Adler Group

Sustainability Report, section 'The role of the administrative, management and supervisory bodies' (p.47) and Corporate Governance Report (pp.25-26). Adler Group S.A. is a Luxembourg company with a one-tier Board of Directors of six members, two executive (CEO and CFO) and four independent, supported by Senior Management (CEO, CFO, CLO, COO). The report names all Board members and their backgrounds and describes Board committees (Audit; Nomination and Compensation; Ad Hoc). The entire Board is responsible for sustainability management and its results, and sustainability is regularly discussed at Board meetings. A dedicated sustainability organisation is headed by the Chief Legal Officer (CLO) together with a Sustainability Board drawing on all relevant departments. The report states that significant diversity exists among employees and management and that diversity is embedded in publicly available guidelines, though it does not give quantified board diversity ratios.

Sustainability Report, section 'The role of the administrative, management and supervisory bodies' (p.47). The report states that the members of the Board of Directors receive timely, regular and comprehensive information from the CLO and the Sustainability Board on current developments in the Company's sustainability performance, the progress of sustainability-related activities and the need to set new targets or develop new strategies. Sustainability is described as a regular agenda item at Board meetings, and the entire Board is responsible for sustainability management and its results. The Corporate Governance Report adds that the Board and Senior Management are regularly informed about data protection and cyber security matters and receive regular and ad-hoc risk reports. This addresses how sustainability matters are brought to and considered by the governance bodies, though it does not tabulate specific matters addressed during the year.

Sustainability Report, section 'The role of the administrative, management and supervisory bodies' (p.47). Adler Group discloses that it has an incentive system which provides the option of including sustainability-related targets through bonus payments. This option is only used for members of senior management whose responsibilities relate to the corresponding sustainability topics. The Corporate Governance Report also references a Remuneration Policy for the Board of Directors and Senior Management, and notes that the Nomination and Compensation Committee advises on benefit and incentive schemes and assists with the remuneration report. The linkage between sustainability performance and remuneration is therefore acknowledged but described as optional and limited in scope, without disclosure of specific metrics, weightings or amounts tied to sustainability outcomes.

EU Taxonomy minimum safeguards section (pp.18-19) and Sustainability Report (p.46). Adler Group states it is guided by the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, including the OECD Due Diligence Guidance for Responsible Business Conduct, and that the German Supply Chain Due Diligence Act (LkSG, section 2(2)) applies. It reports that it has stipulated policies and set up processes to identify, prevent, mitigate and resolve actual and potential negative effects on human rights and labour-law matters, that these processes allow immediate measures and indemnification of affected persons, and that their effectiveness is regularly reviewed in internal audits. Human rights aspects are incorporated into supplier contracts. The narrative covers due diligence but is not presented as a structured GOV-4 mapping table pointing to where core due diligence elements appear in the statement.

Sustainability Report, section 'Risk management and internal controls for sustainability reporting' (p.46), with cross-references to the Corporate Governance Report and the Opportunities and Risk Report. Adler Group maintains a Company-wide risk management system (RMS) that also covers sustainability risks. These risks have been revised and adapted in view of the CSRD, and a sustainability risk management system (SRMS) is fully integrated into the Company's RMS. The Company describes integrated risk management (IRM) as an essential component of business management and internal control, with the Board periodically discussing operational and financial results and associated risks. Compliance and internal audit processes and regular and ad-hoc risk reporting to Senior Management and the Board are described. Detailed information is directed to the Opportunities and Risk Report, so the specific controls over the sustainability reporting process itself are summarised rather than detailed.

Sustainability Report, section 'Strategy, business model and value chain' (pp.47-48). Adler Group specialises in managing multi-family residential properties, owning and managing 17,929 rental units at the end of the reporting period, almost all located in Berlin, with the majority in the affordable housing segment. It also holds development projects in large German cities intended for sale. The business model is to offer tenants high-quality yet affordable living space while operating profitably and meeting sustainability requirements. The strategy includes improving the energy intensity of the portfolio and reducing greenhouse gas intensity, drawing on extensive renovation and refurbishment experience. The report describes the value chain as upstream (purchase of goods and services, mainly maintenance, energy and building materials in Germany), own activities, and downstream (tenant-related services and waste management), noting numerous suppliers and therefore no significant procurement dependencies.

