Akelius Residential Property

Governance roles

Reference: page 58. Listed in the IRO-2 content index at page 58 (pages 86-87). The overall role of the bodies is cross-referred: "see page 41, governance."

Allocation of responsibility (page 58):

• The Board of Directors "has ultimate responsibility for the ESG strategy and compliance with regulatory frameworks", reviews the sustainability policy yearly, and "approves the CSRD aligned annual reporting based on recommendations of the Audit Committee and the Sustainability and Construction Committee".
• The Audit Committee "is responsible for overseeing sustainability impacts, risks, and opportunities and the sustainability reporting" and reports directly to the Board.
• The Sustainability and Construction Committee oversees integration of sustainability objectives into operations and reports to the Board. It "consists of four members, of which one is a Board member".
• The CEO and sustainability team "meet regularly to analyse and monitor the sustainability progress".

Composition: five Board members, "of which four are male, 80 percent, and one member, 20 percent, is executive". "There is no representation of employees or other non-employees on the Board." Expertise is asserted rather than evidenced: "The governance bodies possess or can leverage sustainability-related expertise." Fifteen sustainability governing documents are listed.

Information provided to the bodies

Reference: page 59. Listed in the IRO-2 content index at page 59 (pages 86-87).

The disclosure is brief. "Management and the Board receive quarterly updates through business and operational risk reporting on all sustainability matters" and "Consideration of impacts, risks and opportunities, IROs, are a part of the oversight of the company's strategy" (page 59).

For the reporting year the report names one specific matter addressed: "In 2025, the Board considered all material IROs as part of the review of the materiality assessment, see SBM-3, on page 63. Special attention was made on the increase of green building properties" (page 59).

Corroborating detail sits in adjacent disclosures rather than here: stakeholder feedback is followed up by management and the Board "on a quarterly basis" (SBM-2, page 62); the Audit Committee "is continually informed of the reporting progress to ensure compliance with the legislation" (GOV-5, page 59); the result of the climate risk assessment "was shared with the CEO and regional managers" (page 68); and business conduct findings are "reported to the Board and the Sustainability and Construction Committee" (page 83).

No list of the specific IROs addressed per meeting, and no record of how the bodies took account of trade-offs, is given.

Sustainability in incentive schemes

Reference: page 59. Listed in the IRO-2 content index at page 59 (pages 86-87).

This is a complete nil return rather than an omission. In full, the disclosure reads: "Akelius does not have incentive-based policies. The corporate culture itself encourages employees to embed a sustainable conscious mindset in all operational areas" (page 59).

No sustainability-linked variable remuneration therefore exists for the administrative, management or supervisory bodies, so no GHG-linked share of remuneration is reported. Note 7 to the financial statements confirms the absence of equity-based incentives: "No stock option program has been offered" (page 106).

The GOV-4 due diligence table nonetheless cites GOV-3.29 as a source paragraph for embedding due diligence in governance, strategy and business model (page 60), so the nil statement is treated as the answer to that element.

Statement on due diligence

Reference: pages 59-60. Listed in the IRO-2 content index at page 59 (pages 86-87).

"Akelius due diligence procedures are aimed to adhere to principles outlined in the United Nations, UN, Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises in all operations. Akelius implements corresponding measures in business based on the Code of Conduct and ensures that business partners comply with the same standards" (page 59).

Page 60 carries the required mapping of the five core elements to paragraphs in the statement:

• (a) embedding in governance, strategy and business model - GOV-2.26 a), b), GOV-3.29, SBM-3.48, G1-1.9 and 10a)
• (b) engaging affected stakeholders - GOV-2.26 b), SBM-2.45, IRO-1.53, S.1.12, S1-2.27, S4.8, S4-2.20 and 21, MDR-P: E1-2.22, 23 and 25, S1-1.19 and 24 a, d), S4.1.15, G1-1.9 and 10a
• (c) identifying and assessing adverse impacts - IRO-1.53, SBM-3.48
• (d) taking action - E1-3.28 and 29 a), b), S1-4.37 to 43, S1-4.30 to 36
• (e) tracking effectiveness and communicating - E1-3.28 and 29 a), b), E1-4.33 and 34, S1-4.42, S1-5.46 and 47, S4-5.40 and 41, S4-4.37, G1-4.24 a) and 25 a)

The auditor tested this element specifically (page 159).

Risk management and internal controls over sustainability reporting

Reference: page 59. Listed in the IRO-2 content index at page 59 (pages 86-87).

"The Group accounting team, in collaboration with the sustainability team, is responsible for preparing the sustainability statement. The sustainability team is responsible for overseeing data collection, and sets a standardized internal data framework to ensure consistent definitions, calculations, and metrics. The Group accounting team ensures that appropriate disclosures are included in the reporting" (page 59).

Risks identified: "The sustainability reporting process involves risks such as incomplete disclosures, data inaccuracies, regulatory non-compliance, and operational disruptions" (page 59).

