust speak-up channels within the Group relates to the Group internal investigations policy 
and the complaints procedure. They are implemented through two actions, in particular, the Speak up! whistleblower portal and regular internal and exter-
nal compliance audits. The 100% participation rate of Code of Conduct for Employees training also relates to this impact and the general sustainability 
matter of protection of whistleblowers. The target and the associated action are described in the Prevention and detection of corruption and bribery section. 
In addition to the policies described in the table below, the Code of Conduct for Suppliers and Business Partners further regulates the protection of whistle- 
blowers.

===== SIDA 372 =====

372  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 the grievance mechanism 
Name of policy  Key contents and objective  Scope  
Responsible organizational 
level and monitoring process  
Availability of the policy for 
stakeholders 
Internal 
investigations 
(Group policy) 
 The internal investigations policy regulates how hints regarding potential violations are 
handled. Violations are all intentional or negligent violations of regulations of applicable 
law (e.g., statutory laws, regulations) or internal regulations (especially violations of the 
Code of Conduct for Employees or employment contractual obligations) committed by 
employees in connection with, or based upon, their employment by the TRATON GROUP. 
It describes the TRATON GROUP’s commitment and process to consequently follow up 
on potential violations, such as corrupt behavior. Standards are set such as general 
procedural rules for implementing and executing internal investigation processes in the 
TRATON GROUP, and the competencies, responsibilities, and cooperation requirements 
to be established within the Group are defined. 
The TRATON Central Investigation Office or Brand Investigation Offices conduct an 
internal investigation. The effectiveness of the policy is measured via the tracking of 
incoming hints, regular reporting, audits, and through an IT-based case management 
system, which documents and archives hints on violations and their processing, including 
the results in compliance with relevant data protection regulations. 
 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. 
 Access via intranet 
Complaints 
procedure 
 The TRATON GROUP’s complaints procedure is an important part of safeguarding the 
corporate values and beliefs and serves to identify potential risks and violations to 
remedy them. It describes generally applicable principles for handling reports of 
potential risks or violations in the TRATON GROUP and across the associated supply 
chains. Anyone within the TRATON GROUP and along its supply chain can submit a report 
or complaint about potential risks or violations. The TRATON Central Investigation Office 
and the Brand Investigation offices operate the internal and external reporting channels. 
The TRATON GROUP ensures that reports of potential violations by TRATON GROUP 
employees and business partners along the supply chain are handled properly.  
 TRATON 
GROUP 
 The effectiveness of the 
complaints procedure is 
measured via the tracking of 
incoming hints, regular 
reporting, and audits. The Head 
of Investigations at TRATON SE 
is responsible for the 
implementation of the policy. 
 Accessible via the website. The 
complaints procedure aligns 
with internationally recognized 
instruments by complying with 
the legal requirements for a 
whistleblower system in 
accordance with the EU 
Whistleblower Protection Act. 
 
Actions 
In 2025, the following action was implemented regarding TRATON’s grievance mechanisms. 
Whistleblower portals  
The TRATON GROUP whistleblower portal Speak Up! is accessible 24/7 in several languages for whistleblowers of the TRATON GROU P workforce to report 
any potential violations e.g., white -collar crime, corruption, antitrust law, and data protection concerns. I t also allows for reporting of violations and risks 
related to human rights and environmental obligations, as well as other internal and statutory regulations. Besides, the whis tleblower portal can be used 
by workers, direct, indirect suppliers, and affected communities to report violations of the Code of Conduct for Suppliers and Business Partners as well as 
violations of environmental laws and human rights. Even if the reporters’ preferred language is not offered in the reporting channel, whistleblowers can use 
any language to submit their report. The whistleblower portal is operated by a third party, which hosts the portal on externa l, certified servers, allowing 
whistleblowers to address hints to the company on an anonymous, non -traceable basis. Besides the electronic Speak Up! whistleblower portal, internal or 
external reports of misconduct can be directed towards the contacts within the TRATON Central Investigation Office by post or email, the 24/7 Volkswagen 
whistleblower hotline, and the ombudspersons of the Volkswagen Group.

