Contents
01 Introduction 03
About this report 04
02 Environment 05
Water 06
Pollution control and air quality 07
Environmental KPIs 08
03 Social 10
Diversity, equity and inclusion 11
Community engagement 12
Employment, training and skills development 13
Social KPIs 14
04 Governance 17
(Cyber) Security 18
Data protection 19
02
RWE
Supplementary Sustainability Report 2025
This report provides insight into our management of the
sustainability topics listed below and the relevant key
performance indicators (KPIs), including steps to mitigate
environmental impacts and advance social responsibility.
Environmental topics
• Water
• Pollution control and air quality
Social topics
• Diversity, equity and inclusion
• Community engagement
• Employment, training and skills development
Governance topics
• (Cyber) Security
• Data protection
We hope that this report serves as a valuable resource for
our stakeholders.
About this report
In 2024, RWE adopted the European Sustainability
Reporting Standards (ESRS) in line with the Corporate
Sustainability Reporting Directive (CSRD), establishing a
robust framework for our sustainability reporting. Building
on this foundation, our Group Sustainability Statement in
the Annual Report 2025 is the second RWE sustainability
statement to be prepared in full alignment with ESRS and
provides comprehensive disclosures based on the double
materiality assessment (DMA). This includes a description
of our sustainability strategy, overarching approaches, key
actions, targets and metrics.
For details, please see the Group Sustainability Statement
in the RWE Annual Report 2025.
This Supplementary Sustainability Report covers additional
aspects not included in the Annual Report.
As a result of the DMA, we have identified five overarching
material sustainability topics.
Material environmental topics
Climate change (1) was identified as a material topic, with
the sub-topics of climate change mitigation, climate
change adaptation and energy. In addition to climate
change, the environmental topics of biodiversity (2)
and circular economy (3) were also identified as material.
Material social topics
In the social dimension, our own workforce (4) in terms of
working conditions, and workers in the value chain (5), in
connection with human rights aspects, were identified as
material.
Although a number of sustainability topics were not
identified as material on the basis of our DMA, they remain
relevant for a number of stakeholders and are also
requested for ESG ratings. This Supplementary Sustainability
Report complements the core disclosures on the material
sustainability topics in the Annual Report 2025 with additional
sustainability topics.
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Environment
3
Social
4
Governance
1
Introduction
About this report
Progress
• In 2025, we maintained our CDP Water Security rating
with an overall B score. CDP scores organisations based
on the steps they take on the path to greater
environmental stewardship. With an overall B score,
RWE continues to be among the leading companies in
its field.
• In 2025 we were able to reduce our specific water
consumption by 29%, compared to the 2022 base year.
• The approval procedure to construct a 45-kilometer
pipeline (Rheinwassertransportleitung) from the Rhine
near Dormagen to the Garzweiler and Hambach
opencast mines, which began in 2024, continued as
planned in 2025 and we received the permit to begin
construction of the pipeline. This initiative is integral to
our objective to begin recultivation of the Hambach mine
by 2030. The pipeline is designed to fill in the pits of the
then closed opencast mines, permanently stabilise
groundwater conditions in the Rhenish mining area and
provide water to support local wetlands.
Indicators
For data reporting on water withdrawal, water discharge,
water consumption and water stress, please see the
Environmental KPI table on page 8.
Water
The challenge
As part of its operations - particularly for cooling processes
- RWE relies on a stable water supply to support a range of
power generation technologies. Ensuring secure access to
water is essential not only for RWE’s operations, but also for
local communities and the regional economy. At the same
time, RWE places importance on protecting wetlands,
particularly in areas that are vulnerable to drying out or
exposed to elevated levels of water stress.
Our ambitions
We strive to reduce our total water consumption per
megawatt-hour of electricity produced by 40% by 2030,
compared to the baseline year 2022. This intensity target
refers to our specific water consumption, calculated as the
difference between water withdrawal and water discharge,
divided by the electricity generated. Our ambitions include
conserving water and regularly monitoring our operations
to protect the environment as best as we can while
ensuring compliance with all relevant legal requirements
and permit obligations.
