Consumers and End-Users (S4)

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

The table below provides an overview of the results of our double materiality assessment in relation to material impacts, risks and opportunities (IROs) for issues in connection with consumers and end-users.

Material impacts, risks and opportunities in relation to consumers and end-users (SBM-3)

The focus of our organisation is on our guests and customers with their individual wishes and needs – our ambition is to offer them differentiated and consistent experiences. Our integrated business model enables us to support our customers along the entire customer journey, from the booking and the trip to the destination, the stay in the hotel or on board the cruise ship through to local activities and excursions – both via digital channels and in person. The digital travel experience is complemented by personal support from our employees, which our customers experience in our travel agencies, aircraft and hotels, during tours and experiences, aboard our ships and in the destinations.

Our focus in all operating businesses is on an attractive and safe customer experience. In this regard, the health and safety of our customers plays a key role for us. Due to our integrated business model, we believe these areas create material positive impacts on our customers: effective safety and security management enhances customer satisfaction and may create a competitive edge. TUI is therefore committed to the health, safety and security of customers at all stages of the value chain. This is achieved, for example, by continually monitoring and assessing safety-critical developments in the destinations through regular reviews of accommodation, activities and transport providers as well as specific monitoring protocols for outbreaks of disease. This enables TUI to identify safety risks early on and discuss and initiate response measures with its own tour operators and other business areas involved. In order to secure the quality of the entire customer journey, TUI offers customers multiple digital and physical touchpoints, thereby delivering a strong blend of digital and human interaction.

Impact of the perspective of customers on strategy and business model

As our guests and customers are the focus of our business model, the views, interests and rights of our customers are incorporated when adapting and developing our strategy and TUI Group’s business model in the form of feedback on our product and services portfolio.

By capturing the Net Promoter Score (NPS)¹ across all markets and brands, we continually gauge and evaluate our customers’ satisfaction. In financial year 2024, this indicator was included in the remuneration system for the TUI AG Executive Board as an individual remuneration component for the first time. In financial year 2025, it was again included as a remuneration component for all Executive Board members.

Customer feedback received in delivering services is also taken into account. In health and safety, for instance, we operate a reporting system to record all observed incidents and those reported by customers. These incidents are subsequently examined by the Group Safety & Risk team, resulting where necessary in appropriate measures. When a customer reports a problem following the delivery of a service, this is also forwarded to the Group Safety & Risk team, who examine the incident and initiate further measures as required.

The insights from customer feedback and the reporting systems may provide indications of potential weaknesses, which are taken into account in evaluating Company-specific risks.

The risks determined as material by TUI Group are directly associated with the tourism business model. Our ambition is to make travel safer, in particular by providing package tours that offer customers seamless support. If we fail to meet our own standards, this may potentially result in customer dissatisfaction, reputational damage or litigation costs.

Against this backdrop, it is essential for TUI Group to recognise and respect the individual needs of its customers, regardless of their origin, the circumstances of their lives, or the travel product chosen. TUI Group’s ambition is to guarantee the personal rights, safety and data privacy of all customers, taking into account any individual needs such as the needs of children or persons with limited mobility. The positive impacts of our products and services expressly affect all customers, irrespective of the product or service they purchase and the country where it is purchased.

Customer range

TUI offers tourism and leisure services for different customer groups, in particular solo travellers, couples, families and groups. These customer groups have different needs and expectations, which TUI meets through tailored offerings and services.

This diversity of individual offerings reflects TUI’s ‘Live Happy’ brand promise. It defines an ambition that goes beyond the pure travel experience. TUI’s goal is to support customers’ wellbeing in the long run by means of safe and healthy products and services. Our products and services are not harmful to people and do not increase the risk of chronic disease.

Apart from the physical wellbeing of our customers, we attach great importance to protecting their personal rights and freedoms. Use of our services does not entail the risk of material negative impacts on the right to privacy, the protection of personal data or the right to freedom of expression and non-discrimination. We take care to ensure that we comply with all requirements of the General Data Protection Regulation (EU GDPR).

In the interest of a holistic understanding of responsibility, TUI Group focuses not only on protecting personal data and rights, but also on providing transparent and reliable information to consumers at any time.

