4. Nonfinancial Group Statement
United Internet AG’s Management Board and Supervisory Board are committed to future-proofing the Company and to ensure sustainable value creation by managing the Company responsibly and with a long-term focus. For United Internet, doing business means more than pursuing economic goals and also involves an obligation to society, the environment, and employees.
Sustainability is already an integral part of corporate management in many business processes. In line with this, it is being continuously enhanced and embedded in the organization throughout the Group. In fiscal year 2025, the sustainability managers from all the segments worked together closely and on an equal footing in weekly Sustainability Committee meetings. In addition, the competent teams and departments at United Internet were again strengthened and a Group-wide Sustainability Board was established at Management Board level. This facilitates Group-wide coordination of sustainability initiatives.
Since the regulatory environment remains challenging and dynamic, United Internet’s sustainability work focuses squarely on transparency and traceability, and on getting results. Sustainability is defined as a value that is used to make progress measurable. For example, a Group-wide climate strategy modeled on the Science Based Targets Initiative (SBTi) was established in fiscal year 2025. Measurable targets and actions were also defined and established, or are in the course of being established, in the area of social sustainability and for sensitive topics relating to digital responsibility, such as combating fake news and the responsible use of artificial intelligence (AI).
The “General Disclosures” chapter of this statement sets out the fundamental horizontal requirements for sustainability reporting, including information on the corporate strategy, business conduct, materiality, and stakeholder inclusion. The second chapter contains the environmental information relating to climate change and resource use and the circular economy, and is supplemented by information on the EU Taxonomy. The chapter on social sustainability provides information and metrics relating to the Company’s own workforce, workers in the value chain, and consumers and end-users. Topics that are particularly relevant to the digital economy, such as information security, are also described. Finally, the last chapter provides content on business conduct.
4.1 General Disclosures
United Internet’s nonfinancial group statement (sustainability statement) has been prepared on a consolidated basis. It provides a holistic reflection of the Group’s practices and obligations including all segments, locations, and majority-owned Group companies. The scope of consolidation is the same as for the financial statements.
When performing its double materiality assessment and when collecting data, United Internet took into account material sustainability matters in both the upstream and the downstream value chain extending over the purchase and trading of hardware, the provision of IT infrastructure, and digital services. With respect to downstream value creation, United Internet examines the sustainability dimensions relating to the transportation, use, and disposal of its products and services. The Company’s business model is characterized by long-term customer relationships, which are driven by subscription models and free accounts. These are based on a strong focus on data privacy and information security during the use phase. In the downstream value chain, the handling of IT hardware that has reached the end of its service life and the avoidance of e-waste are a key topic. In addition, United Internet performs in-depth risk analyses on the human rights and environmental risks in its direct supply chain, especially in the case of electronic components that are sourced on the international markets.
The nonfinancial Group statement was prepared in accordance with section 315c in conjunction with sections 289c to 289e of the German Commercial Code (Handelsgesetzbuch – HGB). This also includes the information contained in this nonfinancial reporting on compliance with the requirements of Article 8 of Regulation (EU) 2020/852 (hereinafter referred to as the “EU Taxonomy Regulation”). The structure and presentation of the information is oriented towards the European Sustainability Reporting Standards (ESRSs). This applies in particular to the following aspects:
Oriented towards the approach taken in the ESRSs, the impacts, risks, and opportunities (IROs) identified in the double materiality assessment serve as the starting point for identifying the material sustainability topics. After this, qualitative and in individual cases also quantitative information is provided for these sustainability topics. In its selection of qualitative information, this report is oriented towards the concept of “policies, actions, and targets” as set out in ESRS 2.
Consequently, from a formal perspective no recognized framework within the meaning of section 315c of the HGB in conjunction with section 289d of the HGB is used. The decision on the content of the reporting was made in light of current developments: the ongoing uncertainty regarding the implementation of the Corporate Sustainability Reporting Directive (CSRD) and hence also of the ESRSs into German law and the proposals announced by the EU for a significant reduction in the reporting obligations.
The statutory provisions set out in Article 19a(3) and Article 29a(3) of Directive (EU) 2013/34 give undertakings an exemption option regarding the disclosure of impending developments or matters in the course of negotiation. United Internet did not make use of this option in fiscal year 2025. The option to omit certain information on intellectual property, know-how, or results of innovation from the statement was not utilized.
