GETEC is an international company. The individual entities are responsible for the countries in which they are located and for some neighboring countries. In the following General Disclosures, we focus on general results and KPIs – other than for employees and workers who are not employees. We will start with the general KPIs for our company.

Total number of employees
2,709

Employment contracts (temporary/permanent):
Almost all our employment contracts are permanent.

Employment type:
Most of the company’s activities are performed by workers who are employees. There is no significant amount of seasonal work.

Employees by gender (GETEC Group):

Employee
health rate:

GETEC has a presence in nine European countries and has an international workforce.
We employ people from the following countries:

GETEC is active in many associations, increasingly assuming its responsibility as an expert and a pioneer of the energy transition in the political and regulatory environment. Through our work in associations, we consider ourselves a trendsetter when it comes to innovative solutions and business models aimed at advancing decarbonization. There follows a list of our activities and memberships. See the appendix on page 80 for a complete list.

Decarbonization – especially in energy-intensive industries but also in the real estate industry and public sector – is not an option but a must. In 2024, we clearly defined our company’s goal with our new vision (see also CEO essay, pages 6 to 9). We aim to improve our customers’ carbon footprint and help them reduce CO2 emissions in their business operations. And we aim to achieve this sustainably, economically and reliably. One important step toward achieving this goal is the completion of our double materiality assessment (see next page), which defines the focus of our efforts.

We refer to the policies, agreements and instructions that are applicable to our material topics and described in the respective chapters. Moreover, our company’s responsible conduct is measured by our contribution to the United Nations Sustainable Development Goals (SDGs), especially those relating to “Affordable and clean energy”, “Industry, innovation and infrastructure”, “Sustainable cities and communities”, “Climate action”, “Good health and well-being”, “Gender equality” and “Decent work and economic growth".

Our new double materiality assessment gave us the perfect opportunity to connect with our stakeholders outside our day-to-day business. As an energy supplier, we are in constant contact with politicians, residents, environmental experts and the media. Our status quo and benchmarking analysis enabled us to deepen this dialog. Working with selected topic experts and considering our main peers, standards and frameworks, we analyzed stakeholders’ needs and incorporated the findings into our strategy.

In the course of management change in 2023, we fundamentally revised our double materiality assessment (see pages 22 to 25 for a detailed description of the process and the findings). A detailed analysis of the materiality assessment findings will be included in our CSRD report.

The reporting period is the 2023 calendar year. We report annually on sustainability topics.

Contact for questions regarding the report:

Liza Steudle
Head of ESG Group
esg@getec.de

Contact Corporate Communications:

Carla Haag
Head of Marketing Group
communication@getec.de

External assurance of this report is not planned.

No employees in Germany are covered by a collective bargaining agreement. In Switzerland, 35% of employees were covered by a collective employment agreement (Gesamtarbeitsvertrag, GAV) in 2023. 90% of the Netherlands platform employees are covered by collective bargaining agreements (Collectieve Arbeidsovereenkomst, CAO). All our employees in Italy are covered by the national collective working agreement (contratto collettivo nazionale di lavoro, CCNL).

The materiality assessment was identified by GETEC as the key to sustainable development. As part of our sustainability strategy, we achieved a further important milestone in 2023. By successfully completing a double materiality assessment, we satisfy the requirements of the Corporate Sustainability Reporting Directive (CSRD) and ensure that sustainability is firmly embedded in our corporate strategy. We describe the process on pages 22 to 25 of this ESG Report. A detailed analysis of the materiality assessment findings will be included in our CSRD report.

Our core competence is energy since we supply heating, refrigeration, steam, electricity, compressed air and other media to industrial and real estate customers. We take a holistic approach and our solutions often form a systemic network of different technologies and media. Our company is clearly focused on reducing carbon emissions. However, most solutions are still producing emissions. Even after revision of the materiality assessment, emissions remain one of the most important issues, if not the most important issue, alongside climate change, energy, pollution, the use of resources, waste and the circular economy. We will add further information as part of our CSRD reporting in 2025.

GETEC has a large number of regulations and policies including environmental regulations, a fundamental principle of rigor (sparing use of resources) and our commitment to climate protection by means of decarbonization – not only in respect of our own plants but also our customers’ plants. Our conduct and our action are based on the GETEC Group’s HSE Policy, which applies to all platforms.

Customized energy solutions for the future
GETEC develops technology-agnostic energy infrastructure solutions tailored to customers’ specific needs. The goal is to increase energy efficiency, optimize costs and improve the environmental balance.