===== SIDA 373 =====

373  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 
 
 
After receiving a tip-off, the TRATON Central Investigation Office checks whether it is well-founded. It categorizes the tip-off according to its severity and, if 
appropriate, launches an investigation. It is dedicated to investigating potentially serious violations that could significantly impact the interests of the 
TRATON GROUP, particularly in terms of reputation or financial interests, or that could significantly violate the ethical values of the TRATON GROUP or one 
of its brands. In the event of a con firmed serious violation, the TRATON Central Investigation Office will present the outcome, along with appropriate disci-
plinary measures, to a Disciplinary Committee consisting of several functions. The Disciplinary Committee is chaired by the C hief Compliance Officer of 
TRATON SE and further comprises the Chief Human Resources Officer, the Chief Audit Executive, and the HR Coordinator of TRATON SE for cases concerning 
employees of TRATON SE. For cases concerning employees of a TRATON GROUP brand, the Brand  Chief Executive Officer, Brand Chief Human Resources 
Officer, and Brand Chief Compliance Officer of the brand are included. Furthermore, the Head of the TRATON Central Investigat ion Office provides reports 
to the TRATON Chief Compliance Officer on selective cases on a regular basis and as needed.  
The whistleblower system is designed to protect whistleblowers, the persons concerned, and equivalent individuals. Equivalent  individuals are all persons 
who confidentially support a whistleblower in reporting a hint in a work -related context, individuals who are related to the whistleblower, and who may 
suffer retaliation in a work-related context. Discrimination against them is itself considered a serious violation. The investigation process is based on proce-
dural principles, which include confidentiality, the need-to-know principle, and objectivity. The presumption of innocence applies to all persons concerned, 
as defined in the Internal Investigations Policy. The policy explicitly addresses the prohibition of any form of retaliation against whistleblowers, ensuring 
their protection throughout the investigation process. 
Information about the whistleblower system is available on both the TRATON GROUP website and intranet. Regular and engaging communication measures 
and initiatives are carried out to raise awareness. In addition, TRATON conducts training sessions that are o bligatory for all employees, including Executive 
Board members, and cover information on the TRATON GROUP whistleblower system (see Prevention and detection of corruption and bribery). Specialized 
training is available for key contact points (KCPs) of the whistleblower system. These KCPs are departments that potentially encounter the process of re-
porting, investigating, and sanctioning employee misconduct. 
Actions related to TRATON’s grievance mechanism 
Action  Description and time horizon  Scope  Target in place  
Overall progress in 2025 
and how we track 
effectiveness 
Regular internal 
and external 
compliance 
reports  
 To help ensure compliance with corporate governance, while also increasing corporate 
transparency and accountability across the TRATON GROUP, regular internal reporting related to 
GRC is provided to various boards and committees, including the Audit Committee of the 
Supervisory Board, Executive Board, Compliance Board, Human Rights Committee, and 
Sustainability Board. External GRC-related reporting is also conducted, such as communication on 
TRATON’s website, reports to relevant authorities and to the TRATON GROUP’s investors. GRC-
related reporting is submitted via the digital compliance reporting tool of Volkswagen.  
 TRATON 
GROUP 
 No  This is a recurring action.

===== SIDA 374 =====

374  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 
 
 
Political engagement 
Through the DMA, the following material impacts related to political engagement were identified by TRATON: 
Impacts, risks and opportunities related to political engagement 
Sustainability matter  IRO category  Time horizon  Scope  Description 
Political engagement  Potential negative impact  Long-term  Downstream  Possible impairment of sound decision-making due to opaque or 
questionable political influence 
 Potential positive impact  Long-term  Downstream  Support for a vibrant democracy and informed decision-making through 
transparent political influence. 
 