United Internet AG ’ s Supervisory Board consists solely of members elected by the shareholder representatives. In the period from July 4, 2024, to May 14, 2025, it had five members, including two women (40 % ). Since the regular Supervisory Board elections during the Annual General Meeting on Ma y 15, 2025, the Supervisory Board has had six members including two women. This is a ratio of one to two. All members of the Supervisory Board are considered to be independent.
There were three members of United Internet’s Management Board in 2025. Due to the planned departure of one member of the Management Board as of the end of December 31, 2025 , the Management Board has consisted of two members since January 1, 2026. There were no women on the Management Board in the fiscal year.
Both the members of United Internet’s Management Board and the members of its Supervisory Board have, in their respective bodies, extensive experience relevant to the undertaking’s sectors, products, and geographic locations. Collectively they have the knowledge, skills, and professional experience necessary for them to carry out their tasks as required. As a result, both the Management Board and the Supervisory Board cover the widest possible range of knowledge and experience relevant to the Company, and in particular meet the following requirements:
As United Internet’s founder and long-term CEO, Ralph Dommermuth has extensive knowledge and experience in these areas, as well as many years’ experience in the telecommunications and internet sector. In addition, he has extensive practical experience and knowledge of all material subareas of running a business, and specifically of corporate strategy, operational management, business organization, human resources, financial and risk management, corporate governance, legal and compliance, communications, and stakeholder management. As CEO, he ensures that sustainability matters are taken into account in all major decisions and that they are implemented in the relevant processes.
Markus Huhn, who was a member of the Management Board until December 31, 2025, had worked for the United Internet Group in a number of management positions since 1994. He was the member of 1&1 Telecommunication SE ’ s Management Board responsible for Finance from 2013 to March 2023, and Head of Human Resources until the end of 2025. He was also CFO of 1&1 AG from July 1, 2019, until the end of 2024. He was a member of United Internet’s Management Board from April 1, 2023, until stepping down on December 31, 2025, and was responsible in this capacity for Shared Services, covering Commercial and ICS Services, Corporate HR & HR Services, Corporate Real Estate Management, and Technology Services. As a result, Markus Huhn also has knowledge and experience of the above-mentioned areas. Specifically, he has many years’ experience of the telecommunications sector in the geographical markets in which the Consumer Access Segment offers fixed-network and mobile communications products. His responsibilities included implementing the incorporation of sustainability matters in the relevant processes.
Member of the Management Board Carsten Theurer has been responsible for finance at Board level since January 1, 2025. Prior to this, he worked for more than 20 years in a variety of divisions at the global Schwarz Group, most recently as Group CFO. He has extensive knowledge and experience of all the abovementioned areas, plus experience of strategic and operational corporate management in other sectors, and specifically in the retail sector and in food production. In this context, Carsten Theurer also has many years’ expertise in the sustainability issues that are important for companies and that are also relevant in a large proportion of cases for the United Internet Group. This applies in particular to the development and implementation of a sustainability strategy. As a business studies graduate with many years’ experience as a CFO, Carsten Theurer has expertise in the areas of accounting and auditing and is familiar with accounting principles, control and risk management systems, financial control, governance and compliance, and human resources planning and management. The Corporate Sustainability team reports to and works closely together with Carsten Theurer, who plays a major role in enhancing and implementing the sustainability strategy.
The Supervisory Board members also have relevant knowledge and experience of the above-mentioned areas. The individual Supervisory Board members’ expertise can be seen from the qualification matrix in the corporate governance statement issued in accordance with sections 289f and 315d of the HGB, which is part of the management report.
The Management Board and Supervisory Board ensure the necessary skills and specialist knowledge needed to oversee sustainability matters. The members have knowledge of the CSRD and the relevant ESRSs. In addition, Corporate Sustainability regularly informs them of, and provides training on, current legal and technical developments in the area of sustainability. The Management Board and Supervisory Board members use their skills and expertise in the area of sustainability – which they also continuously expand and grow – in all their business decisions so as to take material sustainability-related impacts, risks, and opportunities into account both in business decisions and in the general management and supervision of the Company.
The names of the Management Board and Supervisory Board members are given in the corporate governance statement issued in accordance with sections 289f and 315d of the HGB in chapter 8. That statement also provides information on the Supervisory Board members belonging to the Audit and Risk Committee established by the Supervisory Board and the areas of expertise of the individual Supervisory Board members in relation to environmental and social sustainability, and compliance.