Our approach
Through technological precautions, routine evaluations
and effective wastewater treatment, we proactively
ensure that surface waters and groundwater remain
uncontaminated. Environmental impacts on rivers and
groundwater are assessed against current licenses, limits,
expert benchmarks, and operational results from previous
years. The findings are evaluated by our internal experts
and a consortium of governmental bodies, associations
and accredited external specialists. Aspects and
responsibilities related to water management are
integrated into our environmental management system,
alongside other environmental topics and are anchored in
our Environmental Protection Group Directive. Since this
Directive applies to all RWE AG affiliated companies
included in the consolidated financial statements,
RWE has achieved 100% coverage with its environmental
management system.
In Germany, the Netherlands and the United Kingdom,
water extraction varies by power plant technology:
gas-fired plants utilise mainly channels, rivers, brackish
water, seawater and groundwater; our Eemshaven hard
coal and biomass fired power plant draws from the sea;
and lignite-fired stations from groundwater. In Turkey, water
is sourced from deep wells for our combined cycle gas-fired
station. All withdrawals comply with national regulations,
forming the foundation of our operational licenses.
To use water resources efficiently at relevant locations,
including those in water-stressed areas, we apply measures
such as recirculating cooling water in power plants, utilising
collected rainwater and reusing process water. In water-
stressed areas, most of our water withdrawals are related
to power plant cooling, with the majority of the water
subsequently returned to water bodies. Overall, we
discharge approximately 98% of the clean water back into
surface waters.
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Introduction
3
Social
4
Governance
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Environment
Water
Pollution control and air quality
Progress
• In 2025, we reduced NOx emissions per megawatt-hour
produced by 25% and SO
2
emissions per megawatt-hour
produced by 32%, compared to the 2022 base year.
• We successfully complied with all relevant thresholds
in 2025.
Indicators
We report metrics related to sulphur dioxide (SO
2
), nitrogen
oxides (NOx) and dust. Please see the Environmental KPI
table on page 9.
The challenge
In addition to greenhouse gases, our conventional power
plants for electricity and heat generation produce other
emissions, including sulphur dioxide (SO
2
), nitrogen oxides
(NOx) and dust (particulate matter). These emissions can
impact people or the environment and are subject to
increasingly stringent regulations.
Our ambitions
While we comply with legislative and permit-related
thresholds to protect people and the environment, our
goal is to further reduce emissions from our plants
and to advance research focused on minimising future
emissions. We aim to reduce our Group-wide NOx
emissions per megawatt-hour produced by 35% and SO
2
emissions per megawatt-hour produced by 70% by 2030,
compared to the baseline year 2022.
Our approach
For decades, RWE has implemented comprehensive
measures to ensure Best Available Techniques (BAT) are
adopted, so that emissions are minimised and remain
below the thresholds established to protect people and the
environment. We maintain robust monitoring facilities and
engage in active communication with regulatory
authorities at our sites. Sulphur dioxide (SO
2
) and nitrogen
oxides (NOx) are the primary pollutants of conventional
generation units.
Conventional combustion plants contribute to secondary
particulate matter formation through atmospheric
reactions involving NOx and SO
2
. Units firing hard coal
and lignite, as well as biomass, also emit fine particles
directly, resulting in primary particulate emissions. Dust
primarily originates from the operation of our opencast
mining facilities and construction activities, potentially
affecting local air quality. RWE employs extensive air
purification and dust control techniques to effectively
reduce our impact.
Except for our gas fired power plant in Turkey, all of our
conventional power plant portfolio operates in Germany,
the United Kingdom and in the Netherlands. The EU
Commission’s Best Available Techniques Reference
Document for Large Combustion Plants (BREF LCP) guides
us in further reducing pollutants, including nitrogen oxides,
sulphur dioxide and dust. We strictly adhere to statutory
emission limits through primary and secondary reduction
measures. This includes optimising combustion technologies
and applying methods such as dust removal and
desulphurisation during operations. With tailored technical
solutions, the objective is to further minimise our impact,
in full accordance with legal requirements and permitting
regulations.