Approaches and policies 
The policies TRATON Code of Conduct for Employees, Donations and sponsoring, Public Affairs One-Voice Policy and State Aid – Europe, as well as Handling 
gifts, hospitality and invitations to events, and conflicts of interest, relate to both potential impacts described in the table above. There is no process in place 
for tracking these policies’ effectiveness as violations of the policy would be handled in the regular compliance and investi gation processes described 
throughout this section. These were discussed in the previous section.  
Policy addressing political engagement 
Name of policy  Key contents and objective  Scope  
Responsible 
organizational level and 
monitoring process  
Availability of the policy 
for stakeholders 
Public affairs one-
voice-policy and 
state aid — 
Europe (Group 
policy) 
 This policy explains the fundamental procedure of the work process between the TRATON Public 
Affairs department, the brands, and TRATON entities. Regarding handling public affairs in the 
Group, the TRATON brands act independently and on their own responsibility but aligned with the 
TRATON Public Affairs department according to the policy. The key content of the policy includes 
a framework for lobbying, the One-Voice policy, the dotted line principle, an explanation of Group 
relevance, as well as principles and obligations that the TRATON GROUP and its brands must 
follow. Additionally, the application and handling process of the state aid and grant register is 
addressed and explained. 
Regarding the state aid and grant register, TRATON Public Affairs reports directly to the 
Volkswagen Group Public Affairs department, which then prepares an annual report on the state 
aid and grant register applied for and received in the EU by the Volkswagen Group and its brands 
and entities. The necessary data is provided by state aid coordinators or parties responsible for 
installing adequate processes for the appropriate and proper application and handling of the state 
aid and grant register. Furthermore, the Volkswagen Group Public Affairs department must be 
informed about the relevant activities of the brands and entities to support the implementation of 
suitable processes. To identify and track risks arising from the receipt of the state aid and grant  
register, brands and entities are obliged to maintain processes to identify and avoid project -
specific risks. In the event of imminent reputational damage or legal consequences for TRATON 
GROUP or the Volkswagen Group, coordination with the departments of Volkswagen Group Public 
Affairs and TRATON Public Affairs takes place at an early stage. 
 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. 
 Access via intranet

===== SIDA 375 =====

375  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 2025, the following actions were related to TRATON’s political engagement. Regarding the sustainability matter of politica l engagement, no relevant 
actions or targets are reported for 2025 as the potential impacts are already well regulated by TRATON GR OUP policies and procedures, as well as by the 
legislation to which the Group adheres strictly. 
Action related to political engagement 
Action  Description and time horizon  Scope  Target in place  Overall progress in 2025 
Chairmanship of 
ACEA 
Commercial 
Vehicles Board 
2025 
 The TRATON GROUP actively contributes to shaping the sustainable transformation of the 
European transportation sector through industry collaboration. In 2025, Christian Levin, CEO of 
TRATON SE, was elected Chair of the ACEA Commercial Vehicles Board, strengthening TRATON’s 
role and visibility within the European automotive industry. 
This chairmanship provides an opportunity to advance TRATON’s ambition to drive the shift 
towards sustainable and innovative transportation solutions and to represent the Group’s 
perspectives in alignment with the TRATON One-Voice Policy. The engagement supports 
transparent and responsible dialog with EU policymakers and stakeholders on key topics such as 
decarbonization, electrification, and fair market conditions. 
 ACEA is 
focused on 
the European 
market. 
 No target has 
been set because 
it is currently not 
possible to define 
a meaningful and 
measurable 
target due to the 
qualitative nature 
of this topic. 
 In the course of its chair activities in 
2025, TRATON defined key focus 
areas and initiated coordination 
with ACEA working groups. 
Internally, the TRATON GROUP 
coordinated across brands and 
functions to set its own priorities. 
Steering TRATON 
Public Affairs 
through the One-
Voice Policy 
 In 2025, TRATON strengthened internal coordination between the Group Public Affairs 
department and the brands to ensure consistent representation of Group positions in political and 
regulatory discussions. The One-Voice Policy served as the guiding framework to align priorities, 
messaging, and stakeholder engagement activities across all brands. Regular coordination 
meetings and strategic alignment sessions were held to enhance transparency and coherence in 
external advocacy efforts. 
 TRATON 
GROUP 
 No target has 
been set because 
it is currently not 
possible to define 
a meaningful and 
measurable 
target due to the 
qualitative nature 
of this topic. 
 Ongoing alignment activities and 
structured coordination processes 
implemented across brands to 
reinforce unified representation in 
public affairs. 
 
