Nonfinancial Group Statement

TRATON SE is exercising its option under section 315b(2) of the HGB to exempt itself from the requirement to issue a nonfinancial Group statement and refers to the combined nonfinancial statement of the Volkswagen Group and Volkswagen AG for fiscal year 2025, which is part of the Group Management Report in the Volkswagen Group’s 2025 Annual Report. This will be available at https://www.volkswagen-group.com/Financial-Reports as of March 10, 2026.

Comprehensive information on the TRATON GROUP’s sustainability activities can also be found in the Sustainability Report chapter.

EU Taxonomy disclosures

1. Background and objectives

Under the European Green Deal, the European Union (EU) has put the issues of climate change mitigation, environmental protection, and sustainability at the center of its political agenda. It has defined the goal of achieving climate neutrality by 2050. In this context, the EU published the Strategy on Financing the Transition to a Sustainable Economy in 2021 in order to support the financing of the transformation to a sustainable economy. This strategy is based on the 2018 EU action plan on financing sustainable growth. It aims to reorient capital flows toward sustainable investments, mainstream sustainability into risk management, and foster transparency and long-termism. The action plan consists of ten actions and has as its core Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 (Regulation 2020/852)¹ , as well as the related delegated acts (hereinafter referred to collectively as “EU Taxonomy”).

The EU Taxonomy is a classification system for sustainable economic activities. Economic activities that fall under the EU Taxonomy, and are thus taxonomy-eligible, are those that are described in the delegated acts and for which technical screening criteria are available for one of the six environmental objectives. Economic activities are deemed to be environmentally sustainable, and thus taxonomy-aligned, if they make a substantial contribution to the achievement of at least one of six environmental objectives (“substantial contribution”), do not significantly harm (DNSH) one or more environmental objectives (substantial contribution and DNSH are together referred to as “technical screening criteria”), and also meet certain minimum safeguards that apply to all economic activities with a primary focus on human rights and social and labor standards. The six environmental objectives relate to:

• Climate change mitigation
• Climate change adaptation
• The sustainable use and protection of water and marine resources
• The transition to a circular economy
• Pollution prevention and control
• The protection and restoration of biodiversity and ecosystems

All other economic activities are taxonomy-non-eligible economic activities.

2. Reporting on fiscal year 2025

For fiscal year 2025, the TRATON GROUP is reporting on the six environmental objectives mentioned above in accordance with Article 8 of Regulation 2020/852 and Article 10(4) of the Delegated Regulation on Article 8 of the aforementioned Regulation, including Delegated Regulation (EU) 2026/73 of July 4, 2025. With the entry into force of Delegated Regulation (EU) 2026/73, various simplifications were enacted with regard to the substance and presentation of the information to be reported. In particular, the associated reduction in the complexity of the DNSH criterion for preventing and controlling pollution means that TRATON can again provide evidence of full compliance with the DNSH criterion for all Scania and MAN sites included in the analysis and can therefore report taxonomy-aligned sales revenue, capital expenditure, and operating expenditure. In the previous year, it was not possible to demonstrate full compliance with the aforementioned DNSH criterion. The comparative figures for the previous year were not retroactively adjusted to reflect the simplifications introduced by Delegated Regulation (EU) 2026/73.

In addition, the EU Taxonomy contains wording and terms that are subject to interpretation uncertainties and could lead to changes in the reporting if they are subsequently clarified by the EU. There is a risk that the reported key performance indicators must be assessed differently. The TRATON GROUP’s interpretation is presented in the following.

3. Economic activities of the TRATON GROUP

With its four brands Scania, MAN, International, and Volkswagen Truck & Bus, the TRATON GROUP is one of the world’s leading manufacturers of commercial vehicles. The portfolio consists of trucks, buses, and light-duty commercial vehicles, as well as the sale of spare parts and customer services. In addition, the TRATON GROUP offers a broad range of financial services to its customers. The TRATON GROUP’s activities are divided into the industrial business (TRATON Operations) and financial services (TRATON Financial Services) business areas.

3.1 Taxonomy-eligible economic activities

The TRATON GROUP’s economic activities were analyzed based on its business model as a manufacturer of commercial vehicles and fall under code C.29.10 (Manufacture of motor vehicles and motor vehicle engines) of the EU’s Statistical Classification of Economic Activities (NACE).

In terms of the “climate change mitigation” environmental objective pursuant to Annex I to Regulation 2020/852, this means that the economic activities related to the manufacture, repair, maintenance, retrofitting, or upgrade of vehicles are allocated to economic activity 3.3 “Manufacture of low-carbon technologies for transport.” The allocation of economic activity is independent of the drive technology of the underlying vehicle.