Mitigations: "Akelius applies a structured governance framework with segregation of duties, and data verification procedures. Sustainability reporting risks are embedded in the Akelius's internal risk management procedures. Findings are addressed across the departments involved and corrected promptly." The Audit Committee "is continually informed of the reporting progress" (page 59).

No risk assessment scoping, no materiality thresholds for reporting error, and no description of how findings are reported to the bodies are given. Data systems are described separately under BP-2: data is collected from "supplier reports from web portals and invoices" and "stored and managed in inhouse systems" (pages 57-58).

Strategy, business model and value chain

Reference: page 61. Listed in the IRO-2 content index at page 61 (pages 86-87).

"Akelius is a long-term investor that manages residential rental properties in major metropolitan areas across Europe and North America. Revenues are generated primarily through rental income from residential units. The business model focuses on acquiring, maintaining, and renovating properties" (page 61). The portfolio spans eleven cities in five countries (page 15); rental income was EUR 368 million (page 93).

"Input are financial resources, investment properties, human capital, and building materials. Output consists of a better living and energy-efficient housing, generating stable long-term return assets" (page 61).

Value chain (page 61): upstream covers property acquisition, "natural resources, energy, raw material, and technology used in construction" and suppliers, with "maintenance work, gardening, and cleaning ... carried out mainly by subcontractors"; own operations cover renovation, property management, employee wellbeing and financing, with "over six hundred employees"; downstream covers tenant wellbeing and property sales, tenants being "Akelius's end customers".

Appendix B records the SBM-1 paragraph 40(d) exclusion datapoints as "not applicable" (page 88). No revenue breakdown by ESRS sector is given.

Interests and views of stakeholders

Reference: page 62. Listed in the IRO-2 content index at page 62 (pages 86-87).

"Akelius is in close contact with its stakeholders including tenants, employees, shareholders, investors, local public bodies and suppliers" (page 62). A table gives purpose, channel and outcome for each group:

• Tenants - "customer service center, private meetings, local events"; outcome "improve safety and good communication".
• Employees - "feedback to and from managers, biennial conference, access to whistleblowing mechanism"; outcome "improve initiative and increase work quality".
• Suppliers - "due diligence process, negotiation during order placement, whistleblowing mechanism"; outcome "improve procurement process to focus on suppliers in line with Akelius's ESG goals".
• Public bodies and industry - industry organization membership and "dialogue forums for urban planning".
• Lenders and investors - "individual calls with banks and investors ... capital market presentations".

"Stakeholder feedback is also considered when overseeing the strategy and business model. Management and the Board follow up on stakeholder feedback on a quarterly basis" (page 62). The report does not state that the strategy was amended as a result.

Material impacts, risks and opportunities

Reference: pages 63-64. Listed in the IRO-2 content index at page 63 (pages 86-87).

The DMA produced eleven material IRO rows across four topical standards, each tagged with value chain position and horizon (all S, M, L). "No entity-specific topics have been identified" (page 63).

E1, seven rows (page 63) - adaptation: "risk for property damage due to extreme weather events leading to increased cost and potential revenue losses" (D). Mitigation: "risk for negative environmental impacts due to fossil fuel consumption" (U, O, actual); "risk for negative environmental impacts from energy use" (O, D, actual); "risk for transition costs to fossil fuel shifts related to regulatory compliance, DPE"; "earnings opportunity from green building certifications". Energy consumption: "risk from energy inefficiency in properties"; "positive contribution from solar panels or energy-efficient measures".

S1 - "risk for employee's health and safety" (O). S4 - "risk for tenants' health and safety" (D). G1 - "creation of a corresponding corporate culture through Code of Conduct" (positive) and "risk for corruption and bribery".

Effects (page 64): current effects "mainly relate to capital and operational expenditures in relation to the transition plan"; anticipated effects add "increased regulation for transitioning" and "damaged properties and disrupted operations due to extreme weather events". No amounts are quantified.

Process to identify and assess material IROs

Reference: pages 64-65. Listed in the IRO-2 content index at page 64 (pages 86-87).

Scoping. Input "consisted of internal descriptions of Akelius's activities, internal operational data, stakeholders and input from specialists". "No topics or sub-topics were omitted from the first round of the assessment", and potential IROs "are aligned with the sustainability matter categories outlined in ESRS 1 to ensure full coverage" (page 64).

Engagement. "Akelius then engaged with a diverse range of internal and external stakeholders, including employees, suppliers and tenants, via interviews, workshops and desktop research. Benchmarking towards peers and alignment with auditors and input from the Board are also a part of the process" (page 64).

Thresholds. Impacts are scored on "severity determined by scale, scope, irremediability, and likelihood, each parameter scored from 1 to 5"; risks and opportunities combine likelihood with magnitude on the same scale. "A risk or opportunity is considered material when the total score exceeds 3" (page 64).

Outcome. The sustainability team "selected seven topics as material". E5 and S2 "were determined to be non-material from both an impact and financial perspective, mainly due to the significant decline in major construction activities". "The recommendations were presented to and approved by the Board" (page 65).

Disclosure requirements covered

Reference: pages 86-87, with the Appendix B datapoint list at pages 88-89.

