GRI Content Index

2-1 Organisational details

Section 01.5 Where we operate

2-2 Entities included in the organisation’s sustainability reporting

a & b.

All entities in the Hager Group financial reporting are included in its sustainability report. The entities includes the following:

1. Hager Middle East FZE
2. Hager Electro Ges.m.b.H
3. Hager Electro Pty Ltd
4. Hager doo
5. Hager Modules S.A
6. Hager AG
7. Hager Industrie AG
8. Hager Systems AG
9. Hager Metal Works (DongGuan) Co. Ltd.
10. Dongguan EFEN Electrical Products Co. Ltd.
11. Hager Electric (Huizhou) Ltd.
12. Hager Electric Management (Shanghai) Ltd.
13. Hager Electro s.r.o
14. Hager Electro GmbH & Co. KG
15. Tehalit GmbH
16. Hager Safety Deutschland GmbH
17. Polo Industrie GmbH
18. Berker GmbH & Co. KG
19. Locate Solution GmbH
20. Hager Eastern Europe GmbH
21. Hager North & Central Europe GmbH
22. Hager Systems Beteiligung GmbH
23. Noris Verwaltungsgesellschaft mbH
24. Hager Vertreibs Geschäftsführungsges. mbH
25. Hager Electro Geschäftsführungsges. mbH
26. Elektro-Apparatebau Ottfingen GmbH
27. Berker International GmbH
28. Hager International GmbH
29. Hager Energy GmbH
30. Hager Vertriebsgesellschaft mbH & Co. KG
31. Hager Sistemas SAU
32. Hager Industrial de Envolventes SAU
33. Hager SAS
34. Hager Electro SAS
35. Hager Controls SAS
36. Hager Safety SAS
37. Hager Next SAS
38. Finatrys SAS
39. Hager Engineering Ltd.
40. Hager Ltd.
41. Hager UK Ltd.
42. Hager Hellas S.A
43. Hager Electro Ltd.
44. Hager Kft.
45. PT Hager Electro Indonesia
46. Hager Ltd.
47. Hager Services Ltd.
48. Hager Electro Private Ltd.
49. Hager Bocchiotti SpA
50. AB Plast S.r.l
51. Hager Lumetal S.p.A
52. Hager Italia Partecipazioni S.r.l
53. Silam-Plast S.r.l
54. Bocchiotti S.p.A
55. Herholdt Controls S.r.l
56. Hager Investment S.A
57. Hager Engineering (M) SDN. BHD
58. Hager Electro B.V.
59. Hager Production Poland Spzoo
60. Hager Polo Spzoo
61. Hager Business Services Spzoo
62. Hager Sistemas Electricos Modulares S.A.
63. Hager Qatar FZE LLC
64. Hager Romania SRL
65. Hager Elektro AB
66. Elektrofabriken i Malmö AB
67. Hager Electro Systems Pte. Ltd.
68. Berker Electronic Tic Ltd.
69. Polo Elektroobladnannia
70. Iboco Corporation
71. IoTecha Corp.

c. Estimation methodologies like extrapolation are implemented when data availability and quality do not meet the required standards. To illustrate, extrapolation is used as an alternative when isolated office size is deemed not material in terms of impact. Newly acquired entities are included in sustainability reporting as part of an onboarding period implemented by our manufacturing department.

GRI 2-3 General disclosure2-3 Reporting period, frequency and contact point

a. 1st January to 31st December, frequency of sustainability reporting is annual

b. 1st January to 31st December

c. 4th of July 2024

d. contact

GRI 2-4 General disclosures2-4 Restatements of information

Section 01.6 Scope and external assurance

Section 04.2.2 The baseline

GRI 2-5 General disclosure2-5 External assurance

a. The company board of directors (Vorstand) commits to obtain external assurance in communicating around our sustainability performance in its sustainability policy.

b. The sustainability report is not externally assured.

GRI 2-6 General disclosures2-6 Activities, value chain and other business relationships

a. According to the Global Industry Classification System Standard (GICS), Hager Group is active in the Industrial Sector, under Capital Goods: Electrical Equipment. According to the Sustainable Industry Classification System, Hager Group is active in the Thematic Sector: Resource Transformation under: Electrical & Electronic Equipment (RT-EE).

d. describe significant changes in 2-6-a, 2-6-b and 2-6-c compared to the previous reporting period

Not applicable

Hager Group is doing GRI-2 disclosure
for the first time

b. i. Products and services.

ii. At Hager Group, we procure a diverse range of supplies and goods that encompass essential raw materials for our manufacturing and project execution. Our key materials, by weight, include metals like copper, aluminium, and various plastics in our products. Additionally, we acquire a wide array of fabricated products, electronic components, and systems. Our global supply chain management network operates with dedicated personnel across our Business Areas, Divisions, and strategic locations. This network comprises multiple teams, each focused on specific product categories. These teams are entrusted with capitalising on opportunities to utilise Hager Group’s global scale effectively to enhance the efficiency of our sustainable supply networks. The objectives of our supply chain management organisation encompass several activities, such as:

- Consolidating and maximising the procurement of materials and services.

- Establishing transparency in Hager Group’s worldwide expenditure through a comprehensive performance and reporting system integrated with our enterprise resource planning (ERP) systems.

- Strengthening Hager Group’s supply chain by implementing an efficient product category management framework and comprehensive training based on competencies.

- Monitoring and enhancing our supply base to ensure sustainability in terms of both materials and processes utilised.