Political influence and lobbying activities 
All political engagement is conducted in accordance with the TRATON GROUP’s strategy and values, with integrity, transparency , and compliance given 
high priority. TRATON SE is listed in the German lobby register for the representation of interests vis -à-vis the German Parliament and the Federal Govern-
ment under registration number R001565. Comparable transparency requirements are also complied with in other jurisdictions. T RATON SE engages in 
transparent, responsible dialog with political and administrative  decision-makers at European, national, and regional level, as well as with relevant stake-
holder groups. The aim of this engagement is to monitor regulatory and political developments, contribute relevant expertise where appropriate, and ensure 
coordinated and consistent representation of the Group’s interests. Activities within TRATON SE focus on coordination, governance, and ha rmonization 
within the Group. This includes ensuring a uniform corporate image, fostering the exchange of information between the Group and its brands, and ensuring 
compliance with applicable laws, transparency regulations, and internal policies. Responsibility for the content of technical, regulatory, or political positions 
lies with the relevant Group functions and brands. The TRATON GROUP’s responsibilities for monitoring lobbying activities are set out in the TRATON Code 
of Conduct for Employees and other Group policies (handling donations and sponsorship activities, public affairs One Voice policy, and state aid — Europe, 
as well as handling gifts, hospitality and invitations to events, and conflicts of interest). The Executive Board is responsible for approving these regulations. 
Since the Handling of donations and sponsoring measures policy of TRATON (see the table on Policies addressing corporate culture) does not allow political 
donations, the amount of political contributions (monetary and in-kind) made in 2025 was €0.

===== SIDA 376 =====

376  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 
 
 
Notes to the Sustainability Report 
References 
Incorporation by reference 
The table below provides an overview of where information can be found relating to ESRS disclosures that have been incorporated by reference and stated 
outside of the sustainability report. 
Disclosure Requirement  Data point(s)  Paragraph  Reference 
GOV-1  §21a-d 
§23, §23a 
   Corporate Governance Statement 
GOV-3 
E1.GOV-3 
 §27 
§29a-e 
§13 
 Information on sustainability-
linked remuneration 
 Remuneration Report  
GOV-5  §36a-e  Information on risk management 
and controls 
 Report on opportunities and risks  
 
Disclosure requirements covered in the TRATON GROUP Annual Report 2025 
The table below provides an overview of ESRS datapoints and indicates where the relevant information can be found if deemed material. 
Disclosure Requirement    Reference 
ESRS 2 BP-1  General basis for preparation of the sustainability report  Basis for preparation 
ESRS 2 BP-2  Disclosures in relation to specific circumstances  Basis for preparation 
Double materiality assessment 
ESRS 2 GOV-11  The role of the administrative, management and supervisory bodies  Sustainability governance  
Corporate Governance Statement 
ESRS 2 GOV-2  Information provided to and sustainability matters addressed by the undertaking’s administrative, management 
and supervisory bodies 
 Sustainability governance 
ESRS 2 GOV-3  Integration of sustainability-related performance in incentive schemes  Remuneration Report  
ESRS 2 GOV-4  Statement on due diligence  Statement on due diligence 
ESRS 2 GOV-5  Risk management and internal controls over sustainability reporting  Report on opportunities and risks  
ESRS 2 SBM-1  Strategy, business model and value chain  Business model and value chain 
Characteristics of the undertaking’s 
employees 
ESRS 2 SBM-2  Interests and views of stakeholders  Double materiality assessment