Under EU consumer protection law, travel services can be considered services for which consumers need accurate information in order to avoid any potentially harmful use or misguided decisions. TUI Group therefore provides comprehensive information to its customers prior to conclusion of a contract, e.g. a detailed description of the service, visa requirements, health indications or rights in the event of cancellation. Consumer rights also apply while they use the travel services, based on the need to provide timely and accurate information to travellers, e.g. safety instructions on flights or guidance for how to behave in the event of a fire in a hotel. In order to ensure that this service-related information is available to all customers, TUI Group instructs its employees across the Group on how to comply with internal rules and on health, safety and security procedures.

In managing the impacts, TUI also takes account of the needs of particularly vulnerable groups such as children and persons with disabilities. As a rule, TUI Group subsidiaries provide information and advice for these groups on their own websites in order to make their travels easier. Special safety equipment for children and infants is available on board our planes and ships. Specific procedures and support are available for people with disabilities, e.g. when they board transport or wish to select an accessible holiday.

TUI’s comprehensive quality standards aim to deliver consistent operational workflows, ensure our customers’ wellbeing and strengthen their positive holiday experience. The goal is to reinforce people’s trust and enhance customer satisfaction.

For more detailed information, please refer to the section Actions on material impacts on consumers and end-users (S4-4).

The risks we have identified in the framework of our double materiality assessment can potentially arise from all customer groups. However, we believe that the risks are, in particular, associated with customers using services outside TUI’s direct sphere of influence or travelling to regions with issues of relevance to security (countries with weak local and statutory rules and regulations and / or particular risks of terrorism or other Security, Health & Safety risks).

Managing impacts, risks and opportunities

Policies consumers and end-users (S4-1)

human rights policy commitments – monitoring and prevention

TUI Group commits to respecting human rights and ecological standards in all parts of its global value chain. Human rights are inextricably linked with our customers’ health and safety, security and wellbeing: fair working conditions for service providers, strict sanitary standards in accommodation facilities and responsible leisure-time offerings aim to build trust and ensure safety and security during the holiday. Protecting human rights is therefore firmly anchored in TUI’s Human Rights Statement. As a global provider of holiday experiences, it is our responsibility to ensure that our services are delivered in an ethical, sustainable manner based on respect for human rights. In this way, we seek to ensure the quality of our portfolio, strengthen people’s trust in our brand and promote long-term customer relationships.

Since 2014, we have pledged to respect the principles of the UN Global Compact in the fields of human rights, labour standards, environmental protection and anti-corruption. We are mindful of laws and international standards, combat human rights violations and discrimination and champion diversity and inclusion. This applies in our dealings with all our employees and directly impacts our dealings with customers. Accordingly, TUI Group’s policies and guidelines relating to customers reflect the principles of the UN Global Compact.

Responsibility for TUI’s commitment relating to human rights protection lies with different individuals and departments, including, in particular, the Human Rights Officer, Integrity & Compliance, Risk Management, Purchasing and HR. A risk management tool is used to identify potential risks. For more detailed information, please refer to TUI AG’s Report on the German Supply Chain Due Diligence Act (LkSG) for financial year 2024. The Company is not planning to update the report for 2025.

For the Report on the German Supply Chain Due Diligence Act, please refer to https://cdn.sanity.io/files/b6xulh2p/production/e035860eb581e65591778ed0bfcb4c8ab90903d9.pdf

In order to prevent any infringements, TUI Group has launched preventive measures including the Integrity Passport – TUI’s Code of Conduct – and carries out regular training programmes. Potential infringements can be reported via the TUI SpeakUp Line. Remedial measures are taken on a case-by-case basis and are disclosed in the annual LkSG reporting.

Enshrined in TUI’s Human Rights Statement is a commitment to always ensure that we keep the perspectives of potentially affected groups and other relevant stakeholders in mind. TUI engages in constant dialogue with customers via the TUI Speak-up Line and other channels.