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Introduction
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Social
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Governance
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Environment
Pollution control
and air quality
Environmental KPIs
Water consumption
Metric Unit 2025 2024 2023
Total volume of water withdrawal million m
3
4,325 4,225 4,662
of which: surface water million m
3
1,470 1,293 1,446
of which: groundwater million m
3
447 460 483
of which: water from third parties million m
3
3 3 4
of which: seawater / brackish water million m
3
2,405 2,470 2,729
Total volume of water discharge million m
3
4,238 4,129 4,505
of which: surface water million m
3
1,797 1,632 1,739
of which: water to third parties million m
3
35 27 36
of which: seawater / brackish water million m
3
2,406 2,470 2,730
Total water consumption
1
million m
3
87 96 157
Specific water consumption m
3
/ MWh 0.71 0.81 1.21
1 Total water consumption is calculated as the difference between total volume of water withdrawal and total volume of water discharge.
Accounting principles
• The water category definitions for water
consumption are based on GRI303: Water and
effluents (2018).
• Specific water consumption: standardised to
electricity generation.
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Environment
Environmental KPIs
Pollution control and air quality
Metric Unit 2025 2024 2023
NOx emissions thousand
metric tons 27.48 29.59 33.68
SO
2
emissions thousand
metric tons 7.45 8.21 9.33
Dust emissions metric tons 1,291.70 1,540.46 1,666.76
NOx emission intensity g / kWh 0.22 0.25 0.26
SO
2
emission intensity g / kWh 0.06 0.07 0.07
Dust emission intensity g / kWh 0.01 0.01 0.01
NOx emission intensity, lignite g / kWh 0.74 0.75 0.75
NOx emission intensity, hard coal g / kWh 0.28
1
0.41 0.38
NOx emission intensity, gas
2
g / kWh 0.12 0.12 0.14
SO
2
emission intensity, lignite g / kWh 0.24 0.24 0.26
SO
2
emission intensity, hard coal g / kWh 0.15 0.16 0.13
SO
2
emission intensity, gas
2
g / kWh 0.0004 0.0004 0.0005
1 The value decreased due to the Amer hard coal plant being fully converted to biomass as of 31 December 2024.
2 Values for 2024 and 2023 have been corrected compared to the reporting in the previous years due to identified instances of double counting.
Accounting principles
• Nitrogen oxides and sulphur dioxide emissions are
only reported for our fossil-fuel power plants.
These emissions are primarily determined
through continuous measurement but may also
be estimated using plant-specific emission
factors.
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Environmental KPIs
• Systemic change was further advanced by embedding
diversity, equity and inclusion principles and debiasing
best practices into our Leadership Principles and the
Executive Journey. This ongoing integration reinforces
systemic changes that increase fairness in the moments
that matter.
• The ‘Power of All Voices’ campaign, launched by RWE
Supply & Trading (RWEST), amplified diverse perspectives,
encouraged employee participation and emphasised
how an inclusive culture benefits both employees and
RWE.
• We expanded practical, global tools and resources
supporting inclusive behaviour in employees’ everyday
work, making inclusive behaviours a clear responsibility
for all employees across the Group.
• Our ongoing achievements received external recognition,
including securing 2nd place in the Women's Career Index
(FKi), highlighting our continued advancement towards
an inclusive culture and gender balance in leadership
roles.
Indicators
We report on the gender distribution in our company,
including leading indicators, to key stakeholders such as the
Supervisory Board, Executive Board and upper management,
in line with the German Codetermination Act. We
transparently share this information on rwe.com.
The challenge
RWE recognises the importance of diversity, equity and
inclusion in fostering innovation, creativity and improved
financial performance. In the face of a challenging and
evolving environment, we continue to work towards
ensuring that our workforce mirrors the diversity of the
regions where we operate. Across RWE’s global operations,
we provide employees with varied work experiences and
development opportunities, reflecting our multinational
presence. However, we recognise the need to further
broaden access to these opportunities, leading to improved
representation at all levels.
Our ambitions
We see a range of talent, skills and individual perspectives
as key strengths that drive growth and success across our
operations. Our commitment is to cultivate an inclusive
work environment - one where discrimination is actively
rejected and personal development is championed,
enabling all employees to reach their potential. In relevant
jurisdictions, RWE has set the goal of achieving greater
gender balance in leadership: by 2030, 30% of
management positions in the Group’s core business should
be held by women. This ambition does not include phaseout
technologies (coal and nuclear) due to personnel
reductions in that sector, or positions based in the US.