===== SIDA 377 =====

377  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 
 
 
Disclosure Requirement    Reference 
ESRS 2 SBM-3  Material impacts, risks and opportunities and their interaction with strategy and business model   Business model 
Material impacts, risks and opportunities and 
their interaction with strategy and business 
model 
Double materiality assessment 
IRO descriptions at the beginning of all 
topical standards 
ESRS 2 IRO-1  Description of the process to identify and assess material impacts, risks and opportunities   Double materiality assessment 
ESRS 2 IRO-2  Disclosure Requirements in ESRS covered by the undertaking’s sustainability report   References 
Double materiality assessment 
E1 ESRS2 GOV-3  Integration of sustainability-related performance in incentive schemes  Remuneration Report  
E1 ESRS 2 IRO-1  Description of the processes to identify and assess material impacts,  
Risks and opportunities 
 Double materiality assessment 
E1-1  Transition plan for climate change mitigation  Decarbonization — Actions 
E1 ESRS 2 SBM-3  Material impacts, risks and opportunities and their interaction with strategy and business model   Material impacts, risks and opportunities and 
their interaction with strategy and business 
model 
Double materiality assessment 
Decarbonization — Approaches and policies 
E1-2  Policies related to climate change mitigation and adaptation  Decarbonization — Approaches and policies 
E1-3  Actions and resources in relation to climate change policies  Decarbonization — Actions 
E1-4  Targets related to climate change mitigation and adaptation  Decarbonization — Actions 
E1-5  Energy consumption and mix  Decarbonization — Performance 
E1-6  Gross Scopes 1, 2, 3 and Total GHG emissions  Decarbonization — Performance 
E1-7  GHG removals and GHG mitigation projects financed through carbon 2 credits  TRATON does not use GHG removals and 
GHG mitigation projects 
E1-8  Internal carbon pricing  TRATON does not use internal carbon pricing 
E1-9  Anticipated financial effects from material physical and transition risks and potential climate -related 
opportunities 
 TRATON uses the option to phase in this 
disclosure requirement in line with ESRS 1 
Appendix C 
E2 ESRS 2 IRO-1  Description of the processes to identify and assess material impacts, 
Risks and opportunities 
 Double materiality assessment 
E2-1  Policies related to pollution  Pollution — Approaches and policies 
E2-2  Actions and resources related to pollution  Pollution — Actions 
E2-3  Targets related to pollution  Pollution — Actions 
E2-4  Pollution of air, water and soil  Pollution — Performance 
E2-5  Substances of concern and substances of very high concern  Pollution — Performance 
E2-6  Anticipated financial effects from material pollution-related risks and opportunities  TRATON uses the option to phase in this 
disclosure requirement in line with ESRS 1 
Appendix C

===== SIDA 378 =====

378  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 
 
 
Disclosure Requirement    Reference 
E4 ESRS 2 IRO-1  Description of the processes to identify and assess material impacts, 
Risks and opportunities 
 Double materiality assessment 
E4-1  Transition plan and consideration of biodiversity and ecosystems in strategy and business model   TRATON uses the option to phase in this 
disclosure requirement in line with ESRS 1 
Appendix C 
E4 SBM-3  Material impacts, risks and opportunities and their interaction with strategy and business model   Biodiversity — Actions 
E4-2  Policies related to biodiversity and ecosystems  Biodiversity — Approaches and policies 
E4-3  Actions and resources related to biodiversity and ecosystems  Biodiversity — Actions 
E4-4  Targets related to biodiversity and ecosystems  Biodiversity — Actions 
E4-5  Impact metrics related to biodiversity and ecosystems change  Biodiversity 
E4-6  Anticipated financial effects from material biodiversity and ecosystem-related risks and opportunities  TRATON uses the option to phase in this 
disclosure requirement in line with ESRS 1 
Appendix C 
E5 ESRS 2 IRO-1  Description of the processes to identify and assess material impacts, 
Risks and opportunities 
 Double materiality assessment 
E5-1  Policies related to resource use and circular economy  Circularity — Approaches and policies 
E5-2  Actions and resources related to resource use and circular economy  Circularity — Actions 
E5-3  Targets related to resource use and circular economy  Circularity — Actions 
E5-4  Resource inflows  Circularity — Performance 
E5-5  Resource outflows  Circularity — Performance 
E5-6  Anticipated financial effects from material resource use and circular economy-related risks and opportunities  TRATON uses the option to phase in this 
disclosure requirement in line with ESRS 1 
Appendix C 
S1 ESRS 2 SBM-2  Interests and views of stakeholders  Own workforce — Approaches and policies 
S1 ESRS 2 
SBM-3 
 Material impacts, risks and opportunities and their interaction with strategy and business model   Material impacts, risks and opportunities and 
their interaction with strategy and business 
model 
S1-1  Policies related to own workforce  Own workforce — Approaches and policies 
S1-2  Processes for engaging with own workforce and workers’ representatives about impacts   Own workforce — Employee representation 
Own workforce — Frameworks for employee 
engagement 
S1-3  Processes to remediate negative impacts and channels for own workforce to raise concerns   Own workforce — Employee representation 
Own workforce — Frameworks for employee 
engagement 
TRATON’s grievance mechanism 
S1-4  Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing 
material opportunities related to own workforce, and effectiveness of those actions  
 Own workforce — Actions 
Own workforce — Performance 
S1-5 1  Targets related to managing material negative impacts, advancing positive impacts, and managing material risks 
and opportunities 
 Own workforce — Performance 
S1-6  Characteristics of the undertaking’s employees  Own workforce — Performance

===== SIDA 379 =====