- We procure numerous product categories containing materials like steel, copper, aluminium, and other commodities. Recent global economic growth in emerging markets, along with fluctuations in foreign currency exchange rates, has resulted in significant variability in these raw material costs in recent years. While we anticipate continued volatility in global commodity prices, we aim to mitigate some market fluctuations by employing long-term contracts and global sourcing strategies.

iii. The downstream entities and their activities are Retail, Distribution & transport, Installation and post-installation services

2-6 Activities, value chain and other business relationships

c. Other relevant business relationships are:

- Technology and innovation partnerships with research institutions and universities for research and development

- Third-party logistics providers

- Banks and financial institutions

- Government Agencies and Regulatory Bodies Consumer support and after-sales service

- Labor unions and workforce representatives

- IT service providers

d. describe significant changes in 2-6-a, 2-6-b and 2-6-c compared to the previous reporting period

Not applicable

Hager Group is doing GRI-2 disclosure
for the first time

2-7 Employees

a. & b.

Appendix-I HR data

c. Hager Group is reporting in headcount for the reporting year from Jan to Dec. The employment headcount is consolidated at the end of December.

d. While Hager Group has a global presence, it production is mainly concentrated in Europe. In most of the other countries they have distribution and service offices. As a result there is a high concentration of its employees in Europe.

e. Due to Hager Group’s talent attraction and retention initiatives, the attrition rate of the company has dropped from 10,2 % in 2022 to 7,8 % in 2023. It also has a positive impact on the company’s hiring rate, increasing from 6,5 % in 2022 to 11,15 % in 2023.

b iii. Non-guaranteed hours employees, and breakdown by gender
and by region

Not applicable

Hager Group has not enrolled
and employee as non-guaranteed
hours employees

2-8 Workers who are not employees

a. Appendix-I HR data

b. Hager Group is reporting in headcount for the reporting year from Jan to Dec. The employment headcount is consolidated at the end of December.

a. i. the most common types of worker and their contractual relationship with the organisation

ii. the type of work they perform

Information unavailable/incomplete

The detail is managed at a local level and Hager Group has not yet started consolidating the data. Also, there is
no plans yet to start the data compilation.

2-9 Governance structure and composition

a. The highest governance body has two boards: Board of Directors and Supervisory Board. The Board of Directors has the sole responsibility for managing the company and Supervisory Board monitors and advices the Board of Directors

b. Sustainability Council: The council has Chief Technical Officer (CTO), Chief Marketing Officer (CMO) as members with Chief Human Resources Officer (CHRO) as the head of the council and the sustainability sponsor.

c. Appendix-II Governance Structure

2-10 Nomination and selection of the highest governance body

a. The highest governance body has two boards:
the Executive Board and the Supervisory Board.

Executive Board selection process: The board consists of at least two people. The supervisory board determines the number of members and appoints them for a maximum of five years. A repeated appointment or extension of the term of office, each for a maximum of five years, is permitted. It requires a new supervisory board resolution to be passed at the earliest one year before the end of the previous term of office. However, in cases of an appointment for less than five years, can an extension of the term of office be provided without a new resolution from the Supervisory Board, provided that the total term of office amounts to at most five years.

Supervisory Board selection process: The members of the Supervisory Board are elected by the Annual General Meeting. The election takes place for a maximum period until the end of the general meeting that decides on the discharge of the Supervisory Board for the fourth financial year after the start of the term of office but for a maximum of six years. The financial year in which the term of office begins is not considered. Reappointments are permitted. If a board member is elected in place of a resigned member, the term of office of the new member is the remaining term of office of the resigned member.

b. Executive Board: It is crucial to note that, as per section 76 of the Stock Corporation Act, in Hager Group, only a natural person with unlimited legal capacity can be a member of the board. It is strictly prohibited for a person to be a member of the executive board if the person:

1. is subject to a reservation of consent (Section 1825 of the Civil Code) in whole or in part when managing their financial affairs

2. takes up a profession or a professional branch due to a court judgement or an enforceable decision of an administrative authority, cannot be a member of the board, and may not carry out a trade or a branch of trade if the object of the business corresponds in whole or in part of the object of the ban, or

3. has been convicted of one or more intentionally committed criminal offences listed in Section 76(3) of the Stock Corporation Act.

Supervisory Board: The member of the Supervisory Board, a role of significant responsibility, must have reached the age of 30 and must be an individual who, based on training and experience, can fulfil the tasks assigned to the Supervisory Board. As per section 100 of the Stock Corporation Act, in Hager Group, no one may be a member of the supervisory board who:

1. is already a member of the supervisory board of ten commercial companies that are legally required to form a supervisory board,

2. is the legal representative of an enterprise controlled by the company

3. is the legal representative of a company whose supervisory board considers a member of the executive board as its member.

2-10 Nomination and selection of the highest governance body

2-11 Chair of the highest governance body

a. Mr. Daniel Hager is the Chairman of the
Supervisory Board and he is not a senior
executive in the organisation

b. if the chair is also a senior executive, explain their function within the organisation’s management, the reasons
for this arrangement, and how conflicts
of interest are prevented and mitigated.