Akelius prints a genuine ESRS content index, headed "IRO-2 disclosure requirements": "The table below summarize the ESRS disclosure requirements from ESRS 2, and the four thematic standards identified as material. This has been the guideline for preparing the sustainability report" (page 86).

The index lists 39 rows with a page reference each: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3 and IRO-1; E1 SBM-3, IRO-1 and E1-1 to E1-8; S1 SBM-3, S1-1, S1-2, S1-4, S1-5, S1-6 and S1-14; S4 SBM-3 and S4-1 to S4-5; G1 SBM-3 and G1-1 to G1-4. Every page reference in the index matches the section it points to.

Requirements absent from the index: E1-9, all of E2, E3, E4, E5, S2 and S3, the S1 DRs other than those listed above, and G1-5 and G1-6.

Appendix B (pages 88-89) lists the datapoints derived from other EU legislation with their location or an explicit "not material" / "not applicable" tag, and closes with the materiality exemption relied on: "Regarding certain data points, Akelius makes use of the materiality exemption under ESRS 1, section 3.2, and omit them from the reporting. The decision to omit reporting for materiality reasons is made based on the significance of the respective information and its usefulness for the user in making decisions" (page 89).

Transition plan for climate change mitigation

Reference: page 69. Listed in the IRO-2 content index at page 69 (pages 86-87).

"Akelius aligns its decarbonization pathway with the Paris Agreement and reports progress in accordance with ESRS E1, climate change." "Akelius has embedded climate action into its operational strategy" (page 69).

Key levers (page 69): energy efficiency, "insulation upgrades, LED lighting, HVAC optimization"; fuel switching, "eliminating oil heating and converting gas systems to electric"; buying renewable energy, "on-site solar photovoltaic systems"; green certifications, "50 percent of portfolio certified by 2030"; technology adoption, "smart metering wherever feasible".

Baseline-year actions. "As 2025 is the baseline year, the transition plan actions include collection and validation of Scope 1 and 2 emissions data, energy intensity benchmarking across all regions, identification of priority properties for upgrades" (page 69).

Funding. "Akelius anticipates an investment of around EUR 100 million from 2026 to 2030 to implement its transition plan. These actions are embedded in capital allocation plans" (page 69).

Not yet approved. "The detailed transition plan will be formally approved by the Board and management" (page 69). No locked-in emissions assessment is disclosed, and the Scope 1 and 2 targets are deferred: "Target to be set in 2026" (page 72).

Identification of climate-related risks and scenario analysis

Back-filled from E1 ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 67-68). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (page 67). "Akelius identified two primary types of climate-related risks": physical, "acute risks such as floods, heatwaves, storms, and chronic risks such as rising temperatures, water stress", and transition, which "arise from the shift to a low-carbon economy and include regulatory changes such as carbon pricing".

Method and scenarios (page 67). "Akelius conducted a climate change risk analysis in 2022 with the help of Climanomics software, based on two emissions scenarios RCP 4.5 and RCP 8.5 across three time periods, short-term under one year, medium-term ... horizon 2030, and long-term ... horizon 2050." RCP 4.5 results in "warming above two degrees Celsius"; RCP 8.5 "leads to a temperature increase of four degrees Celsius".

Results. "fluvial flooding as the primary risk for properties in Toronto and Montreal, and temperature extremes for Canadian properties, Washington D.C., and New York"; transition risk centres on "non-compliance with energy performance certificate, EPC, requirements, primarily in London and Paris" (page 67).

Gaps. No 1.5 degree-aligned scenario is named for transition risk, and the analysis dates from 2022 with no 2025 update stated.

Resilience in relation to climate change

Back-filled from the "ESRS 2 SBM-3 resilience analysis" section, where this content is disclosed in the FY2025 report (page 68). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Scope and method. "In the resilience analysis, Akelius assessed material climate-related risks and evaluated its resilience by reviewing mitigation measures and expected financial impacts. The analysis covers all owned residential properties excluding minor leased office spaces and are done by IROs" (page 68).

Four IROs are worked through, each with mitigation, anticipated financial effect and uncertainties (page 68): Scope 1 and 2 emissions, with uncertainties "future regulations, carbon pricing, and new technologies"; transition risks, effect "higher costs for renovations, fines, decreased income if the apartment cannot be rented"; green building opportunities, "The portfolio is well positioned to benefit"; extreme weather, "Many at-risk properties are covered by adaptation measures, exposure is reduced."

Conclusion. "The main exposures relate to flooding, extreme rainfall, heatwaves and increasing energy-efficiency requirements ... No scenario indicates a threat to the long-term viability of Akelius's business model." Adaptive capacity rests on "high quality maintenance, continuous upgrades" and "portfolio diversification in eleven cities". No amounts are quantified.

Policies related to climate change mitigation and adaptation

Reference: page 69. Listed in the IRO-2 content index at page 69 (pages 86-87).

"Akelius takes a comprehensive approach to climate change by applying a range of policies to all its residential properties" (page 69).

