Management of impacts, risks and opportunities

G1-1 – Business conduct concepts and corporate culture

Energie AG puts great value on an open, respectful and appreciative corporate culture that offers scope for innovation and fresh ideas while creating an environment in which employees can enjoy their work. Every individual should have the chance to reach their full potential and contribute different perspectives.

Given the profound changes in the energy sector, it is all the more important to foster a culture that can cope with a volatile macroeconomic environment, anticipate change at an early stage and maintain a consistent focus on customers. It is also essential to embed innovations within the company at an early stage in order to strengthen Energie AG’s innovative capacity on a sustainable basis.

Cultural work aims to align cultural orientation with the company’s strategic objectives. The transformation is shaped by themes of change, culture and agility. Staff at all levels of the hierarchy play a key role: Cultural Change Agents act as ambassadors for cultural topics and embody change within their respective areas. It is important for Change Agents to exchange ideas with colleagues as well as with senior executives across departments.

Change occurs when it is modelled and consistently driven forward by senior executives. Low-threshold information formats were developed and rolled out to strengthen senior executives' strategic understanding and implementation capabilities. These formats support senior executives in fulfilling their role as translators and ambassadors of the strategy.

Agile Coaches support the implementation of agile projects and promote an appropriate minimum standard across the company. In addition, the ‘Agile Leadership for Action’ (ALFA) initiative has established a group of senior executives that actively promotes agility within the organisation, creates appropriate framework conditions and enables new forms of work. The main task of this group is to regularly evaluate the progress of Energie AG’s agile transformation.

Agility is intended to be made visible within the company. For this reason, agile pilot projects involve as many stakeholders as possible (Agile Coaches, project staff, senior executives) in order to reduce reservations and build familiarity with the topic. In addition, these projects are accompanied by targeted communication measures to ensure broad impact across the organisation.

To optimise internal processes and operating procedures, internal ideas competitions (‘NEULAND’ project, ‘Loominati’ platform) are held to draw on the wealth of practical experience and creative potential of its employees.

Cultural transformation – Cultural Compass

Corporate culture

Content: The Culture Compass defines six cultural directions: future viability, cooperation and partnerships, customer experiences, responsibility, sustainability and diversity. The accompanying Culture Compass Platform serves as a tool to support cultural transformation. Employees can submit initiatives that contribute to one of these six directions. These initiatives demonstrate how culture and strategy are embedded in day-to-day operations and also serve as inspiration for other areas (e.g. sharing expertise, promoting cross-departmental cooperation).

General objectives: The Culture Compass and the associated Culture Compass Platform aim to make corporate culture visible and to actively involve employees in cultural development. This increases employee satisfaction and enables employees to identify with the corporate culture, as their ideas and initiatives contribute directly to shaping it. At the same time, it fosters a common understanding of how strategic and cultural values can be lived in day-to-day cooperation.

Material impacts, opportunities and risks:

Also see SBM-3 – Material impacts, risks and opportunities and their interaction with the strategy and business model.

Monitoring process: The initiatives are reviewed and considered by the project team on submission and further steps are communicated to the employees.

Scope: The scope of the Cultural Compass covers employees in Austria.

Responsibilities: Management Board, managing directors of the Group companies, holding company managers, employees

The Group Strategy holding unit, which also oversees organisational development, acts as the central driver for ‘Change and Culture’ within the Energie AG Group, thereby supporting the transition to a sustainable corporate culture. The managing directors and the management of the Group companies as well as the holding company managers are responsible for advancing actions that promote this shared culture in their divisions and contributing to this cultural transformation.

Involvement of stakeholders: The Cultural Compass was developed through a bottom-up process combined with a top-down process. Involving managers and employees in the development process meant that their views and interests were taken into account.

Implementation support: The Cultural Compass was distributed to all employees in Austria and is also available in digital form on the intranet. It has already been introduced to the Management Board and senior executives. In addition, the Group newsletter provides regular information on ‘Change and Culture’.

Transparent values – Code of Conduct ‘This is how we think; this is how we act’

Protection of whistleblowers, corruption and bribery; measures against violence and harassment at work

Content: Energie AG is fully committed to the highest standards of reliability, quality and integrity - both as a business partner and as an employer. This principle forms the foundation for trustworthy cooperation with customers, suppliers, employees, internal partners and other stakeholders.