For further information, please refer to the chapter Business Conduct (G1)

human rights policy commitments – infringements and consequences

In the framework of the double materiality assessment, no negative impacts of TUI Group’s services on human rights were identified, either in the supply chain, nor in its own business operations or in relation to guests. Should TUI gain knowledge of possible human rights violations associated with TUI or any of its direct and indirect business activities, remedial measures will immediately be taken. In the event of violations in its own business operations, TUI implements direct remedial measures, including the use of defined processes and labour law measures such as warnings and termination. In its supply chain, TUI works with suppliers, uses its influence and contractual measures, and may suspend or terminate business relationships in the event of a lack of cooperation. Processes and monitoring in relation to TUI’s own business operations include appealing to managers to comply with the Integrity Passport and adapt their behaviour accordingly, while a similar approach is taken vis-à-vis indirect suppliers in the supply chain. The measures are reviewed and further developed on a regular basis, at least once a year. TUI also engages in industry initiatives to promote sustainability in the supply chain, such as Futouris e.V. These measures are aimed at quickly dealing with violations in the supply chain and in relation to customers and monitoring the effectiveness of the processes.

In financial year 2025, a total of six incidents of potential human rights violations related to consumers and end-users were reported through the whistleblower system. These cases concerned our own business activities as well as the supply chain. All reported incidents were investigated in accordance with our internal guidelines. Our Human Rights Statement and the Whistleblower System Procedure are publicly accessible.

Management approach related to health and safety

contents

Managing our customers’ health and safety is based on a range of process instructions aligned to the specific characteristics of the business areas. The policies aim to guarantee the health and safety of all customers to the largest possible extent. They are structured to maximise the positive safety-related impacts of TUI’s products and services on customers. At the same time, they are to mitigate the financial risks associated with providing unsafe experiences that might jeopardise the health or safety of our customers. TUI Group’s health and safety management covers both our own business operations and the services provided by business partners and suppliers.

In managing its own business operations, TUI’s ambition is to ensure that all internal processes and customer interactions comply with quality and health and safety standards. Specific guidelines apply to certain segments such as Hotels & Resorts, governing aspects such as balcony rail height, fire prevention protocols, activities for children and safety by the pool or at the beach. In addition, there are guidelines for excursions, including for the safe transportation of passengers to and from excursions and the overall safety of TUI Musement experiences. In Cruises, health and safety aspects relating to our customers are already governed by comprehensive national and international statutory provisions and written agreements with third parties so that no additional internal policies have been introduced. The existing rules cover, for instance, port calls, shore excursions and procedures to deal with incidents and illness. In Airline, there are also strict national and international statutory rules and regulations. In TUI Airline, operational manuals governing various sub-aspects of flight operations guarantee compliance with the strict legal provisions and hence ensure our customers’ health and safety. TUI continually implements monitoring mechanisms such as regular visual and functional tests in order to ensure that the health and safety policies are consistently met by all business areas. This process is complemented by regular checks by Group Safety & Risk Management, carried out to ensure that any new weaknesses are identified and included and that controls remain effective in the long run. This structured risk management approach underpins TUI’s commitment to providing a safe environment for all customers and stakeholders.

TUI’s Supplier Code of Conduct frames the management of business partners and suppliers. It governs the contractual relationships with all suppliers throughout the Group and also sets out minimum health and safety standards and rules for our customers. It ensures that suppliers comply with our requirements. This is especially important as our customers can be in direct contact with many third-party providers on their journey, e.g. hotels or experience providers. In combination, these policies ensure a seamless, safe customer experience.

scope

Management of the health and safety aspects of TUI’s own operations is assigned to the individual business areas in order to take account of the particularities and special requirements of the individual businesses. Some policies, for instance, only apply to hotel operations, excursions, transfers, cruises, or the handling of accidents and illness. Certain areas, e.g. Airline and Cruises, are by now so thoroughly subject to laws and international third-party standards that additional internal health and safety policies are not required. Specific information is provided for special stakeholder groups, e.g. children or people with disabilities, to facilitate accessible travel experiences for these customers. If non-TUI Group airlines are used to carry out flights or excursions, these airlines are examined by the Group Safety & Risk team. Depending on the type and outcome of the pre-operational examination, the checks are repeated at regular intervals ranging from six months to two years. In Airline, a variety of evaluation methods apply.