Not applicable

The chairman is not a senior executive

2-12 Role of the highest governance body in overseeing the management of impacts

a. The role of the highest governance body, in this case, the Board of Directors, is to manage the company under its responsibility, ensuring decisions are made in the organisation’s best interest. As part of the Board of Directors, senior executives jointly decide on matters related to the organisation’s purpose, values, mission statements, strategies, policies and goals related to sustainable development. This is facilitated through regular board meetings where decisions are made collectively or by individual members within their respective departments, as outlined in the company’s rules of procedure.

b. Role of the highest governance body in due diligence and impact management:

i. The highest governance body, the Board of Directors, engages with stakeholders to support due diligence processes. This is evidenced by the coordination of the Executive and Supervisory Board, where strategic direction and significant decisions are discussed and approved. The Supervisory Board, in particular, plays a role in overseeing management decisions and may require consent from certain transactions to be received.

ii. The outcomes of due diligence processes are considered by the Board of Directors, especially in matters requiring approval or significant decision-making. The Supervisory Board, in alignment with the Stock Corporation Act, monitors management decisions and can demand approval from the general meeting if its consent is refused, indicating a level of oversight in managing the organisation’s impact.

c. The Supervisory Board, as the highest governance body, regularly reviews the effectiveness of the organisation’s processes related to due diligence and impact management. This review is mandated to occur at least once every calendar quarter, as per the rules of procedure for the supervisory board. Additionally, significant decisions and outcomes of these processes are reported to the Supervisory Board on a regular basis, ensuring transparency and accountability in governance practices.

GRI 2-13 General disclosure2-13 Delegation of responsibility for managing impacts

Section 03.1 Sustainability governance

2-14 Role of the highest governance body in sustainability reporting

a. The highest governance body, the Board of Directors, is responsible for reviewing and approving the reported information, including the organisation’s material topics. This responsibility encompasses decisions related to financial statements, calling general meetings, transactions requiring approval, and corporate strategy and planning matters. The process involves collective decision-making during board meetings where discussions, analysis, and approval of reported information occur.

b. if the highest governance body is not responsible for reviewing and approving the reported information, including the organisation’s material topics, explain
the reason for this.

Not applicable

Highest governance body is responsible for reviewing and approving the reported information

2-15 Conflicts of interest

a. Compliance and integrity are high priorities for us. The Hager Group implemented a compliance management system some years ago, a core component of its business model. Its intra-company guidelines support secure compliance within the company and provide the employees with guidance during their work. Very concretely, many measures have been put in place to inform and train the people, make them aware of the importance of Compliance issues and collect information to ensure guidelines are complied with and report any problems:

1) Compliance documentation: Drafting of an “Ethics Charter” and “Conflicts of Interest Guideline”, both available in French, English and German languages, easily accessible on the intranet of the Hager Group, called “Hager Group Live”, in a specific and fully dedicated section called “Compliance”.

2) Production of dedicated materials, information and training

I. Implementation of specific online training sessions dedicated to Compliance: 46 % of about 2.000 employees (the first round of managers) have participated in the Anti-bribery and corruption training and the Fraud and conflict of Interests training organised in 2023. Additionally, an ethics module for the managers will be developed in 2024 and also for the blue-collar employees in 2025.

II. Recording of five videos dedicated to Compliance: One contains case studies for conflicts of interest and includes a presentation of the Hager Group directive and the register of conflicts of interest. Those videos are available in French, English, and German. They are used as follows to inform and educate people

- to put them available on the intranet Hager Live together with a robust communications/teasing campaign so that they are watched and used and

- to encourage the managers of the various departments to share these videos as an introduction to their departmental meetings via Teams or face-to-face.

3) Appointment and training of Ethics Ambassadors: 21 ethics ambassadors have been appointed worldwide.

4) Update and roll out of a Compliance Check Lists to be completed once per year by the boards of directors of the Hager Group companies and which includes many questions about “Ethics and Compliance organisation”, “Anti-bribery & corruption”, “Fraud & Conflict of Interests”, “Discrimination & Harassment”, etc. When completed, such lists shall be reviewed regularly, and an audit procedure shall be established to check whether the mentioned requirements have been implemented effectively and comply with the compliance checklists.

b. report whether conflicts of interest are disclosed to stakeholders, including,
at a minimum, conflicts of interest relating to:

i. cross-board membership;

ii. cross-shareholding with suppliers
and other stakeholders;

iii. existence of controlling shareholders;

iv. related parties, their relationships, transactions, and outstanding balances.

Confidentiality constraints

Hager Group sustainability report discloses the number of cases regarding conflict of interest. However, due to sensitivity reasons the details of such issues are kept confidential.

GRI 2-16 – General disclosures2-16 Communication of critical concerns

a. GCC (Group Compliance Committee) information channels and tools

- The register of conflicts of interest available in many languages (French - German – English – Chinese – Polish – Italian – Spanish – Portuguese).
Employees and manager are given access to this register where they can fill the information about the received gift thanks to a drop-down menu. This data, fed into a summary Excel file, is accessible to members of the Group Compliance Committee (“GCC”) in the “compliance-home” area. The GCC will go through the file every quarter. The HR representative on the GCC is the owner of this process who communicates about the ethical concerns to the Board of Directors.

- Implementation of the Hager Integrity Reporting System “Let’s talk”
Available to all employees of Hager Group and to all external partner (temporary employees, customers, suppliers, other business partner). It’s planned to organise a final report of the outcome of every case to the GCC which will decide (I) to inform the Board of Directors about cases with high risk for financial damages or reputation immediately and (ii) about appropriate suitable measures

a. & b.
Section 05.3 Reporting integrity alerts

2-17 Collective knowledge of the highest governance body

a. Hager Group, through a collective effect has implemented several mechanisms to advance the collective knowledge, skills, and experience of its highest governance body.