The Supervisory Board’s Audit and Risk Committee performs a number of tasks and responsibilities, which are set out in its Rules of Procedure. The latter state that the committee supports the full Supervisory Board, among other things, in the in-depth supervision of the accounting and that it examines the annual and consolidated financial statements and the combined management report, including the sustainability statement, in detail. As part of this work, the committee discusses the audit reports, process, focus areas, and methodology with the Management Board and the financial statement auditors; receives the auditors’ reports on the audit findings; and makes recommends on these to the Supervisory Board. It also regularly assesses the quality of the audit and monitors the effectiveness and functionality of the internal control and risk management system, the compliance management system, and the internal audit system together with the Management Board. The presentation of the risks also includes material litigation and associated risks for the Group and covers not only financial risks but also reputational risks and sustainability risks.
The Audit and Risk Committee always takes sustainability matters into account when performing its tasks, both as explicitly required by its Rules of Procedure and above and beyond this. In this context, the Audit and Risk Committee is also responsible for monitoring the material IROs resulting from the double materiality assessment.
United Internet’s Management Board and Supervisory Board are informed at regular board meetings (at least four times a year) of material, sustainability-related IROs and associated strategies, guidelines, policies, actions, metrics, and targets. These and other sustainability-related topics are documented in the report of the Supervisory Board.
The Management Board and Supervisory Board take strategic, economic, and financial matters and environmental and social impacts, risks and opportunities into account during strategic decisions, material risk management transactions, and other important business matters. Potential conflicts of objectives between sustainability criteria and economic requirements are weighed up in cases if compromises are made in individual cases.
The Supervisory Board informs itself regularly of the organizational structure and workflows and of the degree to which targets have been achieved, obtaining information both directly from the relevant departments and from the Management Board.
The targets related to material impacts, risks, and opportunities are developed by the departments together with Sustainability Management and are approved by the departmental management concerned. Targets that are strategically relevant for the Company are agreed with the Management Board and presented to the Supervisory Board’s Audit and Risk Committee . Corporate Sustainability continuously monitors the progress made towards achieving the targets, and reports on this at regular intervals to the Management Board and the Audit and Risk Committee, enabling these bodies to perform their management and oversight functions. Dedicated meetings were held with the Supervisory Board in the 2025 fiscal year on the climate strategy and climate target setting, and on the social sustainability strategy, with a focus on the Company’s own workforce. The Management Board and Supervisory Board officially approved the climate strategy for the Company’s direct emissions (Scope 1 and 2).
The incentive systems for United Internet ’ s Management Board members incorporate ESG criteria as a component of the short-term variable compensation. This is in line with the commitment to sustainability and was resolved for the first time by the Annual General Meeting in May 2021. The rule has been incorporated in new service contracts for Managing Board members since fiscal year 2022. The approach aims to make sustainability-related goals part of the Management Board ’ s decision-making horizon and to facilitate a targeted commitment to sustainability. Detailed information on the remuneration structure for the Management Board and Supervisory Board can be found in the remuneration report published in accordance with section 162 of the German Stock Corporation Act (Aktiengesetz – AktG), which is available on the Company’s website.
Compliance with sustainability-related due diligence obligations at United Internet is guaranteed by a clear organizational structure. The Group-wide Sustainability Management function coordinates implementation of the relevant processes and principles. Overarching principles are formulated at Group level. These core principles are being embedded in the segments’ sustainability work in an iterative process, with the segment management board members being responsible for their concrete implementation and for adapting them to the specific issues and impacts in their business activities. Group-wide policies and guidelines are approved by United Internet’s CFO, the segment CFOs, and the relevant management board members. The departments , in close cooperation with the relevant boards, are generally responsible for actions. Periodic reporting to the full Management Board and the inclusion of the Supervisory Board ensure the continuous oversight and promotion of sustainability efforts throughout the Group.