Mitigation policies (page 69): sustainability policy; supplier Code of Conduct; health and safety policy; sustainable work environment policy; energy management policy; greenhouse gas emissions reduction policy; green procurement policy.

Adaptation measures (page 69): "conducting property inspections" and "integration of environmentally friendly measures into property design and maintenance".

Accountability (page 69). "The Board of Directors holds ultimate accountability for implementing climate-related policies, with oversight provided by the Sustainability and Construction Committee. Operational responsibility is delegated to the head of Business Development and the sustainability reporting manager."

The policies themselves are named rather than summarised: no policy objectives, scope boundaries, third-party standards or availability statements are given for each, which the GOV-4 table cites as the MDR-P source paragraphs "E1-2.22, 23 and 25" (page 60). The full list of fifteen sustainability governing documents, and the fact that all but two are signed by the Board, sits under GOV-1 (page 58).

Actions and resources in relation to climate change policies

Reference: page 69. Listed in the IRO-2 content index at page 69 (pages 86-87).

The E1-3 disclosure is a short list of 2025 outcomes (page 69):

• "procured 2,461 MWh renewable energy"
• "generated 2.23 GWh of solar energy"
• "has in total 30 properties green certified, including 13 for Montreal"
• "received first green certifications in Paris"
• "continued to use smart technology to reduce energy use"

Planned actions sit in the E1-4 table by horizon (page 70): short-term "converting to renewable energy"; medium-term "upgrading building envelopes through improved insulation, energy-efficient HVAC", "expanding smart building technologies", "pursue green building certifications, for example LEED, BREEAM" and "selecting low-carbon and recycled materials"; long-term "ensuring the portfolio remains compliant with evolving regulatory and market expectations".

Resources. The only monetary figure sits in E1-1: "Akelius anticipates an investment of around EUR 100 million from 2026 to 2030" (page 69). No 2025 CapEx or OpEx is allocated to the actions, and the EU Taxonomy tables report 0 percent aligned turnover, CapEx and OpEx (pages 75-77).

Targets related to climate change mitigation and adaptation

Reference: page 70. Listed in the IRO-2 content index at page 70 (pages 86-87).

Targets (page 70): "reducing intensity by two percent annually"; "ensure portfolio energy intensity below 95 kWh per sqm by end of 2030 for Scope 1 and 2"; "have fifty percent of portfolio's floor area green certified by independently recognized organizations by end of 2030"; "become carbon neutral by 2050".

No quantified GHG reduction target yet. The E1-6 table leaves the Scope 1 and Scope 2 rows as "Target to be set in 2026", with 2025 as base year and "net zero" entered for 2050 (page 72).

Scope. Targets "apply to all residential properties across Europe and North America ... both operational activities and the upstream procurement of energy. Downstream tenant activities are not currently included due to limited data availability." "Scope 3 emissions are excluded under CSRD Omnibus relief for companies with fewer than 750 employees" (page 70).

1.5 degree alignment. "Although Akelius does not currently have Science-Based Targets initiative, SBTi, validation, the targets are directionally consistent with limiting global warming to 1.5 degrees C" (page 70). No pathway or model is named.

Tracking is annual "using KPIs such as energy intensity, kWh/m2, and GHG emissions, tCO2e" (page 70). Current intensity is 124.8 kWh/sqm against the 2030 target of below 95 (page 71).

Energy consumption and mix

Reference: page 71. Listed in the IRO-2 content index at page 71 (pages 86-87).

2025 figures (page 71):

• Total electricity consumption 49,920 MWh (like-for-like 47,607); renewable share 5.0 percent; solar electricity sold 260 MWh
• Total fuel consumption, oil 0.0 MWh; gas 168,117 MWh (like-for-like 164,656)
• Total energy consumption 218,037 MWh; like-for-like 212,264 MWh
• Total building energy intensity 124.8 kWh/sqm; like-for-like 126.4

"Renewable sources in total energy consumption is 5 percent, and fossil sources sums up to 95 percent. Akelius does not consume coal or crude oil products, nor renewable fuels such as biomass, biogas or hydrogen. Natural gas is the primary fossil fuel used for heating in certain properties, representing 77.1 percent of total energy consumption" (page 71).

Method and limits. Calculated "using actual utility data and standard emission factors from DEFRA, EPA, and ADEME". Fourth-quarter figures "include estimates based on data from the first two quarters", with "additional estimations ... for Montreal and Toronto". Two German buildings acquired in August 2025, tenant-controlled consumption and leased offices are outside the boundary (pages 57, 71). "Metrics are internally validated and externally assured under CSRD, with no other third-party validation."

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 71-72. Listed in the IRO-2 content index at page 71 (pages 86-87).