A central concern for Energie AG is to communicate its ethical and moral principles clearly, transparently and in a way that is easy to understand. These values are firmly embedded in the corporate culture and inform all business processes. Compliance with applicable laws, regulations and internal policies is not only a legal obligation, but also a core element of responsible and sustainable corporate governance.

Targeted compliance measures, regular training and an open communication culture ensure that all employees are aware of, understand and apply ethical standards in their day-to-day work. Preventive measures such as training courses and contact points, as well as associated guidelines for conflicts or psychosocial crises, raise awareness of these issues, contribute to a respectful working environment and prevent misconduct such as bullying. In doing so, Energie AG fosters an environment characterised by integrity, fairness and mutual respect – thereby laying the groundwork for long-term economic success and strong societal acceptance.

General objectives: The Code of Conduct is intended to act as a guideline and decision-making aid to help employees act appropriately. In addition to its internal organisation, Energie AG regards its business partners as an essential component of responsible and sustainable economic activity. In this context, the Code of Conduct serves as a key policy document, setting out clear expectations regarding ethical behaviour, integrity and lawful conduct. Alongside the Code of Conduct ‘This is how we think; this is how we act’, the Code of Conduct for Contractors applies to employees and all external partners; see also S2-1 Concepts related to value chain workers.

Material impacts, opportunities and risks:

Also see SBM-3 – Material impacts, risks and opportunities and their interaction with the strategy and business model.

Monitoring process: Topics covered by the Code of Conduct are monitored using compliance checks, see G1-1 - Business conduct concepts and corporate culture, Comprehensive compliance management.

The Code of Conduct explicitly refers to the reporting channels and the whistleblower protection system. In addition, employees may report unlawful conduct or behaviour that contradicts the Code of Conduct or similar internal rules to their line manager, the responsible management, the Compliance Officer or the Group Internal Audit holding unit.

Energie AG’s Code of Conduct is not only a central instrument for guiding ethical conduct towards domestic business partners, but also an integral element of the corporate culture. To ensure that all employees are familiar with the values and standards of conduct it sets out, the Code forms an important part of the onboarding process for new staff and is incorporated into the compliance training concept. This training raises awareness of compliance-related matters and promotes a common understanding of appropriate behaviour in day-to-day work. In this way, Energie AG ensures that its core ethical principles are not merely documented but actively practised.

Energie AG’s compliance training concept constitutes a central component of the Group-wide compliance management system and reflects senior management’s responsibility to foster a living culture of compliance. Its purpose is to establish and strengthen rule-compliant behaviour through targeted training and ongoing development measures. The objective is not only to raise awareness of legal and ethical standards, but also to contribute sustainably to ESG compliance.

The concept is based on two complementary perspectives. On the one hand, the Compliance Officer defines binding minimum training standards that apply across the Group. These include mandatory e-learning modules on anti-corruption, data protection and antitrust law for new employees as part of online learning, as well as regular repetition of this content at specified intervals. Employees without PC access are also included through in-person training. In addition, specially designated intervention teams, which may be required to act in the event of a house search, participate in annual refresher training. On the other hand, senior executives in the holding company and in the business and service units are responsible for defining additional training measures tailored to the specific needs of their respective areas. In doing so, they are supported by the Compliance Officer and the Compliance Coordinator of the relevant business unit. Compliance-related training objectives can already be incorporated into the MbO target-setting process.

Scope: The Code of Conduct applies to all employees of the Energie AG Group and to all individuals performing equivalent functions to employees (e.g. temporary workers). This includes all employees and members of the Management Board of Energie AG Oberösterreich and members of the management bodies of Group companies in which Energie AG holds a participating interest of more than 50% or over which Energie AG can exercise a controlling influence. All other companies in which Energie AG holds a direct or indirect interest are also advised to implement this Code of Conduct. The Code of Conduct also allows customers, suppliers and other business partners to acquaint themselves with the guidelines and use them as a guide when conducting business with Energie AG.

Responsibilities: Management Board, managing directors of the Group companies, holding company managers, employees

Stakeholder involvement: The Code of Conduct was created as part of a joint project by the Energie AG Compliance Officer in cooperation with several specialist departments and with the involvement of employees and managers.

Implementation support: The Code of Conduct ‘This is how we think; this is how we act’ is available both on the intranet and on the Energie AG homepage.

Strengthening innovative power

Corporate culture

Content: The framework for Energie AG's innovation work is formed by the Group's overall strategy. It covers all types of innovation (processes, products/services, business models) and combines centralised and decentralised activities.