The Supplier Code of Conduct for TUI Group suppliers universally applies to all contractual partners of the Group. It is used by TUI AG and all companies in which TUI AG directly or indirectly holds a majority stake, whether in Germany or abroad. It also applies to joint ventures and other associated companies, even those over which TUI AG does not have management control, and thus establishes minimum health and safety standards for all business relationships. The Supplier Code of Conduct also obliges direct suppliers of TUI Group to pass on the values and requirements set out in the Code to their sub-contractors and monitor compliance with the requirements by these companies. Our health and safety management system performs risk assessments varying in scope on all suppliers. If a sub-contractor does not comply with the requirements, the reasons must be explained and the supplier has to consider switching to a different sub-contractor.

Overall, these policies ensure a uniform health and safety management approach for the entire value chain covering TUI’s own operations, its suppliers and downstream partners, aiming to ensure the wellbeing of customers and employees.

responsibility

TUI’s centre of excellence Group Security, Health, Safety & Crisis is responsible for defining the safety and hazard management programmes and aims to pursue a uniform, consistent approach within TUI Group. In line with requirements, responsibilities can be delegated on a case-by-case basis. The Group Director SHSC provides regular reports to the GEC or to the Board member in charge of HR. Group SHS is accountable to the stakeholder groups it represents via the Group’s SHS Governance Committee.

External Standards

In addition to the principles of the UN Global Compact in the fields of human rights, labour standards, environmental protection and anti-corruption, TUI has also signed up to the UNWTO’s Global Code of Ethics. Due to a lack of internationally recognised standards for travel and tourism, TUI’s health and safety standards are largely aligned to ABTA’s Tourism Health & Safety Technical Guide. Our cruise brand Marella strictly follows third-party standards, e.g. those of the International Maritime Organization (IMO), the International Convention for the Safety of Life at Sea (SOLAS), the Cruise Lines International Association (CLIA) and the International Safety Management Codes (ISM Codes). These conventions and associations formulate extremely stringent rules for cruise passenger health and safety. In TUI Airline, TUIfly has already received IOSA certification (IATA Operational Safety Audit) in Germany. This voluntary certification is an internationally recognised safety standard in aviation and usually meets higher criteria than statutory safety and quality requirements. At the same time, IOSA offers a uniform organisational framework within which TUI Airline aims to obtain certification for its other regional airlines as well.

Stakeholder interests

In the field of health and safety, customers’ interests are for the most part covered indirectly by local regulatory requirements or the standards defined or applied by TUI. Customers additionally have various communication channels available to inform TUI Group of their needs and interests, so that TUI can take these into account.

Communication

All employees can access the Supplier Code of Conduct and other safety information and instructions via our intranet Smile. For external users, the information is provided to our business partners via our TUI Partners website or attached to the contract documents. Travel and safety information relevant for an activity is provided to our customers during the booking process and during use of a product or service.

Management approach related to personal safety and security

contents

TUI Group implements appropriate guidelines in its various business areas that are tailored to the specific requirements of each area and conform with our Group-wide management approach to customer safety. They govern operations in TUI’s own hotels and resorts, in third-party hotels and during excursions, activities and tours. TUI’s safety management system defines our global safety strategy, the application of our risk-based, data-driven approach and the specific measures to be taken by each TUI business in relation to the products and services offered under the supervision and aegis of TUI Group SHS. Our SHS approach ensures that the focus is placed on the areas of greatest risk with the aim of minimising the likelihood and/or severity of an incident so as to prioritise the safety of customers in the destinations. This focus minimises the financial risks associated with safety-related incidents and plays a key role in making travel safer overall. Through proactive risk management, TUI aims to offer a safe travel experience, reducing the hazards associated with travel for every customer.