In detail, the manufacture and related selling activities for all new and used vehicles (including the sale of leased used vehicles) as well as financial services are allocated to economic activity 3.3 under the “climate change mitigation” environmental objective. In addition, service activities such as maintenance and repair, including the genuine parts used for this purpose, are also allocated to this economic activity.

In contrast, economic activities where TRATON acts as dealer of vehicles or as supplier of components and parts for non-battery-electric vehicles are assigned to the taxonomy-non-eligible activities. They relate to economic activities for vehicles not manufactured internally being sold by the TRATON GROUP brands as well as those in connection with engines, powertrains, and parts deliveries.

Hedging transactions and individual activities that are reported in the “Other sales revenue” item in the Consolidated Financial Statements as of December 31, 2025, do not conform to the descriptions of economic activities in the delegated acts and are therefore classified as taxonomy-non-eligible.

In the course of an analysis of economic activity within the framework of the EU Taxonomy, no activities were identified for TRATON that specifically account for any of the five other environmental objectives. However, the dynamic evolution of EU Taxonomy rules may lead to modifications of economic activities in the future.

3.2 Taxonomy-aligned economic activities

Substantial contribution

The criteria for assessing the substantial contribution of economic activity 3.3 defined in Annex I to Regulation 2020/852 are based on the relevant vehicle classes and the associated CO₂ emissions and drive technologies. For the TRATON GROUP, all internally produced, all-electric vehicles (BEVs) meet the criteria for a significant contribution. This means that economic activities associated with BEVs make a significant contribution to climate change mitigation.

DNSH criteria

The analysis of the DNSH criteria was conducted at the level of the relevant sites. In addition to production sites, component plants and research & development units that are associated with vehicles that meet the technical screening criteria for substantial contribution, or will do so in the next five years, were also analyzed. The majority of the sites included in the analysis are located in countries within the EU, in the USA, and in South America. Our production site in Rugao, China, was not conclusively assessed due to the ongoing changes in its operational and organizational structure. The EU Taxonomy is subject to interpretation uncertainties with regard to the DNSH criteria and poses particular challenges for sites outside the EU due to the potentially different legal situation there.

The assessment of the DNSH criteria was based on the requirements applicable in the EU in 2025 for ongoing business operations as well as on internal policies and processes. Country-specific requirements and internal processes were used for sites outside the EU. In contrast to the previous year, when it was not possible to demonstrate full compliance with the DNSH criterion for the prevention and control of pollution, the assessment of the DNSH criteria for the Scania and MAN brands’ sites included in the analysis was completely positive. This is due to simplifications enacted in 2025 affecting the substance and presentation of the information to be reported. See also the Reporting on fiscal year 2025 section. The TRATON GROUP’s approach to assessing the DNSH criteria is presented in detail in the following.

Climate change adaptation

A climate risk and vulnerability assessment was performed to identify sites that could be impacted by physical climate risks. The assessment of the chronic and acute physical climate risks analyzed was performed in line with the useful life of the relevant assets in relation to economic activity 3.3. TRATON’s climate-based DNSH assessment is based on Shared Socioeconomic Pathway (SSP) 8.5 of the 6th Assessment Report of the Intergovernmental Panel on Climate Change (IPCC) up to the year 2050 and thus assumes the highest expected CO₂ concentration according to the IPCC. In addition, risk-specific analyses were conducted with additional data sources based on the exact locations. Identified threats were assessed for relevance in the local environment, and any necessary risk mitigation measures were developed.

The sustainable use and protection of water and marine resources

Environmental impact assessments, ISO 14001 certificates, local legislation, internal policies and processes, and other external data sources were used to analyze compliance with the DNSH criterion. To achieve good water status and good ecological potential, risks of environmental damage related to maintaining water quality and avoiding water scarcity were identified and analyzed. Countermeasures have been implemented at sites with an increased risk.

The transition to a circular economy

Sustainability is an established concept within the TRATON GROUP brands. The transition to a circular economy is defined in the strategic focus areas specified by TRATON. Specifically, a review was carried out at the level of the brand in question to determine the extent to which local legislation or internal rules cover the specific requirements.

Pollution prevention and control

In order to be considered environmentally sustainable, an economic activity cannot result in a substantial increase in air, water, or ground pollution compared to the levels before it began. The automotive industry is already extremely regulated on the whole⁠ ⁠—⁠ ⁠among other things, this is reflected in the publicly accessible Global Automotive Declarable Substance List (GADSL). Implemented approval and control processes are designed to ensure compliance with the legal requirements and internal regulations applicable to ongoing business operations. In this context, we are already actively addressing the use of alternative, less harmful substances in our analyses and assessments.