Overview of Main Aspects and Steps in the Due Diligence Process in the Sustainability Statement:
a) Embedding due diligence in governance, strategy, and business model
Sustainability Management and Organization: Requirements for the Composition of the Body as a Whole
Business Model, Strategy, and Value Chain: Material IROs and Their Interaction with Strategy and Business Model
Climate Change: Material Impacts, Risks, and Opportunities
Climate Change: Identification and Assessment of Material Climate-related Impacts, Risks, and Opportunities
Resource Use and Circular Economy: Material Impacts, Risks, and Opportunities
United Internet's Workers: Material Impacts, Risks, and Opportunities
Workers in the Value Chain: Material Impacts, Risks, and Opportunities
Consumers and End-users: Material Impacts, Risks, and Opportunities
Governance Information: Material Impacts, Risks, and Opportunities
b) Engaging with affected stakeholders in all key steps of the due diligence process
Business Model, Strategy, and Value Chain: Interests and Views of Stakeholder Groups
Management of Impacts, Risks, and Opportunities: Double Materiality Assessment
Climate Change: Policies
Resource Use and Circular Economy: Policies
Introduction to Social Topics: Protecting Human Rights and Policy Statement
United Internet’s Workers: Policies
Workers in the Value Chain: Policies
Consumers and End-users: Policies
Governance Information: Policies
c) Identifying and assessing adverse impacts
d) Taking actions to address those adverse impacts
Climate Change: Actions
Resource Use and Circular Economy: Actions
United Internet’s Workers: Actions
Workers in the Value Chain: Actions
Consumers and End-users: Actions
Governance Information: Actions
e) Tracking the effectiveness of these efforts and communicating
Climate Change: Targets
Resource Use and Circular Economy: Targets
United Internet’s Workers: Targets
Workers in the Value Chain: Targets
Consumers and End-users: Targets
Governance Information: Targets
Climate Change: Metrics
Resource Use and Circular Economy: Metrics
United Internet’s Workers: Metrics
Governance Information: Metrics
Core elements
Sections of the Sustainability Statement
The goal of the risk management and internal control system (RMS and ICS) is to identify and limit risks at an early state. The approach taken by the risk management and control system for sustainability reporting is based on the methods and processes used in the financial reporting systems, which are described in the “risk report” section of the management report. These are constantly being adapted to the changing framework and are continuously enhanced.
Sustainability reporting risks relate in particular to the failure to publish the nonfinancial group statement, or the publication of a statement containing data errors. These risks were examined by Risk Management together with Corporate Sustainability. No reportable risks with an expected amount in excess of € 250,000 were identified. All employees can report additional risks on an ongoing basis to Risk Management, where they are examined and assessed together with the departments concerned. After this, any new risks are confirmed by United Internet’s CFO.
The question of whether to integrate risks for reporting purposes in the electronic ICS was also examined. A decision not to integrate them at system level was taken in fiscal year 2025, but this will be reviewed again in the coming fiscal year. Corporate Sustainability, which is responsible for central sustainability reporting, checks the completeness, quality, and correctness of the qualitative and quantitative data. Clear, uniform processes that are continuously enhanced have been established to ensure that information is delivered on time by the departments and segments in the Group’s decentralized structure. The data delivery status is tracked using tables and in the Footprint Intelligence sustainability software. Responsibility for core metrics such as employee metrics has been assigned to departmental staff who collect and consolidate the data from the segments bottom-up. It is checked there for completeness and plausibility at the content level, while Corporate Sustainability reviews the metrics again after they have been submitted by the department concerned.
Regular information-sharing meetings are held both with the departments and with the segments’ Sustainability Management units to discuss and find solutions to data delivery risks in good time. If risks that cannot be solved at operational level are identified, the issue is escalated to the segment CFOs. The Management Board and United Internet’s Audit Committee are informed regularly of the status of data collection and reporting, of associated risks, and of the target achievement status for the climate strategy.
United Internet is a Group with a total of 10,970 employees. The following table shows the number of employees by geographical region:
Total number of employees
10,970
11,154
of which: Germany
8,831
9,157
of which: other European states
1,370
1,379
of which: outside Europe
769
618
Number of employees by geographical region
2025
2024
The Group is organized into a number of segments with different business models. Details on the segments and their respective business models, on the products and services offered, and on key markets and customer groups are to be found in section 1 “Group and Company Profile.”
United Internet uses the nonfinancial management indicators “number and growth of fee-based customer contracts” and “ad-financed free accounts.” However, these indicators are not currently classified as the “most significant nonfinancial key performance indicators” within the meaning of German Accounting Standard 20. Additional information is provided in sections 1.3 “Management systems,” 2.2 “Business development,” and 2.3 “Position of the Group.”
In fiscal year 2025, the sustainability strategy focused on developing a Group-wide climate strategy for emissions from own operations. Concrete, science-based reduction targets that are aligned with the SBTi were defined as part of the climate strategy; these are described in detail in the “Climate Change – Targets” section. The reduction pathways resolved correspond to the 1.5°C pathway under the Paris Agreement on climate change. In 2026, the emission reduction targets will be expanded throughout the Group to cover emissions in the value chain.
The topic of energy efficiency is closely linked to emissions reduction, which plays a key role in relation to the data centers and 1&1’s O-RAN in particular. New, ISO-certified energy and environmental management systems were established in the segments so as to use energy and other resources as efficiently as possible. These allow environmental metrics to be systematically captured, assessed, and optimized.
