Climate Change (E1)

Material impacts, risks and opportunities and their interaction with strategy and business model (ESRS 2, SBM-3)

The table below provides an overview of the results of the double materiality assessment in relation to material impacts, risks and opportunities (IROs) for issues in connection with climate change mitigation and climate change.

Climate-related scenario analysis

TUI conducted a qualitative and quantitative climate scenario assessment in financial year 2023 to gain a better understanding of the potential impact of climate change on its business, review its strategy and financial planning and enhance resilience. The results of that assessment remain valid for TUI Group with unchanged business forecasts, regulatory requirements and up-to-date climate-related scenarios. They were therefore included in the double materiality assessment and assessed in accordance with the requirements.

The analysis included two climate-related scenarios: a high-emission scenario to assess the impacts of significant changes in the physical climate, based on Representative Concentration Pathway 8.5 (IPCC RCP 8.5) as set out by the Intergovernmental Panel on Climate Change (IPCC) and the Stated Policy Scenario of the International Energy Agency (IEA), which assumes global warming of around 4.3 °C by 2100, and a low-emission scenario to assess the impact of significant socio-economic changes required to achieve a low-carbon economy, drawing on IPCC RCP 2.6 and the IEA’s Net Zero Scenario, which envisages global warming of approximately 1.5 °C by 2100. The scenarios are based on a number of assumptions relating, for example, to changes in the intensity and frequency of weather-related events, economic growth, technological developments and future energy and carbon prices.

The process began with a qualitative assessment of the risks and opportunities along TUI Group’s value chain which had been identified in the different combinations of scenarios and time horizons in order to establish the climate-related risks and opportunities most relevant to TUI. Based on the findings of that qualitative assessment, various risks and opportunities were subsequently analysed in detail to gain a better understanding of the potential financial impact on TUI Group. TUI analysed short-term, medium-term and long-term climate-related risks and opportunities in its climate-related scenario analysis. TUI defines “short-term” as the period up to 2030 (aligned with its science-based targets), “medium-term” as the period up to 2040, and “long-term” as the period up to 2050 (the date by which TUI aims to achieve net zero emissions across its entire business operations and supply chain). For the double materiality assessment, the findings of the more critical scenario in each instance were reanalysed based on the time horizons defined (short-term: less than one year, medium-term: one to five years, long-term: more than five years).

For details on the time horizons and methodology, please refer to the sections General information according to ESRS 2 and Description of the process used to determine and assess the material impacts, risks and opportunities (IRO-1).

The quantitative climate-related scenario analysis took into account the expected financial effects of physical risks and transition risks as well as the climate change mitigation actions and measures described in the section on Actions. The assessment is based on a number of assumptions relating, for example, to changes in the intensity and frequency of climate-related events, technological developments, future energy and carbon prices, and advances in knowledge about global warming. For TUI Group, the consequences of both emission scenarios are variable. In a low-emission scenario, stricter emission and fuel efficiency targets set by TUI Group or by regulation could increase operating costs. In a high-emission scenario, physical risks from extreme weather events and natural disasters could affect TUI’s tourist destinations. Rising operating costs due to stricter environmental regulations could affect profitability.

The results of the climate-related scenario analysis confirm the appropriateness of TUI Group’s strategic initiatives and reduction paths described in the section on Actions in minimising the respective risks and tapping into opportunities. The impact on financial planning over the three-year observation period is considered immaterial, while potential medium- to long-term uncertainties are continuously monitored and assessed.

TUI is aware that the climate-related scenario analysis is based on a number of assumptions described above and that the uncertainties surrounding the consequences and the likelihood of certain impacts will increase in the medium to long term.

For further details on the impacts of climate-related risks on the useful lives and valuation of assets, please refer to the chapter on Key judgments, assumptions and estimates in the Notes to the Consolidated financial statements in the present Annual Report.

TUI Group decarbonisation roadmap (ESRS E1-1)

TUI Group’s decarbonisation roadmap is derived from the science-based climate targets and underlying action plans aimed at reducing emissions for TUI Airline, Hotels & Resorts and Cruises, the most emission-intensive areas of the TUI Group. The greenhouse gas emission reduction target for TUI Hotels & Resorts is aligned to limiting global warming to 1.5 °C under the Paris Agreement. The targets for TUI Airline and Cruises are aligned to limiting global warming to well below 2 °C. All three targets have been validated by the Science-based Target Initiative (SBTi).

TUI’s action plan for greenhouse gas emission reduction and target performance comprises the decarbonisation levers presented in the section Actions. For TUI Airline, TUI combines fuel efficiency and fleet modernisation measures as well as sustainable aviation fuels (SAF) in order to reduce emissions. The roadmap takes account of the emission output of current and planned aircraft by 2030. TUI has also developed an action plan for Cruises, which comprises the levers required to achieve SBTi’s targets. The roadmap covers specific measures such as the use of shore power, energy efficiency enhancement, route optimisation and the use of lower-emission fuels. The action plan for TUI Hotels & Resorts comprises more extensive use of renewables, based on both sourcing activities and the expansion of on-site generation. In addition, energy efficiency enhancement measures are continually identified.

For more detailed information on the decarbonisation levers in the individual businesses, please refer to the sections on Climate change mitigation actions: TUI Airline, Actions (ESRS E1-3), Cruises, Actions (ESRS E1-3) and Hotels & Resorts, Actions (ESRS E1-3).

In exercising its business activities, TUI Group uses assets that potentially cause locked-in greenhouse gas emissions resulting from the tourism services. The most relevant assets in this context are aircraft and cruise ships. However, the actions mentioned above, such as fleet modernisation and the use of lower-emission fuels, help TUI achieve its targets and include the potentially negative effects of these locked-in emissions in the action plans for the business areas. Potential impacts on transitory climate risks, e.g. high CO₂ prices, are covered by the risk mitigation measures. TUI Group is not exempted from the EU Paris-aligned Benchmark.

Transitioning to net zero is the core ambition of TUI’s Sustainability Agenda. Operational implementation of greenhouse gas emission reduction management activities is the responsibility of the individual business areas, with any investment required covered by the financial planning. The Agenda is managed by the Group Sustainability Officer and has been approved by the Group Executive Committee.