Sustainability Report, section 'Stakeholders' interests and positions' (p.48). Adler Group maintains frequent, regular or event-driven dialogue with key stakeholder groups to inform them and to obtain suggestions for improving services and business processes. Tenants, employees and financial market participants were involved in the materiality analysis. The report describes channels by stakeholder group: employees via annual employee surveys and appraisals; tenants via telephone hotline, on-site caretakers and local tenant offices; cities and municipalities via dialogue on property development and energy supply; the financial and capital market via webcasts, roadshows, conferences and investor meetings; and industry associations such as ZIA and EPRA. It states that this continuous dialogue gives Adler Group a good understanding of stakeholder interests and views, which are taken into account in corporate decision-making, though it does not describe how views were reported back to the Board.

Sustainability Report, section 'Significant impacts, risks, opportunities and business model' (pp.48-49). Adler Group identifies material aspects across the ESRS topics, with most impacts arising from its own business activities. Material areas described include energy requirements (large fossil-fuel consumption, especially by tenants downstream, with competitiveness depending on energy efficiency), climate change (GHG emissions from heating, fleet and building materials, and rising CO2 levies expected from 2027), own employees (high workforce fluctuation from portfolio downsizing and discontinuation of the development business), tenants as customers and end users, and corporate governance and business conduct. The report emphasises that these impacts and risks result from typical industry conditions and general corporate behaviour rather than Adler Group's specific business model, objectives or strategy, and that no sustainability risk was assessed as threatening the Company's existence.

Sustainability Report, section 'Process for identifying and assessing significant impacts, risks and opportunities' (pp.48-50). Adler Group used a double materiality assessment to identify key sustainability aspects from both impact and financial perspectives, in line with EU regulations. Impacts are assessed by their positive or negative and actual or potential nature, extent, scope and irreversibility, with severity multiplied by probability of occurrence to determine significance; financial materiality reflects the ability to use or obtain necessary resources and relationships on acceptable terms. The value chain is divided into upstream, own activities and downstream, with topics screened via a long list and short list. Criteria draw on prior materiality analyses, peer benchmarks, industry associations (EPRA), capital market requirements (ESG and credit ratings), other standards (GRI, SASB), ISO 14001 environmental analysis, LkSG supply-chain risk analysis and stakeholder input. Defined roles span Sustainability/CSR, Compliance/Risk, EHS, Energy, Portfolio, Facility Management, Purchasing, IT, HR and Finance.

Sustainability Report, General Disclosures / basis of preparation (p.46) and 'Results of the materiality test' table (p.51). The report states it is prepared in accordance with the CSRD in anticipation of the ESRS reporting obligation expected from 2025, with references to the standards made in brackets where applicable. It presents a materiality-test table listing each ESRS topical standard (E1-E5, S1-S4, G1) with the sub-topics assessed and whether each was rated material or not material, and notes that ESRS E4 (biodiversity) and ESRS S3 (affected communities) were not material so are not reported. Adler Group also states it has not identified any impacts, risks or opportunities not covered by the ESRS and mandatory disclosures. This functions as the coverage overview, but the report does not provide a detailed datapoint-level content index mapping each individual disclosure requirement to a page.

Sustainability Report, Climate Protection (ESRS E1), pp. 52-53. Adler Group does not present a formal Paris-aligned transition plan for climate change mitigation. It states that because it has not identified acute or chronic physical risks to its assets even under severe climate change, no adjustments to the business model were made. For the downstream value chain it references an intention to halve GHG emissions by 2030 (based on 2020 values), in line with EU targets, but explains that these plans will be reassessed in 2025 with a corresponding analysis to identify optimisation and reduction potential for the remaining portfolio of 17,929 units. A budget for initial measures is planned and the plan is intended to set short, medium and long-term interim targets, but no completed transition plan yet exists for its own operations.

Sustainability Report, pp. 52-53. Adler Group describes its climate concepts and policies. It states that because it identified only low direct and moderate indirect climate impact on its business model, operations and assets, no regulatory measures were initiated and no adjustments to the business model were required. The Company is certified to DIN ISO 50001 (energy management) and endeavours to continuously reduce GHG emissions by cutting energy consumption and increasing the use of renewable energy. It intends to reduce greenhouse gas releases in operations by using more non-fossil energy sources and replacing plant and machinery with more energy-efficient variants, both reflected in financial planning. However, it explicitly states no specific quantitative reduction targets or dates have been set for its own operations.