The sustainability strategy for United Internet employees in the fiscal year focused on strengthening social security, facilitating internal development paths, enhancing employer attractiveness, systematically expanding learning and employability, and establishing a state-of-the-art management and corporate culture. One particular focus area was and is on diversity and inclusion , with the goal being to promote equal opportunities and reinforce a broad variety of viewpoints within the Company. In this way, HR makes a material contribution to social sustainability and future-proofing the Company. Concrete targets are described in the “United Internet’s Workers” section.
In the area of digital ethics and responsibility, the use of artificial intelligence was a strategic topic, especially since integrating AI with products and services runs the risk of AI bias and hence can lead to disadvantages for certain customer groups. Guidelines and segment-specific training on AI in the Group were rolled out so as to raise employee awareness of how to address this topic. The Consumer Applications Segment in particular is deploying a variety of strategies and actions to combat the spread of fake news, which is being propagated on social media using AI, among other things, and which threatens the ability to form fact-based opinions.
In addition, work was performed in the fiscal year on embedding sustainability matters at various levels of the organization and hence to support the transition to consistently incorporating sustainability issues in management, incentive, and work processes. To achieve this ESG targets have been included in the variable remuneration for members of the Management Board at Holding (Corporate) level and in the Consumer Access and Business Applications segments; in the case of the Consumer Access Segment, this also extends to the management level immediately below the Management Board. The Business Applications Segment has linked energy efficiency targets with Management Board remuneration. Obligatory sustainability training was developed for all staff with the exception of those in the Business Applications Segment (where its introduction is planned for fiscal year 2026), so as to promote environmentally aware behavior in day-to-day operations.
Given the different business areas involved, the segments have developed their own sustainability strategies with specific targets for their business models and the associated products and services. These strategies comprise actions to promote environmental and social sustainability in the core products and services, in interaction with customers and stakeholders, and in the value chain.
Unless otherwise stated, the strategy and targets apply to the entire Group, i.e., all locations and countries, at or in which the Company is active, and to all customer categories or products and services.
United Internet ’ s ongoing strategy development includes assessing the actual and potential impacts of United Internet’s business operations and relationships on sustainability matters during the double materiality assessment. The Company endeavors to use this strategy process to identify material challenges, to put them in the context of their financial materiality, and to develop strategic focus areas and achieve sustainability targets on this basis.
United Internet took material sustainability matters into account in both the upstream and the downstream value chain during the double materiality assessment and in the data capture process, which covers everything from raw materials extraction to waste disposal. The information is presented from a segment perspective. All the Group segments mentioned are part of own operations and do not belong to the upstream or downstream value chain from a Group perspective.
The graphic shows United Internet’s three material value chains: “Hardware purchasing and trading,” “Provision of IT infrastructure,” and “Digital services.” These value chains are described individually in the following.
The “Hardware purchasing and trading” value chain is located in the Consumer Access Segment and in Corporate. Consumer Access primarily serves retail consumers in Germany, while Corporate is responsible for purchasing the equipment used by staff in the Business Applications and Consumer Applications segments.
The upstream value chain primarily comprises device manufacturers such as Samsung, Apple, and Dell – which deliver smartphones and laptops in particular – and shipping service providers. Before production starts, numerous raw materials need to be extracted. These include oil for plastics production, aluminum, silicon, lithium, copper, and critical raw materials such as indium, light rare earths, and cobalt, which are primarily extracted in countries such as China, Australia, the U.S.A., Chile, and the Democratic Republic of the Congo. The devices themselves are mainly manufactured in Asian countries such as China, Vietnam, and India, whereas upstream logistics can basically be considered to be global.
United Internet ’ s own value creation happens in Germany, as does its downstream value creation, which includes both transportation to customers and the disposal and refurbishment of old equipment. The environmentally friendly refurbishment or disposal of devices and old IT equipment is a significant environmental matter in downstream activities. United Internet relies on specialized business partners in this area so as to conserve resources and minimize environmental impacts.
The IT infrastructure, which consists of data centers and telecommunications infrastructure, is operated by the Business Applications, Business Access, and Consumer Access segments. The Business Applications Segment plays a special role here as the data centers that it operates inside the Company are used by the Consumer Access, Consumer Applications, and Corporate segments. Equally, Consumer Access also uses the Business Access Segment’s telecommunications infrastructure, meaning that the value chains between the two segments are superimposed. The upstream value chain contains the Business Applications and Business Access segments, plus hardware suppliers; energy, data center, and software providers; and other wholesale network partners. Furthermore, construction of the fiber-optic and antenna network, wholesale network services, the production of hardware such as servers, and electricity supplies are located here.