General objectives: Innovation work seeks to strengthen the Group's innovative power, to promote the development of innovations within the Group and to open up new sources of revenue and value creation for the Group through new products, services and business models. The six defined themes, which provide the strategic focus for innovation activities, offer clear direction: full circularity (identifying, enabling and closing material cycles); decarbonisation and sustainability (accelerating decarbonisation and acting sustainably); climate change fitness (continuous adaptation to climate change and its impacts); leveraging decentralisation (facilitating decentralised energy generation and energy use); energy efficiency and minimal resource use (reducing energy consumption and minimising resource use); and utilising technological tools (to enhance the quality and efficiency of work within Energie AG and to mitigate the effects of demographic changes).

Material impacts, opportunities and risks:

Also see SBM-3 – Material impacts, risks and opportunities and their interaction with the strategy and business model.

Monitoring process: on-going reporting to the Management Board; promote innovation activities and define innovation priorities and governance through an interdisciplinary Innovation Board

Scope: The Group Innovation holding unit supports the innovation work of all units of the Group. This team also implements its own innovation activities (business-related and directly attributable) and is responsible for them ((de)centralised approach as a strategic guardrail). The innovation work is also targeting external expansion and the development of a beneficial innovation ecosystem for the Energie AG Group.

Responsibilities: Management Board, managing directors of Group companies, holding company managers

Stakeholder inclusion: The strategic guardrails for innovation were developed with external support as part of the ‘Innovation’ module of the ‘LOOP’ strategy and organisation project.

Implementation support: The innovation measures are communicated to the Management Board, senior executives and the wider workforce (e.g. via the Group newsletter, internal communication platform, intranet, employee magazine, etc.).

Active ideas management

Corporate culture

Content: Ideas management is the process through which employees can contribute their ideas for improving processes and structures within the Energie AG Group. Employees identify areas for improvement and are recognised by having their suggestions for improvement taken seriously and, where possible, implemented. Ideas management is also used to ensure that successful ideas are maintained and that Group processes and procedures are continuously developed and improved. Suggestions can be made for technical improvements as well as for administrative or organisational processes and structures.

General objectives: The primary goal of ideas management is to leverage the expertise and creative potential of the Group's employees for continuous improvement.

Material impacts, opportunities and risks:

Also see SBM-3 – Material impacts, risks and opportunities and their interaction with the strategy and business model.

Monitoring process: The Technical Management holding unit acts as a central organiser and is responsible for maintaining and developing ideas management and for the corresponding central communication activities (including reporting to the Management Board). Contact persons in Technical Management support the ideas management process from the submission of the improvement suggestion to its implementation and approval, including the associated reporting. The ‘Guidelines for Ideas Management’ were created to supplement the ‘Ideas management at Energie AG Oberösterreich’ Group Policy. In the 2024/25 fiscal year, 300 ideas were submitted (previous year: 236).

Scope: The Group policy and the guidelines apply to the Energie AG Group and are available in German.

Responsibilities: Management Board, managing directors of the Group companies, holding company managers, employees

Stakeholder involvement: A comment process, regulated in the ‘Rules for the preparation and amendment of Group policies’ Group Policy, has been implemented. This Group policy and the guidelines are adjusted as required based on feedback from the Group companies.

Implementation support: The employees must be informed of the identity of the relevant Ideas Management Supervisors. They are responsible for ideas management, i.e. for the introduction, maintenance and further development of ideas management in their organisational unit on behalf of the Managing Directors or the holding company management. They support the employees of the organisational unit through the ideas management process. The Group policy and guidelines are made available to all employees on the intranet.

Comprehensive compliance management

Corruption and bribery

Content: Energie AG is subject to a wide range of legal and regulatory requirements in the course of its business activities. Compliance with these provisions is essential, as infringements may not only result in significant economic harm, but can also give rise to personal liability risks for corporate officers and employees, as well as causing lasting reputational damage.

The core elements of Energie AG’s compliance culture are the Group-wide Code of Conduct ‘This is how we think; this is how we act’ and the ‘Code of Conduct for Contractors’. These documents set out binding principles for lawful and ethical conduct throughout the Energie AG Group. The objective of Energie AG’s Compliance Management System (CMS) is to embed these principles effectively in day-to-day business practice and to anchor them on a sustainable basis.