Our service portfolio spans the modernization of existing plants as well as the planning and construction of new energy infrastructure. During the implementation phase, GETEC assumes responsibility for coordinating equipment manufacturers, construction partners and subcontractors. Upon request, GETEC also invests in its customers’ infrastructure or takes over the plants upon expiration of the contract. On completion of the projects, the company provides qualified employees on site or uses remote monitoring systems to ensure the high reliability and efficient maintenance of the solutions – either on the basis of practical measures or data-based decision-making. All services can be purchased as part of a full package or as individual modules.

GETEC’s product portfolio includes solutions for steam, heating, cooling, energy recovery and waste and water treatment. The company uses a range of state-of-the-art technologies, including biogas and biomass boilers, power-to-heat plants, heat pumps and hydrogen-ready boilers. GETEC also plays a leading role in combined heat and power plants and the use of natural gas boilers. The company has various business models for implementing its projects, covering aspects from planning, through construction and financing, to operation and maintenance.

Thanks to these holistic and flexible solutions, GETEC enables its customers to design sustainable energy supplies and leverage economic benefits. Customers can be certain that their energy infrastructure can be operated viably and efficiently.

GRI 3-3-E

We have implemented a Group-wide energy data initiative to continuously record information about the output of our power plants, with the goal of increasing their energy efficiency. Around 75% of the plants were digitalized in the reporting year, which facilitates large-scale remote monitoring. We are still aiming to define science-based GHG reduction targets and planning for this is ongoing.
Regarding the determination of Scope 3 emissions, we are seeking to use more hard data each year so we can increasingly do without model calculations. We were able to calculate the actual Scope 3 emissions of our customers, i.e. those emissions from assets owned by our customers or from the resale of energy to our customers. Other emissions that are relevant to Scope 3, such as the emissions relating to materials, transport and our suppliers, are determined using our tool-based model calculations.

In the future, we will require our suppliers to reduce their greenhouse gas emissions. To achieve this, we will be integrating a digital database in the form of a supplier portal into our supplier management system. We introduced a prototype of this new system during the reporting year so that we can conduct a pilot project that enables us to handle new issues more effectively. In the years ahead, we aim to use this system – supplemented by an app – to improve processes so we can address the core aspects of Germany’s Act on Corporate Due Diligence Obligations in Supply Chains (Lieferkettensorgfaltspflichtengesetz, LkSG) and the European Supply Chain Act as well as achieve transparency regarding the emissions of our major suppliers.

We are currently revising our KPIs and the databases used so that we can implement targeted and efficient measures.

Decarbonization concerns almost all our relevant stakeholder groups. For this reason, we maintain a constant dialog with our customers, organizing webinars on new regulatory developments and providing information about decarbonization options. For our employees, too, discussion of the company’s purpose is increasingly relevant. That is why “We deliver reliable, decarbonized energy and manage infrastructure” is our mission. It refers to aspects such as decarbonization and is intended to motivate our employees. In the case of new projects, there is an additional obligation to contact stakeholders such as local communities.

• Green steam reference project in Teisnach, Germany: Installation of a climate-neutral energy supply for the Pfleiderer paper mill; heating (process steam) supplied from a modern biomass heating plant with an annual reduction of 27,000 metric tons of CO2 emissions. The plant has been converted and refurbished successfully.
• Biomass reference plant in Gengenbach, Germany: Here, a reduction of 19,000 tCO2 per year will be achieved by converting the plants from pulverized coal to dedicated biomass.
• Green eHeating: The goal of reducing CO2 emissions is also being pursued in other projects, for example, in collaboration with Projekta Grundinvest in Darmstadt, Germany. Here, 122 residential units are supplied with 85% renewable energy from photovoltaic units and heat pumps.
• Development and roll-out of the ISO 50001 management system
• Renewable energy: Increase in the total installed output from renewable sources; improvement and expansion of commercial renewable energy offerings (e.g. photovoltaics)
• Certification to Italian standard UNI CEI 11352:2014 (requirements for energy service companies)
• In recent years, GETEC Netherlands has systematically replaced all gas and diesel vehicles used in logistics with all-electric vehicles. Last month, another milestone was achieved with the introduction of the first all-electric heavy truck. The cafeteria has also been fully electrified.
• Management system implemented and certified to ISO14001
• Waste-to-value: Used and depleted raw materials (used solvents) are recycled by GETEC Switzerland and can be reused by our customer. These solvents have a much lower carbon footprint then new solvents.
• Installation of rooftop photovoltaic units at the sites in Switzerland and Netherlands: First photovoltaic unit completed at the end of 2022; a further 1,050 units with a nominal output of 588 kWp were installed in 2023.