2025 figures, base year 2025 (page 72):

• Gross Scope 1 30,940 tCO2e
• Gross Scope 2 location-based 7,765 tCO2e; market-based 11,723 tCO2e
• Total location-based 38,705 tCO2e; market-based 42,663 tCO2e
• Intensity 105 tCO2e per EUR million location-based and 116 market-based, on net revenue of EUR 368 million, "consistent with the revenue reported in Note 3"

Scope 3 and comparatives are absent by election. "Akelius does not report comparative figures or Scope 3 due to phase-in regulations" (page 71); the table footnote reads "2024 and the percentage are not presented due to the Omnibus phase-in options" (page 72). The applicable Scope 3 categories are named under BP-1: tenant electricity use, "embodied carbon from production and transport of construction materials used in renovation", fuel and energy related activities, and investments, which fell away because "Akelius sold the last share in Castellum during 2025" (page 57).

Method. Actual utility data with DEFRA, EPA and ADEME factors; direct metering for Scope 1, utility invoices and supplier data for Scope 2 (pages 58, 71). "Limitations include incomplete tenant-level data." Assured under CSRD with no other third-party validation.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 72. Listed in the IRO-2 content index at page 72 (pages 86-87).

A complete nil return. In full: "Akelius has not yet purchased any carbon credits. The strategy is to reduce emissions to become carbon neutral" (page 72).

No GHG removals or storage in own operations or the value chain are reported, and no carbon credits are cancelled or planned to be cancelled, so there is nothing to disaggregate by project type, standard or vintage. Appendix B records the E1-7 paragraph 56 datapoint on GHG removals and carbon credits against page 72 (page 88).

The nil return is consistent with the target set out in E1-4, which relies on emission reductions rather than offsets: the 2050 commitment is to "become carbon neutral by 2050" via energy efficiency, fuel switching, renewable sourcing and green certification (pages 69-70). The report does not state whether the 2050 carbon-neutrality claim will rely on credits in future.

Internal carbon pricing

Reference: page 72. Listed in the IRO-2 content index at page 72 (pages 86-87).

A complete nil return, stated in one sentence: "Internal carbon pricing is not applicable for Akelius as of now" (page 72).

No carbon price type, scope of application, price per tonne or share of emissions covered is therefore reported, and the report does not say whether introducing a price is planned. Carbon pricing does appear as an external uncertainty rather than an internal tool: the resilience analysis lists "future regulations, carbon pricing, and new technologies" among the uncertainties for both the Scope 1 and 2 and the transition-risk IROs (page 68), and the transition risk assessment covers "evolving climate-related regulations and taxation" (page 67).

Policies related to own workforce

Reference: page 78. Listed in the IRO-2 content index at page 78 (pages 86-87).

"The Code of Conduct outlines key principles for workforce, promoting a safety culture. The implementation is overseen by the CEO and introduced during employee onboarding. The health and safety policy outlines Akelius's commitment to provide a healthy, safe working and living environment for its employees" (page 78).

Eight further policies are named: anti-corruption policy, supplier Code of Conduct, whistleblower policy, staff diversity and equality policy, political involvement policy, sustainable work environment policy, freedom of association policy and responsible investment policy (page 78).

Appendix B records the S1-1 datapoints derived from other EU legislation - paragraph 20 human rights policy commitments, paragraph 21 due diligence policies on the fundamental ILO Conventions 1-8, paragraph 22 processes for preventing human trafficking and paragraph 23 workplace accident prevention strategy or management system - against page 78 (page 89). The narrative itself does not spell out the trafficking or ILO commitments, and the forced-labour and child-labour risk datapoints at ESRS 2 SBM-3 - S1 paragraphs 14 f) and 14 g) are marked "not material" (page 89).

Scope is limited by the company's phase-in election: "only the elements directly associated with this risk have been disclosed", the risk being employee health and safety (page 78).

Engaging with own workforce and workers' representatives

Reference: page 79. Listed in the IRO-2 content index at page 79 (pages 86-87).

The disclosure is short and is framed around local management rather than a central function or a works council structure:

"The managers' leadership and ability to educate the teams are the most critical factors to create engagement. Akelius decentralizes health and safety management to each local operation due to varying national regulations. Each city implements its own processes to ensure workplace safety. Local management monitors work-related incidents and absenteeism and reports quarterly to the sustainability team" (page 79).

Channels named elsewhere in the statement are "feedback to and from managers, biennial conference, access to whistleblowing mechanism", with the stated outcome "improve initiative and increase work quality" (SBM-2, page 62). A freedom of association policy exists (page 78) and the GOV-4 table cites "ESRS S.1.12, S1-2.27" as the engagement paragraphs (page 60).

No global or senior-level person accountable for the engagement, no workers' representative bodies, no collective agreements and no assessment of the effectiveness of the engagement are identified.

Taking action on material impacts on own workforce

Reference: page 79. Listed in the IRO-2 content index at page 79 (pages 86-87).

Actions are confined to the material health and safety risk:

"Akelius promotes continuous learning and awareness initiatives to strengthen employee understanding of health, safety, and overall wellbeing. Akelius maintains clear safety procedures and ensures that employees have access to proper equipment and training for safe working practices. Construction managers receive on-site safety training when necessary. Staff at the properties or in contact with tenants are trained in emergency response and evacuation procedures. Akelius has a long-standing practice of advancing existing employees into higher-level roles which help retain experience and knowledge" (page 79).