TRATON has established processes and standards that aim to minimize and substitute the use of substances of very high concern (SVHCs). As part of our analysis to assess the substitutability of SVHCs, we include the vehicle-related materials and components as well as their suppliers. Among other things, we consider technical and economic criteria. Our current processes are founded on our suppliers complying with TRATON’s Supplier Code of Conduct and its updates. The Code of Conduct is an integral part of our long-term strategy for supplier relations. Suppliers are automatically notified about changes to our standards and our Code. For the Scania and MAN brand sites that were included in full in the analysis, the audit yielded a positive result, as they have already implemented cross-company processes to restrict the use of SVHCs. Evidence of compliance could not be provided for the other brand sites.

The protection and restoration of biodiversity and ecosystems

To verify compliance with the requirements governing biodiversity and ecosystems, the relevant areas were identified using various information sources (including Natura 2000 areas and environmental impact assessments). To the extent that biodiversity-sensitive areas are close to a site, an assessment of the associated risks and impacts on the area was performed. If necessary, compensatory or remedial measures are generally taken to ensure that the business activity has no significant impact on the conservation objectives of the protected area.

Minimum safeguards

Minimum safeguards ensure compliance with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the fundamental principles and rights from the eight core conventions set out in the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work, and the guiding principles from the International Bill of Human Rights. The analysis was based on the recommendations on minimum safeguards issued by the Platform on Sustainable Finance in October 2022. They require TRATON to have in place effective processes, controls, and compliance measures with regard to the following four core topics:

• Human rights, including workers’ rights
• Bribery/corruption
• Taxation
• Fair competition

The TRATON GROUP is guided by the implementation of its duty to ensure respect for human rights as required by the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. This is reflected in various Group-wide policies and our Code of Conduct. Additionally, the TRATON GROUP recognizes the International Bill of Human Rights and bases its approach to human rights issues on the UN Guiding Principles on Business and Human Rights and the ILO core conventions.

Regular risk analyses identify, assess, and take action to prevent, terminate, and mitigate negative impacts in our own business activities and within the supply chain. The effectiveness of the implementation of the underlying regulations is reviewed with the help of the internal control system (ICS). Regular Group-wide communication relating to compliance and integrity takes place across hierarchical levels and brands using various channels and promotes employee awareness of ethical behavior. In addition, TRATON has various whistleblower channels for reporting violations at any time, in all languages, and anonymously if desired. As a result, TRATON ensures that the minimum safeguard requirements are met.

4. Key performance indicators pursuant to the EU Taxonomy

The key performance indicators (KPIs) for fiscal year 2025 included the taxonomy-aligned turnover, capital expenditure (capex), and operating expenditure (opex) of the TRATON GROUP. Only transactions with third parties have been taken into account. Turnover, capital expenditure, and operating expenditure relate in full to the “climate change mitigation” environmental objective.

To determine the percentages, the taxonomy-eligible and taxonomy-aligned turnover, capital expenditure, and operating expenditure are each set in relation to total turnover, total capital expenditure, and total operating expenditure within the meaning of the EU Taxonomy.

The tables required by the EU Taxonomy are shown at the end of the chapter.

4.1 Turnover

1 The percentage amount shown relates to the total turnover as defined by the EU Taxonomy.

Turnover was calculated on the basis of the sales revenue (denominator) reported in the income statement for the period from January 1 to December 31, 2025, in the Consolidated Financial Statements as of December 31, 2025, which amounted to €44.1 billion in fiscal year 2025.

Economic activity 3.3 accounted for €41.0 billion of this total, or 93% of the TRATON GROUP’s sales revenue, which was classified as taxonomy-eligible turnover. This includes in particular revenue from the sale, lease, and financing of new and used vehicles manufactured internally, as well as revenue from genuine parts and workshop services. By contrast, revenue from the sale of vehicles that are not manufactured internally or revenue in connection with engines, powertrains, and parts deliveries is not included. Other taxonomy-non-eligible turnover is contained in the “Other sales revenue” item in the Consolidated Financial Statements as of December 31, 2025.

In fiscal year 2025, TRATON reports taxonomy-aligned sales revenue of €1.0 billion, or 2%, whereas there was no taxonomy-aligned sales revenue in the previous year. The change compared with the previous year is due to the introduction of new rules. See also the sections Reporting on fiscal year 2025 and DNSH criteria.

The following table contains a breakdown of taxonomy-aligned turnover:

4.2 Capital expenditure

1 The percentage amount shown relates to the total capital expenditure as defined by the EU Taxonomy.

Capital expenditure was calculated on the basis of additions included in the Consolidated Financial Statements as of December 31, 2025, and additions from business combinations to intangible assets, property, plant, and equipment, and assets leased out, which amounted to €5.3 billion in fiscal year 2025. Additions to goodwill are not included in the denominator.