Our approach
Diversity, equity and inclusion are embedded in our values
and reflected in our Code of Conduct, Diversity,
Equity and Inclusion Statement, Anti-Discrimination Policy,
Essential Behaviours and Leadership Principles. The Group-
wide Diversity and Inclusion team develops overarching
strategies to ensure a consistent global approach. As a
global company with a diverse portfolio operating across
multiple regions and technologies, we recognise the unique
needs related to different locations and business areas.
Therefore, each operating company also has a Diversity
Lead and a responsible Board Member, enabling us to act
not only in compliance with local legislation and cultural
contexts but also to address challenges specific to the
operating companies. Our inclusive culture remains our
priority, creating a workplace where everyone can thrive. In
addition, we focus on implementing systemic improvements
that reduce bias, broaden our talent pool, support innovation
and enhance robust decision-making.
Progress
• In 2025, RWE continued to strengthen its inclusive
culture and achieved consistent progress in the
representation of women in management positions.
• Our diversity networks experienced sustained growth,
with increasing membership in the LGBT*IQ & Friends
Network, the Women’s Network and the Empower
Network (focused on disability and neurodiversity). The
rebranded ‘Including You’ network, open to all colleagues,
expanded its membership and outreach activities,
reflecting growing engagement across our organisation.
Diversity, equity and inclusion
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Diversity, equity
and inclusion
Progress
• In the US market, RWE has continued to grow its
community engagement activities, helping the company
improve community relations. Community engagement
activities are integrated into project development plans
with priority given to research, planning and execution. In
2025, the US community engagement team completed
100 social risk and community assessments,
implemented 50 unique community engagement plans
and participated in 200 community events.
• To date in the UK renewable energy projects operated by
RWE have contributed over £50.3 million to local
communities. This includes more than £5 million in 2025
alone which helped to unlock a further £5 million in
match funding. For more information, please visit:
rwe.com/in-your-community.
• In 2025, the RWE Foundation funded 53 projects with a
total volume of around €10.4million approved,
facilitating more equal opportunities for children and
young people across Europe. For more information,
please visit the RWE Foundation website:
rwe-foundation.com.
Indicators
We report on specific measures, including our volunteering
activities and our engagement with communities. Please
see the Social KPI table on page 14.
The challenge
With the energy transition, RWE is at the forefront of a
transformation, shifting infrastructure to renewable and
flexible assets in different countries. This transition and
work in diverse global regions pose various opportunities
and challenges for our engagement with different
stakeholders. The success of this transition is dependent on
a supportive framework. Despite professional relationship
management with the communities in which we operate
and comprehensive mitigation and support measures, there
is still an impact from our activities. Therefore, it is
important for us to be open, honest and proactive with all
affected stakeholders.
Our ambitions
RWE aims to implement effective mitigation measures and,
where possible, to create positive, lasting impacts in the
communities in which we operate, with the long-term goal
of generating shared value. It is crucial for us that all projects
strive to achieve strong community relations and positive
long-term impacts. Therefore, community engagement is an
integral part of our business.
In addition to our community engagement approach, we
have also established the RWE Foundation. Through this
foundation, we want to use our energy to foster lasting
change in the social sphere as well, so that we can help
make a positive difference in society over the long term, in
Germany and abroad, with a focus on helping young people
to improve their future prospects.
Our approach
For decades, RWE has actively engaged with numerous
stakeholders, ensuring that their interests inform our
objectives and plans throughout the entire lifecycle of our
assets – from project development to construction,
operation, decommissioning, demolition and site reuse. In
the UK, RWE has been supporting community development
for over 25 years through our community fund programme,
helping to foster growth, resilience, and sustainability within
local communities, with funding decisions taken by local
people. Our active engagement with German municipalities
also involves significant financial resources: RWE pays the
surrounding municipalities 0.2 euro cents per kilowatt hour
produced from its wind and solar farms in line with the
German Renewable Energy Sources Act, along with
municipal participation models, to name just a couple of
examples.
We have developed a community engagement policy which
serves as a guiding compass, outlining our principles and
goals. The policy is designed to ensure that our initiatives
deliver real value in harmony with the unique needs of the
communities we serve. We have created an internal
framework that incorporates best practices in community
engagement based on our own experience and industry
insights. This framework acts as a roadmap, providing our
teams with the tools and knowledge needed to foster
meaningful and productive relationships with the
communities in which we operate.