It is GETEC’s corporate policy to conduct all its activities in a responsible manner in order to protect and foster the health, safety and well-being of its employees. Many of our employees work in maintenance and service or in installing our energy solutions in plants or on construction sites. They are therefore exposed to the risks that are usual for the industry. Accidents can have considerable consequences for GETEC, both economically and socially. We feel the same sense of responsibility for workplace safety when it comes to our contractors. And customers may also stipulate occupational safety requirements that need to be considered in our occupational health and safety management system. We want to provide a healthy environment for everyone who works for us and give them the training they need to be able to move with foresight and routine in this environment. Moreover, healthy employees are the foundation of our success. Occupational health and safety remain among the material topics that impact the entire GETEC Group. In some cases, separate conditions apply for the employees of our platforms. These are shown in the tables below.

We aim to provide a safe and healthy working environment for all our employees in accordance with the previously applicable requirements of GRI 103-1. The materiality assessment identified our “own workforce” as a material topic. This covers especially the issues of health, training and individual development as part of our new strategy. We will publish details next year and include them in our CSRD report.

All necessary information about occupational safety is made available in our intranet. As well as our 360° Safety Culture, our HSSE Group Policy and our strategy and targets, our platforms’ management systems in accordance with ISO 45001 and ISO 14001 ensure that the risks to our employees and all external stakeholders are very low and that plants and work are operated and performed in accordance with the law thanks to compliance with the standards. The management systems are supported by a wide range of process and operating instructions, detailed plant safety and risk assessment templates, documented training, an accident and incident reporting system combined with root cause analysis and measures for the continuous improvement of the working environment and individual conduct, hazardous substance management, activity-based hazard assessment, health management and subcontractor management.

Our HSSE Policy applies to all consolidated GETEC Group companies in all countries. Due to regional requirements such as national legislation, each site has its own independent HSSE management system. This is aligned with the Group’s objectives and is regularly coordinated at Group level.

Our management approach in accordance with GRI 403 requirements:

As part of the reorganization of the GETEC companies and the establishment of Golf BidCo GmbH as a holding company, the management approach is being revised and adapted to the new circumstances. All adjustments and changes will be published in the CSRD report.

Our platforms’ occupational safety measures – progress and future planning

How we are continuously improving occupational health and safety by way of international and local initiatives

Our policies are adapted for implementation in the individual countries in line with their respective culture and local laws. Each company aligns its measures with local requirements, while overarching targets and policies are coordinated at Group level. Below is an overview of the main developments and plans.

In Germany, the focus is on certifying the occupational safety and environmental protection systems in accordance with ISO 14001 and ISO 45001. Certification has already been completed for GETEC Holding GmbH and other Group companies are to follow. In the area of occupational medicine, ergonomic furniture such as height-adjustable desks has been introduced at the Eschborn, Leipzig and Düsseldorf sites in order to foster employees’ health.

In Italy, measures are focused on reducing accident rates. Special training and targeted workplace inspections have been introduced to identify potential risks and analyze near misses. In addition, the occupational health services were expanded and the medical team enlarged. A prevention program was launched in 2023. Employees are given a preventive healthcare budget and can decide individually whether to invest this in gym sessions, meditation courses, nutrition counseling or psychological support.

In the Netherlands, the HSSE management system was certified to ISO 50001 and ISO 55001 in 2022. The company’s own emergency team can provide first aid on site and transfer employees to a doctor or hospital if necessary. The platform also offers medical check-ups focused on the psychosocial effects of work.

Switzerland is working to introduce an integrated management system in accordance with ISO 14001 and ISO 9001. The HSEQ department is now more strongly integrated into project execution to ensure the compliance with high standards during the construction and start-up phases. In addition, the 360° Safety Culture program was established. This involves weekly safety meetings with the managers of the operating units to discuss and implement safety measures.

These measures highlight the GETEC Group’s continuing commitment to creating and maintaining safe and healthy working conditions. By way of regional customizations and Group-wide standards, we ensure the health of our employees and foster proactive occupational safety.

Our employees participate on a continuous basis in developing, implementing and assessing our occupational health and safety management system. In 2022, we initiated an employee survey on occupational safety for the platforms so that our employees can provide their specific feedback on issues that are relevant to them. We have also established meetings with employees who are returning to work after their recovery following an accident at work. These extensive meetings are led by the employee’s supervisor. The goal is to define suitable measures for preventing any similar accidents in the future. The involvement of the employee affected is invaluable in this respect. In the context of ISO 14001 certification, measures exist to involve external stakeholders in the occupational safety issues addressed during the reporting year.

We refer to the ESG Report 2022, page 92. In accordance with the existing GRI 103-3 (evaluation of the management approach), we explained our tracking of effectiveness, including the list of the various initiatives of our international companies in response to accidents. As a general rule, the tracking of effectiveness in accordance with GRI 3-3-e was ensured by each platform in the course of the ISO 14001/ISO 45001 management review and monitored by external certification audits.