The value chain starts with the extraction of raw materials for the hardware required; this takes place in countries such as China, the U.S.A., Chile, and the Democratic Republic of the Congo. Hardware production itself takes place in the U.S.A., Taiwan, and Japan, among other places. In addition to the raw materials needed to manufacture devices, raw materials such as cement, quartz sand, copper, and steel are required for network construction. The wholesale network services were sourced from Germany in fiscal year 2025 – from Telefónica and Vodafone, among other providers. Upstream data centers are located throughout Europe as well as in the U.S.A. These include the co-location data centers run by external partners and the Business Applications Segment data centers. Electricity for the data centers is generally supplied locally.
The Company’s own value creation primarily takes place in Germany, since this is where the material office locations and the fiber-optic and antenna network are located. In addition, there are isolated offices in other European countries, the Philippines, and the U.S.A.
In principle, downstream value creation can happen anywhere in the world. However, most Business Applications customers are to be found in Europe and North America, whereas Business Access and Consumer Access customers are primarily located in Germany.
The third value chain is provided by the Consumer Applications and Business Applications segments. In turn, Consumer Applications uses digital services supplied by Business Applications, which is why this segment is also to be found in the upstream value chain. Upstream value creation also includes the necessary IT infrastructure, which is supplied both by Business Applications and by co-location data centers. Raw materials extraction, hardware production, and electricity supplies take place in a similar manner to the “Provision of IT infrastructure” value chain. The same applies to the data centers and offices that form part of the Company’s own value creation.
Whereas the Business Applications Segment primarily targets business customers in Europe and North America, Consumer Applications’ activities are focused on the DACH region of Germany (D), Austria (A), and Switzerland (CH). However, in principle the digital services can be accessed and used worldwide.
United Internet does not engage in any material activities in the fossil fuel sector, or in extracting, processing, or trading coal and oil. Previously, energy trading by the Consumer Applications Segment was an additional link in United Internet’s value chain that offered end customers electricity and gas contracts. These activities accounted for less than 1 % of Group revenue in the past. The division was sold in October 2025.
United Internet’s business depends on continuous dialog and successful cooperation with a wide range of stakeholder groups. Close contact with a range of stakeholder groups is particularly vital with respect to impacts on society and the environment, and for identifying material sustainability aspects during the double materiality assessment, developing the sustainability strategy, setting targets, and determining target achievement. United Internet uses a variety of different platforms and formats to dialog with stakeholders so as to further enhance communication and cooperation with them and take their interests into account:
United Internet's business models are continuously evolving and are adapted to stakeholder groups’ interests on an ongoing basis. For example, efforts are being made to further reduce emissions and resource consumption, including along the value chain, so as to protect the environment and society. In addition, information security is a key component of the Group’s social responsibility as an internet company. Measures to protect sensitive customer, employee, and partner company data are constantly enhanced to prevent cyberattacks and new forms of data theft. United Internet discharges its responsibility as an employer by including key employee matters (both for its own workforce and for its value chain) in its HR strategy and in a number of governance matters. As regards digital ethics and responsibility, United Internet reacts to trends such as fake news and AI by introducing new policies and guidelines, training employees, and creating transparency for consumers. Details of the topics described and the relevant targets, actions, policies, and metrics are to be found in the individual chapters of this statement.
The material IROs identified during the double materiality assessment, their impact on the environment and society, and how they interact with United Internet’s strategy, business model, and business relationships are explained in greater detail in the individual topical standards.
The material IROs were reviewed and updated in fiscal year 2025. Compared to the previous year, a number of IRO categories were restructured and evaluated across all segments (e.g., the specific impacts and risks relating to the circular economy) so as to improve the quality of the data captured and enhance the uniformity of the procedure across all segments. In addition, the formulations used in IROs on topics such as artificial intelligence and information security were tightened to reflect current market developments. IRO formulations for social topics such as inclusion, equal opportunities, and working conditions were revised together with human resources managers so as to ensure that they reflect the key employee matters.
Impacts identified for the governance area in the previous year no longer applied, since the materiality threshold was not reached during the reassessment. This was due in particular to the fact that the prior-year IROs were adjusted to remove redundancies and actions that had been included. For example, the “Inadequate prevention/lack of awareness among employees regarding internal guidelines such as the Code of Conduct can result in a negative corporate culture or disrespectful behavior. The impacts can lead to psychological stress and consequences for employee health.“ IRO was changed to the social impact of “Psychological stress among employees and risk of misconduct with financial impacts,” which reports on both. The “Sustainable value creation and resilience through responsible, long-term business conduct” impact had been formulated extremely broadly, which made deriving concrete actions and targets difficult. In practice, integrating this impact has improved management of the impacts in the environmental and social area, which is reported in detail. The “Exploitation of service providers in the downstream value chain” impact is no longer considered to be material due to the reassessment of its scope.