1) Through the Management Summer School (MSS), the Hager Group systematically enhances the competencies of its highest governance body, ensuring that sustainability remains at the core of its leadership and strategic vision. Established in 2012, the MSS exemplifies the Hager Group’s dedication to sustainable leadership and fostering a culture of innovation and digitalisation.
Over the past decade, the MSS has become a platform where members of the Board of Directors, senior managers, young talents, and special guests come together to explore and learn. The MSS agenda covers topics critical to the company’s vision of creating a safer, cleaner, and more enjoyable world through electrical innovations. This vision emphasises the importance of people, customers, and stakeholders in the journey towards sustainable development.
A key component of the MSS is the inclusion of external inspiration. Since its inception, the MSS has featured over 50 renowned guest speakers who share their experiences in transformation and change. These “learning expeditions” are integrated into the programme to ensure participants, including the highest governance body members, are exposed to diverse perspectives and best practices from various industries. This external engagement is crucial for fostering a mindset open to new ideas and innovations.
The MSS is structured as a learning journey, with participants engaging in company tours and workshops. For instance, the 2018 MSS highlighted the importance of external learning by organising visits to companies excelling in different fields, such as handheld power equipment, robotics, and automotive industries. These visits provided participants with specialised knowledge that could be adapted within the Hager Group.
This commitment to learning and development underscores the Hager Group’s dedication to sustainable leadership and its proactive efforts to equip its governance body with the skills and knowledge necessary to drive sustainable development.

2) The Board of Directors, as the ultimate authority responsible for managing the company, is deeply committed to making decisions in the best interest of Hager Group, including those related to sustainable development. Regular board meetings serve as forums for collective decision-making, where matters related to the organisation’s purpose, values, mission statements, strategies, policies, and sustainable development goals are deliberated upon.

3) Hager Group has established a dedicated Sustainability Council, a key driver in our sustainability journey. Led by the Group’s Chief Human Resources Officer (CHRO) and comprising essential executives such as the Group’s Chief Technical Officer (CTO) and Chief Marketing Officer (CMO), this council plays a pivotal role in identifying risks and gaps in sustainability practices, setting ambitious goals and strategies, developing pertinent policies, and monitoring progress. Notable initiatives like the Sustainability Policy and Blue Planet Commitment strategy are the outcomes of this council’s invaluable contributions.
The sustainability-related issues identified by the Sustainability Council are seamlessly integrated into board meetings. This integration underscores our commitment to making sustainability a core consideration in board discussions, thereby enhancing the collective knowledge, skills, and experience of all board members.

4) Close collaboration between the Executive Board and the Supervisory Board ensures alignment on strategic direction, including sustainable development priorities. Regular discussions on strategy implementation status facilitate knowledge exchange among board members, enriching their understanding and expertise in sustainable development.

2-18 Evaluation of the performance of the highest governance body

a. The Supervisory Board of Hager Group assesses the performance of the executives on the Board of Directors based on the annual targets set by the Board of Directors. These targets are aligned with the company’s strategic priorities and include a significant focus on sustainability. For instance, specific sustainability targets such as the reduction of energy-related greenhouse gas (GHG) emissions across six factories and the completion of the “Blue Planet Starter” training programme are integral to the annual performance metrics. Starting from 2024, the Board of Directors has committed to ensuring that at least 20 % of its annual targets are sustainability-focused. These sustainability targets are directly linked to the group’s bonus scheme, reinforcing the importance of sustainability in the company’s overall performance evaluation framework. This structured approach ensures that the highest governance body oversees and but actively drives the management of the organisation’s impacts on the economy, environment, and people, fostering a culture of sustainability and accountability.

b. The evaluation process aligns with the group and individual targets of the executives on the Board of Directors and is conducted twice a year.

c. The Supervisory Board members decide the actions in response to the evaluations, including the performance based incentive.

2-19 Remuneration policies

b. When determining the total remuneration of an executive board member, the supervisory board ensures that it is appropriate for the board members’ tasks and services, including sustainability and long-term development-related tasks.

a. describe the remuneration policies for members of the highest governance body and senior executives, including:

i. fixed pay and variable pay;

ii. sign-on bonuses or recruitment incentive payments;

iii. termination payments;

iv. clawbacks;

v. retirement benefits;

Confidentiality constraints

The remuneration of the Executive Board members is determined by the Supervisory Board. For Supervisory Board members, the remuneration is set out in the articles of association or approved by the general meeting. However, due to confidentiality issues, the classification of the remuneration is not disclosed.

2-20 Process to determine remuneration

a. Hager Group salary management principles are based on market best and standard practices. The salary and increment for each job band take local market specificities (inflation, unemployment, labour regulations, etc.) into consideration. It also counts in employee contribution while evaluating an individual’s evolution. The salary management principles in Hager Group consider two groups: Senior Managers and executives and below Senior Managers.

Senior Managers & Executives:

1) In Germany and France, there is an industry-specific predefined salary range for each job band. The annual base salary is decided from this range.

2) In the rest of its operating countries, Hager Group considered Mercer’s median to decide the annual base salary per job band. Mercer is the world’s largest and most comprehensive remuneration database.

3) Group Compensation and Benefits prepares and coordinates Salary Reviews at the group level.

Below Senior Managers:

1) Mercer median on Target Total Cash (Annual Base Salary + any Target short-term or Target sales bonus) is used to assess the salary per job band.

2) Salary review (files) prepared and coordinated by Local HRBPs/People Solutions according to Group C&B guidelines.

An additional element called the Merit matrix for Senior Managers and Executives links their performance to the Group’s Key Performance Indicators (KPIs). The design tool enables managers to access the individual’s increment based on their yearly performance, Compa Ratio (current annual base salary/ salary range ID point or Mercer median) and the merit increase budget. This merit matrix is updated per country every year depending on the salary budget of the legal entity, inflation rate and any specific local context. The yearly performance is assessed through an annual appraisal rating, evaluating employee contributions through continuous delivery against the job’s permanent mission and responsibilities, which aligns with leadership behaviours and Hager Group values. The rating ranges from 1 (unsatisfactory) to 5 (outstanding).