Community engagement
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Progress
• In 2025, a key development focus has been the strategic
upskilling of all employees in artificial intelligence (AI). To
enable responsible, scalable and efficient AI adoption,
RWE has implemented an enablement programme. The
holistic training and transformation approach offers
employees various training workshops and covers three
major pillars: leadership and trust, awareness and
enablement, and mindset and behaviour. The portfolio
includes more than 15 major events, such as the Group-
wide Promptathon and AI Day, as well as over 50
individual team AI experience sessions. Additionally, it
encompasses the identification of relevant AI use cases.
In this way, RWE is strengthening employee competence,
building confidence, and accelerating the productive use
of AI.
• In 2025, over 178,000 training courses were booked
through our SuccessFactors learning platform,
demonstrating a strong commitment to employee
growth and skill enhancement. Employer branding
remained a key focus, with continued efforts to reinforce
our positioning through HR toolkits and recruitment
strategies that align with our corporate values.
Indicators
Please see the Social KPI table on page 15. For more
information on our own workforce including health and
safety KPIs, please see chapter ‘S1 Own workforce’ in the
RWE Annual Report 2025.
The challenge
Today’s job market is a challenging environment when it
comes to attracting and retaining employees. As RWE
continues on a journey of transformation, it is vital to strike
a balance between recruiting specialised talent for our
expanding renewables and flexible generation business
and managing a socially responsible transition with regard
to our phaseout technologies. Our success hinges on the
knowledge and skills of our employees, whose competence
and commitment are essential.
Our ambitions
At RWE, our ambition is to be recognised as an employer
of choice, attracting and retaining talent while nurturing the
professional growth of our workforce. We are committed to
creating a work environment that empowers employees to
realise their full potential and contribute to a sustainable
energy future. With continuous learning, skill enhancement
and talent mobility, we strive to facilitate career development
across the Group.
Our approach
To achieve these ambitions, RWE applies a comprehensive
set of measures for talent attraction, career development
and employee support. By providing competitive working
conditions, modern workspaces and ample career
opportunities, RWE has developed its image as an attractive
employer in the energy sector.
Continuous learning is integral to our strategy, including a
wide array of training programmes that enhance technical
skills, leadership abilities, IT competencies and project
management expertise. These programmes are accessible
in various formats, including in-person training, blended
learning, online courses and video-based instruction.
We emphasise the dual education system in Germany,
combining practical training at RWE with formal instruction
at vocational schools to ensure high-quality learning
experiences that benefit both the company and the
industry.
To bolster career development, RWE offers specialised talent
programmes for employees aspiring to advance in expertise,
project management or leadership roles. These initiatives
support internal mobility and facilitate the exploration of
new opportunities within the Group. Our HR teams actively
curate learning, development and change processes to
support employees throughout their careers.
For those affected by the phaseout technologies, RWE has
launched comprehensive programmes, providing responsible
solutions to facilitate transitions and prioritising internal
redeployment opportunities via our own job market or
offering attractive alternative solutions. If suitable positions
within the Group are unavailable, alternative solutions are
considered, such as early retirement or qualification
programmes.
Employment, training and skills development
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Employment, training and
skills development
Social KPIs
Community engagement
Metric Unit 2025 2024 2023
Donations by the Group € million 1.7 2.1 1.7
Sponsorships by the Group € million 3.8 2.4 3.8
Contributions to Community Funds in
the United Kingdom £ million 5.7 6.1 > 5
Grants by Community Funds in the United Kingdom number 741 703 578
Accounting principles
• Donations made by the Group: data includes
grants made by Community Funds.
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Social KPIs
Employment, training and skills development
Metric Unit 2025 2024 2023
Employees FTE 20,120 20,985 20,135
Employees HC 21,265 22,098 21,233
of which: full-time employees HC 19,758 20,569 19,779
of which: part-time employees HC 1,507 1,529 1,454
of which: male % 79.1 79.2 80.5
of which: female % 20.9 20.8 19.5
Tariff / payscale employees % 49.1 49.7 51.5
Non-tariff / non-payscale employees % 42.3 41.9 40.1
Share of executive employees % 4.0 3.8 3.8
External hirings
1
HC 1,153 2,352 3,508
of which: male HC 934 1,673 2,596
of which: female HC 219 678 912
Apprentices in the Group HC 738 707 707
of which: Germany HC 652 639 644
Share of apprentices in the Group % 3.5 3.2 3.5
of which: Germany % 4.7 4.4 4.8
Apprentices p. a. approx. HC 245 234 200
Average training time per employee hours 5.9 4.6 —
Training sessions booked number 178,747 139,141 140,708
Proportion of employees undergoing training
(including compliance) % 100 100 100
1 In fiscal 2025, the FTE calculation was replaced by headcount (HC). Therefore, the reduced working hours of part-time employees are no longer considered.