All employees at all GETEC companies are covered by an occupational health and safety management system.

In the reporting year, there were no fatalities as the result of work-related injuries. There were likewise no work-related injuries with serious consequences. The total recordable injury rate (TRIR) for the GETEC Group was 2.1 and the lost time injury rate (LTIR) 1.9.

• Diversity: GETEC signed Germany’s Diversity Charter in 2021 and has since held kick-off workshops for the People, Culture and Diversity Circle, which is made up of 17 employees of different ages, ethnicities, functions, hierarchical position and gender. The nominated employees collaborate to develop measures and serve as lighthouse figures for implementing these within their respective organizational units.
• Diversity: An extensive English-language HR marketing campaign on various social media platforms (XING, LinkedIn, Facebook and Instagram) focused on international engineering specialists.
• Equal opportunities: Foster diversity by employing appropriate language to address potential candidates on the company’s job portal and in job advertisements
• Personnel development: Start of the six-month certification course on climate, energy and sustainability management delivered by EBZ Akademie; six GETEC employees were selected to participate and will serve as experts and multiplicators on this subject in their departments in the future. Different programs have been implemented at other GETEC sites.
• Work-life balance: Flexible working methods or working hours; mobile working as a flexibilization tool (does not include support and on-call services, marketing, service and installation activities or customer visits), time off in lieu (working time accounts, time credit), a collective agreement on mobile working (since March 2021; voluntary participation; in Germany, restricted by law to a maximum of eight days per calendar month), child care center at the Magdeburg site with places for 39 infants and toddlers and 44 places for preschoolers
• Strategic talent development: One example is the dual degree program to transfer company-specific knowledge; practical application thanks to internships at GETEC as part of the degree program; intensive support from GETEC partners, mentors, managers and dedicated HR contacts; regular feedback meetings. There are different scholarship, trainee and mentoring opportunities in every GETEC company.
• Social security: Form and scope of company pension plans at our companies in Italy; supplementary pension plan under the national collective labor agreement (optional membership) with contributions of up to 2% each from employer and employee
• Certification in Italy: SA8000 Ethical Certification is based on the SA8000 Standard, a globally recognized certification program created with the aim of ensuring optimal working conditions. It is an accredited standard meeting the needs of organizations that want to highlight their commitment to sustainable development and, particularly, social issues.
• Equal pay: Map of who gets paid what, whether this is in line with the market and whether treatment is equal (Netherlands/Germany)

• Occupational safety and environmental protection management system, certified to ISO 14001 and ISO 45001: G+E GETEC Holding GmbH, Magdeburg, Germany
• HSSE management system (certification) in Switzerland: An integrated management system in accordance with ISO 14001, ISO 45001 and ISO 9001 has been implemented at the site to ensure high health and safety standards. External certification is planned for a later date but external auditors have stated that health and safety is a strong feature of our IMS.
• HSSE management system (further certifications) in the Netherlands: Certified to ISO 50001 (energy management system) and ISO 55001 (asset management system)
• Accident prevention in Italy (reduce the number of accidents, LTIR, TRIR); implementation of higher standards by:
  • Special safety culture training for all employees with HS responsibility
  • Targeted workplace HSE inspections for the preventive assessment of risk situations
  • Reporting, recording and analysis of near misses
  • Increased monitoring of suppliers’ qualifications
• Health promotion in Italy: Company medical examinations (voluntary) for employees from the age of 45 to prevent illnesses
• Communication of safety, environmental and housekeeping issues in Italy: SEWAT system (safety and environmental walks and talks) with periodical rotation; contract and departmental managers meet employees at the workplace to discuss safety, environmental and housekeeping issues (to be conducted twice yearly by a C-level manager).
• Workplace inspections in Italy: Workplace inspections by HSE specialists (reviewing compliance with all valid HSE regulations) and follow-up reports; meetings with contract coordinators, contract managers and departmental managers to discuss improvement measures; proposals for improvement derived from the HSE inspections are included in the MBO (management by objectives) and discussed regularly with the departmental managers.
• Occupational health services in Emmen: On-site emergency service (company fire brigade) to provide first aid; if necessary, employees are transferred for treatment by their doctor and/or the company doctor or, in acute cases, sent to hospital.
• HSSE management system (certification) in Italy: An integrated management system in accordance with ISO 14001 ISO 45001 and ISO 50001 has been implemented at the site to ensure high health and safety standards.

At GETEC, there have been two fundamental changes in compliance reporting. 1. In the context of our company’s realignment, the compliance system has been restructured (see “Transformation for more” on pages 68 to 71). 2. The transition from GRI to CSRD reporting is resulting in a change of perspective in the way we report our compliance. Many of our new achievements strengthening our existing activities are currently still undergoing reorganization and can therefore not be reported adequately. However, we will report on them in detail in our CSRD report.