The affected groups are identified at SBM-3: "Akelius's employees working in properties, such as property managers, construction managers and leasing managers are the main groups impacted by health and safety concerns" (page 78).

Effectiveness is tracked through the S1-14 metrics, "prepared by the staff department and reported to management" quarterly, with major incidents "analysed in-depth" and "corrective and preventive actions" implemented (page 80). The GOV-4 table cites "S1-4.37 to 43" and "S1-4.30 to 36" as the action paragraphs (page 60).

No resources allocated to the actions are quantified, and no remediation of actual harm is described.

Targets related to own workforce

Reference: page 79. Listed in the IRO-2 content index at page 79 (pages 86-87).

The target disclosure is a single sentence: "Akelius focus is on continuously reducing the injury rate, lost day rate, and to keep a zero fatality rate" (page 79).

The direction of travel is therefore stated but only the fatality limb is a measurable target. No baseline year, no target year, no percentage reduction and no milestones are given for the injury rate or the lost day rate, and no target is set for any other S1 sub-topic, consistent with the company's phase-in election to disclose "only the elements directly associated with this risk" (page 78).

The metrics the target would be measured against are reported under S1-14: injury rate 1.0 per 100,000 hours worked, lost day rate 50.1 per 100,000 hours worked and zero fatalities in 2025 (page 80). With 2025 as the first reported year there is no comparative against which progress could be shown.

The report does not state whether employees or their representatives were involved in setting the target, nor how the target was derived. The GOV-4 table cites "S1-5.46 and 47" among the paragraphs for tracking effectiveness (page 60).

Characteristics of the undertaking's employees

Reference: pages 79-80. Listed in the IRO-2 content index at page 79 (pages 86-87).

Headcount by gender (page 80): 343 male, 261 female, 0 other, 0 not disclosed, total 604. Of these, 584 are permanent (335 male, 249 female), 19 temporary (7 male, 12 female) and 1 is a non-guaranteed-hours employee.

Headcount by country (pages 79-80): Canada 305, USA 182, UK 53, France 44, Sweden 11, Germany 9.

Turnover (page 80): new hires 126, rate 21 percent; employee turnover 142, rate 23 percent.

"Most Akelius employees have permanent positions. A unsignificant portion of the Akelius's workforce is made up of non-employees" (page 79). SBM-1 corroborates the scale: "Akelius has over six hundred employees contributing to the company's development" (page 61).

The same section adds narrative that the ESRS would locate under other S1 requirements: "Work-life balance is a core priority. Akelius complies with all national parental-leave regulations and, where feasible, provides flexible working arrangements to support employees' personal needs" (page 79). No headcount is broken down by full-time or part-time, and employee numbers are reported as headcount rather than full-time equivalents. The methodology for the turnover rate is not stated.

Health and safety metrics

Reference: page 80. Listed in the IRO-2 content index at page 80 (pages 86-87).

2025 figures (page 80):

• Injury rate 1.0 per 100,000 hours worked
• Lost day rate 50.1 per 100,000 hours worked
• Fatalities 0

"Quarterly safety performance metrics, including injury rates, fatalities and lost day rates, are prepared by the staff department and reported to management. Those metrics measures the frequency and severity of incidents, highlighting high-risk areas, and track the effectiveness of mitigation measures over time, helping to reduce employee health and safety risks. Major incidents are analysed in-depth. Lessons learned are shared, and corrective and preventive actions are implemented" (page 80).

Appendix B records the S1-14 datapoints against page 80: paragraph 88 b), c) number of fatalities and number and rate of work-related accidents, and paragraph 88 e) number of days lost to injuries, accidents, fatalities or illness (page 89).

The percentage of own workers covered by a health and safety management system is not reported as a figure, although S4-1 states that "Akelius aligns with standards and certification ISO45001, Occupational Health and Safety" (page 81). Cases of recordable work-related ill health are not reported, non-employees are outside the metrics, and absolute injury and lost-day counts are not given alongside the rates. The definitions section defines the injury rate (page 167).

Policies related to consumers and end-users

Reference: page 81. Listed in the IRO-2 content index at page 81 (pages 86-87).

The policy disclosure is two sentences: "The governing documents related to tenants are health and safety policy, data protection policy and sustainability policy. Akelius aligns with standards and certification ISO45001, Occupational Health and Safety" (page 81).

Scope is set by the phase-in election: "In line with the phase-in regulations, only the data points directly related to the identified risk are presented below", the identified risk being tenants' health and safety (page 81). Appendix B records the S4-1 paragraph 16 datapoint, policies related to consumers and end-users, against page 81, and marks paragraph 17, non-respect of the UN Guiding Principles and OECD guidelines, as "not material" (page 89).

The affected group and the impacts the policies address are identified at SBM-3: "Akelius's end-users are the tenants at the residential properties. Akelius's operations have actual and potential impacts on tenant well-being related to building safety, data privacy and indoor environmental quality. These may directly affect the physical health and quality of life of the tenants" (page 81).

No policy objectives, scope, accountable function, third-party standards or availability statement is given for each of the three documents, and no explicit human rights commitment to end-users is stated.