Although there is a merit matrix in place, the salary management principle ensures that, wherever applicable, it considers general increases and increments decided by the Government, Employers’ associations, Union representative bodies, etc. This increment happens regardless of an employee’s proven contributions.
Hager Group has a Merit Matrix for its senior executives. The design tool enables managers to access the individual’s increment based on their yearly performance, Compa Ratio (current annual base salary/ salary range ID point or Mercer median) and the merit increase budget. This merit matrix is updated per country every year depending on the salary budget of the legal entity, inflation rate and any specific local context. The yearly performance is assessed through an annual appraisal rating, evaluating employee contributions through continuous delivery against the job’s permanent mission and responsibilities, which aligns with leadership behaviours and Hager Group values. The rating ranges from 1 (unsatisfactory) to 5 (outstanding).

b. report the results of votes of stakeholders (including shareholders)
on remuneration policies and proposals, if applicable.

Not applicable

Remuneration policy is finalised in board meeting after consent of all the executives. No voting system is involved in the process.

2-21 Annual total
compensation ratio

Completely Omitted

Not applicable

The comparison is not meaningful
because compensation varies by country and is based on local market conditions. Therefore, such a calculation does not provide a valid conclusion.

2-22 Statement on sustainable development strategy

CEO Statement

GRI 2-23 General disclosure2-23 Policy commitments

a. & b.

Section 03.4 Rules, processes and controlling: embedding sustainability in daily operations

c. The policies are not publicly available, but they are accessible to all Hager Group employees who are required to adhere to them.

d. The sustainability policies of Hager Group is approved and signed by the senior executives of the Board of Directors

e. The policies apply to all entities covered under sustainability reporting. Hager Group also encourages its suppliers and other business partners to adopt the policy principles.

f. Hager Group uses its intranet system, Hager Live, to communicate these policies to its employees. Additionally, other communication channels such as PeopleDoc, meetings, and the Hager training platform Hi! University are also used to disseminate these policy principles. The Code of Purchasing Conduct outlines Hager Group’s expectations on sustainable development based on these policies. As part of the contracting process, the code ensures that our policy principles are communicated to our business partners.

GRI 2-24 and 2-25 General disclosures2-24 Embedding policy commitments

Section 05.1 Our Ethical commitment - 05.5 Ethics Ambassadors

GRI 2-25 – General disclosures2-25 Processes to remediate negative impacts

Section 05.1 Our Ethical commitment - 05.5 Ethics Ambassadors

GRI 2-26 – General disclosures2-26 Mechanisms for seeking advice and raising concerns

Section 05.3 Reporting integrity alerts

Section 05.5 Ethics Ambassadors

GRI 2-27 – General disclosures2-27 Compliance with laws
and regulations

Section 05.2 Driving ethical behaviour

c. describe the significant instances
of non-compliance;

d. describe how it has determined significant instances of non-compliance.

Not applicable

Hager Group has not paid any fine

or non-monetary sanctions for
reasons of non-compliance with laws and regulations.

2-28 Membership associations

a. As a member of the ZVEI | Germany’s Electro and Digital Industry, Hager Group provides expert input in the opinion-forming process that shapes and promotes sustainable development in Germany and Europe. In addition to the ZVEI, Hager Group is an active member in the following associations:

- The German Sustainable Building Council (DGNB) – Europe’s biggest network for sustainable building.

- European Committee of Electrical Installation Equipment Manufacturers (CECAPI).

- Coordinating Committee for the Associations of Manufacturers of Switchgear and Control gear equipment for industrial, commercial and similar use in the European Union. (CAPIEL).

- Europe’s technology industries at EU level: innovative companies across the mechanical engineering, electrical and electronics, ICT and metal technology sectors that develop and manufacture the products, systems and services that enable a prosperous and sustainable future: ORGALIM.

- The Spanish Association of Manufacturers of Electrical Material.

- UK trade association for manufacturers and providers of energy infrastructure technologies and systems (BEAMA).

- The trade association for electro digital technologies in France (GIMELEC).

- The French Industrial Alliance that offers electrical and digital solutions to give life and animate the building for the benefit of its occupants (IGNES).

- The French Federation of Electrical, Electronic and Communication Industries. (FIEEC)

- The Austrian Association of the electrical and electronics industry (FEEI).

- ANIE federation of electrotechnical and electronics sector in Italy.

GRI 2-29 General disclosures2-29 Approach to stakeholder engagement

Hager Group stakeholder engagement approach

2-30 Collective bargaining agreements

Completely Omitted

Information unavailable/incomplete

We adapting to the process to get this information at global level and will be able to provide correct information from 2025.

GRI 3:
Material topics 2021

GRI 3-1 Material topics3-1 Process to determine
material topics

Section 02.1 Materiality assessment process

GRI 3-2 Material topics3-2 List of material topics

Section 02.2 Material topics

GRI 3:
Material topics 2021

GRI 3-3 Material topics3-3 Management of
material topics

Section 03.6 Responsible sourcing

GRI 204 Procurement PracticesGRI 204:
Procurement practices 2016

204-1 Proportion of spending
on local suppliers

Section 03.6.4 Supporting local suppliers

GRI 3:
Material topics 2021

3-3 Management of
material topics

Section 05.1 Our ethical commitment
Section 05.2 Driving ethical behaviour

GRI 205 Anti-corruptionGRI 205:
Anti-corruption 2016

GRI 205-1 – Anti corruption205-1 Operations assessed for risks related to corruption

Section 05.2.1 Ethical risk assessment

GRI 205-2 – Anti corruption205-2 Communication and
training about anti-corruption policies and procedures

a. The anti-corruption policies and procedures are drafted in Hager Group’s ethics charter, which is communicated to all governance body members.

b. Appendix-III. The anti-corruption policies and procedures are publicly communicated in Hager Group’s intranet platform (Hager Live) to all connected employees of the group. In 2022, 9.650 of the 12.903 employees (75 %) were registered to Hager Live.

c. The anti-corruption policies and procedures are publicly communicated in Hager Group’s intranet platform (Hager Live) to all connected employees of the group. In 2022, 9.650 of the 12.903 employees (75 %) were registered to Hager Live.