For the operational implementation of the CMS, at least one Compliance Coordinator is appointed in each Group company and holding unit. These officers are nominated by the respective Managing Directors and holding company managers, and support the central Compliance Officer in the implementation, monitoring and further development of the Group-wide compliance measures. The Compliance Officer is appointed by the Management Board, acts independently and without instruction, and reports directly to the Management Board. This structure ensures objective, effective and credible oversight of adherence to legal and ethical standards across the Group.

The Compliance Coordinator serves as the interface between the operational units and the central compliance organisation. They play a key role in strengthening a living culture of compliance and contribute to promoting awareness and understanding of compliance requirements at all levels of the company.

General objectives: Internal Group policies govern the systematic approach to compliance and define the content, responsibilities and division of roles, as well as documentation and reporting obligations within Energie AG’s CMS. The policies are intended to define the terms compliance and compliance management system as used within the Group and to ensure their uniform understanding, to set out the structure and processes of the compliance organisation, to establish responsibilities, to specify the minimum requirements for the CMS, to ensure appropriate standardised reporting, and to regulate the handling of compliance breaches.

Material impacts, opportunities and risks:

Also see SBM-3 – Material impacts, risks and opportunities and their interaction with the strategy and business model.

Monitoring process: Compliance checks and monitoring activities are used to verify adherence to the Codes of Conduct and Energie AG’s compliance regulations and are reported to the management bodies at regular intervals. In addition, compliance checks may be used to assess the effectiveness of the CMS and to define improvement measures. Compliance checks form part of Energie AG’s internal control system, are defined on the basis of process risks and are reviewed during internal control system audits. This additional control mechanism is carried out by the Group Audit department at specified regular intervals. Where necessary, external experts bound by confidentiality may also be engaged. To reduce any risks, compliance controls are defined, for example, to ensure adherence to the training concept or compliance with the deadlines set out in the Whistleblower Protection Act.

Scope: The regulations outlined in the ‘Compliance Management System’ Group Policy apply to Energie AG and all Group companies that Energie AG controls directly or indirectly within the meaning of § 15 of the Austrian Stock Corporation Act (AktG). Individuals who perform the same functions as employees (e.g. temporary workers) are also included.

Responsibilities: Management Board and managing directors of Group companies, holding company managers

Stakeholder involvement: A comment process, regulated in the ‘Rules for the preparation and amendment of Group policies’ Group Policy, has been implemented.

Implementation support: The information on the CMS is available on Energie AG's intranet and in PowerData (sharepoint for the Czech Republic Segment) for all employees with computer access. The Compliance Officer is available to answer questions in this regard. The external reporting channels and other relevant information are available to external stakeholders on the Energie AG website.

Protecting whistleblowers

Protection of whistleblowers

Content: The Energie AG Group strives to make it easier for potential whistleblowers to submit reports and to guarantee comprehensive protection. The whistleblower system makes it possible for employees to report company-related unlawful and/or unethical behaviour without discrimination or retaliation.

General objectives: Confidential handling of whistleblower reports

Material impacts, opportunities and risks:

Also see SBM-3 – Material impacts, risks and opportunities and their interaction with the strategy and business model.

Monitoring process: Compliance checks and audits are used to ensure compliance, see G1-1 - Business conduct concepts and corporate culture, Comprehensive compliance management.

The incident management policy defines the process for incoming reports. The following steps have been defined for the process of identifying, reporting and investigating concerns about unlawful behaviour or behaviour that conflicts with the Code of Conduct or similar internal rules: receipt of report, initial evaluation, case handling, closure and follow-up. This is done with the greatest possible care and confidentiality while fully preserving integrity and privacy. Investigations and enquiries are only carried out if there is sufficient ‘initial suspicion’ of a gross violation of the law with a connection to the company.

The compliance training concept stipulates that employees should be informed on the whistleblower system at least once every three years. As part of the introduction of the whistleblower system, training and awareness programmes were carried out for managers and employees. Employees, including those without computer access, received a whistleblowing folder as part of the process. Information about the whistleblower system is available on the intranet and is part of the compliance information provided during the Christmas period.

At Energie AG, open communication is the foundation for reporting and clarifying misconduct. The Management Board of Energie AG Oberösterreich therefore encourages all employees to report suspected misconduct immediately.

Employees have the option of using the web-based whistleblower system or submitting a personal report to a contact person. Employees can contact either their direct line manager, the managing directors of the relevant Group company, the Group Internal Audit team, the Compliance Officer or the works councils. The contact persons can be notified in writing (e.g. by e-mail) or verbally (in person or by telephone). External whistleblowers can also use the compliance hotline or the compliance e-mail address.