Progress towards the achievement of targets is presented for TUI Airline, Targets (ESRS E1-4), Cruises, Targets (ESRS E1-4) and Hotels & Resorts, Targets (ESRS E1-4).

For further details on the TUI Sustainability Agenda, please refer to the section on Strategy, Business model and value chain (SBM-1).

Management of the impacts from CO₂e emissions from own operations and the value chain

TUI Group’s management approach addresses the following topics: climate change mitigation, climate change adaptation, energy efficiency and use of renewable energies and fuels.

Management approach (ESRS E1-2)

The Planet dimension of the TUI Sustainability Agenda reflects TUI’s ambition to achieve net zero emissions in all business areas and in the supply chain by 2050. In support of that ambition, TUI has joined the SBTi and has committed to implementing emission reductions on the basis of globally acknowledged scientific climate-related findings.

TUI’s Sustainability Agenda applies to TUI Group as a whole. The targets set in the Planet dimension focus, in particular, on TUI Airline, Cruises and Hotels & Resorts. TUI’s Sustainability Agenda is managed by the Group Sustainability Officer and has been approved by the Group Executive Committee. The operational responsibility for managing reductions in carbon emissions lies with the individual business areas.

Within TUI’s Sustainability Agenda and its Planet dimension, Science-based Targets (SBTs) and specific decarbonisation roadmaps aimed at significantly reducing emissions have been drawn up for the TUI Airline, Cruises and Hotels & Resorts. However, other business areas and segments such as TUI Musement, our offices and our purchasing departments are likewise committed to reducing emissions in pursuit of the Agenda. The targets relating to climate change mitigation are outlined in greater detail below.

The net zero ambitions of TUI’s Sustainability Agenda and the activities launched to achieve the SBTs are specified in policies for operational activities in the individual business areas. For TUI Airline, these include the Airline Environmental Policy and a specific action plan for emission reductions aligned to the Science-based Target.

In Cruises, too, an action plan has been drawn up to achieve the emission reduction target validated by the Science-based Targets Initiative by 2030. The measures and investments in these action plans are based on planned budgets and CO₂e forecasts. Implementation of these measures is monitored by the project management teams.

A similar action plan to achieve the Science-Based Target has been drawn up for Hotels & Resorts. In addition, Green Building Guidelines have been published to provide Group-owned hotels and hotel partners with specific recommendations for construction and refurbishment projects. The aim is to reduce pollution and achieve water and energy savings. The Guideline also addresses topics such as monitoring systems, sustainability certification and stakeholder communication. In addition, there are specific policies for individual hotel brands, e.g. the Riu Sustainability Policy, the TUI Blue Sustainability approach and the ROBINSON ROBsponsible Programme. These policies set out the management approach to be adopted by hotels with regard to climate change mitigation, energy efficiency and other measures to prevent negative impacts on the environment.

In TUI Musement, the key policies relevant to climate change mitigation are the Policy for More Sustainable Offices and the Policy for More Sustainable Mobility and Guest Transfers. Both policies set out measures for reducing emissions, thereby contributing to the environmental goals of the business and the ambitions defined in TUI Group’s Sustainability Agenda.

Moreover, the People dimension of the Sustainability Agenda with its focus on Buy local aims to establish a management approach that strengthens links with local suppliers and creates new income opportunities for the local community so that emissions in the upstream supply chain can be reduced. TUI is building a sustainable sourcing organisation and to that end has launched its Policy for Diverse, Sustainable and Ethical Sourcing. All procurement processes are subject to standards that play their part in day-to-day requirements and sourcing specifications. When purchasing or replacing goods or services, these specifications apply to such aspects as energy efficiency, use of renewable energies and fuel efficiency. Moreover, all suppliers are obliged by the Suppliers’ Code of Conduct to minimise any adverse impacts on the environment.

The Sustainability Council receives regular reports from the managers and executives responsible for operations of key significance within TUI about the progress delivered in connection with the Sustainability Agenda. TUI’s Sustainability Agenda supports the United Nations’ Sustainable Development Goals (SDGs) – 17 global goals to fight inequality, end poverty and protect our planet by 2030. The management approach for reducing greenhouse gas emissions addresses SDG 7 “Affordable and Clean Energy” and SDG 13 “Climate Action”.

TUI’s Sustainability Agenda takes account of the interests of stakeholders around the world in climate change mitigation. Insights into the interests of our stakeholders help guide our strategy and actions, not least because they are reflected in our materiality assessment. We run national and international processes to engage in dialogue with our stakeholders in the destinations and with political decision-makers. We also engage with various stakeholder groups through our committees and the associations representing us.

The management approach and the resulting policies are communicated in-house by a number of decision-making bodies and reporting formats, e.g. via the Sustainability Council or the intranet. External stakeholders receive information about our management approach from our sustainability reporting, press releases, and customer and investor meetings.

TUI Airline

target (ESRS E1-4)

Under TUI’s Sustainability Agenda, the Group is targeting a 24% reduction in CO₂e emissions per revenue passenger kilometre from TUI Airline by 2030. In this way, TUI is helping to limit global warming to well below 2 °C, taking into account the climate scenarios of the applicable sectoral decarbonisation approach for airlines associated with the Science-based Targets Initiative (SBTi). This target is, accordingly, not compatible with the goal of 1.5 °C. TUI includes emissions from flights from all own-fleet flying operations as well as sub-charter operations within the target scope, including well-to-wake emissions for aircraft activities (emissions from aviation fuel, Scope 1 and Scope 3, Category 3). The SBTi target does not include Scope 1, 2 and 3 emissions from support services such as ground handling, engineering and maintenance, and onboard services. This area of application is derived from the SBTi methodology for aviation and therefore addresses the strongest CO₂e drivers in TUI Airline.

The following greenhouse gases associated with climate change are included: carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), perfluorocarbons (PFCs), sulphur hexafluoride (SF₆) and nitrogen trifluoride (NF₃). 82.7% of emissions are allocated to Scope 1 and 17.3% to Scope 3, Category 3. The intensity target also reflects future developments such as the expanding flight portfolio based on the Group’s recent growth scenarios.