Hager Group’s Code of Purchasing sets our expectations regarding our relationships with our suppliers and their compliance with anti-corruption and anti-bribery standards. The code is a part of the contracting process, ensuring our anti-corruption policies are communicated to all our business partners.

d. & e. Section 05.4 Ethics training programme

GRI 205-3 – Anti corruption205-3 Confirmed incidents of corruption and actions taken

Section 05.3.1 Let’s talk

GRI 3:
Material topics 2021

3-3 Management of
material topics

Section 04.1 The blue planet commitment

GRI 301:
Materials 2016

301-1 Materials used by
weight or volume

a. No distinction is made between renewable and
non-renewable materials.

Data differentiation management processes are necessary at sourcing level for future reporting purposes.

1) Metals - 48.414 t

2) Plastic Chemicals & PVC - 75.077 t

3) Packaging & Consumables - 12.898 t

GRI 301-2 Materials301-2 Recycled input
materials used

Section 04.2.3 Our emission reduction

301-3 Reclaimed products and their packaging materials

Completely Omitted

Information unavailable/incomplete

Hager Group currently do not compile
this data.

GRI 3:
Material topics 2021

3-3 Management of
material topics

Section 04.1 The blue planet commitment
Section 04.3 Our energy mix

GRI 302 – EnergyGRI 302:
Energy 2016

GRI 302-1 Energy302-1 Energy consumption
within the organisation

a, b, & c.

Section 04.3 Our energy mix

d. Electricity sold: 15,8 MWh of solar electricity in 2022 and 31,6MWh in 2023

e. Total energy consumption (including fuels): 228,9GWh in 2022 and 212GWh in 2023

f. Energy is collected according to ISO50001 management systems and audited accordingly for all sites with consumption > 5GWh

g. International Energy Agency Conversion factors
and unit abbreviations.

c. In joules, watt-hours or multiples,
the total:
iii. cooling consumption
iv. steam consumption

d. In joules, watt-hours or multiples,
the total:
ii. heating sold
ii. cooling sold
iii. Steam consumption

Not applicable

Hager Group do not consume or
sell cooling energy and steam. We also

do not sell heating energy.

GRI 302-2 Energy302-2 Energy consumption
outside of the organisation

a. Section 04.3 Our energy mix

b. We are collecting the yearly amount of energy used in our third party logistics centres. For those where we do not have information, we base our extrapolation on average kWh/sqm

c. International Energy Agency Conversion factors
and unit abbreviations.

302-3 Energy intensity

a. 82 MWh/k€ sales

b. 2,8 billion (gross sales)

c. All types of energy considered in 302-1 are included in the calculation

d. The ratio uses energy consumption within the organisation

GRI 302:
Energy 2016

302-4 Reduction of energy consumption

a. Energy consumption in 2022 was 22 GWh less
than the base year 2021.
Energy consumption in 2023 was 39 GWh less
than the base year 2021.

b. All types of energy considered in 302-1 are included in the calculation

c. The reduction is calculated from the base year 2021 because of our data collection efforts from this year.

d. Comparison of year-on-year energy consumption
(in terms GWh)

302-5 Reductions in energy requirements of products and services

a. There is no significant reduction in energy requirement of our sold products and services.

b. Basis for calculating reductions in energy consumption, such as base year or baseline, including the rationale for choosing it.

c. Standards, methodologies, assumptions, and/or calculation tools used.

Not applicable

No calculation is being made because
the energy requirement of sold products and services remains the same.

GRI 3:
Material topics 2021

3-3 Management of material topics

Section 04.1 The blue planet commitment
Section 04.2.3 Our emission reduction

GRI 305-1 to 305-3GRI 305:
Emissions 2016

GRI 305-1 to 305-3305-1 Direct (Scope 1)
GHG emissions

a, b & e.
Section 04.2.3 Our emission reduction

c. 12 tCO2e

d. Section 04.2.2 The baseline

f. Operational control. We rely on physical flows activity data (mainly the amount of kWh used) for 95 % of our emissions. For the remaining 5 % we perform an extrapolation.

g. The Greenhouse Gas Protocol was followed for the calculation

305-2 Energy indirect (Scope 2) GHG emissions

a, c & e.
Section 04.2.3 Our emission reduction

b. We are only reporting our emissions in location based. Until 2022, for France and Germany, we did purchase guarantees of origins, and therefore “green electricity” certificates. However, we consider that certificates are not backed by geographical and temporal reality and therefore decided to rely on the location based methodology that is more precise and consistent.

d. Section 04.2.2 The baseline

f. Operational control. We rely on physical flows activity data (mainly the amount of kWh used) for 95 % of our emissions. For the remaining 5 % we perform an extrapolation.

g. The Greenhouse Gas Protocol was followed for the calculation

305-3 Other indirect (Scope 3) GHG emissions

a, b, d & f.
Section 04.2.3 Our emission reduction

e. Section 04.2.2 The baseline

g. The Greenhouse Gas Protocol was followed for the calculation

c. Biogenic CO2 emissions in metric tons
of CO2 equivalent.

