Altarea

Altarea's Management defines the Group's CSR strategy and sets objectives, while the Supervisory Board, composed of 14 members, 35% of whom are independent including its Chairman, ensures social and environmental issues are taken into account. The Audit and CSR Committee, an offshoot of the Supervisory Board, examines and prepares CSR issues, monitors the preparation of sustainability information, and reviews the audit approach and the double materiality matrix, while the Compensation Committee ensures integration of sustainability criteria (at least one linked to climate) into variable compensation and the Appointments Committee addresses CSR expertise. The CSR Department, which reports to the Group Strategic Marketing, CSR and Innovation Director and is composed of four employees on open-ended contracts, plays a cross-functional role, relying on a CSR Committee of around forty coordinators that meets once or twice a year, ad hoc working groups, a dedicated cross-functional Steering Committee, and a network of operational CSR ambassadors set up in 2021. The Executive Committee, which meets every two weeks, validates the double materiality matrix and material impacts, risks and opportunities.

Throughout the year the Group Director of Strategic Marketing, CSR and Innovation informs Management about the Group's CSR performance metrics, collected and consolidated by the CSR Department in collaboration with the Finance Department, and items are regularly discussed at Executive Committee meetings. The Supervisory Board is informed annually of the results obtained by Management as part of the Group's CSR strategy. Each year an item on the Audit and CSR Committee's agenda is devoted to the review of CSR and sustainability issues; matters addressed in 2024 included the review of the non-financial performance statement (DPEF), environmental performance, European taxonomy and decarbonisation strategy, the Say on climate resolution presented to the General Shareholders' Meeting, and the recommendation for the appointment of sustainability certifiers. The Committee also reviewed the CSRD regulations, the audit approach and double materiality matrix, and the assessment of material impacts, risks and opportunities, with its Chairwoman reporting to the next Supervisory Board meeting.

Sustainability results are included in Altarea's financial incentive systems, with the incentive maintained in 2023 and 2024 based on a financial criterion linked to Funds from operations and non-financial criteria built around three factors: Climate (taxonomy-related metrics and carbon intensity in grammes of CO2 per euro of revenue), Employees (female representation in management, mobility and internal promotion) and Customers. The medium- and long-term variable compensation of Officers and Managers, including Executive Committee members, includes non-financial criteria, with vesting of 50% of free share grants subject to financial and non-financial performance over two fiscal years, up to 25% depending on progressive FFO thresholds and up to 25% on climate objectives (up to 9%, of which 4.5% relates to taxonomy and 4.5% to carbon intensity), human resources (up to 8%) and customer satisfaction (up to 8%). The Management's compensation policy requires the Supervisory Board to set variable compensation with at least one criterion related to the Company's climate objectives, though Management exceptionally waived in advance any variable compensation for the 2024 fiscal year given the real estate crisis.

Altarea is not subject to Act 2017-399 of 27 March 2017 on the duty of vigilance in France, but provides information relating to the CSRD's duty of care through a mapping table of the core elements of due diligence to the relevant sections of the sustainability statement. Embedding due diligence in governance, strategy and business model is covered in ESRS 2 GOV-1 and GOV-2; engaging with affected stakeholders in SBM-2 and the S1 to S4 engagement disclosures; identifying and assessing adverse impacts in IRO-1 and SBM-3; and taking and tracking actions in the S1 to S4 action and target disclosures. This information is based on the UN Guiding Principles on Business and Human Rights and the OECD Principles of Corporate Governance.

The internal control process for sustainability information includes a first level of control under the Group's operational departments (legal, human resources, by brand or activity for environmental information) responsible for producing, consolidating, analysing and, in Property Development, estimating data such as waste, and a second level under the CSR Department which verifies the consistency, integrity and exhaustiveness of the reported data and calculates coverage rates where data is non-exhaustive. Where anomalies were detected the CSR Department contacted operational teams to correct the values or exclude them from reporting. The risk mapping carried out every three years, managed by the Risk Department and presented to Management and the Executive Committee, already includes sustainability risks such as climate risk, and the sustainability risks were reviewed and reassessed as part of the double materiality analysis. The next step is to integrate all identified material (gross) risks into the Group risk mapping through a net risk analysis, after which Altarea will implement a risk management and internal control process in its internal procedures.