These changes reflect the development of the internal sustainability management framework. Changes to the methodology are shown in the “Process for Identifying and Assessing Material IROs” section.
The sustainability risks identified during the double materiality assessment were examined to determine whether they reached the materiality threshold set out in section 315c in conjunction with section 289(3) and (4) of the HGB and hence very likely have or will have severe negative impacts on nonfinancial matters. This is not the case for any of the identified risks. The process for identifying and assessing material IROs using the double materiality assessment is described in the “Process for Identifying and Assessing Material IROs” section .
The Group-wide double materiality assessment has been updated annually since fiscal year 2022. In fiscal year 2025, materiality was determined at the level of the IROs with reference to the ESRSs, the FAQs, and the materiality assessment guidance published by EFRAG (the European Financial Reporting Advisory Group). The prior-year results were updated. This was done by reviewing al l IROs from the previous year for completeness and consistency, checking their assessments for changes. I f necessary, new IROs were added . The assessments were primarily updated by the segments’ sustainability managers, with departmental managers being consulted where needed. This applied in particular to IROs that were to be reassessed.
The IROs are identified on the basis of a long list that was generated with reference to the ESRSs’ topics, sub-topics, and sub-sub-topics and on the basis of entity-specific topics (including the segment-specific topics) . The content-related materiality of the sustainability topics was determined using a double materiality assessment oriented towards the requirements contained in section 3.2 of ESRS 1.
In addition to the long list, the materiality workshop conducted by Corporate Sustainability in mid-2024 together with the segments’ Sustainability Management staff is still used as the basis for the updated double materiality assessment. The goal was to categorize all topics included in the long list on the basis of their relevance and to provide reasons for this, while taking into account and analyzing the value chain. In addition, the workshop served to capture new IROs so as to be able to take them into account during assessment. One particular focus was on the geographical region and regulatory requirements (occupational health and safety, working conditions, and pollution) at the Company’s own locations, while another was on the areas of origin of purchased products and the raw materials needed for them. In addition, the downstream value chain (such as the handling of e-waste) was examined. The core topic of climate change played a particular role here. In this context, collection and assessment of the IROs also included the results of the climate risk analysis and United Internet’s carbon footprint .
Corporate Sustainability combined the IROs collected in the workshop with the IROs from the double materiality assessment in previous years in a consolidated list. The IROs were assigned to the relevant topics (sub-sub-topics) and the segments where this fitted their business model or their upstream and downstream supply chains.
Affected stakeholders were represented by Sustainability Management and the segment departments both for the identification of IROs and for their assessment. The views of the Company’s own employees were included e.g., by representatives from Human Resources. Customer viewpoints were covered by the Customer Experience and Legal departments and by Partner Management. A mapping table was drawn up to ensure that affected stakeholder groups are covered.
A check was also made as part of this assessment as to whether certain groups of employees in the value chain could potentially be exposed to greater risks, for example due to their characteristics, working conditions, or activities. The assessment was based on internally available information and the specialist expertise in the units involved.
The Group-wide double materiality assessment takes a bottom-up approach and covers all segments. Each segment assesses the individual topics on the basis of a long list provided for Corporate Sustainability and adds segment-specific issues where necessary. All topics identified are then consolidated by Corporate Sustainability.
The IROs were assessed by Corporate Sustainability, the segments’ sustainability managers, the stakeholders concerned or the departments representing them, and the risk owners in coordination with Risk Management. Impacts were assessed on a gross basis using the dimensions of scale, scope, irremediable character, and likelihood of occurrence.
The severity is the average of the scale, scope, and irremediable character. Risks and opportunities were also assessed on a gross basis using their financial scale and their likelihood of occurrence. The scales used at segment level were adapted in line with the scales used in classic risk management.
The stakeholders performing the assessment were requested to take not only their own perspective but also publicly available studies into account. The assessments of the individual segments were consolidated at Group level so as to determine the material IROs from a Group perspective.