In its Code of Conduct (CoC), GETEC undertakes to observe applicable compliance regulations and thus conduct itself in a legally compliant manner, to ensure that the company and its employees comply with the law and internal regulations, and to act with integrity, honesty and in line with business ethics. Hereinafter, compliance refers to all measures introduced and implemented by GETEC to ensure both the legally compliant and honest conduct of our business activities and the corresponding conduct by our employees. We believe that our company’s success depends on a strong and sustainable compliance culture that is based on the company’s corporate and risk culture and the tone from the top, supported by an effective system of incentives and sanctions. Ultimately, compliance serves to protect our company – in the case of a violation of the applicable regulations – against often far-reaching consequences and also to protect the company’s employees with responsibility from imprisonment or fines; in the event of a violation, it also avoids disciplinary action up to and including dismissal.

Corruption, fraud and other financial crimes in particular may undermine the confidence of investors and other stakeholders in our company, result in criminal proceedings and fines and jeopardize the company’s growth and innovation. German law (section 299 of the German Penal Code – StGB) not only prohibits bribery of government representatives but also in private business transactions. Therefore, sanctions may be imposed on anyone who grants or receives benefits in return for unfair advantage or a breach of duty vis-à-vis the company, i.e. a breach of the duty of loyalty to the employer, the customer or the company.

Especially in respect of socioeconomic compliance, ethical conduct is essential for our company because our business success largely depends on our market reputation. The compliance measures we have implemented serve to identify or prevent any violations of laws and regulations and thus, in particular, criminal and civil law risks (fines or claims for damages), as well as competitive disadvantages resulting from reputational harm or exclusion from tenders. A condition for participating in private or public tenders is the submission of statements concerning compliance with ethical business standards. As compliance violations elsewhere in the supply chain may also reflect on us, we require our business partners to ensure the observance of compliance regulations for the duration of our business relationship.

In summary, upholding statutory, contractual and internal requirements and preventing corruption, money laundering and the financing of terrorism are of great importance in the business development of a company like GETEC and in protecting our employees.

Safety, environmental protection and respect for our environment are an essential part of our corporate philosophy. Each day, we reduce the burden on our environment thanks to the way we operate. Our goal is:

• to cause no accidents,

• to avoid health hazards and

• to cause no environmental damage.

For a company in our industry, environmental compliance is therefore another essential requirement in ensuring a functioning business model. Environmentally relevant laws must be observed. In day-to-day business decision-making, we seek to avoid negative impacts on nature and the environment so that no significant environmental pollution or consequences for human health or diversity occur. Failure to achieve this may lead to fines, sanctions or environmental damage. The latter may also endanger people and thus violate human rights.

GETEC’s corporate ambition is for its operations to have a positive impact on the environment and society and to contribute significantly to making a difference for the generations to come. GETEC recorded no significant compliance incidents during the reporting year. The company’s operations resulted in a further reduction of GHG emissions. In all respects, the company acted in accordance with its Code of Conduct. We protected and respected human rights as described in our Human Rights Policy and Code of Conduct.

Socioeconomic compliance policies

Our Code of Conduct (CoC) governs how we behave vis-à-vis our environment and how we seek to act in a legally compliant, moral and ethical manner. The CoC is described in detail online at: https://www.getec-net.de/code-of-conduct/.

All our employees are obliged to familiarize themselves with the CoC. The Code of Conduct applies to the platforms in Germany, the Netherlands and Switzerland. In addition, each site supplements the Code of Conduct with its own guidelines. These cover signing powers, data protection, purchasing, donations and sponsorship, travel, gifts and invitations, in particular. They can be found on the intranet and should be studied regularly, alongside the CoC.

However, we do not believe that our corporate responsibility is restricted just to our company. We expect compliant conduct from our suppliers as well. Our Supplier Code of Conduct (SCoC) directly addresses them and communicates our understanding of fair treatment and compliant conduct in the supply chain. The SCoC is described in detail online at: https://www.getec-energyservices.com/en/.

Our SCoC applies to Germany, the Netherlands and Switzerland. The CoC for the Italian sites also applies to its suppliers. It is still to be harmonized with the Group’s CoC. GETEC has been working with a supplier management system since the start of 2023. With the help of this software, GETEC performs a continuous risk analysis of its largest and most important suppliers in respect of the requirements of Germany’s Act on Corporate Due Diligence Obligations in Supply Chains (LkSG). This includes the acceptance of our SCoC.

