ÖBB Annual Report 2025

Group Management Report 84 Österreichische Bundesbahnen-Holding Aktiengesellschaft Consolidated Financial Statements | Group Management Report 41 In order to adapt our own policies to the current status of international requirements, our existing policies (Code of Conduct, Supplier Code of Conduct, ÖBB internal Equal Opportunities Policy) were revised in 2024 on the basis of a market environment analysis and a review of the aforementioned international frameworks. – In addition to the section on “Human rights,” information on equality as well as specific standards, actions and grievance mechanisms with respect to equal opportunities, diversity and inclusion in the ÖBB Group can be found in Chapter E.3 “Social information” under S1 “Own workforce.” – Information on compliance management and the protection of whistleblowers can be found in Chapter E.4 “Governance information.” – Information on monitoring and grievance mechanisms can be found in the respective Chapters E.3 “Social information” as well as E.4 “Governance information.” Outside Austria, the issue primarily affects the Rail Cargo Group. 4,000 employees work for the sub-group internationally. The members of the Rail Cargo Group Board of Management and the respective managing directors signed the “Children’s Rights, Human Rights and Forced Labor Policy” in 2019. The established human rights policy is intended to ensure the human rights of all employees at all sites. It is intended to exclude labor practices that violate human rights, such as child labor, forced labor, human trafficking and exploitation. Throughout the ÖBB Group, there have been no human rights-related incidents to date among employees, service providers, suppliers, consumers or end-users. On this basis, there is currently no need to implement further specific remedial measures or additional actions that go beyond the actions, policies and processes described. ESRS S1-20.c, 21, 22; ESRS S4-16.b, c, 17 Privacy of consumers and end-users (customers) Protecting the privacy of customers and complying with the General Data Protection Regulation (GDPR) by processing personal data lawfully, transparently and for a specific purpose are high priorities within the ÖBB Group. Strict measures for data minimization, confidentiality and security ensure the responsible handling of sensitive information. In addition, the rights of data subjects (such as access, rectification and erasure) are comprehensively safeguarded. ESRS S4.16.b, c, 17 Fair competition and transparency The ÖBB Group is fully committed to fair competition and respects the legal framework of free competition. In their business activities, ÖBB companies must comply with the legal regulations in the respective country in their business activities – national competition law and, for members of the EU or the EEA, with European competition law as well as with national special competition law. Unfair business practices, price fixing or market manipulation will not be tolerated. Adherence to these standards is ensured by internal compliance systems, regular training for employees and external audits. Responsibility in taxation As one of Austria’s largest employers, the ÖBB Group makes a significant contribution to tax revenue in the Republic and is committed to a responsible tax policy. Tax avoidance or aggressive tax planning are rejected. All tax payments are made in accordance with the applicable laws and in the country in which the economic value creation takes place. Strategy Strategy, business model and value chain Strategy development process in the ÖBB Group ÖBB-Holding AG defines the strategy for the entire Group. The individual companies adapt their own strategies accordingly and implement projects. The strategy is reviewed once a year and adapted if necessary. The most important information on the corporate group strategy and business model can be found in Chapter B.1 Projected development. Detailed, strategically relevant information on material impacts, opportunities and risks is explained in the corresponding topic-specific ESRS disclosures. Information on the business model of the ÖBB Group can be found in Chapter A.1 Report on business performance, subchapter “Structure and investments.” | MR41 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