Disclosures required by the EU-Taxonomy Regulation

GENERAL INFORMATION ON THE EU-TAXONOMY

Since January 1, 2022, public-interest entities with more than 500 employees must classify their economic activities in accordance with the EU Taxonomy Regulation and publish the results thereof in their consolidated non-financial statements or in their consolidated non-financial report (pursuant to the requirements of Section 267a and Section 243b Austrian Commercial Code (UGB)). All economic activities are to be classified as to their environmental sustainability.

When classifying its economic activities, voestalpine at times refers to the FAQs on the application of the EU taxonomy published in the EU Official Journal on October 20, 2023, as well as to the FAQs from March 5, 2025.

Assessment of alignment with the taxonomy regulations is carried out in a multi-stage process in which it is first determined whether an economic activity is taxonomy-eligible (i.e., in principle covered by the Taxonomy Regulation), and subsequently whether it is also taxonomy-aligned. Economic activities of a company that are not covered by the Taxonomy Regulation are not taxonomy-eligible.

The taxonomy-eligible economic activities must make a significant contribution to at least one of the environmental objectives listed below in order for them to be classified as taxonomy-aligned. In addition, they must not significantly impair the achievement of other environmental goals (Do No Significant Harm; DNSH) and must meet minimum social protection criteria (minimum safeguards), e.g., with respect to occupational safety and human rights.

The EU Regulation identifies six environmental objectives:

a. Climate change mitigation
b. Climate change adaptation
c. Sustainable use and protection of water and marine resources
d. Transition to a circular economy
e. Pollution prevention and control
f. Protection and restoration of biodiversity and ecosystems

In implementing the Regulation, voestalpine classified all of its economic activities as related to the “climate change mitigation” objective. This also prevents activities from being counted twice.

Description of the multi-stage taxonomy process

IMPLEMENTATION OF TAXONOMY ELIGIBILITY IN THE voestalpine GROUP

The assessment of voestalpine’s economic activities with regard to their taxonomy eligibility was carried out for the first time in the 2021/22 business year. Environmental goals 3 to 6 were also analyzed and evaluated with regard to their taxonomy eligibility as part of the 2023/24 business year’s reporting.

A project team comprising personnel from the Group’s Finance, Investor Relations, Environment, and Corporate Responsibility departments along with experts from each division was set up to this end. External experts were also consulted, including technical experts and scientific experts. In addition, clarifying interpretations and statements from European industry associations, such as the rail industry association UNIFE, were taken into account in the assessment.

The implementation process included reviewing the taxonomy eligibility of all Group entities. In addition, ongoing evaluation is carried out with regard to the applicability of the business activities to all environmental objectives.

This analysis identified economic activities of the voestalpine Group as taxonomy-eligible and allocated them to the following categories under the climate change mitigation objective:

• 3.9. Manufacture of iron and steel

The voestalpine Group engages in steel production based on the blast furnace route in Linz, Austria (Steel Division), and in Donawitz, Austria (Metal Engineering Division). The High Performance Metals Division engages in steel production based on electric arc technology at two plants in Europe (Kapfenberg, Austria; and Hagfors, Sweden) and one in South America (Sumaré, Brazil).

• 6.2. Freight rail transport

The voestalpine Group operates a rail transportation entity that uses the European railway network in Linz, Austria (Steel Division).

• 6.14. Infrastructure for rail transport

Worldwide, the voestalpine Group produces material components for railway infrastructure (Metal Engineering Division). These components include rails, turnout systems (from components to pre-assembled complete systems including drives, locking systems, and monitoring equipment), diagnostic and monitoring systems, as well as railway infrastructure services (logistics, rail treatments, rail welding, rail grinding, recycling, etc.).