Sustainability Report, pp. 52-53. Adler Group lists concrete actions to reduce emissions. In the upstream value chain it installs photovoltaic systems or heat pumps where technically feasible and economically viable, increases use of district heating, replaces old heating systems with modern more efficient ones, and promotes local public transport among commuting employees to reduce Scope 3 emissions. It expects installing new heating technology in properties to be the most effective measure. It notes that portfolio restructuring and reorganisation over the past two years meant planned downstream energy-efficiency measures were not implemented; all energy-efficiency and emissions projects will be reassessed in 2025 for medium-term implementation up to 2030, with a budget already planned for initial measures. Financial resources for modernisation will be made available depending on 2025 business development.

Sustainability Report, p. 53. Adler Group states it aims to continuously reduce energy requirements and GHG emissions but has not formulated any specific quantitative targets for its own business operations. The only quantified target relates to the downstream value chain, where GHG emissions are to be halved by 2030 based on 2020 values, in line with EU targets, though this plan will be reassessed in 2025. Heating energy consumption fell to 102.2 kWh/a/m2 in 2024 (from 129.9 in 2023) and GHG emissions to 0.029 tCO2/a/m2, but these are reported as parameters rather than against formal targets. No interim milestones or base-year-anchored reduction pathway for own operations are disclosed.

Sustainability Report p. 53 and Environmental Performance Measures, pp. 291-293. Energy intensity was 102.2 kWh/a/m2 in 2024 (heating energy consumption), with electricity consumption of 4.8 kWh/a/m2. In the EPRA table, total building energy intensity was 193.7 kWh/m2 (electricity 4.8, district heating and cooling 102.2, fuels 87.8). Absolute figures include total electricity consumption of 8,170 kWh, total district heating and cooling of 173,201 kWh, and total fuel consumption of 148,706 kWh (tenants and landlord combined), split into natural gas and heating oil. The Company is certified to DIN ISO 50001. It notes a new data-collection tool revealed that parts of the portfolio had accidentally been omitted in prior years, understating energy consumption, but prior-year figures were not recalculated.

Environmental Performance Measures, p. 293, and Sustainability Report p. 53. Total direct (Scope 1) GHG emissions were 37,047 tonnes CO2 in 2024 (from natural gas 31,036 t, heating oil 5,366 t, and cars/machinery 592 t), up 0.9 percent on 2023. Total indirect (Scope 2) GHG emissions were 11,958 tonnes CO2 (electricity 507 t, district heating and cooling 11,451 t), down 2.7 percent. GHG intensity was 0.029 tonnes CO2/m2 and 1.955 tonnes CO2 per residential unit. Adler Group explicitly states it has not yet collected or calculated any Scope 3 emissions due to the complexity of doing so. It also notes prior-year emissions were understated because parts of the portfolio were accidentally omitted, and these were not recalculated.

Sustainability Report, p. 53. Adler Group explicitly states that it has not acquired any certificates to offset existing GHG emissions. No GHG removals in its own operations or value chain, and no purchase of carbon credits or offsets, are disclosed. This DR is therefore addressed only by an explicit negative statement of none.

Sustainability Report, p. 53. Adler Group explicitly states that it does not use an internal CO2 pricing system. The DR is addressed by a clear negative statement, so no internal carbon price, scope of application, or influence on decision-making is applied.

Sustainability Report, p. 52. Adler Group discusses transition risks qualitatively. It states it could not identify acute or chronic physical risks to its real estate assets even under severe climate change. However, it flags that climate change could significantly affect the Company through increasing CO2 levies, rising energy prices, and political climate-protection decisions. As long as fossil energy is used in operations or by tenants downstream, Adler is liable for part of the associated GHG levies, which are currently set politically but will be market-determined from 2026, creating a potentially significant risk to earnings and, absent measures, to asset values. No quantified monetary estimate of these anticipated financial effects is provided.

Sustainability Report, Pollution (ESRS E2), p. 54. Adler Group states its double materiality analysis found pollution impacts, risks and opportunities were not material in any scenario, for its own operations and up- and downstream value chain. It complies with government environmental regulations at all property locations, thereby avoiding negative environmental effects. Given these high standards it deliberately refrained from developing further concepts for managing pollution-related impacts, and likewise for incident and emergency prevention given the extremely low probability of such scenarios. Because building materials procured for maintenance and refurbishment could theoretically cause pollution during production, but only indications exist, the Company decided not to develop a dedicated pollution-prevention concept. It therefore reports having no dedicated pollution policy, with substance.

Sustainability Report, p. 54. Adler Group states that in view of the very low pollution load from its own operations and from the downstream and upstream value chain, it has not formulated any specific targets or measures related to environmental pollution. It notes it provides all necessary human and financial resources to meet legal and internal requirements on environmental pollution, and that it has operated at a high level of pollution prevention for many years, leaving only marginal room for further improvement. No dedicated pollution-reduction action programme is disclosed beyond regulatory compliance.