A number of decarbonisation levers are being used to achieve the target. They include actions to enhance operational fuel efficiency, modernise the aircraft fleet and use sustainable aviation fuels. For a more detailed description, please refer to the section on Actions below.

actions (ESRS E1-3)

For TUI Airline, actions to reduce CO₂e emissions are implemented in three different areas: operational fuel efficiency, aircraft fleet modernisation, and use of sustainable aviation fuels (SAF). TUIfly Deutschland actively supports the scientific understanding to reduce the impact of other climate-related effects of aviation, e.g. by taking part in a research programme to prevent contrails under the aegis of the German Aerospace Centre (DLR).

fuel efficiency

Continuous improvements in fuel efficiency are a cornerstone of TUI Airline’s emission reduction roadmap and a key lever to reduce greenhouse gas emissions from flight operations. Targeted technical and operational measures are taken in order to systematically optimise fuel consumption. The measures, ranging from short-term optimisation schemes to long-term innovation projects, entail close cooperation between the relevant departments and operational areas. They serve to identify potential improvements across the entire aviation process, from flight planning and the flight itself to ground operations.

Examples of efficiency enhancement measures include:

• Weight reduction through technical modifications and optimised loading
• Adjustment of flight profiles, taking current weather data into account
• Digital tools to analyse and optimise flight performance
• Lower fuel consumption on the ground by drawing on external power supply
• Training schemes for pilots to promote fuel-efficient flying

The measures apply to all flights operated by TUI’s own fleet and are regularly evaluated and improved. External flight partners are requested to pursue their own efficiency strategies and communicate them in a transparent manner. Implementation depends on available resources, technical developments and the regulatory framework.

fleet modernisation

TUI’s rolling re-fleeting programme is contributing to significant reductions in CO₂e emissions from flight operations. TUI specifically invests in state-of-the-art aircraft such as Boeing 787 and Boeing 737 Max. On average, these planes are around 20% (787) and 15% (737 Max) more fuel-efficient than the aircraft they replace in TUI’s fleet. A total of 95 Boeing 737 Max are scheduled for delivery by 2029 – with 45 of these planes already delivered by the end of financial year 2025. As the new aircraft are introduced, older, more fuel-intensive aircraft are successively taken out of service.

Wet lease providers are also requested to supply the most efficient aircraft possible, for example aircraft with winglets. Together with our partners, we analyse fuel data and identify optimisation potential. The re-fleeting measures apply to all flights operated under TUI flight numbers by both the Company’s own fleet and external capacity providers, with a focus on TUI’s own aircraft.

Currently, around 54% of TUI’s fleet is equipped with new engine technology. The implementation of the re-fleeting programme depends largely on Boeing’s ability to deliver the agreed aircraft on time.

sustainable aviation fuel (SAF)

Sustainable aviation fuels are a key component of TUI Airline’s decarbonisation strategy and play a crucial role in reducing CO₂e emissions in aviation. SAF is a liquid fuel that causes significantly lower greenhouse gas emissions over its entire life cycle compared to conventional aircraft fuel. It can be produced from bio-based raw materials such as used cooking oils, non-food animal waste or biodegradable waste from various industries, but it can also be produced synthetically. SAF is a drop-in solution and can be blended with conventional aircraft fuel and used in existing aircraft and infrastructure without any technical modifications.

TUI works with various partners to secure supplies of SAF. SAF can reduce emissions by up to 80% compared to conventional Jet-A1 fuel, and even more with synthetic variants. SAF is going to be used on flights operated under TUI flight numbers, provided that it is available at the respective departure airport. TUI purchases both mandatory quantities in accordance with EU quotas and voluntary quantities.

In financial year 2025, over 11,000 tonnes of SAF were voluntarily refuelled, mainly in Amsterdam. This represents an increase of around 10,000 tonnes year-on-year. The 2% minimum supply mandate for SAF, in force since January 2025, adds further to the total SAF volume. Fuel suppliers largely comply with the EU timeline and will not provide airlines with the documentation required for certification of SAF sourced during calendar year 2025 until February 2026. This means that the total amount of SAF refuelled in financial year 2025 cannot be audited and confirmed until spring 2026. Currently, the evidence is only available for the first three months of the financial year (October to December 2024) under review, as these fall within the previous calendar year.

Allowances for Eligible Aviation Fuels – EU Emissions Trading Scheme (EU ETS): In March 2025, TUI Airline applied for support available under the framework of the European Union Emissions Trading Scheme (EU ETS), Directive (EU) 2003/87/EC, Article 3c(6), and further defined in the Commission Delegated Regulation (EU) 2025/723 supplementing Directive 2003/87/EC of the European Parliament and of the Council. This incentive aims to promote the uptake of eligible aviation fuels, notably of SAF, identified in Regulation (EU) 2023/2405 on ensuring a level playing field for sustainable air transport (ReFuelEU Aviation), by granting EU ETS allowances to commercial aircraft operators that use such fuels on eligible routes within the scheme. By doing so, it seeks to mitigate the cost disparity between conventional kerosene and SAF. The scheme runs by calendar year, and financial support is decided only 9 months after calendar year end. In calendar year 2024, TUI Airline uplifted a total of 5,019 tonnes of eligible aviation fuel, including 3,702 tonnes delivered in the fourth quarter of calendar year 2024, which corresponds to the first quarter of TUI financial year 2025. In the calendar year 2024 1,675 tonnes were attributable to routes falling within the scope of the EU ETS. These include flights within the European Economic Area (EEA), between the EEA and Switzerland, and flights from the EEA to the United Kingdom. These quantities were substantiated by the documentation required to qualify for the EU ETS incentive. As a result, TUI received 16,871 EU ETS allowances in September 2025, which were credited to the company’s EU ETS account. These allowances provided financial relief by offsetting a portion of the additional costs associated with the use of SAF in place of conventional Jet Fuel.

The availability of SAF remains a key challenge. SAF is significantly more expensive than conventional fuel and is subject to considerable price uncertainty. TUI secures SAF volumes by means of letters of intent with suppliers and actively participates in political discussions in the EU and the UK to promote SAF production. The further development of synthetic SAF technologies, in particular, requires targeted support.

reducing further climate impacts: Contrails

Apart from CO₂ emissions, the global climate is affected by other aviation impacts, in particular contrails. Although greater scientific uncertainty surrounds their exact climate impact compared with CO₂, the overall effect of contrails is assumed to be relevant.