DETERMINATION OF TAXONOMY ALIGNMENT

The underlying technical assessment criteria must be fulfilled in order for an economic activity to be classified as “environmentally sustainable” under the taxonomy regulations. These are quantifiable guidelines (environmental targets) on how an activity should be assessed in terms of its contribution to the respective environmental target. The Taxonomy Regulation specifies this significant contribution to the respective environmental target and also defines whether these economic activities cause significant harm to any of the relevant environmental targets. The DNSH criteria (Do No Significant Harm) must therefore also be observed in addition to the significant contribution criterion. This review must provide evidence that a given economic activity does not undermine the other environmental objectives.

voestalpine makes comprehensive contributions to climate change mitigation. As far as the business activities related to the production and downstream processing of steel as well as the transportation of freight by rail are concerned, they are generally deemed to contribute substantially to climate action as long as they fulfill the significant contribution to the environmental goal of climate protection pursuant to Category 3.9 and/or 6.2 or are lower than the predefined CO₂ limits on emissions. As far as the business activities of voestalpine Railway Systems 6.14 are concerned, they are generally deemed to make a substantial contribution to climate change mitigation as long as they fulfill the technical assessment criteria set forth in that category. The services of voestalpine Railway Systems fulfill the requirement that they are suitable for the use of trains with no direct CO₂ exhaust emissions. Services for rail tracks that are only intended for the transportation of fossil fuels are not included.

A comprehensive DNSH conformity assessment was carried out for the relevant economic activities (3.9, 6.2, 6.14).

The review of the DNSH criterion regarding the environmental objective “climate change adaptation” was conducted using a simulation-based software tool for identifying, quantifying, and disclosing physical climate risks to the relevant operating sites. A detailed climate risk and vulnerability analysis was performed for all relevant sites based upon this review. The representative concentration pathways RCP 2.6, RCP 4.5, RCP 6.0, and RCP 8.5 of the future scenarios used by the Intergovernmental Panel on Climate Change (IPCC), the assessment reports on climate change by the IPCC, and central Copernicus services of the European Commission are used as the methodological basis. Adaptation solutions were determined as necessary and implemented based on the findings of this climate risk and vulnerability assessment.

In addition, the voestalpine Group also uses its management systems, such as the environmental management systems certified according to ISO 14001 or EMAS, which are widely implemented in the companies worldwide, to fulfill the DNSH criteria. These systems ensure that environmental impacts are identified and reviewed as to their relevance to a given operating site’s environment and that any adaptation solutions aimed at impact mitigation are developed as necessary.

In particular, these analyses comprise and/or take into account environmental matters such as water (sustainable use and protection of water and marine resources) and biodiversity (protection and restoration of biodiversity and ecosystems).

In order to prevent and reduce environmental pollution, the voestalpine Group has created processes in its companies that ensure the production, use and marketing of substances in accordance with the national laws on chemicals.

In accordance with the DNSH requirements, certain bans and restrictions on substances based on European specifications must be observed, and substances with properties of very high concern may only be used if no other technically and economically suitable alternative substances or technologies are available on the market. If such a replacement is not yet possible, these substances must be used under controlled conditions. The Group-wide review of the DNSH compliance criteria came to the conclusion that these are already met to a very high degree at the sites carrying out the relevant economic activities. Non-compliant sub-areas were excluded from the calculation of the relevant key figures. Appropriate measures have been introduced to increase the degree of fulfillment on a continuous basis.

The dynamic development of EU Taxonomy Regulations may lead to adjustments to economic activities and adaptations to the assessment criteria in the future.

MINIMUM SAFEGUARDS

All economic activities that contribute substantially to at least one of the six environmental objectives, do not adversely affect another objective, and fulfill the (social) minimum safeguard requirement are recognized as being environmentally sustainable. In accordance with Article 18 of the EU Taxonomy Regulation, the review of the minimum social protection of workers and compliance with human rights is also the final stage of taxonomy alignment. This serves to ensure that a given economic activity fulfills international human rights standards as well as rules and regulations regarding issues such as bribery, corruption, taxation, and fair competition. The standards specified in Article 18 identify four core topics in regards to which alignment with minimum safeguards is defined.

The following guidelines and standards must be complied with:

• OECD Guidelines for Multinational Enterprises
• UN Guiding Principles (UNGPs) on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work (“ILO Core Conventions on Labor”)
• International Bill of Human Rights

The Platform on Sustainable Finance (PSF) takes up the following central issues as they apply to social minimum safeguards:

• Human rights (incl. rights of workers)
• Avoidance of bribery and corruption
• Taxation
• Fair competition

voestalpine has already surveyed the aforementioned topics of the Platform on Sustainable Finance on a Group-wide basis in the past. This is also covered comprehensively in this sustainability statement (see, for example, sections S1, S2 on human rights, TAX-1 on taxation, and G1 on the topic of anti-corruption).