Accounting principles
• Employees: this figure can be measured as
headcount (HC) or measured in full-time
equivalents (FTE).
• Average training time per employee: the
calculation method for this KPI was updated with
a new survey methodology in 2024. Therefore, the
value is no longer comparable with the previous
year’s values.
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Social KPIs
Employment, training and skills development
Metric Unit 2025 2024 2023
Severely disabled persons, Germany HC 678 785 880
Disability ratio, Germany % 4.9 5.4 6.1
Average age years 42.9 43.0 43.5
Employees < 20 years % 1.6 1.4 1.3
Employees 20 – 29 years % 14.2 15.1 14.8
Employees 30 – 39 years % 27.1 26.6 25.3
Employees 40 – 49 years % 25.4 23.9 22.9
Employees 50 – 59 years % 24.5 25.9 28.8
Employees ≥ 60 years % 7.2 7.1 7.0
Lost Time Incidents (LTI), own employees number 32 49 37
Lost Time Incidents (LTI), own employees and
contract workers number 87 113 94
Sickness rate % 4.4 4.6 4.9
Externally certified management systems for occupational safety % 49 50 49
Accounting principles
• Disability ratio: share of workers with disabilities.
We report this metric for Germany only. It takes
into account severely disabled employees
according to the German SchwBG or equivalent
(GdB of min. 50 or min. 30).
• LTI: number of lost time incidents resulting in at
least one day of absence.
• Sickness rate: percentage of work time that an
employee is absent due to sickness, accidents
or treatment. It is calculated by looking at the
number of working hours missed out of a certain
period of total working hours, according to
country-specific regulations.
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Social KPIs
holistic approach, addressing all potential critical
disruptions.
The RWE Group Security department identifies security
risks, sets Group-wide protection standards and
strengthens RWE’s business resilience by providing
frameworks for crisis management, business continuity
management and employee security, and by monitoring
the implementation of these minimum requirements. With
the expansion of our international operations, we continue
to promote a strong security culture across the entire
Group. We regularly update our security measures and
maintain detailed crisis and continuity plans to support
effective responses to potential disruptions. Our risk
management approach is continuously improved to adapt
to new challenges.
Progress
• In 2025, strengthening RWE’s resilience approach
continued through enhancements to the Group-wide
Business Continuity Management and alignment of crisis
management structures with evolving requirements.
• Cybersecurity measures were reinforced through risk-
based updates, the continuous integration of advanced
security technologies and broadened cybersecurity
awareness initiatives.
The challenge
The electricity supply industry is deemed to be critical
infrastructure that is crucial for society’s well-being. As a
result, RWE is affected by growing legal requirements, such
as the EU Critical Entities Resilience Directive and NIS2, as
well as by the evolving geopolitical situation. These
requirements cover cybersecurity, physical security and
related areas such as resilience, business continuity
management and crisis and emergency management.
Digital technologies and cloud solutions have modernised
and interconnected our entire generation portfolio. These
new solutions, as well as new technologies and AI, can also
involve new risks, such as vulnerability to cyberattacks.
Disruptions in any of the crucial parts of our business
could impact energy supply. This, in turn, could pose a
threat to daily life and the safety and health of individuals.
Our ambitions
We ensure the reliable operation of facilities and maintain a
high degree of resilience in internal systems against crises.
We identify and protect our key business processes, facilities
and information. By following strict security measures, we
aim to ensure stable electricity production. Our overarching
goal is to proactively prevent security and cyber incidents
and to ensure the protection of our people, information,
operations and assets.