TUI Airline actively engages in research to contain these effects. Since 2024, TUI fly Deutschland has conducted normal passenger flights as test flights to prevent contrails, serving both to gain a better understanding of operations and to carry out scientific evaluation. In the framework of the D-KULT project funded by Germany’s Federal Ministry for Economic Affairs and Climate Protection, TUI fly transmitted flight data from over 25 contrail avoidance flights to the German Aerospace Centre (DLR) in calendar year 2024. The evaluations have shown that these avoidance measures are highly effective.

As a partner in the consortium for the A4Climate research project, TUI fly has received funding to conduct additional 400 avoidance flights in the period from 2025 to 2027. In addition, in early 2025, TUI Airline was admitted to the Jet Zero Task & Finish Group Contrail Avoidance in the UK, which aims to conduct test flights in British airspace. Information on the experience gained from these projects was presented at a number of technical conferences. Reducing the climate impact of contrails hinges on technical possibilities and financial mechanisms in the regulatory framework.

Cruises

Target (ESRS E1-4)

As part of TUI’s Sustainability Agenda, TUI Group, together with the joint venture TUI Cruises and its subsidiary Marella Cruises, has set itself a target to reduce greenhouse gas emissions in Cruises. The aim is to cut CO₂e emissions by 27.5% by 2030 compared to baseline year 2019. As a joint project, the target covers all cruise ships operated by TUI Cruises, including the Mein Schiff and Hapag-Lloyd Cruises brands, as well as the ships operated by Marella Cruises, which belongs to TUI Group. In this way, TUI is supporting to limit global warming to well below 2 °C, based on the applicable absolute contraction approach by the SBTi. This target is, accordingly, not compatible with the goal of 1.5 °C. TUI takes account of the above-mentioned cruise ships along with well-to-wake emissions for cruise activities (emissions from marine fuels, Scope 1 and Scope 3, Category 3). The target exclusively relates to activities in Cruises but includes joint ventures in addition to TUI’s own business activities. The companies included differ, therefore, from those in TUI Group’s greenhouse gas balance.

The following greenhouse gases associated with climate change are included: carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), perfluorocarbons (PFCs), sulphur hexafluoride (SF₆) and nitrogen trifluoride (NF₃). 80.1% of emissions are allocated to Scope 1 and 19.9% to Scope 3, Category 3. The combined target also reflects future developments, such as the planned expansion of TUI Cruises based on recent growth scenarios.

A number of decarbonisation levers serve this target. They include the use of lower-emission fuels, the use of shore power, improved energy efficiency and route optimisation. For a more detailed description, please refer to the section on Actions below.

actions (ESRS E1-3)

Cruises, too, uses a number of decarbonisation levers to achieve the climate change mitigation targets: the use of lower-emission fuels, the use of shore power, improved energy efficiency and route optimisation. The actions outlined below cover TUI’s subsidiary Marella Cruises and the joint venture TUI Cruises, with the brands Mein Schiff and Hapag-Lloyd Cruises.

user of lower-emission fuels

The transition to lower-emission fuels is a key element of the climate strategy pursued by TUI Group’s cruise companies. The goal is to significantly reduce emissions in the marine business area through the gradual adoption of alternative fuels. Currently, all ships operated by TUI Cruises can theoretically be powered with biodiesel or biodiesel blends. Due to the limited availability and high cost of sustainable biofuels, the use of such fuels is phased in gradually and tested in trial runs. Other low-emission fuels, such as synthetic e-fuels and methanol, require technical modifications, for example to engines and fuel tanks.

Since 2022, biodiesel blends have been successfully tested and used by all TUI cruise lines. In the financial year under review, Hapag-Lloyd Cruises’ expedition ship HANSEATIC spirit bunkered 100% biofuel for the first time in the port of Amsterdam: 100.6 tonnes of second-generation biofuel made from residual and waste materials, cutting CO₂ emissions by at least 80%. Between May and September 2025, around 6,741 tonnes of biofuel were used on the Marella Cruises vessels Voyager and Discovery. This corresponds to a projected emission reduction of 6,453 tonnes of CO₂e compared with conventional fuel. In addition, TUI Cruises launched Mein Schiff Relax, the first ship with dual-fuel engines technically equipped for the use of e-fuels. In July 2025, the ship was supplied with 1,875m³ of bio-LNG (around 900 tonnes) for the first time – reducing CO₂ emissions by at least 70%.

The potential for emission reductions through the use of alternative fuels depends largely on the availability of such fuels at the respective locations and ports. Developing appropriate infrastructure therefore remains a key success factor.

use of shore power

Using shore power is an effective lever to reduce emissions from cruising. As cruise ships spend around 40% of their operating time in port, facilities providing shore power connection during these layovers can allow cruise ships to turn off their engines and thus significantly cut CO₂ emissions. The shore power capability of the fleet is a key element in reducing emissions at TUI Cruises. Both brands, Mein Schiff and Hapag-Lloyd Cruises, have made a voluntary commitment to use shore power. A prerequisite for the use of shore power is that the power has been produced from renewable sources of energy.

All newbuilds at TUI Cruises are equipped with shore power connections as a standard feature. Existing vessels are being gradually retrofitted during routine dry-dock periods. In the financial year under review, Mein Schiff 3 was equipped with a shore power connection. Twelve of the thirteen ships at TUI Cruises therefore featured the relevant technology by the end of the financial year under review. In financial year 2025, shore power calls increased significantly to 115 calls compared to 72 in the previous year, an increase of 59.7%, with power consumption amounting to 2.8 million kWh.