Not applicable

In our GHG emission calculation, wherever applicable, biogenic emission is a part of the emissions per category. It is not calculated separately.

305-4 GHG emissions intensity

a. 542 tCO2e/Mio. € sales

b. 2,8 billion € (gross sales)

c. All types of GHG emission included in the intensity ratio: Scope1, 2 and 3

d. All the gases are included in the calculation

GRI 305:
Emissions 2016

305-5 Emissions305-5 Reduction of GHG emissions

a & b.
Section 04.2.3 Our emission reduction

c. Section 04.2.2 The baseline

d. Reduction took place in Scope 1 and 2

e. We have set science based reduction targets by 2030 compared to our baseline year 2021:
- -50 % on scopes 1 & 2 emissions
- -25 % on scope 3 emissions

305-6 Emissions of ozone-depleting substances (ODS)

Completely Omitted

Not applicable

Hager Group production system does
not have the emission of such gases

305-7 Nitrogen oxides (NOx), sulphur oxides (SOx), and other significant air emissions

Completely Omitted

Not applicable

Hager Group production system does

not have the emission of such gases

GRI 3:
Material topics 2021

3-3 Management of material topics

Section 02.2 Material topics
Section 03.6.3 Enhance compliance and sustainability risk management
Section 04.1 The blue planet commitment

GRI 308 Supplier environmental assessmentGRI 308:
Supplier environmental
assessment 2016

308-1 New suppliers that were screened using environmental criteria

100 % of active tier 1 supplier in direct sourcing are screened with Hager’s third party tool SPHERA.

308-2 Negative environmental impacts in the supply chain
and actions taken

a & b.
Section 03.6.3 Enhance compliance and sustainability risk management

c. & d.
No significant actual or potential negative environmental impacts identified in the supply chain.

e. No supplier relationships were terminated during the reporting period due to significant actual or potential negative environmental impacts.

GRI 3:
Material topics 2021

3-3 Management of material topics

Section Our employees

GRI 401:
Employment 2016

401-1 New employee hires and employee turnover

Appendix-I HR data

401-2 Benefits provided to
full-time employees that are
not provided to temporary or
part-time employees

Completely Omitted

Confidentiality constraints

Due to sensitivity, such information is not disclosed. Hager Group meets all legal regulatory requirements in terms of providing access to benefits to temporary or part-time workers.

GRI 401:
Employment 2016

401-3 Parental leave

Completely Omitted

Information unavailable/incomplete

We are compiling the information and
will present the data in our next report.

GRI 3:
Material topics 2021

3-3 Management of
material topics

Section 06.2 Occupational health & safety

GRI 403 – OH&SGRI 403:
Occupational health and safety 2018

GRI 403-1 – OH&S403-1 Occupational health and safety management system

Section 06.2 Occupational health & safety

GRI 403-2 – OH&S403-2 Hazard identification, risk assessment, and incident investigation

a & b.
Section 06.2.1 Our safety management

d. Hager Group has a well-established safety reporting and investigation process. The process has clearly laid out the timeline for raising safety alert, investigation and deployment of corrective action. It also has identified responsible person in each of the process. As per the process a safety alert must be raised within 24 hours of an incident. Site/function leader is responsible to raise the alert. Investigation of the incident and its report along with the recommended improvements has to be submitted within 5 working days of the incident by the site/function leader. Once the investigation report along with the recommendations is submitted the H&S board of the subsidiary will review the accident report and decide potential action to deploy within 10 working days of the investigation report submission. It is also obligatory to organise a face-to-face meeting between management and employee within 5 working days after return to work. Site/function leader and the direct manager is responsible to conduct this meeting.

c. A description of the policies and processes for workers to remove themselves from work situations that they believe could cause injury or ill health, and an explanation of how workers are protected against reprisals.

Not applicable

There is no policy like this at group level. The new OH&S function of Hager Group will make policies and processes, including how workers can remove themselves from work situations and that they believe could cause injury or ill health, and how they can be protected from reprisals.

GRI 403-3403-3 Occupational health services

Section 06.2.2 Our health management

403-4 – OH&S403-4 Worker participation, consultation, and communication on occupational health and safety

a. Section 06.2.1 Our safety management

b. There are dedicated Occupational Safety Committees per subsidiary that meet regularly (typically quarterly but that could vary depending on the country). The committees typically consist of the specialist for occupational safety (HS Manager) of the specific subsidiary, safety officers, company doctors, members of the work council, fire protection officer the operations manager, an HR manager, and a representation from top management.

403-5 Worker training on occupational health and safety

16%

GRI 403-6 – OH&S403-6 Promotion of worker health

Section 06.2.2 Our health management

403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

Completely Omitted

Not applicable

We do not have a group level system at present to prevent or mitigate the OH&S risks caused by our business relationships in our operations, products, or services. However, we recognise the need for such a system and will work towards establishing it.

403-8 Workers covered by an occupational health and safety management system

Completely Omitted

Information unavailable/incomplete

The H&S management in our production and logistic sites applies to all people working on the premises, including workers whom the organisation does not employ. However, the number and percentage of such employees still need to be calculated. We will publish this data in our following report.