Since its creation in 1994, Altarea has deployed a business model based on two complementary pillars, Investor and Developer, positioning itself as a leader in low-carbon urban transformation across Residential, Retail, Business Property, photovoltaic infrastructures and eco-responsible data centers. The Group's urban transformation strategy is mainly carried out in France but also in Italy and Spain, with 2024 revenue of 2,768.5 million euros and 1,981 employees. Resources supporting the model include equity of 3,163 million euros, liquidity of 2,530 million euros, net financial debt of 1,681 million euros, assets under management of 5,275 million euros, energy consumption of 126,893 MWh and a 93% share of renewable energy in the energy consumed. The value chain covers upstream activities (raw materials, materials, building sites) and downstream (use of buildings, energy and water needs of users, waste and travel), with Altarea reporting no revenue from the fossil fuel, chemical production, armaments or tobacco sectors.

Due to the diversity of its activities, Altarea engages a wide range of stakeholders grouped as Clients, Employees, Suppliers and service providers, Financial partners and analysts, Company (local authorities, affected communities, sector working groups, public opinion and media) and Environment (the planet as a silent stakeholder). Dialogue mechanisms include customer satisfaction surveys and green-lease environmental committees, consultation with the brands' Social and Economic Committees (CSEs), a responsible purchasing charter in supplier contracts, Shareholders' Meetings and investor relations, and participation in sector working groups such as the Observatoire de l'Immobilier Durable, BBCA and Booster du Réemploi. Stakeholder views have shaped the strategy, for example the new Access offer for first-time buyers, and Altarea is committed to external initiatives including the UN Global Compact and the Charte Paris Action Climat. The Group's non-financial ratings include MSCI BBB and a low ESG risk rating from Sustainalytics (12.1 in 2024), with information on stakeholders handled by the Strategic Marketing, CSR and Innovation Department.

Following the double materiality analysis, Altarea identified 30 material impacts and 26 risks and opportunities above the materiality threshold, grouped by challenge in the Group's double materiality matrix and covering ESRS E1, E3, E4, E5, S1, S2, S3, S4 and G1, with ESRS E2 Pollution assessed as non-material. Material topics include GHG emissions and energy consumption, adapting buildings to climate change, water efficiency, land sufficiency, biodiversity and ecosystems, renovation and reconversion of buildings, waste sorting and recovery, value sharing, working environment, career development, social guarantees in the value chain, urban transformation, purchasing power of customers, corporate culture and business conduct. All current impacts identified as material occur on a continuous basis throughout the Group's activities, while potential impacts were assessed as medium-term impacts that could occur occasionally over one to five years. Altarea did not identify any impacts, risks or opportunities whose topics are not covered by the ESRS standards.

Altarea carried out its double materiality analysis between end 2023 and May 2024 in four stages: identification of sustainability issues (cross-referenced to the ESRS using the ESRS 1 sub-topics list, a sector bibliographic assessment and the Group's specific context), identification of impacts, risks and opportunities, assessment of their materiality, and validation. IROs were assessed on a gross basis in line with EFRAG guidance, with impact materiality assessed on severity (scope, extent, reparability) and probability and financial materiality assessed by the Finance Department with the CSR Department on the scale and nature of financial effects, probability and long-term severity, using rating scales aligned with the Group's risk mapping. Impacts, risks and opportunities were scored from 1 to 4 and a materiality threshold of 2.5 was chosen, resulting in 30 material impacts and 26 risks and opportunities. Climate physical risks were analysed using the OCARA method and TCFD recommendations across ten climate hazards under RCP 4.5 and RCP 8.5 scenarios over horizons of 2030, 2050 and 2090 for the REIT and 2005, 2055 and 2070 for Development, while biodiversity dependencies and impacts were assessed following TNFD recommendations using the ENCORE tool and the five IPBES pressures; the process was overseen by the Audit and CSR Committee and the Executive Committee.