Sustainability Report, p. 54. Adler Group explicitly states that in view of the very low pollution load from its own business operations and from the downstream and upstream value chain, it has not formulated any specific targets or measures related to environmental pollution. No quantitative pollution-reduction targets are set.

Sustainability Report, p. 54. Adler Group states that due to the nature of its activities it has not caused significant pollution of air, water resources or soil, whether within or outside legal limits, and that any pollutants released were below detectable levels. It reports no production or use of microplastics and no use of substances of concern or substances of very high concern in providing services. Pollution is generally possible in the upstream value chain but the Company has no indications of any suspected cases, and there are no indications of negative effects in the downstream value chain from tenant behaviour. No quantitative pollutant emission figures are disclosed.

Sustainability Report, p. 54. Adler Group explicitly states that substances of concern and substances of very high concern were not used in the provision of its services, and that microplastics were neither produced nor used. The topic is addressed with an explicit negative statement rather than quantitative volumes.

Sustainability Report, p. 54. Adler Group states that its analysis of developments in the environment with an impact on the Company's finances and the associated pollution-related risks and opportunities identified none. This is a qualitative statement that no material anticipated financial effects from pollution could be identified; no monetary figures are provided.

Sustainability Report, Water and marine resources (ESRS E3), p. 55. Adler Group states that due to a lack of relevance there are no special control mechanisms and no dedicated water policy. Nevertheless, for business reasons it makes careful use of water, documented by its ISO 50001 certificate, and in the downstream value chain uses flow-limiting sanitary facilities in its flats to counteract excessive consumption of fresh water. It complies with all legal water-management requirements, particularly regarding installed sanitary facilities, across its portfolio without restriction. It reports having no dedicated water policy, with substantive explanation.

Sustainability Report, p. 55. Adler Group describes limited water-related actions despite a lack of materiality: it installs flow-limiting sanitary facilities in its flats in the downstream value chain to counteract excessive fresh-water consumption, and complies with all legal water-management requirements regarding installed sanitary facilities across its property portfolio. Its careful use of water is documented by the ISO 50001 certificate. No further dedicated water action programme is described.

Sustainability Report, p. 55. Adler Group explicitly states that beyond compliance with all legal water-management requirements, no individual water targets were set, in its own operations due to a lack of relevance and in the downstream value chain for reasons of limited controllability. No quantitative water targets are disclosed.

Sustainability Report p. 55, and Environmental Performance Measures, p. 293. Water intensity of buildings (tenants) was 3.5 m3/a/m2 in 2024 (from 3.6 in 2023). Total water consumption by tenants (withdrawal from the water mains) was 5,043,644 m3/year, with like-for-like total water consumption of 3,327,649 m3. Adler draws the fresh water required to provide services and supply tenants exclusively from the public mains at property locations, and states there is no water shortage at any of these locations and that properties are not in areas of high water stress. In the downstream value chain tenants determine water volumes used autonomously.

Sustainability Report, p. 55. Adler Group states that its analysis of water demand on the environment and on the Company's finances did not reveal any significant impacts in the freshwater sector, and no impact at all on marine waters and marine resources. This qualitatively addresses anticipated financial effects by stating none were identified; no monetary figures are provided.

Sustainability Report, Resource utilisation and circular economy (ESRS E5), pp. 55-56. Adler Group reviewed its entire operations and the up- and downstream value chain, with stakeholder involvement, to determine environmental and financial impacts of its resource/material procurement and waste practices. As it exclusively provides services, materials and goods are purchased in negligible quantities and office and other equipment is recycled properly when no longer useful. When selecting materials for renovation and refurbishment of properties (which typically have an 80-year lifespan) it considers durability and good recyclability alongside quality and price. Its only relevant resource use is heating oil and natural gas for tenant heating. No dedicated circular-economy policy is described beyond these embedded practices.

Sustainability Report, pp. 55-56. Adler Group describes resource and waste actions. When selecting materials and goods for renovation and refurbishment it pays attention to durability and good recyclability, and it ensures office and other equipment is recycled properly at end of life. It sees the main opportunity in improving the energy efficiency of heating systems and buildings over coming years. On waste, its own operations generate comparatively small quantities while significant volumes arise from tenant consumption behaviour that the Company can hardly influence; it encourages tenants to minimise and separate waste for recycling by providing advice and information.

