Annual Report 2025 – ÖBB-Infrastruktur AG

ÖBB-Infrastruktur Aktiengesellschaft Group Management Report | Consolidated Financial Statements 124 1) Unless adopted for the entire ÖBB Group, the strategies are approved by the relevant member of the Management Board and apply to the company specified therein. 2) Strategies are adopted by the Management Board of ÖBB-Infrastruktur AG and apply to the ÖBB-Infrastruktur Group. The ÖBB Group is committed to human rights, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the international labour standards of the International Labour Organisation (ILO) – and expects the same from its suppliers. Our collaboration with key suppliers is based on clear requirements (see the ‘Policies’ table): The General Terms and Conditions cover, among other things, health and safety at work, data protection, measures against wage and social dumping, and regulated working hours, including for subcontractors. The Supplier Code of Conduct supplements these with ethical principles and requires compliance with international standards. Acceptance of the Code is carried out via the procurement system. In general, these provisions apply to all workers throughout the value chain, although certain key issues relate specifically to particular groups. The guidelines and the “Sustainable Procurement” toolbox are aimed at purchasers within the ÖBB Group and are, therefore, also applied within the ÖBB-Infrastruktur Group. They help ensure that sustainability principles are upheld in procurement. The issues of “ modern slavery”, “forced labour”, “child labour”, “human trafficking” and restrictions on employees’ freedom of movement are also addressed in the Supplier Code of Conduct. To assess relevant suppliers, external sustainability assessments are required, which also cover the topics of “Human rights” and “Sustainability management in the supply chain”. In addition, on-site audits can be conducted if required. At the same time, suspected cases within the supply chain can also be reported to ÖBB via direct contact with buyers, project staff or end users. In addition, employee representatives are consulted, for example, when analysing material risks in the value chain. Where relevant contracts are awarded, trade unions and other social partners are involved: e.g. to take into account the needs of particularly vulnerable groups. S2-2 Processes for engaging the workforce in the value chain regarding impacts As part of the double materiality analysis and the stakeholder round-tables in 2024 and 2025, official representatives of workers in the value chain were involved and were also consulted on risks to vulnerable groups. The materiality analysis will be updated regularly in future. S2-K-4 Sustainable procurement toolbox” The toolbox contains tender criteria that have been reviewed in accordance with public procurement law to ensure that sustainability considerations are taken into account in procurement. It is continuously updated and includes, amongst other things, criteria relating to social sustainability labels, improving health and safety at work, and equality (diversity, accessibility, the employment of older workers, the use of apprentices, gender and diversity, and social responsibility). The scope covers the upstream and, to some extent, downstream value chain. The content is coordinated by Holding Group Procurement in collaboration with subject matter experts; responsibility lies with the Chief Procurement Officer. S2-K-5 #INFRA sustainabilitystrategy 2) #INFRA.sustainabilitystrategy sets out key priorities and operational objectives, including in the social sphere, and complements #INFRA.mobilitytransition. The strategy defines the following strategic priorities for topics relating to workers in the value chain: We ensure that sustainability objectives are reflected and adhered to by integrating them into procurement processes, while also focusing on social issues within the value chain. We are further developing our supply chain risk management with regard to location and sector-specific risks, in order to identify priorities and prevent potential breaches. We promote the knowledge level of our employees through training and continuing education programmes in the area of sustainable procurement and the social aspects of the value chain. We take part in research projects and industry initiatives aimed at improving our understanding of the value chain and developing further social criteria.