The anticorruption code applied at our site in Italy is considered to be best practice. It is integrated into an organic and coherent system in order to prevent the risk of unlawful practices by management and all other functions. The anticorruption code is described in the ESG Report 2022, page 112.

Environmental compliance policies

When it comes to environmental compliance, GETEC is subject to various technical and environmental regulations. The company’s activities must be designed and managed in such a way as to minimize or prevent pollution and health impacts. Our HSSE Policy (see pages 61 to 65) applies to all consolidated GETEC Group companies at all sites. Due to regional requirements, each platform is subject to different laws.

Detailed documentation has been produced for our plants, covering their safety installations and protective measures. In compliance with legal requirements, there are also extensive operating and process instructions for handling hazardous substances (safety data sheets). These describe protective measures and rules of conduct. We also expect our partner companies to have a functioning environmental compliance program and require their compliance with all applicable environmental, occupational health and safety regulations.

The EU’s Renewable Energy Directive (RED II) was also relevant in 2023. This Directive anchors the sustainability criteria for biomass in EU law and defines, for example, legal harvests, the preservation of soil quality, improvements in production capacity, biodiversity and the respect of protected areas. It concerns combined heat and power plants fueled by biomass and biogas plants, depending on the output, suppliers and biomass dealers. If a company does not have a RED II certificate for its plant, it risks the proportional loss of its EEG feed-in remuneration. The EU is already discussing RED III, which will include restrictions on the use of biomass. We will add the relevant aspects to our supplier audits.

When employees join the company, they must participate in compliance training. Annual refresher courses are also held. Team meetings additionally include Compliance Moments, which aim to raise employee awareness of the subject.

Our compliance management system is described in the ESG Report 2022, pages 106 and107. The process presented there also satisfies the requirements of GRI 2-25-b and c.

Each and every employee can seek advice on the implementation of our guidelines and practices for responsible business conduct. Various options are available: All compliance units – whether at platform or Group level – can be contacted on compliance issues. The platforms in Germany and Italy each have their own compliance officer whereas the platforms in the Netherlands and Switzerland use lawyers who are responsible for compliance issues in the respective country. Moreover, all employees are obliged to familiarize themselves with the Code of Conduct, consulting their supervisor for guidance if necessary. Questions may also be asked during regular compliance training sessions. During the Compliance Moments at team meetings, any incidents are discussed and employees are reminded of the significance of compliance and the Code of Conduct. The platforms’ compliance officers regularly query the possible occurrence of incidents.

When recognizing our SCoC, our suppliers may ask the compliance officers any questions they have or ask for advice. The recognition process is managed by Group Procurement.

Any employee can report compliance concerns via our whistleblowing system. More information and explanations about the whistleblowing system can be found in the corresponding policy. In the course of 2023, the GETEC Group will be switching to a software-based ombudsman system. The new software allows both external and internal whistleblowers to submit anonymous reports of human rights violations in their own business areas or by indirect and direct suppliers.

A conflict of interest is a situation in which one or more natural or legal persons have conflicting interests and the pursuit of one interest might harm another interest. This may involve a violation of legal or supervisory obligations or duties of loyalty, unethical conduct or an impairment of a natural person’s professional judgment or objectivity. If a conflict of interest is not identified and managed in a suitable manner, this may result in disproportionate or disadvantageous consequences for GETEC, its employees and other stakeholders such as reputational damage, damage to customer relationships, regulatory sanctions and the risk of litigation.

The most important obligations of GETEC’s Advisory Board members in respect of conflicts of interest are described below:

• The members of the Advisory Board must always act in the interests of GETEC and ensure that processes are in place to identify and prevent conflicts of interest. They are responsible for ensuring that business decisions are not affected by conflicts of interest and must therefore:
  • act on their own initiative to identify conflicts of interest in connection with their position as an Advisory Board member and disclose such conflicts of interest; and
  • refrain from any action that might disadvantage GETEC.
• Material conflicts of interest must be documented appropriately and reported to the Advisory Board for discussion and resolution at its meetings.

Stronger compliance measures in Germany, Italy and Switzerland

As part of an international compliance program, GETEC is relying on a number of measures to ensure transparency, sustainability and legal compliance. In order to achieve these goals, GETEC has developed initiatives in Germany, Italy and Switzerland with a special focus on protecting human rights and procurement practices.

Germany: Whistleblower protection and sustainable procurement
The Whistleblower Protection Act (Hinweisgeberschutzgesetz) plays a key role in Germany. GETEC has introduced its own system that enables whistleblowers to report misconduct anonymously. Particularly sensitive cases are handled by an external service provider known as the ombudsman to ensure the independence of processing (see page 66). Active since the third quarter of 2023, the system enables reports to be submitted by phone or electronically, thus ensuring that misconduct can be recorded comprehensively. GETEC also prioritizes sustainable procurement. The company’s guideline for sustainable procurement provides the framework for this and fosters the integration of sustainability aspects in all purchasing processes. This responsibility was further strengthened with the entry into force of Germany’s Act on Corporate Due Diligence Obligations in Supply Chains in 2024. In order to comply with the new requirements, GETEC is planning to use software to monitor ESG risks and foster a sustainable supply chain.