Sustainability Report, pp. 55-56, and Environmental Performance Measures. Adler Group states it exclusively provides services and purchases materials and goods in negligible quantities, so its only relevant resource inflow is the purchase of heating oil and natural gas to provide heating energy to tenants. Associated fuel consumption is reported in the Environmental Performance Measures table (total fuel consumption 148,706 kWh, split into natural gas and heating oil). No tonnage of materials or share of recycled/biological inflows is quantified beyond these energy-carrier figures.

Sustainability Report, p. 56, and Environmental Performance Measures, p. 293. Adler Group notes that materials used for renovation and refurbishment are selected for durability and good recyclability and that office equipment is recycled at end of life, but it produces no products. On waste outflows, the recycling rate was 40.9 percent in 2024 (from 41.2 percent in 2023). Recyclable material totalled 27,396 m3 (glass 2,988, paper 59,577, organic waste 8,672) and residual waste was 142,614 m3. The Company does not quantify product or material outflow tonnages beyond these tenant-generated waste figures, as it is a service provider rather than a manufacturer.

Sustainability Report p. 56, and Environmental Performance Measures, p. 293. The total volume of waste was 241,246 m3/a in 2024, up 1.5 percent from 237,681 m3/a in 2023, with like-for-like volume of 156,810 m3. The recycling rate was 40.9 percent. Composition included residual waste 142,614 m3, paper 59,577 m3, recyclable material 27,396 m3, organic waste 8,672 m3 and glass 2,988 m3. Adler Group notes that its own operations generate comparatively small quantities of waste, while significant volumes are generated by tenant consumption behaviour it can hardly influence; it encourages tenants to minimise and separate waste for recycling through advice and information.

Sustainability Report, Own workforce (ESRS S1, pp. 56-61) plus Minimum safeguards (pp. 15-16). Adler Group states it complies without exception with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises, with no violations identified to date. It is a signatory to the UN Global Compact and the German Diversity Charter (signed 2006). Written, publicly accessible guidelines cover human rights, freedom of assembly, non-discrimination and diversity, anti-corruption, data protection and equal pay for men and women. Diversity principles are codified and published on the company website. Health and safety is managed by a dedicated HSE department. Policies apply to all employees Group-wide with no differentiation by employee group.

Sustainability Report, Own workforce (pp. 56-58). Adler Group conducts an annual employee survey as its most important channel for determining employee wishes and satisfaction and for reporting negative impacts. All employees are involved individually in relevant processes as part of the duty of care; the manager responsible for personnel oversees involvement and monitors the effectiveness of personnel-policy measures. Engagement formats include fireside chats at major locations, divisional events, virtual town halls, internal communication channels and at-least-annual digitalised employee appraisals. Key 2024 communication topics were the recapitalisation, portfolio adjustments, job security and management changes.

Sustainability Report, Employee feedback (p. 58). Employees can report negative impacts through various channels to achieve prompt remedial action, the most important being the yearly employee survey. Misbehaviour may be reported anonymously through the whistleblower system, which is available to the company's own employees as well as to suppliers in the upstream value chain. Minimum-safeguards processes (p. 16) ensure that in the case of any acute human rights violation immediate measures can be taken and affected persons indemnified, with effectiveness reviewed during internal audits.

Sustainability Report, Own workforce (pp. 56-61). Actions to address material impacts and strengthen the company as an employer include performance-related market-standard remuneration, numerous monetary and non-monetary benefits, high transparency in personnel policy, regular employee-manager exchange, expansion of internal training programmes and further strengthening of diversity. In 2024 the HR department completed a risk assessment of all employees for mental workplace stress, offered health-food information, yoga courses and body-function checks, and carried out workplace risk assessments with individual improvement measures. Adler Group commits to socially responsible separations when discontinuing business, including ensuring portfolio-management employees are taken on by buyers in portfolio disposals.

Sustainability Report, Own workforce (pp. 57-58). Adler Group has set the goal of offering all employees the most pleasant working environment possible, on the understanding that satisfied employees are more committed and productive. HR objectives for the reporting year focused on performance-related market-standard remuneration, additional benefits, transparency, regular information exchange, expanding and maintaining training opportunities and further strengthening diversity. However, the company explicitly states it has not defined any targets for gender proportions in management, and other objectives are described qualitatively rather than as measurable, time-bound quantitative targets.