Reports received are immediately forwarded by the contact persons to the Compliance Officer. Within seven days of receiving a report, whistleblowers will receive confirmation that the report has been received. Every report received will be investigated, unless the report contains no substantiated facts. Depending on the nature of the suspected misconduct, the Compliance Officer will involve internal/external legal experts (on a case-by-case basis) – the Group Internal Audit if need be – to clarify the reported violation. Depending on the outcome of the investigation and where necessary due to any misconduct discovered, the company will take appropriate corrective action and/or impose sanctions. Once the case has been closed or discontinued, the whistleblower will be informed, provided that doing so does not compromise their anonymity.

Regardless of the reporting channel chosen, whistleblowers are free to decide whether they wish to remain anonymous or reveal their identity. All whistleblowers are assured strict confidentiality with regard to their identity as well as the contents of the reported circumstances. The content of the report will be treated in strict confidence with regard to all persons who are not personally involved in receiving the report, conducting the investigation or deciding on any follow-up action. In exceptional cases, it may be necessary to disclose the identity of whistleblowers if the matter becomes the subject of an official investigation or court proceedings and the parties involved must be summoned. Energie AG assures whistleblowers who report a violation of laws, regulations or internal policies in good faith that they will be protected against retaliation and other adverse consequences. Any employee who retaliates against whistleblowers will be subject to disciplinary action, up to and including termination of employment.

All employees reporting misconduct must act in good faith and have reasonable grounds to believe that the disclosed behaviour constitutes a violation of applicable laws, regulations or internal policies. Any allegation that proves to be malicious or which the person making the allegation knows to be false will result in disciplinary action, up to and including termination of employment. Bullying and denunciation are not tolerated in the Energie AG Group.

Scope: This policy applies for Energie AG and all Group companies. Individuals who perform the same functions as employees (e.g. temporary workers) are also included. The whistleblower system policy has been translated and adapted to Czech law for the Czech Republic Segment. The provision of external reporting channels also covers affected interest groups in the upstream and downstream value chain.

Responsibilities: Management Board, managing directors of the Group companies, holding company managers, employees

Stakeholder involvement: The whistleblower system and corresponding incident management policies and processes were implemented as part of a Group-wide project by the Compliance Officer of Energie AG with the involvement of several internal stakeholders, including Personalmanagement GmbH, the holding company Human Resources Strategy and Controlling, the board office, the Works Council and employees.

Implementation support: The information and policies on the whistleblower system and incident management are available on Energie AG's intranet and in PowerData (sharepoint for the Czech Republic Segment) for all employees with computer access. In addition, a service link for the whistleblower system has been integrated into the intranet homepage. New employees are informed of the policies when they join the company. The external reporting channels and other relevant information are available to external stakeholders on the Energie AG website.

Prevention of corruption

Corruption and bribery

Content: Energie AG is committed to the ethical and moral principles set out in the Code of Conduct ‘This is how we think; this is how we act’; this commitment is also required of business partners in the ‘Code of Conduct for Contractors’, see S2-4 Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions, Code of Conduct for Contractors. The Energie AG Group aims to engage in open and honest cooperation to generate added value for stakeholders and shareholders. Policies and regulations such as the ‘Anti-corruption’ Group Policy and the principles set out therein support these goals.

General objectives: To provide clear instructions for employees on how to act and behave in order to comply with the legal requirements and the requirements of Energie AG to prevent corruption; to protect employees from disciplinary consequences and consequences under criminal law and civil law; to meet the high standards that are placed on Energie AG and that it sets for itself, and thereby to strengthen trust in the company

All forms of corruption relating to Energie AG's business activities are prohibited. Non-compliance with the policies can lead to damage to the Group's reputation, but can also have disciplinary consequences or consequences under criminal law and civil law for individual employees.

Material impacts, opportunities and risks:

Also see SBM-3 – Material impacts, risks and opportunities and their interaction with the strategy and business model.

Monitoring process: Compliance checks and audits are used to ensure compliance, see G1-1 - Business conduct concepts and corporate culture, Comprehensive compliance management.

Scope: The ‘Anti-Corruption’ Group Policy applies to all employees and members of the Management Board of Energie AG as well as the employees and members of the management bodies of Group companies in which Energie AG holds a participating interest of more than 50% and/or over which Energie AG can exercise a controlling influence. Individuals who perform the same functions as employees (e.g. temporary workers) are also included.

