G1 Business Conduct

Strategy and Governance

ESRS-Kennzeichnung:ESRS 2 GOV-1, ESRS 2 GOV-4, G1-1

General information on overarching policies such as our Policy Statement on Human Rights, our Code of Conduct or the policy for our compliance management system can be found in the General Disclosures of this (Consolidated) Sustainability Statement (see General Disclosures). The specific aspects of these policies are explained in this chapter.

Fundamental principles of responsible corporate governance

ESRS-Kennzeichnung:ESRS 2 GOV-1, G1-1, G1-3

We are committed to doing business in a responsible and respectful manner. Adherence to compliance standards is the foundation of responsible corporate governance – this is embedded in our CORE corporate values (see Our Strategy). Our standards are based on applicable laws and regulations, in some cases exceed them and take internationally recognized principles into account. We respect and promote

• The Universal Declaration of Human Rights of the United Nations (U.N.) and the two U.N. Human Rights Covenants
• The Ten Principles of the UN Global Compact
• The core labor standards of the International Labour Organization (ILO) and the Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy
• The U.N. Guiding Principles on Business and Human Rights
• The OECD Guidelines for Multinational Enterprises
• The Responsible Care^® Global Charter of the International Council of Chemical Associations (ICCA)
• The German Corporate Governance Code (GCGC)

Our values, corporate principles and guidelines are firmly anchored in our Corporate Governance. The Board of Executive Directors is responsible for ensuring that the company’s activities comply with the applicable legislation and regulatory requirements as well as internal corporate requirements and ethical business practices. This includes the establishment of a compliance management system as well as embedding a company-wide compliance culture with undisputed standards. Our Code of Conduct firmly embeds these mandatory standards into our employees’ day-to-day business. The members of the Board of Executive Directors are also expressly committed to follow these principles. The Audit Committee established by the Supervisory Board checks the effectiveness of the compliance management system as part of its monitoring activities for the company’s internal control and risk management system.

Compliance organization

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The head of our Legal and Compliance organization also acts as BASF Chief Compliance Officer (CCO). The CCO reports directly to the Chairman of the Board of Executive Directors and manages the further development of our global Compliance organization and compliance management system. Support is provided by the Corporate Compliance unit and more than 100 compliance officers and representatives in the regions¹ and countries worldwide as well as in the operating divisions, service units and in the Corporate Center. Key compliance topics are regularly discussed in the compliance committees established at global and regional level. The Compliance organization reports to the Supervisory Board’s Audit Committee twice a year on the status and key developments of the Compliance Program. In the event of significant incidents, the Audit Committee is immediately informed by the Board of Executive Directors. The Board of Executive Directors reports to the Supervisory Board regularly, without delay and comprehensively, on all issues important to the company, including compliance, and coordinates the company’s strategic direction with the Supervisory Board.

To ensure that members of the Board of Executive Directors have relevant expertise with respect to business conduct, BASF’s long-term succession planning takes into account the role model function of potential candidates in implementing the corporate values as well as various diversity criteria (see Corporate Governance Report). As part of their onboarding, newly appointed members of the Board of Executive Directors are individually briefed on BASF’s Compliance Program, the compliance management system, and the legal and internal corporate governance requirements. The members of the Board of Executive Directors together with senior management play a key role in our compliance culture. All new Supervisory Board members also familiarize themselves with the BASF Code of Conduct at the beginning of their term of office. Supervisory Board members who serve on the Audit Committee also receive separate training on our Compliance Program. Due to their many years of leadership experience within the BASF Group, all members of the Board of Executive Directors are very familiar with corporate governance, culture and policies, and in particular with the Code of Conduct. On the Supervisory Board, Dr. Kurt Bock, Prof. Dr. Stefan Asenkerschbaumer, Alessandra Genco and Tamara Weinert have in-depth knowledge of corporate governance and corporate policy thanks to their decades of management experience.

Human rights due diligence

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Human rights due diligence is an integral part of our responsible corporate governance and our strategy. We see human rights due diligence as an important, comprehensive task we can only fulfill if everyone in the entire organization works together. We are committed to respecting internationally recognized human rights in our own operations and promoting them along our value chains. In our own operations, we are strictly careful not to cause or contribute to human rights violations.

Part of our corporate value “responsible” (see Our Strategy) is that we strive to apply high standards for responsible labor standards and the protection of health and safety worldwide. In order to meet this high standard and our commitment, we developed an integrated and risk-based approach as well as clear processes for monitoring and managing human rights risks.

