Own workforce (ESRS S1)

Actions (S1-4)

The five-year data protection strategy with a focus on the implementation of the General Data Protection Regulation (GDPR) and digitalization applies equally to customer and employee data. In 2025, the data protection organization supported specialist departments in implementing the requirements of the EU AI Act and in establishing governance structures for artificial intelligence (AI). This also applies to the data-protection-compliant implementation of AI applications in order to protect the rights of employees when it comes to digital innovations.

A digital specialist portal for the data protection organization was set up in 2025 to strengthen internal knowledge management. It bundles processes, documentation and specialist knowledge to support data protection consulting for specialist departments. At the same time, a central data protection wiki was created for all employees and will be accessible via an internal AI assistant in future. This facilitates access to data protection knowledge and raises awareness of data- protection-compliant action. In addition, a new e-learning module for executives that teaches data protection obligations in a practical way was developed in 2025 and introduced throughout the Group at the beginning of 2026. This measure is intended to strengthen data protection competence and support compliance with legal requirements.

Action plans 2026

The measures described will be continued in 2026.

Sustainability indices

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