GRI 403-9 – OH&S403-9 Work-related injuries

a. Section 02.2.1 Our safety management

b. i. 0

ii. 0
iv. work-related injuries that result in operational disruptions or slowdowns due to lost time

e. It is calculated by using 1.000.000 hours worked.

f. All the employees of Hager group are included in this disclosure.

g. Following formula was used to compile and calculate the LTA and LTAR data at group level:

LTA (Jan-Dec) = ∑((Number of all occupational work accident per site))

LTAR (Jan-Dec) = (No. of LTAs × 1.000.000) / (No. of real working hours)

b. For all workers who are not employees but whose work and/or workplace is controlled by the organisation:
iii. The number and rate of recordable work-related injuries;

c. The work-related hazards that pose a risk of high-consequence injury, including:
i. how these hazards have been determined;

ii. which of these hazards have caused or contributed to high-consequence injuries during the reporting period;
iii. actions taken or underway to eliminate these hazards and minimize risks using the hierarchy of controls.

d. Any actions taken or underway to eliminate other work-related hazards and minimize risks using the hierarchy of controls.

Information unavailable/incomplete

b. We do not have a separate record of the work related injuries of the workers who are no employees of Hager group. We will work on this and try to submit the data in the following report.

c. This is currently managed at subsidiary level. After the formation of group level OH&S function by 2025, we will compile and share the information.

d. This is currently managed at subsidiary level. After the formation of group level OH&S function by 2025, we will compile and share the information.

b. For all workers who are not employees but whose work and/or workplace is controlled by the organisation:
v. The number of hours worked.

Confidentiality constraints

In France it is illegal to record worked hours by external force.

403-10 Work-related ill health

Completely Omitted

Information unavailable/incomplete

Hager Group manages these records at site level according to the compliance requirements in that region. After the formation of group level OH&S function by 2025, we can compile and share the information.

GRI 3:

Material topics 2021

3-3 Management of
material topics

Section Our employees
Section 06.3 Talend development

GRI 404GRI 404:

Training and education 2016

GRI 404-1 Training and education404-1 Average hours of training per year per employee

Section 06.3 Talent development

GRI 404-2 Training and Education404-2 Programs for upgrading employee skills and transition assistance programs

a. Section 06.3 Talent development

b. Transition assistance programs provided to facilitate continued employability and the management of career endings resulting from retirement or termination of employment.

Not applicable

Hager Group does not offer a specific transition assistance programme. However, employees can use our training platform, Hi! University, to upgrade their skills, which may aid them in their transition and facilitate continued employability.

404-3 Percentage of employees receiving regular performance and career development reviews

96 % of the total employees received a performance and career development review during the reporting period. The rest, 4 %, are either in progress or have not yet started. However, the distribution of this detail by gender is not available.

GRI 3:
Material topics 2021

3-3 Management of
material topics

Section Our employees
Section 06.4 Equal opportunities and diversity

GRI 405GRI 405:
Diversity and equal opportunity 2016

GRI 405-1 – Equality405-1 Diversity of governance bodies and employees

Section 6.4 Equal opportunities & diversity
Appendix-I HR data

405-2 Ratio of basic salary and remuneration of women to men

Completely Omitted

Information unavailable/incomplete

Hager Group is adapting its process to get this information at global level and will try to provide correct information in the following report.

GRI 3:
Material topics 2021

3-3 Management of
material topics

Section 02.2 Material topics
Section 03.6.3 Enhance compliance and sustainability risk management
Section 04.1 The blue planet commitment

GRI 414 Supplier social assessment;GRI 414:
Supplier social
assessment 2016

414-1 New suppliers that were screened using social criteria

100 % of active tier 1 supplier in direct sourcing are screened with Hager’s third party tool SPHERA.

GRI 414-2 – Supplier social assessment414-2 Negative social impacts in the supply chain and actions taken

a, b & c.
Section 03.6.3 Enhance compliance and sustainability risk management

d. 0,3 % suppliers identified as having significant actual and potential negative social impacts with which improvements were agreed upon as a result of assessment.

e. Percentage of suppliers identified as having significant actual and potential negative social impacts with which relationships were terminated as a result of assessment, and why.

Not applicable

No business relationship has been terminated due to this reason.

GRI 3:

Material topics 2021

3-3 Management of material topics

Section 05.2.4 Product safety

GRI 416-1416-1 Assessment of the health and safety impacts of product and service categories

Section 05.2.4 Product safety

416-2 – Customer H&S 416-2 Incidents of non-compliance concerning the
health and safety impacts of products and services

Section 05.2.4 Product safety

GRI 303:

Water and effluents 2018

GRI 303-3 Water withdrawal303-3 Water withdrawal

Section 04.4.2 Water management

d. Each site has shared the water consumption data manually.

GRI 304:
Biodiversity 2016

GRI 304-1304-1 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas

Section 04.4.1 Biodiversity footprint

a. For each operational site owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas, the following information:
ii. Subsurface and underground land that may be owned, leased, or managed by the organisation;

v. Size of operational site in km2 (or another unit, if appropriate);

Not applicable

There is no subsurface and underground land owned, leased or managed by Hager Group.

Size of operation site was not used as a parameter for assessment.

GRI 304-2 Biospanersity304-2 Significant impacts of activities, products and services on biodiversity

Section 04.4.1 Biodiversity footprint

b. Significant direct and indirect positive and negative impacts with reference to the following:

iii. Duration of impacts;

iv. Reversibility or irreversibility of the impacts.

Information unavailable/incomplete

We have not estimated the duration
and reversibility or irreversibility of the impacts.

GRI 304-4 Biospanersity304-4 IUCN Red List species
and national conservation list species with habitats in areas affected by operations

Section 04.4.1 Biodiversity footprint

a. Total number of IUCN Red List species and national conservation list species with habitats in areas affected by the operations of the organisations, by level of extinction risk:
iv. Near threatened
v. Least concern

Information unavailable/incomplete

We have not estimated for the level of
risk near threatened and least concern.

GRI 306-3 to 306-4 Waste306-3 Waste generated

Section 04.5 Waste

306-4 Waste diverted
from disposal

Section 04.5 Waste