TUI’s overall ambition is to set standards in terms of travel safety and enhance safety in the destinations, not just for its own customers but for the entire sector. By taking account of safety aspects in our business operations and partnerships and by implementing risk management practices, we hope to make continual progress towards achieving our target of safer travel for all.

scope

TUI’s risk management programmes for safety and hazard control take account of the local circumstances under which a product or service is offered, external factors such as local laws to be adhered to as minimum standards, and international best practice. Maintaining a uniform global approach, TUI implements additional guidelines and management approaches in order to optimise the management of certain situations. Our approach focuses on key risk areas in connection with accommodation, transport and activities. Depending on the business area at stake, additional policies and management approaches are implemented to manage situations in line with requirements. Our hotel policies focus on maintaining high safety standards in TUI’s own hotels, hotels operated under management contracts or managed under the TUI brand in order to ensure the safety of customers and employees as well as the integrity of our brand. For third-party hotels, TUI implements strategic minimum requirements relating to safety, including risk assessments and quality assurance processes, in order to ensure that the safety standards correspond to those applied in TUI’s own accommodation. Cruises and Airline are governed by strict international rules and regulations, ensuring personal safety and security in implementing transport services.

responsibility

The Executive Board of TUI AG and the Group Executive Committee set the strategic direction and supervise the appropriate handling of personal safety and security in the Group. Group SHS is responsible for TUI’s safety and security risk management. This body ensures safeguards the resources for safety and security risk management and advises the Executive Board in safety and security-related matters. TUI Group Security is in charge of TUI’s security strategy and management. The function is responsible for the development and revision of security manuals, policies and specification, the establishment of minimum security requirements and reviews of the Group’s security practices. It also supports the source markets and destination management in implementing and monitoring compliance with the safety and security risk management framework.

External Standards

When it comes to safety and security information, priority is always given to government travel advice, which serves as a point of reference and basis for all assessments of a given country. The Cruises segment additionally makes substantial use of third-party standards such as those of the International Maritime Organization (IMO), International Convention for the Safety of Life at Sea (SOLAS), Cruises Line International Association (CLIA) and International Safety Management Codes (ISM Codes). All of these conventions and associations have strict rules governing the safety and security of passengers on cruises. In Airline, safe flight operations are ensured by a comprehensive policy based on strict statutory regulations and rules defined by TUI which set the bar higher. Implementing these rules is aimed to guarantee the health, safety and security of passengers.

Stakeholder interests

In the field of health, safety and security, most customers’ interests are covered indirectly by local regulatory requirements or the standards defined or applied by TUI. Customers additionally have various communication channels available to inform TUI Group of their needs and interests, so that TUI can take these into account.

communication

As a leading tourism group strongly committed to quality and safety, TUI regularly reviews all policies and instructions. Internally, the framework is provided to all stakeholders via our intranet Smile and the TUI Security Knowledge Hub, while it is provided externally via our TUI Partners website.

Processes for engaging with consumers and end-users about impacts (S4-2)

Type, frequency and responsibility

TUI Group engages in dialogue with its customers and business partners, governments, authorities and the general public. As part of that process, TUI absorbs external perspectives. These can help in the further development of safety and quality standards.

TUI Group companies use different channels to contact customers and obtain their direct feedback. This dialogue supports customer retention and helps to further improve quality and safety standards. Group Security, Health, Safety & Crisis uses the direct feedback obtained from customers in order to identify potential risk areas. This is part of our strategy of developing a data-driven approach for safety and security risk management. We use our internal data sources Qualtrics and Watchtower as well as external data for our analysis, focusing on our accommodation, destination and product types.

For more detailed information on the feedback channels, please refer to Channels for consumers and end-users to raise concerns (S4-3).

Our customers essentially have the opportunity to reach us quickly at any time. In particular after the booking or during the trip, we are in regular dialogue with customers so as to ensure their continual involvement. After the trip or use of a travel component, at the latest, we ask our customers to provide a review. Customers are free, meanwhile, to limit the frequency of our contacts.

Operational responsibility for dialogue with our customers first and foremost rests with the employees concerned in Airline, Cruises, Hotels & Resorts and Musement. At the top management level, the Executive Board of TUI Group is responsible for incorporating customer perspectives into TUI Group’s business model. This ambition is reflected by using customer satisfaction as expressed in the NPS as a parameter for Board remuneration.

For further details about ESG factors reflected in Board remuneration, please refer to the Remuneration Report.

