Annual Report 2025 – ÖBB-Infrastruktur AG

ÖBB-Infrastruktur Aktiengesellschaft Group Management Report | Consolidated Financial Statements 123 However, beyond these existing measures addressing the issue of “Workers in the value chain”, no material positive impacts, risks or opportunities were identified as part of the double materiality analysis. The potential negative impact on workers in the value chain has been identified in relation to the value chains associated with the procurement priorities of the ÖBB-Infrastruktur Group. This is because the expansion of railway infrastructure and renewable energy forms part of sustainable mobility provision, which is, however, also dependent on the raw materials involved and the intensity of raw material use. In 2024, stakeholder consultations were held on the topic of “Workers in the value chain” in order to assess risks. Building on this, three stakeholder round-table discussions have been held over the past two years, during which participants identified, discussed and assessed risks in key sectors. In this context, there was a discussion as to whether workers with certain characteristics or those working in a particular environment might be more at risk from material risks. Stakeholders indicated that the safety of employees working at sites operated by the ÖBB-Infrastruktur Group may be more vulnerable to potential risks. Furthermore, potential solutions for addressing the risks were identified. S2-1 Policies related to value chain workers The following policies play a decisive role for the ÖBB-Infrastruktur Group in relation to the material impacts, risks and opportunities associated with the workforce in the value chain [S2-A-1]: No. Policies 1) Description S2-K-1 General Terms and Conditions for supplier relationships The ÖBB Group’s General Terms and Conditions (GTC) set out binding framework conditions for working with suppliers – including the provision of sustainability-related data, product safety requirements, social standards and data protection. Measures to combat wage and social dumping, as well as compliance with labour rights and safety regulations by potential subcontractors, are also mandatory. The General Terms and Conditions apply to the upstream and, in some cases, downstream parts of the value chain. The content is determined by ÖBB-Holding Group Procurement in consultation with the Group companies, with responsibility being assigned by a resolution of the Management Board. Where relevant, aspects of inclusion – in particular, accessibility – are taken into account. S2-K-2 Supplier Code of Conduct (SCC) The Supplier Code of Conduct (SCC) defines the requirements of the ÖBB-Holding Group regarding the business conduct of its suppliers. It addresses key sustainability issues such as corruption, data protection and intellectual property rights, human rights, diversity, working conditions and safety, as well as the prohibition of forced labour, modern slavery, child labour and human trafficking. Suppliers are required to pass on the principles set out in the SCC throughout their entire supply chain. The scope covers the upstream and, to some extent, downstream value chain of the ÖBB Group’s suppliers. The content was revised by Holding Group Procurement in consultation with the Group companies, with the decision being taken by the Management Board. The SCC is committed to promoting equal opportunities and fair treatment of employees, regardless of gender, sexual orientation, age, nationality, cultural or ethnic background, social background, political affiliation, religious beliefs or philosophical views, physical or mental disability, marital status, pregnancy, or membership of employee organisations, including trade unions. 2-K-3 Guidelines for sustainable procurement The guidelines set out principles for sustainability in ÖBB’s procurement and are aimed at strategic buyers (lead buyers) within the Group. In particular, it addresses the ensuring due diligence obligations are met throughout the supply chain, as well as the application of sustainability criteria in tenders. The scope of application covers the upstream and downstream value chain. The content is revised by Holding Group Procurement in consultation with the Legal Department and approved by the Chief Procurement Officer. No specific groups of workers in the value chain are addressed.