Altarea identified the material information to publish by linking its material impacts, risks and opportunities to the CSRD topics and sub-topics (AR 16 of ESRS 1) and cross-referencing them with the CSRD data points, reporting on all the disclosure requirements presented in a detailed table of contents covering ESRS E1, E3, E4, E5, S1, S2, S3, S4 and G1. As a result of the double materiality analysis, Altarea does not report on ESRS E2 Pollution, though pollution information appears under Article 8 of the Taxonomy Regulation. Several disclosure requirements are not addressed this year, including E1-1 (transition plan), E1-8 (internal carbon pricing, deemed immaterial), and, under the applicable CSRD transitional arrangements, the anticipated financial effects requirements E1-9, E4-6 and E5-6, while E3-5 is not reported as no material water risks or opportunities were identified. S1-12 (people with disabilities) and S1-17 (incidents, complaints and severe human rights impacts) were not assessed as material for the Group given its European geographical footprint, though a material impact on the value chain was identified. The metric G1-6 on payment practices is not published as not all necessary data are currently available.

Altarea's climate change mitigation and adaptation policies are coordinated by the Group Director of Strategic Marketing, CSR and Innovation working with the Finance Department, and cover the upstream and downstream value chain (design, companies, partners, customers) as well as internal employees. The policies address the two material issues identified through the double materiality analysis: GHG emissions and energy consumption, and adaptation of buildings to climate change. Mitigation policies include implementing a carbon footprint reduction policy across all business lines, an energy sufficiency policy on the Group's sites, developing renewable energy through the Altarea Renewable Energies subsidiary, and installing photovoltaic plants across the portfolio. Adaptation policies cover conducting physical risk analysis on all Group assets, anticipating climate-related costs in business plans, and strategic diversification into new businesses such as renewable energies, data centers and urban logistics. Since 2021, climate-related criteria have been integrated into employee compensation via the profit-sharing agreement and managers' variable compensation.

Since the winter of 2022/2023, Altarea has rolled out an energy sufficiency plan and numerous actions to improve the energy efficiency of REIT assets. Mitigation actions deployed in 2024 at the REIT include launching an audit to identify sites needing energy performance improvement, an audit to assess the financial cost of replacing gas boilers, replacement or improvement of building management systems, continued deployment of the carbon master plan and the environmental management system (in place since 2014), and purchase of green energy; nine sites in the own operations scope deployed electric vehicle charging infrastructure in 2024. In Property Development, 2024 actions included the acquisition of Woodeum to create a French leader in low-carbon property development, selectivity in land choice near public transport, increased use of renewable and low-carbon energy, and increased use of low-carbon materials. Altarea states it is currently unable to provide information on the financial resources allocated as the work to assess these financial impacts is ongoing, with publication expected within the next three years. Planned decarbonisation levers will be implemented over the next five years and monitored at operational level.

Altarea targets a 2030 GHG emission volume of between 950,000 tCO2e and 850,000 tCO2e (location-based), an emission reduction of 39% to 46% compared to the 2019 reference year of 1,562,454 tCO2e, estimated via the SBTi absolute contraction method over a range of +/-6% consistent with a 1.5C level. For Property Development, the target is to reduce intensity per unit area from 36% to 42%, reaching between 1,000 kgCO2e/m2 and 900 kgCO2e/m2 by 2030 versus a 2019 reference of 1,553 kgCO2e/m2. For Real Estate (Retail), the target is to reduce intensity per unit area from 29% to 36%, reaching between 4.5 kgCO2e/m2 and 4.1 kgCO2e/m2 on a location-based basis versus a 2019 reference of 6.3 kgCO2e/m2, aligned with the tertiary decree (DEET). The reference year is 2019 for GHG emissions and 2010 for energy consumption, and an adaptation target is to conduct physical risk analysis on 100% of Group assets. The 2030 targets are described as transitional objectives for the 2024 fiscal year pending finalisation of the Group's decarbonisation trajectories and transition plan.