Economic activity 3.3 accounted for €5.1 billion of this total, or 97% of the TRATON GROUP’s capital expenditure classified as taxonomy-eligible. This includes in particular capital expenditure related directly to taxonomy-eligible economic activities. Capital expenditure on administration or distribution primarily benefits taxonomy-eligible economic activities and has therefore been included. By contrast, capital expenditure incurred in connection with vehicles not manufactured internally or the business with engines, powertrains, and parts deliveries is taxonomy-non-eligible. Also excluded is capital expenditure on investment property since it is not economically required by TRATON to manufacture low-carbon technologies for transport.

In fiscal year 2025, TRATON reports taxonomy-aligned capital expenditure of €690 million, or 13%, whereas there was no taxonomy-aligned capital expenditure in the previous year. The change compared with the previous year is due to the introduction of new rules. See also the sections Reporting on fiscal year 2025 and DNSH criteria.

The following table contains a breakdown of taxonomy-aligned capital expenditure:

4.3 Operating expenditure

1 The percentage amount shown relates to the total operating expenditure as defined by the EU Taxonomy.

Operating expenditure is determined on the basis of noncapitalized research & development costs. These are calculated by subtracting capitalized development costs from primary R&D costs. The calculation of the denominator of the KPI includes the following:

• Maintenance expenses for owned or leased real estate and other assets
• Expenses attributable to short-term leases (up to twelve months) and not recognized as right-of-use assets in the balance sheet

The TRATON GROUP’s total operating expenditure as defined by the EU Taxonomy amounted to €2.0 billion in the year under review.

Economic activity 3.3 accounted for €1.9 billion of this total, or 97% of the TRATON GROUP’s operating expenditure, which was classified as taxonomy-eligible. This only included operating expenditure incurred in direct connection with taxonomy-eligible economic activities. Operating expenditure related to taxonomy-non-eligible economic activities, such as the business with engines, powertrains, and parts deliveries, has therefore not been included in the numerator.

In fiscal year 2025, TRATON reports taxonomy-aligned operating expenditure of €229 million, or 11%, whereas there was no taxonomy-aligned operating expenditure in the previous year. The change compared with the previous year is due to the introduction of new rules. See also the sections Reporting on fiscal year 2025 and DNSH criteria.

The following table contains a breakdown of taxonomy-aligned operating expenditure:

4.4 Disclosures on the capex plan

Under the EU Taxonomy, taxonomy-aligned capital expenditure in the reporting year is divided into a) capital expenditure relating to assets or processes already associated with environmentally sustainable economic activities and b) capital expenditure that is part of a plan to expand taxonomy-aligned economic activities, or to upgrade taxonomy-eligible economic activities to taxonomy-aligned economic activities (capex plan). The capex plan includes the aggregated capital and operating expenditure incurred and expected to be incurred during the reporting period and within the next five years to expand taxonomy-aligned economic activities or to upgrade taxonomy-eligible economic activities to taxonomy-aligned economic activities.

In the course of the allocation, all taxonomy-aligned additions to assets leased out (primarily vehicle leases) were entirely taken into account as capital expenditure that was already associated with environmentally sustainable economic activities because the underlying vehicles are already manufactured and taxonomy-aligned. These were therefore not included in the capex plan. By contrast, taxonomy-aligned additions to intangible assets and to property, plant, and equipment as well as noncapitalized research & development costs are allocated to the capex plan on a pro rata basis with the help of the allocation key. The allocation key compares the ratio of the production volume of taxonomy-aligned vehicles for the reporting year in question with the average taxonomy-aligned production volume under the five-year plan. The proportion over and above is allocated to the capex plan. As a result, €482 million of the taxonomy-aligned capital expenditure for the reporting year is allocated to the capex plan, while €177 million of the taxonomy-aligned operating expenditure is allocated to the capex plan. The total capital expenditure of the capex plan incurred in the reporting period and expected to be incurred during the five-year planning period amounts to €9.2 billion.

4.5 Table overview according to the EU Taxonomy

Proportion of turnover, capital expenditure, and operating expenditure from products or services associated with taxonomy-eligible or taxonomy-aligned economic activities

Turnover

Proportion of turnover from products or services related to taxonomy-eligible or taxonomy-aligned economic activities

1 Abbreviations used in the table: CCM: Climate change mitigation, E: Enabling activity, T: Transitional activity.

Capital expenditure

Proportion of capital expenditure from products or services related to taxonomy-eligible or taxonomy-aligned economic activities

Operating expenditure

Proportion of operating expenditure from products or services related to taxonomy-eligible or taxonomy-aligned economic activities