Our approach
To ensure preparedness for both physical and cyber
attacks, and to enable a prompt response, we continuously
analyse and assess the threat landscape. At RWE,
cybersecurity is a fundamental element of our operational
strategy, extending across all Group companies. We
emphasise planning and training to effectively handle a
wide array of potential events, including highly improbable
but impactful cyber incidents. Our security services monitor,
detect and respond to threats in both Information
Technology (IT) and Operational Technology (OT). The
cybersecurity enterprise programme integrates IT and OT
cybersecurity, providing centralised governance, global
threat monitoring and incident response management. This
programme safeguards RWE’s operations and objectives
from cyber threats, managing risks related to information
security and IT systems under the oversight of our Group
Cybersecurity department.
Our approach includes protecting business assets against
worldwide threats through cybersecurity management
and secure IT integration. We employ security-by-design
principles, manage user access rights and maintain an
enterprise security architecture to fortify our security
landscape. Group Cybersecurity promotes employee
awareness through various campaigns, evaluates Group-
wide risks and coordinates critical incident management.
Our Cyber Security Incident Response team and IT Security
Operations Centre handle cybersecurity incidents with a
(Cyber) Security
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(Cyber) Security
The Executive Boards of each operating company oversee
compliance with data protection regulations, appointing
representatives from the Executive or Management Boards
to handle data protection. Depending on the data categories
or specific tasks, responsibility for processing activities
involving personal data may be delegated to subordinate
bodies or officers.
Progress
• The DPMS was successfully maintained and further
developed. New frameworks for assessing the data
protection compliance of AI solutions were established.
The ongoing revision of internal standards and processes
aligns with official statements of supervisory authorities,
court rulings and industry best practices. In parallel, the
use of AI-powered tools to support operational processes
within the DPMS was systematically expanded, and the
accelerating integration of platforms and services has
been proactively supported, with new software solutions
successfully implemented and internal processes further
streamlined.
• In 2025, RWE advanced its capabilities by introducing
dedicated AI & Data Law advisory services, ensuring
ongoing alignment with fast-changing legal and
regulatory requirements. The team enhanced its global
professionalism by standardising processes, introducing
new performance indicators and expanding cross-
functional and international collaboration alongside the
Group-wide update of Records of Processing Activities.
Data protection
The challenge
Data protection is not only a legal obligation for RWE – it is
also a growing priority in today’s digitally interconnected
world. Recent media coverage of data breaches and the
misuse of personal information underscores the importance
of robust measures for the protection of personal data. As
awareness of the need for effective data protection
continues to increase, so too does the economic value
associated with personal data. At the same time, the rapid
advancement of new technologies – including artificial
intelligence and robotics – introduces additional complexity
that requires proactive and forward-looking data protection
governance.
Our ambitions
It is our priority to ensure that employees and external
stakeholders feel secure and confident whenever their data
is processed. By safeguarding personal data against
misuse, we build and strengthen the trust of our employees,
partners and other stakeholders. Achieving key security
objectives - including data availability and resilience -
remains fundamental to our approach. Our data
protection organisation is both customer-centric and
innovation-driven, continuously enhancing its services to
meet the evolving needs of our internal clients. By staying
current with the latest regulatory and technological
developments, RWE ensures data protection while also
supporting our commitment to operational excellence and
trust.
Our approach
To ensure compliance, we have implemented a
comprehensive Data Protection Management System
(DPMS) across the Group, aligned with the RWE Code of
Conduct and our sustainability principles. These
frameworks and guiding principles facilitate the legally
compliant processing of personal data, both within our
organisation and by external partners acting on our
behalf, and are continuously monitored and updated to
reflect the dynamic regulatory landscape.
Data protection is integrated into processes involving
personal data (‘data protection by design’ and ‘data
protection by default’). Employees are responsible for
adhering to data protection requirements and are
encouraged to reach out to the data protection officer or
the data protection coordinators in departments and
units if they have questions.
Group Data Protection consistently promotes awareness
and training among employees and management
regarding data protection requirements. Key focus areas of
the DPMS include raising awareness, consulting on projects
and processes, safeguarding individuals’ rights and
handling data protection incidents. The Group Data
Protection Officer regularly provides updates on pertinent
data protection matters to the Executive Board of RWE AG
and other boards of the RWE Group operating companies.
19
RWE
Supplementary Sustainability Report 2025
1
Introduction
2
Environment
3
Social
4
Governance
Data protection