SIGNIFICANT CHANGES FROM THE PREVIOUS YEAR

Economic activity 3.9. Manufacture of iron and steel

The EU Commission published a new set of FAQs (C/2025/1373) on the EU taxonomy on March 5, 2025.

These FAQs are intended to clarify, among others, which products fall under 3.9. Manufacture of iron and steel and 3.18. Manufacture of automotive and mobility components.

In 3.9. Manufacture of iron and steel, FAQ 11 clarifies that only all process steps specified in Regulation 2019/331 count as the manufacture of iron and steel. These include:

• coke (coking plant)
• sintered iron ore
• hot pig iron (blast furnace)
• cast iron
• high-alloy steel produced using the electric arc process
• carbon steel produced using the electric arc process

Processing steps subsequent to these processes are explicitly excluded from 3.9. Manufacture of iron and steel. Therefore, forming processes such as rolling or forging are no longer part of this economic activity. The last product that falls under 3.9. Manufacture of iron and steel is therefore a slab or billet.

These products represent semi-finished products for voestalpine, most of which are processed internally and only a small proportion of which are sold externally. However, since it was made clear by the FAQs above that the further processing of the semi-finished products no longer included them under 3.9. Manufacture of iron and steel, the taxonomy-eligible and taxonomy-aligned transactions have fallen in the range 3.9. Manufacture of iron and steel. The products that were previously subsumed under 3.9. Manufacture of iron and steel, such as sheets or rods, are now classified as not taxonomy-eligible.

The KPIs for CapEx and OpEx have also been adapted in the FAQs (C/2025/1373). All investments that are necessary for the further processing of steel (e.g., rolling mills, forges) were also classified as not taxonomy-eligible. Since all investments/operating expenditures at the aforementioned sites continue to be included in the CapEx/OpEx KPI, and voestalpine is making significant investments in two EAFs with greentec steel, the key figures in this area have decreased less than the revenue KPI.

As a result of the clarifications made in these FAQs, the KPIs for 3.9 have also been adjusted for the comparative period to reflect the revised treatment of the economic activity.

Economic activity 3.18. Manufacture of automotive and mobility components

The FAQs (C/2025/1373) have also clarified which products fall under item 3.18. Manufacture of automotive and mobility components. FAQ 17 states that only “the essential parts necessary for the environmental performance of the zero-emission vehicle” are covered by this economic activity. These include, for example, “control units, transformers, electric motors, charging connections, and chargers.” Since voestalpine focuses on the production of car body components, these are not included in economic activity 3.18. Manufacture of automotive and mobility components. All items included in this economic activity in the previous reporting period were therefore classified as not taxonomy-eligible, with the result that, in the current business year, voestalpine reports neither revenues nor CapEx/OpEx under 3.18. Manufacture of automotive and mobility components. The previous year’s figures have been adjusted accordingly, and for this reason, the current reporting forms no longer include a description of economic activity 3.18.

RESULTS OF THE KPIS

The following summarizes the performance indicators of revenue, investment, and operating expenses from taxonomy-eligible or taxonomy-aligned economic activities of voestalpine for each environmental target for the 2024/25 business year.

Taxonomy-eligible/aligned revenue

Pursuant to the EU Taxonomy Regulation, revenue as per IAS 1.82(a) must be used to determine the taxonomy-eligible revenue. The revenue figures equate to the revenue shown in the Consolidated Income Statement of this Annual Report and thus are used as the denominator for the calculation in the following table. The numerator includes revenue generated by economic activities covered by the EU Taxonomy Regulation. The current review for alignment in the 2024/25 business year resulted in 12.2% taxonomy-aligned revenue, which is mainly attributable to revenue from the railway infrastructure segment. Compared to the previous reporting period, revenues from the further processing of steel were no longer identified as taxonomy-eligible/taxonomy-aligned due to a clarification by the EU Commission. The comparative figures have also been adapted accordingly (for more detailed background on the adaptations, see the section Significant changes from the previous year). The adjustment results in taxonomy-eligible and taxonomy-aligned revenue in 3.9. Manufacture of iron and steel of 0.4% compared to 48.2% published in the previous year. This leads to the following classification for the voestalpine Group:

Taxonomy eligibility by economic activity

Taxonomy alignment by economic activity

Taxonomy-eligible/aligned capital expenditure (CapEx)

Additions to assets—including additions from business combinations to property, plant and equipment; intangible assets; and right-of-use assets under leases—were utilized as the basis for determining the taxonomy-eligible CapEx. Investments via joint ventures, investments in financial instruments as well as additions to goodwill were not considered. Due to the clarification of FAQ 2023/305 item 31, which stipulates that capital expenditure should only be recognized when it is recognized in accordance with the relevant invoicing standards, the additions to advance payments made were excluded from the additions to the CapEx KPI. When the underlying property, plant and equipment/intangible assets are capitalized, the advance payments made on the respective asset are reclassified and also allocated to the additions to the CapEx KPI. This approach may result in a shift between the business years. The difference between the capital expenditure used here in the denominator and the data published in chapter D.2. Operating segments relates to goodwill additions and the above-mentioned change in advance payments made. The numerator includes those capital expenditures that relate to assets or processes that are associated with taxonomy-eligible or taxonomy-aligned economic activities and are part of the CapEx plan. In comparison to the previous reporting period, capital expenditure from the processing of steel was no longer reported as taxonomy-aligned due to a clarification by the EU Commission. The comparative figures have also been adapted accordingly (for more detailed background on the adaptations, see the item on significant changes from the previous year). The adaptation results in taxonomy-eligible and taxonomy-aligned CapEx in the area 3.9. Manufacture of iron and steel of 28.8% compared to 61.9% published in the previous year.

In investment expenditure, the taxonomy-aligned share is 20.4% (EUR 237.4 million). With greentec steel, voestalpine has developed an ambitious phased plan for green steel production. As part of the first stage of the phased plan, one green electricity-powered electric arc furnace (EAF) will be built in Linz and one in Donawitz. This will make it possible to produce around 2.5 million tons of CO₂-reduced steel each year from 2027 following the ramp-up. The greentec steel flagship project is also included in the CapEx plan. The individual processes within the scope of future EAF production are to be regarded as independent production units, which will be integrated into the existing plant configurations at the Linz and Donawitz sites. Taxonomy alignment within the context of economic activity 3.9. Manufacture of iron and steel can be determined for electric arc furnaces as an independent production unit with the corresponding technical evaluation criteria under the environmental objective of climate change mitigation. The CapEx plan has a total volume of EUR 1.5 billion and is expected to be completed in the 2027/28 business year. In the current business year, EUR 134.4 million (2023/24: EUR 64.3 million) were classified as taxonomy-aligned under economic activity 3.9. Manufacture of iron and steel.

This leads to the following classification for the voestalpine Group:

Taxonomy eligibility by economic activity

Taxonomy alignment by economic activity

Taxonomy-eligible/aligned operating expenditures (OpEx)

Unlike the revenue and the capital expenditure, the figure for the operating expenditure cannot be taken directly from the annex notes of this Annual Report. This is because only a few expense categories are relevant to the determination of the denominator for the operating expenditure. These include building renovation measures, maintenance and repair of property, plant and equipment, research and development expenses, training expenses for employees, and current leasing expenses. The numerator includes operating expenditures that relate to assets or processes that are associated with taxonomy-eligible or taxonomy-aligned economic activities. In comparison to the previous reporting period, operating expenses from the processing of steel were no longer reported as taxonomy-eligible/taxonomy-aligned due to a clarification by the EU Commission. The comparative figures have also been adapted accordingly (for more detailed background on the adaptations, see the item on significant changes from the previous year). The adjustment results in taxonomy-eligible and taxonomy-aligned OpEx in 3.9. Manufacture of iron and steel of 33.6% compared to 67.3% published in the previous year. Operating expenses from taxonomy-aligned economic activities amount to EUR 114.2 million. This corresponds to 10.9% of operating expenses pursuant to the EU Taxonomy. This leads to the following classification for the voestalpine Group:

Taxonomy eligibility by economic activity

Taxonomy alignment by economic activity