By using NPS (an indicator of willingness to recommend) and CSAT (Customer Satisfaction Score)², TUI monitors the effectiveness of all customer-related initiatives. The scores for all source markets are provided on a weekly basis.

TUI carries out regular surveys in order to gain a better understanding of the needs and wishes of its customers. The results help to further improve our services, increase customer satisfaction and ensure that all customer groups, including children and people with special needs, are taken into account. The communication channels used for that purpose are described in the section below.

Channels available to consumers and end-users to raise concerns (S4-3)

TUI has various channels in place to enable dialogue with its customers, including the TUI App providing 24/7 support, hotlines, channels on social media platforms, travel agencies and local tour reps in many destinations. TUI therefore is directly available at any time, regardless of whether customers want to change their booking, book an excursion or have personal concerns, e.g. a visit to a doctor at the holiday destination. With its Holiday Experiences sector, TUI maintains a local presence in over 100 destinations worldwide with almost 40,000 employees.

In addition, customers and prospective customers can use the external TUI SpeakUp hotline to raise concerns regarding actual or potential infringements of applicable laws or internal policies. In particular after the booking or during the trip, we are in regular dialogue with customers so as to ensure their continual involvement. After the trip or use of a travel component, we actively ask our customers to provide a review. TUI analyses the feedback from its customers, i.e. feedback from holiday trips and experiences and feedback received via other contact channels such as e-mails, phone calls or social media posts. The most relevant data include the Net Promoter Score, accommodation ratings and comments regarding aspects of relevance to health and safety. The system recognises and screens out key terms such as “theft” or “sexual assault” in order to facilitate a better understanding of the risks associated with our services and manage these risks in a targeted manner.

As TUI is available as universal point of contact for all matters related to a package tour booked by a customer, direct communication channels between customers and sub-contractors or business partners are not required.

For information about the process for following up on and monitoring matters raised via our whistleblower channels, please refer to the section Management approach 2: Whistleblower protection in the chapter Business conduct (G1).

The information about the TUI SpeakUp Line for employees provided in the chapter Business conduct (G1) equally applies to customers. TUI tour reps use special, tailored processes such as “Solve on the spot” in Germany to provide solutions if customers unexpectedly are not happy with their holiday. By immediately reporting their complaint to the TUI Service, customers can meet their obligation to submit a notice of defect and offer TUI the opportunity to quickly remedy the situation. If the situation cannot be remedied, TUI usually offers its customers adequate compensation.

As a general rule, all information channels are openly communicated: from the contact data of a travel agency through to the contact options on our websites, via our TUI App or via our social media presence. These contact options are also explicitly communicated to customers in the booking documents. The active use of these channels reflects the trust our customers place in our services. The associated delivery, e.g. the performance of travel agents in relation to processing the contacts, is continually recorded and monitored.

Actions on material impacts on consumers and end-users (S4-4)

Actions in relation to health and safety

CONTENTS

TUI Group’s ambition is to use its business model to enhance the safety of travel. The goal is to provide its customers with safe holiday experiences and also meet its own high quality standards. TUI Group has implemented a range of actions to maintain and reinforce positive impacts and to mitigate risks.

All employees working in safety-relevant environments take part in regular training programmes on health and safety issues. The goal is to enable them to ensure our customers’ health and safety. The frequency of the training programmes varies, depending on the topic and the underlying legal regulations.

As TUI maintains various touchpoints with its customers in delivering the services it offers, the actions launched by the Company vary to match business activities. The key health and safety-related actions aiming to ensure customers’ wellbeing and ensure consistent processes include:

• Raising employees’ awareness of health and safety: All employees undergo training on health and safety, depending on their role within the organisation. Our employees learn how to handle potential incidents. This ensures a high safety management standard and therefore the wellbeing of TUI customers on their holiday trips and experiences.
• A universal approach to health and safety risk management: TUI pursues a risk-based, data-driven and data sciencebased approach for managing health and safety risks in our entire accommodation, activity and transport portfolio. The approach takes account of the degree of control and influence we exercise over individual providers, based on our contractual relationship and the definition of appropriate and feasible requirements. This ranges from full ownership and control to contractual agreements via third parties. All suppliers are subjected to a risk matrix to establish where the biggest risks are. Targeted assessments are carried out, if and as required, and depending on the overall risk score, additional follow-up actions, training programmes and various other measures varying in scope will be implemented.
• Food safety: TUI carries out various actions to avoid health risks, including the introduction and maintenance of a management system for food safety, such as an HACCP (Hazard Analysis Critical Control Point) plan, appropriate to the range of food and beverages offered. These actions include processes to handle food allergens. All contract businesses working for TUI must provide evidence that they alert customers to potential food allergens. TUI also uses processes to evaluate and track risks, so that concerns about health and safety can be raised and remedied within a given timeframe. If a problem is not resolved, it can be passed on to the TUI Management, and preliminary actions to control the risk can be initiated. These actions aim to effectively contain, minimise or eliminate risks related to food safety in order to enhance customers’ wellbeing during their holidays.
• Fire protection: TUI operates strict measures, including the installation and regular maintenance of fire protection systems, the provision of unimpeded emergency exit routes through protected stairways and the use of self-closing fire protection doors in guest rooms and risk zones. TUI also attaches importance to clearly marked emergency exits and fire instructions as well as a documented emergency plan including fire protection measures, training programmes for employees and evacuation drills. TUI also has processes in place to support people with limited mobility in the event of a fire. All actions aim to minimise the fire risk, prevent the spread of fires and ensure the safe evacuation of all persons in the event of a fire. Similar risk-specific policies and processes are in place for other risk areas, e.g. water management and pool safety.
• Hotel infrastructure, TUI Airlines and Cruises: TUI has a number of Group policies in place that set out actions to prevent accidents, e.g. in TUI’s hotels. These policies comprise regulations, e.g. relating to the height of balcony rails, fire protection and pool areas. In Cruises and Airline, TUI complies with the applicable statutory regulations. TUI makes every effort to address safety matters at an early stage when planning newbuilds or major renovation projects. The goal of the actions is to ensure a safe holiday experience for our customers.
• TUI Musement: TUI Musement offers most transfers and activities in the destinations, partly operated by TUI Musement itself, but for the most part provided by third parties. For TUI’s own vehicles, TUI has established measures to reduce health and safety risks, including the selection of and training of drivers, standards governing drug and alcohol consumption, and the safety of customers on board. TUI has also established an emergency plan and processes for vehicle maintenance in order to protect the health and safety of drivers and passengers. Other providers of TUI Musement activities and transports, usually operating as sub-contractors, are obliged under the Supplier Code of Conduct to anticipate, identify, assess and control risks, including emergency situations and events. They must implement emergency plans and response procedures, which include reporting emergencies, informing employees, carrying out evacuations, providing emergency training and drills for employees, offering appropriate first-aid materials, fire detectors and extinguishers, appropriate escape options and recovery plans.
• Reporting and managing incidents: The reactions to incidents vary, depending on the scope and severity of the incident. Day-to-day incidents are usually handled by the local team on the spot. All customer-related health and safety incidents must be recorded in the Group’s incident reporting system Riskonnect. These incidents are monitored by the Group’s Safety and Risk team, which launches measures, if necessary, ranging from a trend analysis all the way to TUI Annual Report 2025 Management Report 160 comprehensive local investigation with the support of experts. If an incident is reported, immediate escalation is required in the destination, and the source markets is immediately contacted and involved. The service in charge is available 24/7 to inform the required departments. Internal escalation in the source market ensures that the relevant internal departments, including the Communication Department, Health & Safety and the Social Teams, are notified. In the event of damage, customers and their relatives are offered comprehensive support and services, including medical aid, provision of interpreters, an escort for appointments with hospitals and doctors, private transfers and arrangements for customers to stay in their hotel rooms until their departure. In addition, arrangements are made for the onward journey and repatriation of the customers’ personal belongings, and follow-up contact is established in order to offer further support.

SCOPE

The actions are implemented by the individual business areas, taking account of any particularities including the legal framework. TUI’s contract partners are obliged to comply with all applicable national and local laws and regulations and obtain all licences, certificates, approvals and permits required for the accommodation and the services offered.