We want to ensure that we:

• Identify, weight and prioritize our human rights risks through regular and incident-related analyses
• Address risks with effective preventive measures and with appropriate remedial actions in the case of violations
• Integrate the measures into all relevant functions and operational processes and regularly review their effectiveness

Effective cross-functional cooperation is a crucial building block for this – we have structured our organization accordingly. The head of our Legal and Compliance organization also acts as Chief Human Rights Officer and is responsible for monitoring overall risk management, including human rights risks. Our compliance organization reports regularly to the Board of Executive Directors and the Audit Committee.

Our Corporate Compliance unit is responsible for the overarching governance of human rights due diligence, ensuring that human rights-related assessments are integrated into our governance and decision-making processes – for example, in the case of investments and acquisitions. In addition, various specialist units are responsible for managing specific human rights issues. Experts in the fields of international labor standards, environmental protection, health and safety, as well as corporate security take a risk-based approach to ensure that we respect the relevant human rights in our own activities.

Our internal cross-unit Human Rights Expert Working Group, managed by the Corporate Compliance unit, facilitates close collaboration and exchange on current human-rights related topics and developments between the above mentioned specialist units, which also include specialists from the areas of Procurement, Legal, Human Resources, Sustainability, Communication and Government Relations. Additionally, our approach involves structured collaboration with the operating divisions to identify and actively address division-specific risks. This allows us to ensure that we take a holistic approach to our responsibility for human rights and that we can continuously improve. Like our Corporate Compliance unit, the aforementioned specialist units have their own global organization, train it and are supported by it in the global implementation of due diligence processes and measures worldwide in the countries in which BASF is active. The Expert Working Group, among other things, provides support and advice in challenging and critical situations, in the further development of internal processes and in the creation of information and training opportunities. We also obtain additional external human rights expertise through our Human Rights Advisory Council (see General Disclosures). In addition, we are a founding member of the UN Global Compact and a member of the Global Business Initiative on Human Rights and are involved in initiatives such as Together for Sustainability (TfS) and Responsible Care^® (see S2 Workers in the Value Chain).

• More information on our Policy Statement on Human Rights and our human rights commitment and approach

The following chapters of this (Consolidated) Sustainability Statement address our corporate due diligence obligations in further detail.

Explanation of the material impacts of our business

Our global Code of Conduct as well as our compliance management system and associated measures promote a positive business environment both for our employees and throughout the upstream and downstream value chain. This contributes to an environment characterized by respect and ethical and responsible conduct in accordance with applicable laws.

Contribution of our global compliance measures and systems

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Our Compliance Program is based on our corporate values and voluntary commitments as well as applicable international standards. We are convinced that compliance with these principles plays a key role in ensuring our company’s long-term success.

The global program describes our commitment and requirements for responsible conduct of all BASF employees in their interactions with business partners, officials, coworkers and society. The main guidelines are primarily summarized in our BASF policies on compliance, human rights, labor standards and in the Supplier Code of Conduct (see General Disclosures). With our comprehensive management and monitoring systems, we want to ensure that we act in accordance with the applicable laws and uphold our responsibility to the environment and society. This also involves system audits carried out by the Corporate Audit unit (see Global targets).

Through our Compliance Program, we aim to create positive impacts for employees across the entire value chain, for example by creating an environment that reflects our values and in which human rights are respected. We promote a culture in which concerns can be openly addressed, making it easier to report potential violations of applicable law or internal company guidelines. This helps us to uncover potential shortcomings and take appropriate measures to remedy them.

Contribution of our global Code of Conduct

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At the core of our Compliance Program is the global, standardized Code of Conduct, which is overseen by the BASF Board of Executive Directors and to which all employees and leaders must adhere. It covers topics ranging from corruption and antitrust laws to human rights, labor standards, conflicts of interest, whistleblower protection, trade control and data protection. The Code of Conduct is supplemented by additional global and regional requirements that address specific topics such as corruption and conflicts of interest in more detail. Through our Code of Conduct, we aim to generate positive impacts on compliance with these rights in our own business activities and in the upstream and downstream value chain. Accordingly, we have specified our responsibility for human rights in our Code of Conduct and Policy Statement on Human Rights and embedded this in our Supplier Code of Conduct. The latter indicates that we expect our business partners to comply with prevailing laws, regulations and internationally recognized principles.

For the success of compliance in the company, it is crucial that values and commitments are lived within the company. The principles embedded in our Code of Conduct are established and recognized in our day-to-day business. We expect all employees to act in line with these principles.