Marella Cruises, too, uses shore power for its Explorer 2 and made five shore power calls in Malta in the financial year under review, sourcing over 91,000 kWh of electricity in total. An expansion of shore power use aboard Explorer 2 is planned for the future. The availability of shore power in port remains a decisive factor for implementation.

improving energy efficiency

Enhancing energy efficiency on board is key to reducing CO₂ emissions in cruise operations. Potential energy savings can be identified and harnessed by well-chosen technical and organisational measures. In the financial year under review, Marella Cruises implemented a selection of measures aboard several ships to improve energy efficiency and cut CO₂ emissions. These include optimising galley equipment aboard the Discovery 2, Explorer and Voyager, as well as installing new propeller caps to improve hydrodynamics aboard the Explorer.

In the financial year under review, TUI Cruises introduced a software solution to improve energy efficiency by combining data analysis and behavioural research to cut fuel consumption. The behavioural changes prompted by the software are expected to result in annual savings of approximately 1,250 tonnes of CO₂e. In addition, Mein Schiff 4 was given a new underwater coating that reduces friction and therefore resistance to enhance fuel efficiency by estimated 6% and fitted with two optimised propellers to improve propulsion.

These continual measures to enhance energy efficiency contribute directly to TUI Group’s SBTi climate targets. Actual implementation depends on the availability of necessary components, delivery times and technical challenges during installation.

route optimisation

The rolling optimisation of travel itineraries is an effective tool for reducing fuel consumption and associated emissions in cruise operations. The teams of experts at TUI’s cruise lines regularly analyse route planning using specialist software.

Savings can be generated by selectively adjusting arrival and departure times and travel speeds. This enables more efficient programme planning, better fuel requirement forecasts and targeted implementation of efficiency enhancement measures. In winter 2004, TUI Cruises introduced a new Voyage Optimisation Tool, which analyses data from actual voyages and helps to identify additional potential for improvement. The potential for route optimisation depends on a number of external factors, including the availability of itineraries, geopolitical developments, local regulations and events, and weather conditions.

Hotels & Resorts

target (ESRS E1-4)

As part of its Sustainability Agenda, TUI Group has set a target for greenhouse gas emission reductions in Hotels & Resorts. CO₂e emissions are to be reduced by 46.2% by 2030. In this way, TUI is helping to limit global warming to 1.5 °C.

The following greenhouse gases associated with climate change are included: carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulphur hexafluoride (SF₆) and nitrogen trifluoride (NF₃). 41.9% of emissions are allocated to Scope 1 and 58.1% to Scope 2.

The target covers emissions from all sources of energy as well as gases from refrigerants (Scopes 1 and 2). The target refers to owned hotels and hotels with leasing and management contracts, including joint ventures. The scope for the SBT therefore differs from the activities covered by TUI Group’s greenhouse gas balance presented in the section Metrics.

The target takes account of future developments such as the planned expansions to the hotel portfolio based on current growth scenarios. Due to portfolio changes, regular assessments are carried out to establish whether the baseline value must be recalculated; if necessary, the value is adjusted accordingly. This process ensures that actual emissions are reported, taking into account changes in the portfolio. In the financial year under review, the baseline value was adjusted in conformity with the SBTi standard to reflect changes in the hotel portfolio. The new value for the baseline year is 875,468 tonnes of CO₂e.

A number of decarbonisation levers serve the target. They include enhancing energy efficiency, producing energy from renewable sources and sourcing renewables. For a more detailed description, please refer to the section on Actions below.

actions (ESRS E1-3)

Our hotels and hotel partners continue to focus on promoting the sustainability transformation across their operations. Emission reductions remain our key priority. To that end, the following decarbonisation levers have been identified for Hotels & Resorts so as to achieve our science-based target, and action plans have been drawn up: enhancing energy efficiency, producing energy from renewables and sourcing renewable energy. The actions outlined below cover all hotels owned by TUI Group, either directly or via joint ventures, and hotels operated under lease or management contracts. At the end of the financial year under review, the total number of in-scope hotels was 375.

Energy efficiency

Cutting energy consumption contributes substantially to emission reductions and therefore helps TUI Group achieve its climate-related targets. TUI Group implements a wide range of measures to enhance energy efficiency, including the comprehensive use of modern LED lighting and electric cars.

Sustainable building is an important lever to improve energy efficiency, enabling significant reductions in energy requirements and CO₂ emissions of hotels. The measures implemented in this area are additionally supported by the Green Building Guidelines mentioned above. In financial year 2025, examples include the installation of a trigeneration system for combined cooling, heat and power generation at the Royalton Blue Waters in Jamaica, a particularly efficient way to produce and use energy. Energy efficiency measures are continually implemented. The specific measures depend on the availability of technological solutions, specific circumstances in the hotels, the legal framework and the infrastructure in the respective countries.

generating renewable energy

Expanding the on-site generation of renewable energy is a key element of TUI Group’s Sustainability Agenda. The use of energy from solar power enables the Group to significantly reduce emissions and partially cover its electricity requirements. More than a third of all hotels in TUI Hotels & Resorts produce power from renewable sources. In financial year 2025, new photovoltaic systems were installed in hotels around the world, including Riu Touareg in Cape Verde Islands, where a system with a capacity of around 1,500 kWp came onstream. In the period under review, the capacity of photovoltaic systems in Türkiye increased by around 4 megawatts to 19 megawatts. In financial year 2025, photovoltaics are estimated to have cut emissions by 20,000 tonnes of CO₂.

The implementation of photovoltaic systems depends on country-specific conditions, including legal regulations, customs regulations for certain components as well as local availability. In addition, electricity price fluctuations may have an impact on the economic efficiency of the systems.

sourcing renewable energies

Apart from on-site generation, TUI Group selectively procures power from renewable sources in order to further reduce emissions from electricity consumption. Where available, hotels are requested to source electricity through green tariffs, direct Power Purchase Agreements (PPAs), or to obtain Energy Attribute Certificates (EACs). These measures help to significantly reduce their carbon footprint in comparison with the conventional power mix. Examples include TUI’s hotel partner Blue Diamond, which managed to reduce 10,000 tonnes of its CO₂ emissions from electricity consumption from a market perspective in financial year 2025 by obtaining EACs.

Sourcing renewable energies is a continuous process heavily dependent on local availability. In many countries, green electricity tariffs are not always available, and EACs can only be obtained in certain regions. In destinations with neither green tariffs nor certificates, TUI Group makes greater use of on-site generation from renewable sources.