Engaging with consumers and end-users

Reference: page 81. S4-2 and S4-3 are presented under a combined heading, and the IRO-2 content index lists both at page 81 (pages 86-87).

"Akelius offers a customer service hotline for reporting maintenance, safety, or emergency issues. Akelius holds meetings during major refurbishments to gather tenant input on health and safety impacts ... Tenant satisfaction is conducted by customer service or the property manager after each move-in, as well as in response to feedback or reviews shared on social media" (page 81).

Stage and frequency are therefore specific: engagement happens during refurbishment planning, at move-in, and on demand. SBM-2 adds the channels "customer service center, private meetings, local events" and the outcome "improve safety and good communication" (page 62).

Effectiveness is judged by outcome indicators rather than by an engagement assessment: "Management monitors tenant turnover and satisfaction, which remains strong, with low vacancy rates and improving Google ratings. Akelius employees often visit the properties to ensure tenant safety and satisfaction" (page 81). Turnover of tenants and vacancy rates are reported in the key figures (page 56).

No senior-level person with operational responsibility for tenant engagement is identified, and no process is described for engaging tenants who may be particularly vulnerable.

Remediating negative impacts and channels to raise concerns

Reference: page 81. S4-3 is presented with S4-2 under a combined heading and is listed in the IRO-2 content index at page 81 (pages 86-87).

"Akelius offers a customer service hotline for reporting maintenance, safety, or emergency issues ... For reported health or safety incidents, Akelius provides follow-up updates on actions taken, preventive measures, and resolution status" (page 81).

Remediation of the underlying condition is described under S4-4: "Akelius conducts regular property inspections and upgrades buildings that do not meet safety standards" (page 81), supported by "preventive maintenance to address risks like mold, asbestos, fire hazards, and structural issues" and "property investments in ventilation, fire detection and hazard mitigation" (page 82).

Tenants are also among the groups the whistleblower system covers, in the sense that corruption involving tenants is in scope: "bribes to secure apartments for friends or family" is named as a corruption risk (page 84), and the whistleblower channel is open to "Employees, suppliers, and other partners" (page 83).

The report does not say whether tenants are aware of or trust the channels, does not report the number of complaints received, and does not describe how the company tracks and monitors issues raised to resolution beyond the follow-up updates quoted above.

Taking action on material impacts on consumers and end-users

Reference: pages 81-82. Listed in the IRO-2 content index at page 81 (pages 86-87).

Actions to ensure tenant safety (pages 81-82):

• "compliance with safety standard, meaning that all properties meet local building codes, fire regulations, and health standards, verified through regular inspections"
• "preventive maintenance to address risks like mold, asbestos, fire hazards, and structural issues"
• "tenant communication to provide safety guidance and receive concerns through customer service"
• "property investments in ventilation, fire detection and hazard mitigation"

Approach to risks and opportunities (page 82): "Property inspection application check list that property managers use during a property inspection, is updated to identify vulnerabilities related to tenant health and safety. Akelius also invests in green building certification which enhances both safety and environmental performance."

Effectiveness. "The effectiveness of actions is measured using Key Performance Indicators, KPIs" and the reader is directed to S4-5 (page 82), where 100 percent of properties were inspected in 2025 and 39 property compliance incidents were recorded (page 82).

Appendix B marks the S4-4 paragraph 35 datapoint on human rights issues and incidents as "not material" (page 89). No resources allocated to the actions are quantified, and no 2025 remediation case is described.

Targets related to consumers and end-users

Reference: page 82. Listed in the IRO-2 content index at page 82 (pages 86-87).

Targets, each with the company's own rationale (page 82):

• "have all properties inspected annually to ensure that potential hazards are identified and addressed proactively, preventing accidents and unsafe conditions"
• "reduce property compliance incidents in each city by ten percent annually", because "reducing property compliance incidents drives continuous improvement in meeting local safety and building regulations, lowering the risk of tenant exposure to unsafe conditions"
• "have fifty percent of properties green certified by 2030", since "green-certified properties support healthier indoor environments, improved air quality, and safer building systems, which indirectly reduce tenant health risks"

2025 performance (page 82): property inspections 100 percent; property compliance incidents 39.

The inspection target is therefore met in the first reported year. The ten percent annual reduction target is measurable but has no stated baseline year, and with no comparative for 2025 no progress can be shown. The certification target is cross-referred to the environmental disclosures, where 12 percent of property area is certified, 30 certifications are held and 31 percent of the area is under evaluation (page 72).

The report does not state whether tenants were involved in setting the targets or in tracking performance against them.

Business conduct policies and corporate culture

Reference: pages 83-84. Listed in the IRO-2 content index at page 84 (pages 86-87).

"Akelius's Code of Conduct for employees is the foundation of its ethical business practices and applies universally across all cities. It promotes excellence, integrity, and sustainability, and is mandatory for all individuals acting on behalf of the company including employees, management, board members, and consultants" (page 84). "In 2021, Akelius signed the UN Global Compact, committing to uphold its ten principles" (page 84). "Akelius has developed the Code of Conduct without direct involvement of the stakeholders."