Responsibilities: Management Board, managing directors of the Group companies, holding company managers, employees

Stakeholder involvement: A comment process, regulated in the ‘Rules for the preparation and amendment of Group policies’ Group Policy, has been implemented.

Implementation support: See G1-1 - Business conduct concepts and corporate culture, Comprehensive compliance management.

G1-3 – Prevention and detection of corruption and bribery

The Code of Conduct ‘This is how we think; this is how we act’ and the ‘Code of Conduct for Contractors’ provides essential information for the own workforce and for suppliers. Allegations or incidents relating to corruption and bribery can be reported using the whistleblower system or other reporting channels made available on the Energie AG homepage. Energie AG does not tolerate any corrupt behaviour on the part of employees or suppliers. For this reason, an internal policy has been implemented and a compliance training concept put in place. For suppliers the ‘Code of conduct for Contractors’ applies. Reported incidents are investigated according to a process designed for this purpose, which defines roles, responsibilities and detailed instructions for action. In principle, the person responsible for the investigation is independent of the management chain involved in the matter. See also G1 Business conduct.

The Compliance Officer reports to the Management Board every six months, which in turn reports to the Audit Committee on compliance management at Energie AG. At the following Supervisory Board meeting, the Chair of the Supervisory Board will report on this to the full Supervisory Board.

Compliance policies, information and documents are communicated within the Group in an appropriate form, e.g. on the intranet, newsletter, employee magazine, PowerData, etc. There is also a Group-wide policy on how Group policies are to be drawn up and communicated. In addition, the compliance organisation and in particular the Compliance Coordinators have a role in disseminating information on the roll-out of compliance action. As part of the onboarding process, new employees sign a compliance declaration of commitment and undertake to read the Code of Conduct, the Group policies on the Compliance Management System, antitrust law, corruption and data protection and to complete the learning modules on anti-corruption, data protection and antitrust law.

Employees of Energie AG are considered public officials and are therefore subject to strict legal standards, particularly with regard to personal integrity. Corrupt behaviour can affect all areas and can have devastating economic, social and cultural consequences. In this regard, the roles within the company that are most exposed to corruption and bribery risks are those that deal directly and routinely with customers, business partners and third parties, both in a professional and, where relevant, private context.

Within Energie AG, the prevention of corruption is given the highest priority. As a general principle, roles involving extensive external contact, decision-making authority over financial resources or influence over procurement processes may present an increased corruption or bribery risk. These include, for example, functions in purchasing, sales, project management or certain technical roles with interfaces to external partners.

To address these potential risks systematically, a comprehensive risk-assessment approach is currently being developed. Its purpose is to identify and assess the most vulnerable functions at Group level and to define targeted preventive measures. The final list of these roles and the associated measures is expected to be completed in the 2025/26 fiscal year.

Through this proactive approach, Energie AG underscores its clear commitment to integrity, transparency and a strict zero-tolerance policy towards corruption and unethical conduct.

The compliance training concept applies to all Energie AG employees in Austria. In this regard, the training concept covers all roles that deal directly and on a daily basis with customers, business partners and third parties, both professionally and in a private context. The Energie AG Group's training concept and the compliance checks defined for this purpose are aimed at increasing awareness to ensure compliance with the principles of corporate governance and to promote compliant behaviour among employees. Energie AG is committed to protecting the company and its employees from misconduct and to promoting an overall culture of compliance. The compliance training concept is intended to communicate the values of cooperation so that compliant behaviour is understood to be a matter of course.

The training concept is designed to cover two perspectives. Specific actions on compliance training and awareness to be complied with are provided from the Group's perspective, e.g. during the onboarding process or recurring training sessions such as web-based anti-corruption, antitrust law and data protection training. In addition, each holding, business and service unit can define further appropriate, suitable and effective compliance training programmes for a specific target group in consultation with the Compliance Officer.

As of 30 September 2025, 80.8% (previous year: 86.8%) of employees with PC access had completed the web-based ‘anti-corruption’ training offered in Austria.

As part of compliance reporting, biannual meetings are held with the Management Board regarding the CMS and reports are submitted to the Audit Committee meetings of Energie AG. When new members of the Management Board, Managing Directors and holding company managers join the company, a compliance meeting is held with the Compliance Officer. In the Czech Republic Segment, mandatory annual compliance dialogue days are held for managers.