TUI Musement

As TUI Musement accounts for a relatively small proportion of TUI’s overall emissions, TUI has not established a separate SBTi target covering this business. Nevertheless, TUI Musement implements climate change mitigation measures, contributing to TUI Group’s overall net zero ambition (climate neutrality). The key decarbonisation levers are the transition to Sustainable Mobility and the Sustainable Offices project.

actions (ESRS E1-3)

sustainable mobility

In the framework of the transition to sustainable mobility in ground operations, TUI’s fleet of buses uses alternative fuels to reduce its greenhouse gas emissions. Moreover, diesel-powered vehicles for transporting employees are being replaced by hybrid or electric cars as well as e-bikes to cut greenhouse gas emissions from employee transport.

The measures to increase sustainable mobility are ongoing and cover TUI’s entire vehicle fleet for ground transport in Spain, Cape Verde Islands, Morocco, Tunisia and Türkiye. Towards this transition, 246 lower-emission vehicles were in operation by the end of the financial year under review. This corresponds to 14.5% of the fleet. In addition, TUI tested two coaches of its fleet in Benidorm, Spain, on Hydrotreated Vegetable Oil (HVO) in financial year 2025. This diesel fuel produced from renewable resources, can reduce lifecycle greenhouse gas emissions by up to 90% compared to conventional diesel. The trial was subsequently extended from two to ten coaches, five in Benidorm and another five in Málaga in the financial year under review. For the future, TUI is planning to replace the diesel-powered fleet with more sustainable electric or hybrid vehicles; this also applies to the vehicle fleet of TUI reps in the destinations. Expanding the use of HVO fully depends on the availability of the fuel and the allocation of resources. To enhance transparency and manage transport emissions more efficiently, TUI is continually implementing measures to strengthen the calculation of greenhouse gas emissions. The focus is on improving the data base for emissions by the Group’s own vehicle fleet.

sustainable offices project

TUI continually works to improve the sustainability and reduce greenhouse gas emissions of its office buildings. As a first step, a TUI Group Offices Database was created in order to obtain an overview of the design of existing office buildings. Subsequently, office-related processes were standardised with the introduction of the Sustainable Office Guidelines. In addition, questionnaires were used to collect and analyse information about consumption and successful approaches in the offices. The Guidelines and the survey results serve as a basis to initiate measures towards more sustainable office design. The project initially covers all TUI Musement offices around the world fully controlled by TUI Group, whereas airport counters and small harbour offices have not yet been regularly included. The Sustainable Office Guidelines and related surveys were implemented across all TUI Group offices in February 2025.

Complementary disclosures on the climate change mitigation targets (ESRS E1-4)

The climate change mitigation measures described above for TUI Airline, Cruises and Hotel & Resorts have been validated by the SBTi and are derived from scientific findings. They are based on the Greenhouse Gas Protocol methodology and the ambitions of the 2015 Paris Agreement to limit global warming as well as the European Green Deal to become climate neutral by 2050. In establishing the targets, TUI took account of the interests of stakeholders by applying the recognised SBTi methodology, which recognises various stakeholder interests through a range of organisations including CDP, WWF, the UN and the World Resources Institute.

TUI’s SBT cover the emissions reported in ESRS E1-6 Scope 1 and Scope 2 (market-based) by 99%, Scope 3, Category 1 by 3% and Scope 3, Category 3 by 94%. Of the total gross GHG emissions reported in E1-6, TUI's SBTs cover 58%.

The year 2019 was selected as the baseline year for all SBTs. The baseline year is therefore representative and unaffected by external factors such as the effects of the COVID-19 pandemic in subsequent years. Unless stated otherwise, the target values were not changed in financial year 2025. No intermediate targets were publicly announced for the three SBTs.

The SBT for TUI Airline is aligned to limiting global warming to well below 2 °C. The target was derived from SBTi’s sectoral decarbonisation approach. In establishing the target and the emission reduction roadmaps, future developments such as new technologies and regulatory developments were taken into account. The underlying climate scenarios are based on the SBTi methodology to achieve the ambition of well below 2 °C for airlines.

The SBT for Cruises is aligned to limiting global warming to well below 2 °C. The target was set on the basis of SBTi’s Absolute Contraction Approach. In establishing the target and the emission reduction roadmaps, future developments such as new technologies and regulatory developments were taken into account. The underlying climate scenarios are based on the SBTi methodology and the ambition of well below 2 °C.

The SBT for Hotels & Resorts is aligned to limiting global warming to 1.5 °C. The target was set on the basis of SBTi’s Absolute Contraction Approach. In establishing the target and the emission reduction roadmaps, future developments such as new technologies and regulatory developments were taken into account. The underlying climate scenarios are based on the SBTi methodology and the ambition of well below 1.5 °C.

The targets are continually monitored by the management of the business areas, the Group Sustainability Team and the Sustainability Council, and the current performance is published annually in the CDP (Carbon Disclosure Project) Report.

Complementary disclosures on climate change mitigation actions (ESRS E1-3)

The greenhouse gas emission reductions achieved through the measures are counted towards the performance of TUI Airline, Cruises and Hotels & Resorts in achieving their Science-based Targets. Total reductions are presented in the annual progress report covering the targets.

The management of the material impacts is driven ahead by members of the Group Sustainability Team and the business areas in charge. Any material investments made in connection with the measures are included in the financial planning for the segments. Disclosures on significant investments, e.g. payments made to modernise our aircraft fleet, are presented in the section on Financial position of the Group. For information on the taxonomy, please refer to the section Disclosures pursuant to the EU Taxonomy Regulation (2020/852); under the taxonomy criteria, the climate change mitigation measures do not result in any taxonomy-aligned disclosures.

See sections Financial position and Disclosures pursuant to the EU Taxonomy Regulation (2020/852)

Management of risks from impacts of climate change and climate change adaptation

Management approach (ESRS E1-2)

The Group Risk Management Policy governs the handling of existing risks and the identification of potential critical risks within TUI Group in order to secure its long-term success. The management approach comprises all risks and opportunities for the Company and the management of risks relating to emissions as well as TUI’s Sustainability Agenda.