• More information on the Code of Conduct

Contribution of our training courses to the prevention of corruption and bribery

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Workshops and mandatory training are a key element in preventing compliance violations and are conducted on an ongoing basis either in person or online. Within a prescribed time frame, all employees are required to complete basic, refresher or specialized training on topics such as antitrust legislation, money laundering and trade control regulations. Refresher training must be repeated every two years. Training materials and formats are continuously updated taking into account the specific risks of individual target groups and business areas, and include training content on the prevention of corruption and bribery as well as information about our grievance mechanisms.

1 The regional structures were dissolved as part of the new strategy. We are reviewing the compliance officer structure in this context.

Actions

ESRS-Kennzeichnung:ESRS 2 GOV-4

While our responsible corporate governance measures are implemented centrally and globally, they are not governed by a centrally managed action plan. This goes hand in hand with the BASF approach to sustainability steering (see General Disclosures).

Our primary goal is to prevent violations from the outset and we rely chiefly on the following actions:

• Training on the BASF Code of Conduct
• BASF Compliance Hotline
• Risk analyses
• Business Partner Due Diligence

Information offerings and training to strengthen our compliance culture

ESRS-Kennzeichnung:G1-1, G1-3

In 2025, we registered more than 111,000 participations worldwide (2024: >120,000) in our Code of Conduct trainings. In total, more than 93,000 training hours were completed (2024: 105,000). Functions-at-risk are fully covered by the training program. Training data is collected through documentation in our learning management system as well as individual decentralized reports from Group companies.

Leaders play a key role in our compliance culture by embodying and communicating our values both internally and externally. In addition to special workshops on integrity as a leadership task for newly appointed senior executives, separate training sessions were also offered in 2025 for the managing directors of BASF Group companies.

The online version of the BASF Code of Conduct is aimed at our employees and offers user-friendly features such as case studies, FAQs and additional references. We continuously provide our employees worldwide with up-to-date content such as videos, links to specialist units and requirements as well as direct contact to subject matter experts on the internal online platform and the corresponding app.

Other binding governance documents (policies, corporate requirements) are provided on an internal digital platform that offers our employees an advanced search function and context-based links to further information. The managing directors of BASF Group companies can find important information and assistance on ensuring compliance in their Group companies on an intranet page set up especially for them.

We particularly encourage our employees to actively and promptly seek guidance if in doubt. They can consult their supervisors, specialist units, such as the Corporate Legal unit, and the BASF compliance officers and representatives. In addition, the internal compliance information platform and the corresponding app provide continuous access to advice through direct contact channels.

Grievance procedure for monitoring adherence to our compliance principles

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BASF’s Compliance Hotline serves as a grievance mechanism and is open to all BASF employees as well as external stakeholders, particularly workers in our value chains (see S2 Workers in the Value Chain). The hotline can be used to raise questions or concerns about potential or actual misconduct, as well as to report violations of regulations, laws, BASF requirements or BASF’s global Code of Conduct. Reports may address any topic covered by the global BASF Code of Conduct, including human rights and environmental issues. Individuals submitting a report have the option to remain anonymous. The Compliance Hotline is explicitly mentioned during training courses and in the context of specific campaigns, such as during our Global Compliance Week in November 2025.

Availability, confidentiality, and protection from retaliation

To ensure confidentiality, we have contracted an independent external provider to operate this global Compliance Hotline. Reported cases are systematically documented and processed worldwide using a single, uniform system. The central point of contact is a website that informs all employees worldwide about the hotline and the grievance procedure in their national language. In addition to local phone numbers, the website also offers an online contact option. The website is also available to third parties such as suppliers (see S2 Workers in the Value Chain), partners and the public. All relevant information, including the rules of procedure, is publicly available on our website in over 50 languages.

Handling compliance reports

We take reports and complaints very seriously and follow up on them. An electronic summary of the concerns is forwarded only to the responsible employees of the BASF Compliance Team, who review the case and decide on further actions. Depending on the circumstances, various BASF specialist units may be involved in the investigation. In certain cases, we may also involve external lawyers or subject matter experts in the investigation, if necessary. We aim to always respond promptly to violations, to process all concerns promptly and to provide feedback on the status.

Remedial measures are determined after the investigation, depending on the severity of the specific case. Examples of such measures include verbal warnings and training. In individual cases, we take internal disciplinary action in accordance with uniform standards up to termination of employment.

We do not tolerate any retaliation against anyone who, in good faith, reports a concern or participates in an investigation, even if the complaint proves to be unfounded. Retaliation is strictly prohibited according to our Code of Conduct and would be treated as serious misconduct. Our procedures are based on the legal requirements for whistleblower protection to which BASF SE and other Group companies are subject.