Culture and its evaluation. "Akelius evaluates its corporate culture through the monitoring of key indicators such as employee's turnover and numbers of confirmed cases to identify improvements" (page 83).

Training. "Akelius does not have a separate formal policy on business conduct training. However, all employees are required to read to the Code of Conduct ... and pass the comprehensive test at least once per year." Training for the bodies is not in place: "Akelius is assessing the need to introduce formal training for these bodies" (page 84).

Appendix B records the G1-1 datapoints at page 84: paragraph 10 b) UN Convention against Corruption and 10 d) protection of whistleblowers (page 89).

Management of relationships with suppliers

Reference: pages 84-85. Listed in the IRO-2 content index at page 84 (pages 86-87).

"Akelius manages its relationships with suppliers through transparent procurement processes that promote fair and responsible business practices. Akelius has a designated person responsible for procurement in almost every city. Many suppliers in construction, maintenance, and property operations are small companies. Akelius ensures that payment terms are clear, invoices are centrally processed, and payments are made within agreed timelines" (page 84).

Due diligence on onboarding (page 85). "all new suppliers are always approved by two employees in operations, disclosing the scope of the work and if it is a related party within Akelius, checking credit scoring" and "by the finance department, reviewing tax compliance documents and bank details to detect mismatches between the supplier's name and accountholder name to avoid fraud".

Code of Conduct coverage. "Akelius requires all strategic suppliers to sign the Code of Conduct. It excludes municipalities and established corporations as they have stated their Code of Conduct on their website." The supplier Code "requires suppliers to follow all laws and standards, maintain a safe workplace and uphold international human rights" (page 85).

No share of suppliers signed up, no audit or screening counts, and no social or environmental criteria weightings are reported.

Prevention and detection of corruption and bribery

Reference: page 85. Listed in the IRO-2 content index at page 85 (pages 86-87).

Prevention (page 85). "Akelius mandates all employees to complete annual training on anti-corruption and bribery, and Code of Conduct. 85 percent undertook the anti-corruption and bribery training, and 85 percent fulfilled the Code of Conduct training requirements. 81 percent completed the data protection training. 84 percent undertook the annual training on sustainability targets, while 77 percent completed the diversity training."

Detection (page 85). "Akelius maintains a record of any incidents related to corruption or bribery. Internal auditors investigate all incidents. The company takes appropriate actions to prevent future occurrences, including dismissing the involved employee if corruption is confirmed."

Independence (page 83). "Investigations are conducted by a designated independent manager or the internal auditors to maintain impartiality." Access to the whistleblowing system "is restricted the chairman of the Board and Kerstin Engström, Board member."

Risk areas are concrete: the sector "is exposed to numerous interactions with local officials or government approval to get permit construction", plus "kickbacks or benefits from contractors, suppliers, or tenants to Akelius decision-makers, and bribes to secure apartments for friends or family" (page 84). Training is not broken down by function or at-risk group.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

A stated, measurable target exists. "Akelius has set a target of achieving zero legal convictions for corruption and bribery offenses. It applies to both our employees and the company's business partners" (G1-4, page 85). Performance in 2025: "The number of confirmed incidents of bribery and corruption was zero in 2025", and "The fines for violation of anti-corruption and anti-bribery laws amounted to EUR 0 million in 2025" (page 85).

Effectiveness tracking alongside the target. "Akelius evaluates its corporate culture through the monitoring of key indicators such as employee's turnover and numbers of confirmed cases to identify improvements" (page 83). Training completion is tracked annually, at 85 percent for anti-corruption and bribery and 85 percent for the Code of Conduct (pages 84-85). Planned 2026 actions are "roll out targeted training" and "internal audit focusing on high-risk processes" (page 83).

No target is set for the training completion rates themselves, no baseline year or milestone is given for the zero-convictions target, and no target covers the G1 positive impact on corporate culture.

Incidents of corruption or bribery

Reference: page 85. Listed in the IRO-2 content index at page 85 (pages 86-87).

2025 figures (page 85): "The number of confirmed incidents of bribery and corruption was zero in 2025." "The fines for violation of anti-corruption and anti-bribery laws amounted to EUR 0 million in 2025." "No significant breaches were confirmed during the reporting period."

Method and limitations. "Akelius collects data from multiple sources such as the whistleblower channels and reports from local management. All reported cases are reviewed to determine whether they constitute a potential breach." The stated assumptions are unusually candid: "only internal investigation according to company policy, no external input"; "timing difference can occur as investigations can span multiple reporting periods"; "subjectivity in assessing an incident can be seen as a limitation of the methodology".

Near-misses are disclosed rather than suppressed. "Possible issues are identified, such as expenses claimed without proper justification, conflicts of interest that were not declared, and gifts received above the allowed limit. These issues are reviewed to check compliance with internal policies and legal requirements" (page 85).

Appendix B records both G1-4 datapoints at page 85 (page 89). The number of convictions, and incidents relating to contractors rather than employees, are not separately reported.