The risk management approach aims to reduce risks. An effective Group-wide risk management system also aims to create a positive risk governance and culture. The management approach affects all TUI Group employees at every level of the organisation. The effective implementation of the management approach is the responsibility of the management team of the TUI Group subsidiary concerned. Group functions are responsible for identifying, assessing and handling risks. The Group Risk & Internal Control function provides support and submits regular reports to the Group Risk Oversight Committee (GROC). The GROC’s role is to review the risks and formulate risk strategies and management approaches on that basis. It also ensures the effective monitoring of the risks and provides reports to the Executive Board, which has ultimate responsibility for risk management and reviews and approves the strategies and approaches of the GROC.

TUI Group’s relevant central functions involved in the risk process submit their questions and comments. The experts involved also represent relevant stakeholder interests and ensure they are taken into account. The Executive Board is in charge of internal and external communication of the management approach. The Group Risk Policy is available to all employees on the intranet. The processes and risks are presented in the publicly available Annual Report.

For more detailed information on the processes, please refer to the Risk report.

target (ESRS E1-4)

The climate change mitigation targets mentioned above for TUI Airline, Cruises and Hotels & Resorts help mitigate the climate change-related impacts and minimise the identified risks in relation to climate change and climate change adaptation.

risk mitigation actions (ESRS E1-3)

Disclosures on risk-mitigating factors are presented in the section Risk report under main risk no. 5 Sustainable tourism and main risk no. 8 Climate change. The scope of the measures differs as described in the section on Actions outlining the design and structure of the measures for TUI Airline, Cruises and Hotels & Resorts. Unless stated otherwise, the measures are continually implemented and optimised.

For more detailed information on risk-mitigating factors, please refer to the Risk report.

Metrics

Energy (ESRS E1-5)

calculation basis: energy consumption and energy mix

TUI Airline: The main source of data for TUI Airline is the Airpas system, an industry-specific fuel and cost management solution. The data is collected per flight and transferred to Airpas on a daily basis (overnight). The data is consolidated quarterly at fleet level.

Cruises: The cruise lines use NAPA as their primary data source. NAPA is an industry-specific solution supplying real-time shipping data on a daily basis. The environmental managers enter the data manually into the NAPA system aboard the ships. The data is compiled as a Voyage Performance Report (VPR) once a week or at the end of a voyage and consolidated quarterly for each individual vessel.

Hotels & Resorts: Data collection varies within the portfolio. A small proportion of the hotels have installed AMRs (Automatic Meter Reading) or smart meters for automated data capture. Most data is billed and / or recorded every month. The data is consolidated quarterly for each individual hotel.

TUI Musement: Data is collected based on manual requests for information and consolidated annually at fleet level.

Markets and travel agencies: Data is retrieved manually via invoices or AMRs and consolidated annually at regional level.

Offices: Data retrieval varies, with some sites transferring information via a data capture tool in the form of check boxes. The data is consolidated annually at the level of individual buildings.

Definition of energy types

Fuel consumption from crude oil and petroleum products: Hotels & Resorts consume heating oil, diesel, petrol, liquefied gas (propane) and butane. Cruises consume HFO (high-sulphur fuel oil), HFO-VLSFO [0.5%], HFO-VLSFO [1.5%] and marine gas oil. Markets, retail shops and central functions consume heating oil. Also included are aircraft fuel for Airlines and diesel for public transportation. Fuel consumption from natural gas relates to the natural gas consumed in Hotels, retail shops and central functions.

Consumption of purchased or acquired electricity, heat, steam or cooling from fossil fuels: This comprises purchases of electricity from the grid by Hotels & Resorts, central functions and retail shops. It includes district heating and cooling purchased by Hotels & Resorts, central functions and retail shops.

Fuel consumption from renewable sources: Comprises the use of biomass by hotels and biofuel.

Fuel consumption of purchased or acquired electricity, heat, steam or cooling from renewable sources: This comprises green electricity acquired by hotels, retail shops and central functions.

Consumption of non-fuel renewable energy generated on site: Comprises e.g. PV energy generated and consumed by hotels.

Energy intensity is derived from the energy consumption mentioned above and net revenues of TUI Group as a whole. TUI’s entire business activities must be classified as high climate impact operations.

GHG-Emissions (ESRS E1-6)

calculation methods for the scope categories

Significant change: The scope of TUI's key performance indicator reporting changed in financial year 2025 compared with previous years and was adjusted to the requirements of the ESRS standard. The most significant changes are the exclusion of TUI Cruises (Mein Schiff and Hapag-Lloyd fleets) and TUI Hotel & Resorts, which do not comply with the financial consolidation approach. All relevant previous year figures have been recalculated accordingly.

Scope 1: For Scope 1 emissions, the methodological approach comprises the quantification of direct greenhouse gas (GHG) emissions from sources belonging to or controlled by the company, e.g. incineration of fuel in the company’s vehicles (aircraft, cruise ships and ground transport), on-site fuel incineration (hotels, larger buildings and retail shops) and the use of coolants. This process follows the Greenhouse Gas Protocol’s Corporate Accounting and Reporting Standard in order to ensure accuracy and comparability.

Scope 2 (location-based): For Scope 2 emissions, the method comprises calculation of indirect emissions resulting from the consumption of purchased electricity, heat, steam or cooling from own or controlled sources (hotels, larger buildings and retail shops). Our location-based approach calculates emissions using grid average emission factor types (IEA) of the geographic location at which the electricity is consumed, regardless of the specific energy procurement choice.

Scope 2 (market-based): For Scope 2 emissions, the method comprises calculation of indirect emissions resulting from the consumption of purchased electricity, heat, steam or cooling from own or controlled sources (hotels, larger buildings and retail shops). Our market-based approach calculates emissions from electricity that the company has purposefully chosen, deriving supplier-specific emission factors from the data compiler and contractual instruments such as Energy Attribute Certificates (EACs).

Scope 3, Category 1: A combination of spend-based and average-based calculations following the Greenhouse Gas Protocol (GHGP) were used for purchased goods and services. In order to calculate emissions from spend-based data, TUI uses factors provided by the Environmental Protection Agency (EPA) (v1.3 according to NAICS-6). As the approach for this category was updated to include average-based approach, the 2024 values were recalculated.