Italy: Anticorruption certification and supplier audits
In Italy, GETEC had similar compliance targets with a special focus on fighting corruption. Italy had already received ISO 37001 certification for its anticorruption system in 2022 and continues to maintain this. In addition, a customer satisfaction monitoring process was introduced in order to further improve transparency. In the supply chain, regular health, safety and environmental (HSE) audits were introduced for subcontractors. These ensure compliance with the law and internal guidelines, especially by suppliers with an annual volume of more than €100,000.

Switzerland: Extensive training and environmental measures
Switzerland is ensuring extensive compliance training for all employees. In 2022, all employees there completed ethics and anticorruption training aimed at raising awareness for ethical conduct. In addition, an integrated management system in accordance with ISO 14001, ISO 45001 and ISO 9001 was introduced to ensure a legally compliant organization. One particular milestone was the commissioning of a new waste gas system in Switzerland which uses safety switches to reduce the release of hazardous substances. This is further evidence of GETEC’s commitment to sustainability and environmental protection.

An international strategy
GETEC pursues a uniform but country-specific compliance strategy that satisfies various legal requirements. With the whistleblowing system in Germany, anticorruption certification in Italy and comprehensive environmental protection measures in Switzerland, GETEC is relying on transparency, sustainability and legal compliance to demonstrate its global role as a responsible stakeholder.

Information about tracking the effectiveness of the compliance measures taken can be found in the ESG Report 2022, page 105for environmental compliance and page 114 for socioeconomic compliance, in accordance with the existing GRI 103-3 (evaluation of the management approach). Supplier audits round off our tracking of effectiveness. The LMS integration audit was performed successfully. The system is already integrated into the supplier audit process and includes an extensive database of information about the listed suppliers.

In the event of non-compliance with SCoC regulations, business partners must take immediate remedial action. We reserve the right to terminate agreements with business partners who are unable to verify their compliance with this SCoC in the course of a review (audit, assessment). Since 2020, suppliers have been gradually accepting the SCoC. The start was made in 2020 with Platform Germany and its top suppliers. In 2023, 93% of the Group’s main suppliers had already accepted the SCoC. They represent 75% of GETEC’s total spend (main suppliers > €100,000). It remains our goal to ensure acceptance by all suppliers by 2030.

There were no significant violations of laws and regulations during the reporting period and no fines were imposed.

In 2024, we successfully implemented a new organizational unit named Group Procurement, which is responsible for creating uniform structures, processes and policies for purchasing goods and services for the GETEC Group – with the exception of primary fuels and the associated emission certificates. One key task of Group Procurement is the conclusion of framework agreements for the following product groups that are applicable for the entire Group, ensuring cross-platform synergies, sustainability and cost savings. The individual platforms’ procurement units must comply with and implement the processes and framework agreements defined by Group Procurement.

Our central product groups are:

• Systems and components for our plants at customers’ sites; examples include components for heating and cooling, electricity generation in boiler and condensation systems, fuel supply, measurement and control equipment
• Construction services and various assembly/dismantling services for the construction of plants
• Services, repair and replacement parts during operation
• Chemicals, process and auxiliary materials
• Planning and engineering services
• IT systems and technology (hardware and software)
• Commercial services and external consultancy services
• Facility management and fleet services

In order to optimize our procurement structures, we pursued the following projects in 2023 and implemented them in 2024:

• We developed an app to create Group-wide transparency of procurement data and the quality of purchase-to-pay (P2P) processes. This software solution is based on a process mining software that digitally maps business processes, thus facilitating the analysis, optimization and monitoring of individual processes. The app also supports expenditure analysis, helping to identify cost levers and savings potential. In 2025, we will introduce Power BI for this purpose. We are currently preparing to recreate the functionalities of the old app in the Power BI Spend Cube. This will make it easier to report our Group procurement KPIs because Power BI will also be used by other Group functions.
• The app was established for the Procurement department of Platform Germany in 2022 and various use cases were developed. In 2023 and 2024, we continued to work on expanding the app and implemented the following use cases:

- Link to other platforms (first in Switzerland and the Netherlands) in the areas of P2P and Accounts Payable in order to create Group-wide transparency

- Creation of a sustainable spend app (showing the results of the supplier survey and LkSG risk assessments from the Integrity Next app): We have set ourselves the goal of using Integrity Next to audit 90% of our main suppliers in terms of their environmental and human rights performance by 2027 and will work with the suppliers to develop suitable continuous improvement measures.