TIME HORIZON

The Safety Management System and the associated policies and procedures are reviewed at regular intervals with a view to continuous improvement. As we are constantly working to mature our approach to managing health and safety risks, the next steps will be for us to introduce training programmes on topics we have identified as offering the greatest potential for further improvements in the customer experience and customer health and safety.

EFFECTIVENESS

A multi-stage system is in place to continually monitor and assess the effectiveness of the health and safety-related actions outlined above. Key elements of that system are regular visual and function inspections carried out in all relevant business areas. The results of these inspections are systematically documented and evaluated in the Group-wide risk management systems, enabling us to identify trends, recurring weaknesses and potential improvements early on. In addition, all incidents of relevance for health and safety are recorded and analysed in the central reporting system. If any irregularities are noticed, measures ranging from trend analyses to detailed local investigations are promptly launched. The implementation and effectiveness of these measures is regularly reviewed and the measures are modified, if necessary. Effectiveness is also assessed on the basis of indicators such as the number and severity of incidents, the time required to remedy reported defects and the results of customer surveys. The findings are incorporated into a continuous improvement process in order to further develop the health and safety standards and adapt them in the light of new requirements.

This structured process ensures that TUI Group implements actions that are effective in the long term and meet the Group’s high quality and safety standards.

OUR ASPIRATION

Our ambition in implementing the actions outlined above is to ensure that TUI Group’s business operations do not have any negative impacts on customers and that the positive impacts are maintained and reinforced.

In financial year 2025, there were no material problems or incidents in connection with the human rights of our customers.

The means and resources required to implement the above actions are included in the budgets of the relevant business areas and departments. For larger investments, an investment budget is established as part of the financial planning process.

Actions related to personal security

CONTENTS

TUI Group has implemented various actions to promote safe travel. The goal of its process for handling environmental and country-specific risks is to ensure safe travel for TUI customers and offer them security throughout their journey.

• Determining risks: Risk management serves to identify, assess and document predictable risks
• Determining actions to reinforce security: Based on the risk assessment, actions are implemented in accordance with needs.
• Developing emergency plans: Emergency plans offering protection form safety hazards are developed and have to be complied with in all sites.
• Information and consent: In the event of risks existing prior to departure, customers have to be informed about the risks and must grant their consent.
• Raising awareness: Training programmes on current risks and safety instructions are carried out for employees and contract partners.
• Offering appropriate support: TUI provides support and insurances to support employees and customers in the event of an incident. TUI Group Security works for the source markets, TUI Hotels & Resorts and TUI Musement, setting Group-wide safety standards to ensure that TUI minimises all potential safety risks in all destinations and has initiated appropriate response strategies and control measures. The measures are controlled by Group Security at Group level.

There is no systematic tracking and assessing of these actions, as their preventive nature, external factors such as dynamic environmental and country risks, and subjective perceptions of security prevent any clear measurement of their effectiveness.

SCOPE

Group Security, Health, Safety & Crisis monitors the actions for TUI Group overall. Operational implementation and the scope of the actions taken are determined on a case-by-case basis for the individual regions. The scope of the key measures excludes accommodation providers that have to be used in an emergency situation, e.g. in the event of flight diversions or delays, as providers outside of the existing portfolio may have to be called upon in that type of scenario.

TIME HORIZON

The above actions are implemented continually and are not subject to a specific time horizon.

Targets related to managing material negative impacts, advancing positive impacts and managing material risks and opportunities (S4-5)

TUI does not have any fixed targets related to our customers’ health and safety, as our fundamental goal is to protect our customers’ health and safety as far as reasonably possible. The risks to which our customers and the Group are exposed are monitored, with priority given to the areas of highest risk. We constantly strive to offer our customers experiences that are as safe as possible, without defining any detailed targets. If any incidents occur, reports are submitted in accordance with the process outlined above and appropriate measures are taken.

NPS as an indicator of our customers’ willingness to recommend is above all an indicator for the perceived quality of our products and services. It is used as a qualitative indicator to assess the effectiveness of our safety measures. Compliance with our safety concepts and measures is a necessary but insufficient condition for achieving a high NPS score. NPS is therefore not regarded as a target within the meaning of ESRS S4.