ÖBB Annual Report 2025

181 Group Management Report Österreichische Bundesbahnen-Holding Aktiengesellschaft Consolidated Financial Statements | Group Management Report 138 Sensitization One of the core tasks of the compliance organization is to raise ÖBB employees’ awareness of compliance-relevant topics in a lasting manner. Target group-oriented and risk-oriented training and awareness-raising actions are carried out. These can be face-to-face events, training via video conference or an e-learning program that is redesigned and rolled out every three years. ESRS G1-3.20, 21.a The training courses focus in particular on the following topics to convey compliance concepts: corruption (including bribery, corruptibility, benefits), conflicts of interest (especially related to tenders), white-collar crime, secondary employment, and the whistleblower system. ESRS G1-3.21.a Due to their status as public officials, all ÖBB employees can be regarded as persons in high-risk functions. Over 90% (py: >90%) of all ÖBB employees that have their own ÖBB e-mail address are covered by the training programs offered (face-to-face training and/or e-learning), including those identified as members of an administrative, management, or supervisory body. According to the definition in the ÖBB Group, this includes the Supervisory Board members of the ÖBB companies as well as members of the Board of Management, managing directors and managers at all management levels (management levels A and B). ESRS G1-3.21.a, b, c Corruption and bribery incidents In the 2025 financial year, there were no convictions of ÖBB employees related to corruption offenses within the meaning of the Austrian Criminal Code (py: 0). ESRS G1-4.24.a Actions to address violations of anti-corruption and anti-bribery procedures and standards include, but are not limited to: ESRS G1-4.24.b – Personnel and labor law actions – Systemic and procedural actions, e.g.: • Ongoing adaptation of internal processes and regulations based on findings from tracking cases • Key topics for compliance training • Carrying out extraordinary audits • Compliance risk analyses MR138 | ÖBB-Holding/Konzernstrategie, Unternehmensentwicklung und -organisation TLP grün (ÖBB-K nzern intern) 1 Compliance organisation – What we do Prevention Detection Reaction Compliance Goals / Compliance Culture / Compliance Organisation Communication Compliance System Audits Policies & Procedures Trainings Sanctions and Fraud Management Whistleblowing Advisory Services Ad hoc Audits Risk Analysis Case Tracking Remediation 06.06.25 7 E.4. G1 Corporate management