• In 2023, we successfully created and introduced the risk monitor for the Procurement department of Platform Germany. This, together with a further supplier app, ensures the continuous monitoring of our main suppliers. We are thus able to respond at an early stage to any potential risks, especially the risk of supplier failure. Moreover, the creditworthiness of new suppliers can be checked in advance, as well as their possible inclusion on sanctions lists. The app was also rolled out successfully across the GETEC Group in 2024. Each platform currently uses the CreditSafe app to detect potential risks relating to creditworthiness, supplier failure and inclusion on sanctions lists at an early stage.
• An automated and process-controlled supplier assessment was added to the Platform Germany order system in 2024. It is planned to implement a uniform supplier assessment tool for the GETEC Group in 2026 with the introduction of a procurement platform. The precondition for this is that all country platforms will have been migrated to SAP S4/HANA. Switzerland and the Netherlands already migrated in 2023/2024, Italy will follow at the start of 2025 and Germany plans to do so in 2026.
• In March 2023, we launched the Integrity Next software for LkSG risk assessments and supplier surveys. The first 500 suppliers were invited to complete the survey. The results of the assessments and surveys are already visible in all of the aforementioned software systems. The roll-out to other country platforms took place in 2024.

A major part of our supply chain concerns the project business. In the reporting year, the main projects were:

Platform Germany:

• Six large projects in the Real Estate Segment: refurbishment of the heating plants at six sites for Bayernwärme
• Real Estate Segment: installation of an air-to-water heat pump for EMPIRA
• Industrial Segment: 4 MW heat pump with storage and an electric boiler for industrial heating for SMS group
• Industrial Segment: straw and biomass heating boiler to generate steam for Drewsen

Platform Italy:

• Heat recovery from a CHP for reuse in district heating; customer: Curia, pharmaceuticals company
• Heat recovery from a CHP for reuse in district heating; customer: TDK, chemical company

Platform Switzerland:

• ACNL regeneration with five-stage rectification plant and tank farm for Novartis
• Battery storage enabling Swissgrid to store and draw electricity to stabilize Switzerland’s power grid (state-of-the-art technology)

Total expenditure by our four regional platforms in 2023 was in the triple-digit million euro range (see table for further details).

GETEC Group procurement spend in 2023

Total €556 m
1/3 OPEX Recurrent, mainly services
      > Annual competitive negotiation

2/3 CAPEX Non-recurrent projects
      > Intense negotiation process

• Diversity: GETEC signed Germany’s Diversity Charter in 2021 and has since held kick-off workshops for the People, Culture and Diversity Circle, which is made up of 17 employees of different ages, ethnicities, functions, hierarchical position and gender. The nominated employees collaborate to develop measures and serve as lighthouse figures for implementing these within their respective organizational units.
• Diversity: An extensive English-language HR marketing campaign on various social media platforms (XING, LinkedIn, Facebook and Instagram) focused on international engineering specialists.
• Equal opportunities: Foster diversity by employing appropriate language to address potential candidates on the company’s job portal and in job advertisements
• Personnel development: Start of the six-month certification course on climate, energy and sustainability management delivered by EBZ Akademie; six GETEC employees were selected to participate and will serve as experts and multiplicators on this subject in their departments in the future. Different programs have been implemented at other GETEC sites.
• Work-life balance: Flexible working methods or working hours; mobile working as a flexibilization tool (does not include support and on-call services, marketing, service and installation activities or customer visits), time off in lieu (working time accounts, time credit), a collective agreement on mobile working (since March 2021; voluntary participation; in Germany, restricted by law to a maximum of eight days per calendar month), child care center at the Magdeburg site with places for 39 infants and toddlers and 44 places for preschoolers
• Strategic talent development: One example is the dual degree program to transfer company-specific knowledge; practical application thanks to internships at GETEC as part of the degree program; intensive support from GETEC partners, mentors, managers and dedicated HR contacts; regular feedback meetings. There are different scholarship, trainee and mentoring opportunities in every GETEC company.
• Social security: Form and scope of company pension plans at our companies in Italy; supplementary pension plan under the national collective labor agreement (optional membership) with contributions of up to 2% each from employer and employee
• Certification in Italy: SA8000 Ethical Certification is based on the SA8000 Standard, a globally recognized certification program created with the aim of ensuring optimal working conditions. It is an accredited standard meeting the needs of organizations that want to highlight their commitment to sustainable development and, particularly, social issues.
• Equal pay: Map of who gets paid what, whether this is in line with the market and whether treatment is equal (Netherlands/Germany)