Sustainability Report, Characteristics of employees (p. 57). Headcount fell from 597 at 31 December 2023 to 500 at 31 December 2024, with 82 additions and 168 disposals in 2024. Of the 500 employees, 264 were male and 236 female; 421 were full-time and 79 part-time. Full-time equivalents totalled 477 at year end, with an annual average of 511 FTE. Adler Group employs only salaried employees, almost exclusively on permanent contracts. The appendix Social Performance Measures table shows a 2024 turnover of 168 departures (31.0 percent rate) against 82 new hires (15.0 percent rate).

Sustainability Report, Characteristics of employees and Remuneration (pp. 57, 61). Adler Group discloses that employee remuneration is not based on a specific collective labour agreement; instead pay is set by reference to salaries paid in the industry for comparable jobs, and salary structures are reviewed once or twice a year against market levels and the collective agreement for the property industry. The report does not state a percentage of employees covered by collective bargaining agreements or provide a formal social-dialogue coverage figure, so the quantitative coverage metric is effectively absent even though the topic is addressed narratively.

Sustainability Report, Diversity table (p. 59) and Diversity narrative (p. 60). Group-wide gender distribution in 2024 was 52.8 percent men and 47.2 percent women (2023: 53.4/46.6). Age distribution: under 30 years 10.0 percent, 30-39 years 24.6 percent, 40-49 years 26.6 percent, 50-59 years 24.2 percent, over 59 years 14.6 percent. There were no women in Senior Management in 2024, and the share of women among executives (levels C-1 to C-3) was 25 percent. The appendix Social Performance Measures table shows management gender diversity of 4 men and 0 women, and executives of 26 men and 5 women in 2024. Employees represent 31 different nationalities.

Sustainability Report, Remuneration (p. 60). Adler Group states it pays hourly rates above the minimum in most cases, with grading depending on position and level of training and in line with the market. Remuneration comprises basic salary, capital-forming benefits, travel allowance, function and hardship allowances and a performance-related bonus where applicable. According to the employee survey, pay is considered by employees to be in line with the market. The report does not benchmark wages against a formally defined adequate or living-wage floor, but confirms payment above statutory minimum levels.

Sustainability Report, Diversity/social protection narrative (p. 60). All employment contracts of Adler Group are subject to social insurance contributions, so all employees are protected against loss of income due to illness through social security, public programmes or benefits offered. The company also operates a company pension scheme with a 15 percent allowance on amounts saved by employees. Coverage against other risks such as unemployment, parental leave and old age is implied through the German statutory social-security system, though the report does not enumerate each protection category separately.

Sustainability Report, Diversity (pp. 58-59). Adler Group promotes inclusion by implementing all relevant specific regulations and addressing individual needs. The proportion of employees with disabilities in the workforce, subject to legal restrictions on data collection, was 4.0 percent in 2024 (2023: 5.2 percent; 2022: 4.7 percent), as shown in the Diversity in the workplace table.

Sustainability Report, Continuing education and skills development (p. 60) and appendix Social Performance Measures (p. 295). In 2024, 504 employees took part in training programmes, spending a total of 10,024 hours, an average of nearly 21 training hours per employee (20.96 hours). Topics ranged from MS Office, IT, compliance, project management and legal specifics to foreign languages and sustainability, plus mandatory courses on occupational safety, equal treatment, IT security, data protection and anti-corruption. All employees participated in performance and career development reviews in 2024; of training participants 49 percent were female and 51 percent male. The appendix reports average training hours of 20.1 (2023: 23.3) and 22.2 percent of employees receiving performance appraisals.

Sustainability Report, Health and safety (p. 58) and appendix Social Performance Measures (p. 295). In 2024 there were 0.8 work or commuting accidents per 100,000 working hours (2023: 1.3). There were no fatalities in 2024 (2023: 0). Seven percent of all working days were lost due to illness in 2024 (absentee rate 7.0 percent, up from 6.0 percent in 2023). The appendix reports lost working days of 14.5 per 100,000 working hours in 2024 (2023: 58.1). Health and safety is managed by the HSE department, which conducts workplace risk assessments, arranges regular medical check-ups and, in 2024, assessed all employees for mental workplace stress.

Sustainability Report, Reconciliation of work and private life (p. 61). In 2024 a total of 66 employees (13 percent of year-end employees) took leave for family reasons; of these 58 percent were female and 42 percent male. The proportion of parents in the workforce (employees with at least one child) was 55.0 percent in 2024 (2023: 50.6 percent). Work-life measures include flexible weekly working hours, the option to work four tenths of hours at chosen locations, various part-time concepts to ease reintegration after parental leave, mobile working two days a week, working-time accounts, sabbaticals and workation, and 30 days of holiday for full-time employees.

