ÖBB Annual Report 2025

Group Management Report 158 Österreichische Bundesbahnen-Holding Aktiengesellscha ft Consolidat ed Financial Statements | Group M anagement Report 115 1) Unless adopted for the entire ÖBB Group, the strategies are decided by the relevant Board of Management and apply to the company defined therein. ESRS 2.MDR-P.65.b, c; ESRS S2-1.16, 18; ESRS S2-4.35. 2) ESRS 2.MDR-P.65.a. 3) ESRS 2.MDR-P.65.b, c. The ÖBB Group is committed to upholding human rights, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the international labor standards of the International Labour Organization (ILO) and expects its suppliers to do the same. Cooperation with key suppliers is based on clear requirements (see the “Policies” table): The GTCs regulate matters including occupational safety, privacy, data protection, actions to combat wage dumping and social dumping, and regulated working hours, not least for subcontractors. The SCC supplements these with ethical principles and an obligation to comply with international standards. Suppliers indicate their agreement to the code via the purchasing system. In general, these provisions apply to all workers in the value chain, with some key issues affecting specific groups in particular. The Guidelines for Sustainable Purchasing and the Sustainable Procurement Toolbox are aimed at purchasers within the ÖBB Group and aid compliance with sustainability principles in purchasing activities. The issues of “ modern slavery,” “forced labor,” “child labor,” and “human trafficking” and the restriction of employees’ personal freedom of movement are also addressed in the SCC. ESRS S2-1.16, 17.a, 18, 19; ESRS S2-2.22.d To assess relevant suppliers, external sustainability assessments are also requested that also cover the topics of “human rights” and “sustainability management in the supply chain.” In addition, on-site audits are carried out directly by the ÖBB Group’s sub-groups on a case-by-case basis. At the same time, suspected violations in the value chain can also be reported to ÖBB directly. ESRS S21.17.a No. Policies 1) Description 2) S2-K-1 General Terms and Conditions for Supplier Relationships The General Terms and Conditions (GTCs) of the ÖBB Group set out a binding framework for working together with suppliers, including the provision of sustainability data, product safety requirements, social standards, privacy, and data protection. Actions to prevent wage dumping and social dumping are also stipulated, as is the requirement for potential subcontractors to comply with labor rights and apply protective regulations. The GTCs are applied along the upstream and, in some cases, downstream value chain. Their content is shaped by Group Purchasing in ÖBB Holding in coordination with the Group companies, with the responsibility established by a resolution of the Board of Management. 3) Where relevant, aspects of inclusion, in particular accessibility, are taken into account. 1) S2-K-2 Supplier Code of Conduct (SCC) The Supplier Code of Conduct (SCC) sets out the ÖBB Group’s requirements for the business conduct of its suppliers. It addresses key sustainability matters such as corruption, privacy, data protection, intellectual property rights, human rights, diversity, working conditions, and safety as well as the prohibition of forced labor, modern slavery, child labor, and human trafficking. Suppliers are required to apply the principles defined in the SCC along their entire supply chain. It is applied along the upstream and, in some cases, downstream value chain of the ÖBB Group’s suppliers. The Group Purchasing department of the holding company is responsible for revising the content in coordination with the Group companies, with the responsibility established by a resolution of the Board of Management. 3) The SCC requires the promotion of equal opportunities and fair treatment of employees regardless of sex, gender, sexual orientation, age, nationality or cultural and ethnic affiliation, social background or political affiliation, religion and world view, physical or mental disability, marital status or pregnancy, and membership in employee organizations including trade unions. 1) 2-K-3 Guidelines for Sustainable Procurement The guidelines set out principles for sustainability in ÖBB’s purchasing activities and are intended for strategic purchasers (lead buyers) within the Group. In particular, they address ensuring due diligence along the supply chain and applying sustainability criteria in tenders. They are applied along the upstream and downstream value chain. The Group Procurement department of the holding company is responsible for revising the content in consultation with the lawyers, with approval being given by the Chief Procurement Officer. 3) No specific groups of workers in the value chain are addressed. 1) S2-K-4 “Sustainable Procurement” Toolbox The toolbox contains tender criteria that have been reviewed under public procurement law and are geared toward taking sustainability matters into account in purchasing activities. It is updated on an ongoing basis and includes criteria for social sustainability seals and for improving occupational safety and equal rights (diversity, accessibility, the employment of older workers, the use of apprentices, gender, diversity, and social responsibility). It is applied along the upstream and, in some cases, downstream value chain. Its content is coordinated by the Group Procurement department of the holding company together with industry experts, with the Chief Procurement Officer holding overall responsibility. | MR115 E.  Non-financial statement E.1. General information E.2. Environmental inform ation E.3. Social information E.4. Governance information E.5. ESRS index