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Each concern is documented according to specific criteria, properly investigated in line with standard internal procedures and answered as quickly as possible. The principles of an investigation include objectivity, independence, accuracy, confidentiality and fairness, as well as respect for human rights and other legal provisions. The responsible Compliance Officers and employees of the Compliance organization designated by them are responsible for receiving reports and initiating an appropriate investigation process. The procedure for handling compliance reports is set out in an internal requirement. The outcome of the investigation as well as any measures taken are documented accordingly and included in internal reports.

The grievance procedure is analyzed and evaluated annually for its appropriateness and effectiveness. This includes analyzing the number of complaints received, their distribution, processing status and derived measures.

Reported cases and follow-up measures

We consider the number of cases reported through our reporting channels and the resulting follow-up measures, including disciplinary actions, court convictions and internal audits conducted in this area to be key indicators of the effectiveness of our compliance management system and adherence to our Code of Conduct.

In 2025, the BASF Compliance Hotline received 739 reports (2024: 751). These reports are recorded in our global compliance case management system. The information received related to all categories of our Code of Conduct, including respect in the workplace, corruption, handling of company property and environmental, health and safety issues.

We carefully investigate all cases of suspected misconduct that come to our attention via the BASF Compliance Hotline or other channels and, when necessary, take countermeasures on a case-by-case basis. These included, for example, improved control mechanisms, additional informational and training measures, clarification and expansion of the relevant internal regulations, as well as disciplinary action as appropriate. Most of the substantiated cases related to violations of our principles on respect in the workplace and personal misconduct in connection with inappropriate handling of conflicts of interests or the protection of company property. In such individual cases, we took disciplinary action in accordance with uniform internal standards and also pursued claims for damages where there were sufficient prospects of success. In 2025, violations of our Code of Conduct led to termination of employment in 59 cases (2024: 67). This affected various groups of employees, including managers.

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As in the previous year, in the reporting year there were no court convictions for violations of anticorruption and antibribery regulations.

Identification of compliance risks

Based on ongoing systematic risk analysis we identify and evaluate material risks from compliance violations, including corruption. This is done from the perspective of the divisions and the Group companies. Accordingly, we implement targeted local and unit-specific requirements. Employees responsible for procurement are considered to be most at risk of corruption and bribery. Consequently, these employees in our Procurement organizations are prohibited from accepting gifts of any kind, in accordance with our Zero Gift Policy. Training materials and formats (see section Information offerings and training to strengthen our compliance culture) are continuously updated, taking into account the specific risks of individual target groups and business areas.

The regular compliance audits performed by the Corporate Audit unit are another source for the systematic identification of risks. These risks are documented in the relevant risk or audit report. The same applies to specific risk minimization initiatives as well as the time frame for their implementation. The Corporate Audit unit continuously monitors compliance with guidelines.

Business partner due diligence

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We conduct ongoing risk-based reviews of our business relationships worldwide for signs of corrupt behavior, human rights violations, or noncompliance with internationally recognized ESG standards. Based on our global requirement “Third-Party Compliance Due Diligence,” we use an IT solution to audit all of our sales intermediaries for potential compliance risks. We have established control mechanisms accordingly. BASF compliance experts evaluate system alerts and initiate appropriate control measures. The results are then documented.

A dedicated global Supplier Code of Conduct (see S2 Workers in the Value Chain) also applies to our suppliers, which covers compliance with environmental, social and corporate governance standards, among other requirements. With regard to environmental protection, health and safety, we regularly review our performance as part of our Responsible Care Management System, which also covers audits (see E2 Pollution Prevention).

Furthermore, as part of our trade control processes, we continuously check whether persons, companies or organizations appear on sanction lists due to suspicious or illegal activities and whether there are business processes with business partners from or in countries under embargo. Sanctioned persons, companies or organizations are excluded as business partners.

Global Targets

Even though BASF has not set a specific target for the topics identified as material in the area of business conduct, we nevertheless track the effectiveness of our actions and requirements in this field. The corporate requirements cited in this chapter are aimed at continuous optimization and further development. Our Group-wide Compliance Program aims to ensure adherence to our compliance principles.

The internal Corporate Audit unit also regularly reviews the effectiveness of our systems, including our compliance management system, and whether compliance principles are being adhered to. All areas in which compliance violations could occur are covered. It checks that employees uphold regulations and make sure that the established processes, procedures and controls are appropriate and sufficient to minimize potential risks or preclude violations in the first place. In 2025, Corporate Audit conducted and documented 50 such audits Group-wide (2024: 68).