Sustainability Report, Remuneration indicators (p. 61) and appendix Social Performance Measures (p. 295). Adler Group pursues equal pay for equal tasks, with a set salary for new vacancies regardless of gender. Female-to-male average salary ratios by level in 2024: C-1 100 percent (equal), C-2 74 percent, C-3 104 percent, and total workforce excluding managers 99 percent (2023 total: 97 percent). The appendix restates second management level 100, third management level 74 and total 99. The report does not disclose a single overall gender pay gap percentage or a CEO-to-median-employee pay ratio, so those specific ESRS metrics are not provided.

Sustainability Report, Diversity (p. 59) and appendix (p. 296). In 2024 no incidents of discrimination, including harassment, were reported to the company. Adler Group states it complies without exception with the UN Guiding Principles on Business and Human Rights, ILO and OECD standards, and that to date no violations have been identified. The appendix reports 0 health and safety compliance incidents (indicator 416-2) in 2024, consistent with 2023. No severe human rights incidents, complaints filed through mechanisms, fines or sanctions relating to the own workforce are reported for the period.

Sustainability Report, Labour in the value chain (ESRS S2, p. 62). Adler Group states it is guided by international standards including the UN Guiding Principles on Business and Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work with regard to the value chain, and that these standards form an integral part of the Company's human rights policy. Requirements on value chain workers are anchored in the General Terms and Conditions and the Business Partner Code. The EU Taxonomy minimum safeguards section (p. 18-19) adds that the Group has stipulated policies and processes to identify, prevent, mitigate and resolve negative effects on labour-law matters, that these policies are publicly accessible on the website, and that human rights aspects are incorporated into supplier contracts. Because the vast majority of goods and services are purchased in Germany under the LkSG, the Group has not formulated a dedicated value-chain-worker strategy.

Sustainability Report, Labour in the value chain (ESRS S2, p. 62). Adler Group attempts to understand the legitimate interests, viewpoints and rights of workers in the value chain as far as possible and with reasonable effort. It describes this as both active engagement, by analysing accessible information and holding discussions and information exchanges with companies in the value chain, and passive engagement, by providing value chain workers with a whistleblower system through which they can express their interests, viewpoints and criticism to the Company. The disclosure does not specify frequency, worker representatives involved, or how the Group assesses the effectiveness of this engagement.

Sustainability Report, Labour in the value chain (ESRS S2, p. 62). Adler Group has established a whistleblower system that is also accessible to workers in the value chain so they can report material impacts. Where there are justified indications of impairment or violation of workers' interests or rights, the Group states it will follow up and endeavour to remedy the situation, which under the German Supply Chain Due Diligence Act (LkSG) could extend to terminating business relationships. The Group reports it is not aware of any serious human rights problems or incidents in the upstream value chain, so no measures had to be taken.

Sustainability Report, Labour in the value chain (ESRS S2, p. 62). Adler Group states its purchasing and sales conditions are not designed to have or accept negative effects on value chain labour. Risks are limited through corresponding requirements in the General Terms and Conditions and the Business Partner Code, together with a systematic complaints procedure via the whistleblower system. The Group reports it is not aware of any cases of labour, human rights or environmental violations and could not identify specific groups at increased risk. As no serious incidents were identified, no remedial actions were required.

Sustainability Report, Consumers and end users (ESRS S4, p. 62-63). Tenants are Adler Group's direct customers and end-users. The Group gives tenants the opportunity to raise individual concerns in person, by telephone or in writing, and has developed concepts and solutions for recurring issues such as property management, technical defects and safety, contractual matters, operating costs, lettings, relocations and data protection, offered to all tenants on the same terms. Approaches to avoid or reduce negative effects include environmentally friendly production processes, supplier audits, diversification of supply chains, honest and clear communication to avoid misleading information, strict data protection guidelines, and transparency in data processing. The Group states it does not offer services harmful to customers and does not expect negative effects for financially vulnerable groups.

Sustainability Report, Consumers and end users (ESRS S4, p. 62-63). Adler Group states it engages in regular and systematic dialogue with tenants as its main customers and important stakeholders, in order to receive suggestions on service quality, tenant support and administration and feed these into improving the business model. All requests, suggestions and criticisms received are, in justified cases, taken into account in the provision of services, and tenants' views are given high priority in planning and decision-making. Senior management is responsible for tenant communication, while the heads of the respective departments handle day-to-day dialogues. The disclosure does not quantify engagement frequency or describe how its effectiveness is assessed.