The materiality threshold at the IRO level is determined by individually examining the likelihood and the severity or financial scale. Actual impacts are an exception to this rule: in this case, only their severity is taken into account. All IROs that were assessed as having a likelihood of occurrence of more than 35% and that have a severity of more than three on the risk scale from one to five (as for the financial scale of risks and opportunities) were classified as material. In addition, IROs for which at least one criterion was assessed as having a severity of five (as for the financial scale) were examined individually for materiality by Corporate Sustainability. Impacts related to human rights issues were also explicitly examined individually for materiality in those cases in which their severity was below the materiality threshold.
The ESRSs provide for three time horizons to be used in the IRO assessment: short-, medium-, and long-term. These relate to the point in time when the IROs occur. Impact assessment is based on the point in time when the most severe impact occurs. For example, the impacts of greenhouse gas emissions are assessed using a long-term horizon due to their cumulative effect .
Where discrepancies with respect to the materiality assessment arose in the course of the process, these issues were discussed individually by the responsible staff at the segments or departments and Corporate Sustainability. Corporate Sustainability was responsible for overall management of the materiality process, meaning that consistency of assessment was assured by a central entity.
Quantitative fundamentals were used where available to assess the IROs so as to ensure the classification was performed in as objective a manner as possible. The assessors used external, objective sources such as scientific studies, sector analyses, and specialist publications where these were appropriate and available.
The assessment was performed in a topic-specific manner on the basis of different data sources. A limited level of detail was sufficient in many cases since the methodology used to categorize the scale, scope, and irremediable character provides for the use of a uniform five-point scale. In the case of climate change, prior-year figures for the Group-wide carbon footprint were used as a key quantitative base. In the case of resource use and circular economy, no complete Group-wide metrics were available as of the time of the double materiality assessment; however, data regarding IT hardware refurbishment that was already available was incorporated.
Risks were primarily estimated on the basis of model-based calculations using metrics such as revenue, the number of employees, and the number of customers. In the case of business conduct, revenue figures were used to estimate the size of potential sanctions, among other things. Potential reputational damage was not quantified.
Where no quantitative data was available, the categorization was made on the basis of plausibilized assumptions and professional estimates; in this case, conservative approximations and industry-standard comparative figures were used where necessary. The decisive boundaries for the data pool relate in particular to incomplete metrics for resource use in parts of the value chain. These uncertainties were addressed using cautious assumptions and transparent disclosure.
The assessments relate to all business activities along the value chain. The calculations were performed at segment level and then consolidated at Group level.
The material sustainability risks resulting from the double materiality assessment were transferred to general Risk Management and aligned with the existing risk portfolio there (net risks) in 2025 so as to embed them in the system. As part of this process the sustainability risks were assigned to existing, overarching business risks. Risks were prioritized on the basis of their expected amount (i.e., the size of the loss multiplied by the likelihood of the risk occurring). The risk mitigation strategy consists of developing and implementing appropriate, effective actions. The consolidated risks are reviewed regularly (once a quarter) in the Group’s risk management system by the responsible risk manager and are updated where necessary. In addition, United Internet analyses human rights and environmental supply chain risks originating in international markets, as described in more detail in the “Workers in the Value Chain” and “Governance Information” sections. In fiscal year 2026, there are plans to consider the material sustainability risks from the double materiality assessment independently of the business risks, to evaluate the net risk amounts, and if necessary to establish a risk management process for them.
At United Internet, sustainability targets relating to material IROs are specified locally by the departments responsible in each case. This is done using specific specialist expertise, existing metrics, risk analyses, and the individual units’ operating requirements. The departments regularly evaluate their requirements and then deduce the need for new or revised targets based on their experience and the developments observed over time. The departments use quantitative and qualitative data from internal systems, monitoring processes, and relevant management indicators when formulating targets. If necessary, external sources of information and specifications such as regulatory requirements, industry standards, and publicly available market data are also consulted or observed.
The targets are set in compliance with applicable national and European statutory requirements and relevant international frameworks where these are relevant for the topics concerned. Additionally, the local and entity-specific context in which the underlying impacts arise is taken into account, ensuring that the targets are both practicable and effective in terms of the material impacts, risks, and opportunities identified. The assumptions are based on the departments’ current knowledge, expected organizational or technological developments, and realistic estimates as to resources, feasibility, and time horizons. In line with this, targets are adapted as necessary as soon as the framework, regulatory requirements, or internal priorities change.
The following material action areas were identified for United Internet in the course of the double materiality assessment: climate change (E1), resource use and circular economy (E5), own workforce (S1), workers in the value chain (S2), consumers and end-users (S4), and business conduct (G1). Information on the IROs identified is provided in the following chapters.
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