Scope 3, Category 2: Spend-based data were used for calculation of TUI’s capital goods emissions. In order to calculate emissions from spend-based data, TUI uses factors provided by the Environmental Protection Agency (EPA) (v1.3 according to NAICS-6). TUI’s calculations for capital goods are in conformance with the spend-based method of the GHGP.

Scope 3, Category 3: Fuel and energy-related data at company level are entered in Sphera on an annual level during the data compilation period. In order to calculate emissions from fuel and energy-related data, TUI uses the factors provided by the UK Department for Environment, Food and Rural Affairs (DEFRA), applying the most recent versions available. TUI’s calculations for fuel and energy-related activities are in conformance with the average data method of the GHGP.

Scope 3, Category 4: Spend-based emissions were used for all postal and logistics services offered by TUI. In order to calculate emissions from spend-based data, TUI uses factors provided by the Environmental Protection Agency (EPA) (v1.3 according to NAICS-6). TUI’s calculations for upstream transportation and distribution are in conformance with the spend-based method of the GHGP.

Scope 3, Category 5: Waste generated in operations is entered into Sphera on an annual basis during the data compilation period. In order to calculate emissions from waste data, TUI uses the factors provided by the UK Department for Environment, Food and Rural Affairs (DEFRA), applying the most recent versions. The calculation of Waste generated in operations at TUI is in conformance with the average data method of the GHGP partly applying the waste-type-specific method.

Scope 3, Category 6: Spend-based emissions were used for all business travel within TUI. In order to calculate emissions from spend-based data, TUI uses factors provided by the Environmental Protection Agency (EPA) (v1.3 according to NAICS-6). The calculation of business travel at TUI is in conformance with the spend-based method of the GHGP.

Scope 3, Category 7: All FTE and working contract type (location) data of the consolidated companies is aggregated and shared with an external consultant who have developed an employee emission commuting tool. Factors such as country specific break-downs of commuting times and transport types are accounted for. The calculation of employee commuting emissions is in conformance with the average data method of the GHGP.

Scope 3, Category 8 (immaterial for TUI): TUI Group’s main business is to sell travel experiences. The leased assets under TUI’s operational control fall under Scopes 1 and 2. This category is therefore not reported.

Scope 3, Categories 9 to 13 (immaterial for TUI): TUI Group’s main business is to sell travel experiences. The Company does not sell physical products and does not lease any assets. These categories are therefore not reported.

Scope 3, Category 14: Fuel and energy-related data at the Company level are entered into Sphera on an annual basis during the data compilation period. The list of the portfolio of TUI Hotels & Resorts is provided by Portfolio Management on an annual basis during the data compilation period. TUI’s franchise hotels are operated by third-party hoteliers. In order to calculate emissions from fuel and energy-related data, TUI uses the factors provided by the UK Department for Environment, Food and Rural Affairs (DEFRA), applying the most recent versions available. The list of the portfolio of TUI Hotels & Resorts is reviewed and the number of franchise hotels counted. Average (market-based) emissions for the franchise hotel brands are calculated and multiplied by the number of franchise hotels in the portfolio in order to obtain the total. TUI’s franchise calculations are aligned to the average data method of the GHGP. For a small number of franchise hotels primary data is available which is used instead of the average data method.

Scope 3, Category 15 (immaterial for TUI): TUI Group’s man business is to sell travel experiences. TUI does not carry out any investment activities but acquires companies and brands it intends to manage under the TUI banner. This category is therefore not reported.

calculation basis

The calculation of emissions is identical for the consolidated accounting group and the associated companies within the scope.

For Scope 1 emissions, the methodological approach comprises the quantification of direct GHG emissions from sources owned or controlled by the company, e.g. the burning of fuel in company assets (aircraft, cruise ships and ground transportation). This process follows the Greenhouse Gas Protocol’s Corporate Accounting and Reporting Standard in order to ensure accuracy and comparability.

For Scope 2 emissions, the methodology comprises the calculation of indirect emissions resulting from the consumption of purchased electricity, heat, steam or cooling from owned or controlled sources (hotels, business premises and retail shops). Our location-based approach calculates emissions using grid average emission factor types (from IEA) of the geographic location at which the electricity is consumed, regardless of the specific energy procurement choice. Our market-based approach calculates emissions from electricity that the company has purposefully chosen, drawing on supplier-specific emission factors or contractual instruments such as Energy Attribute Certificates (EACs).

TUI’s Scope 3 primary data: 21% of the emissions are calculated using primary data obtained from suppliers and from within businesses own operations. Comprises fuel and energy-related emissions of aircraft, cruise ships and Musement ground transportation vehicles. Comprises fuel and energy-related emissions of fuel burned on site in hotels, retail shops and central functions. Comprises fuel and energy-related emissions from purchased electricity, heating and cooling of hotels, retail outlets and central functions. Comprises waste generated in operations of cruise ships and hotels.

TUI’s Scope 3 secondary data: Comprises waste generated in operations of airlines, franchise hotel emissions and employee commuting. Comprises all spend-based calculations, e.g. purchased goods and services, capital goods, business travel and transportation and distribution.

calculation basis ghg intensity

Total location-based GHG emissions are divided by the net revenue recognised in the annual financial statements. Total market-based GHG emissions are divided by the net revenue recognised in the annual financial statements.

Calculation basis

The type of electricity consumption according to contract type is reported separately via our Group-wide ESG data capture, analysis and reporting system. Green tariffs comprise certified green electricity purchased by hotels, retail shops and central functions. EACs comprise Energy Attribute Certificates purchased by hotels. PPAs comprise hotel power purchase agreements. The disclosure shows the share of the energy purchased with these contractual instruments in relation to the total volume of purchased energy.

Disclosures relating to the external validation of metrics complied for the section Metrics

The metrics disclosed under E1-5 and E1-6 include fuel consumption data for TUI Airline and associated emissions (in tonnes) externally verified with limited assurance by an independent emission inspection body. This applies to the data consolidated in Scope 1 and Scope 3 Category 3 and the consolidated energy consumption data. Further data compiled in this report was not externally verified by inspection bodies other than those conducting the inspection with limited assurance in the framework of the present report.