Sustainability Report, Consumers and end users (ESRS S4, p. 62-63). Adler Group provides tenants channels to raise concerns in person, by telephone or in writing, covering issues such as technical defects, safety, contractual matters and data protection. It states that all requests, suggestions and criticisms received are, in justified or justifiable cases, taken into account, and that it generally endeavours to avoid negative effects on tenants, to eliminate them if they occur, or at least reduce them as far as possible. The description is qualitative and does not detail a structured grievance mechanism, track volumes of complaints, or assess channel effectiveness.

Sustainability Report, Consumers and end users (ESRS S4, p. 62-63). Adler Group identifies tenant health and safety and access to adequate information on using rental properties as key aspects. To manage these it prioritises reliable service provision through regular plant maintenance, inspections, risk assessments and employee trainings. Further approaches to avoid or reduce negative effects on tenants include environmentally friendly production processes, supplier audits, supply chain diversification, honest and clear communication, strict data protection guidelines and transparency in data processing. Customers are said to receive all necessary and comprehensive information to ensure proper use of flats. The Group states possible impacts affect all end-users equally and no specific vulnerable groups could be identified.

Sustainability Report, Consumers and end users, Objectives (ESRS S4, p. 63). Adler Group measures tenant satisfaction using the tenant turnover rate, on the reasoning that satisfied tenants have little reason to move out while dissatisfied tenants do. However, the Company explicitly states that its objective is not to set a specific target, but rather to maintain the turnover rate at its present low level in the long term. There is therefore no time-bound, quantified target with a defined baseline for consumer and end-user outcomes.

Sustainability Report, Corporate Policy (ESRS G1, p. 63-64) and Corporate Governance Report, Compliance (p. 36-37). Adler Group's compliance management system is based on the United Nations Convention against Corruption, and the Group is a signatory to the UN Global Compact and the Diversity Charter. Corporate culture is developed through a corporate constitution with clear allocation of responsibilities, a defined set of values in the Code of Conduct, management acting as a role model (tone from the top), a motivational working atmosphere and an effective compliance management system. Key documents made available to employees and published on the website include the Code of Conduct, Codes of Conduct for Freelancers and for Business Partners, Anti-Corruption Policy, Anti-Discrimination Policy, Human Rights Policy, Data Protection Policy and Policy on Political and Social Engagement. New employees are trained on the Code of Conduct during onboarding via interactive online and classroom training.

Sustainability Report, Corporate Policy, Management of relationships with suppliers (ESRS G1, p. 65). Adler Group has numerous suppliers for services and goods and states there are no dependencies on individual business relationships. Relationships with suppliers have so far been unremarkable and without significant problems. Requirements regarding certain sustainability aspects are part of the Group's General Terms and Conditions, and a Code of Conduct for Business Partners applies. On this basis the Group considered there was no need to formulate a dedicated supplier guideline. Supplier management is listed as one of the CMS's key compliance topics (p. 36), and other sections note supplier audits for careful selection and that human rights aspects are incorporated into supplier contracts. No payment practices toward suppliers are described here.

Sustainability Report, Corporate Policy (p. 63-64), EU Taxonomy minimum safeguards (p. 19) and Corporate Governance Report (p. 36). Adler Group identifies purchasing and sales as areas of increased corruption and bribery risk and states it minimises these through strict internal control mechanisms and clear compliance and ethical-conduct guidelines. Anti-corruption measures are set out in a written Anti-Corruption Policy that forms an integral part of the Code of Conduct. Regular risk assessments to prevent and combat corrupt practices are carried out by the respective risk owners, usually the head of the relevant business unit. Mandatory anti-corruption training covering conflicts of interest, gifts and invitations, with proof of participation, is required for all employees. A whistleblower system allows internal and external stakeholders to report suspected violations anonymously.

Sustainability Report, Corporate Policy (ESRS G1, p. 64). Adler Group states that, due to the resources allocated and the effectiveness of its systems, it neither registered any cases of corruption or bribery nor paid any fines for violations of anti-corruption and anti-bribery laws in the 2024 reporting year. No convictions or other confirmed incidents are reported.

Sustainability Report, Corporate Policy (ESRS G1, p. 65). Adler Group states plainly that it does not engage in political or lobbying activities. The Group also maintains a Policy on Political and Social Engagement, listed among its published compliance documents (Corporate Governance Report, p. 37), and the EU Taxonomy minimum safeguards section notes written guidelines on political and social involvement (p. 19). No financial or in-kind political contributions, lobbying expenditure or memberships used for lobbying are disclosed, consistent with the stated position of no such activity.