Total energy consumption for the Group's own operations was 126,893 MWh in 2024, down from 144,465 MWh in 2023, a decrease of around 12% driven mainly by Corporate consumption (down around 30%) while REIT consumption decreased by around 9%. Renewable sources made up 93% of total energy consumption (118,409 MWh), fossil sources 7% (8,484 MWh), and nuclear 0%, reflecting that most Retail REIT assets are located in France and the assumption that non-transport consumption is almost entirely of guaranteed renewable origin. Energy intensity from activities in high climate impact sectors was 0.00047 MWh per euro of net revenue in 2024 versus 0.00056 in 2023, a 17% reduction, with the denominator based on REIT rental income and external services of 270.5 million euros. In 2024, Altarea generated 579 MWh of renewable energy through its Prejeance Industrial and Altarea Energies Renouvelables brands.

In 2024 the Group's total emissions (scopes 1, 2 and 3) were 776,047 tCO2e location-based (775,609 tCO2e market-based), down 16% compared to 2023 and down 51% versus the 2019 level. Scope 1 gross GHG emissions were 1,931 tCO2e (up 11% versus 2023), Scope 2 gross emissions were 1,297 tCO2e location-based and 859 tCO2e market-based, and total gross indirect Scope 3 emissions were 772,819 tCO2e (down 16% versus 2023 and down 51% versus 2019). The largest Scope 3 categories in 2024 were purchased goods and services (482,360 tCO2e), use of products sold (231,362 tCO2e), end-of-life treatment of sold products (20,285 tCO2e), waste generated in operations (18,806 tCO2e), and employee commuting (10,214 tCO2e). Property Development accounts for 96% of Group emissions, strongly concentrated on Residential Development (73% of the total), while the REIT represents only 4%; the Group covers 7 of the 15 GHG Protocol Scope 3 categories. Emissions are measured in accordance with the GHG Protocol, with 231 thousand tCO2e relating to future use of buildings under construction and 65% of value-chain emissions produced upstream and 33% downstream.

The Group did not wish to finance GHG reductions or removals. Altarea is analysing whether this might be done in coming years but has not yet quantified the projected value.

Altarea has implemented an environmental sufficiency policy covering water resources, in particular for its upstream value chain (building sites) and downstream where the marketing of real estate projects requires water. The Group commits to deploying water-efficient systems across all of its projects, in line with its actions to increase alignment with the taxonomy, and to identify real estate assets in areas of high and very high water stress in order to implement specific preservation actions. Altarea notes it has set targets for reducing water consumption in its various assets for around ten years. Water has a low financial materiality for the Group, so the issue is managed using a sufficiency approach to limit negative impacts on water stress.

The Group deploys actions including installing water-efficient equipment in new operations, integrating water recovery and reuse systems, incorporating local species into green spaces, raising customer awareness via guides, and installing water sub-meters to detect leaks. In 2024 Altarea conducted an initial comprehensive mapping of its sites using the Aqueduct tool of the World Resources Institute (WRI): of the 481 sites mapped, 112 are located in areas of high and very high water stress. Affected regions include France (Hauts-de-France, Normandy, Pays de la Loire, Nouvelle-Aquitaine, Occitanie and Provence-Alpes-Cote d'Azur) and Italy (Campania and Lazio). By 2028 the Group plans to develop a water resource management roadmap for each site identified in water-stressed areas, and the operating and capital expenditure for these actions is not considered significant.

Given the CSRD framework, 2025 will be the reference year for all targets. Targets include maintaining 100% DNSH alignment of the Water Management System for Residential Development projects (ongoing objective), integrating water resource recovery and reuse equipment in 100% of own operations located in high and very high water stress areas over 2025-2030, and installing recovery and reuse equipment for 100% of assets with a "Water" plan over 2025-2027. Altarea also targets reducing water consumption in Retail assets to maintain 1 L/visitor/year in 2030, covering the period 2019-2030. The definition of targets is based on internal analysis, not scientific analysis, and the Group did not specifically call on external stakeholders.

Total water consumption of REIT assets was 257,912 m3 in 2024 versus 274,923 m3 in 2023 pro forma, comprising 74,086 m3 in common areas and 183,825 m3 in private areas. Total water intensity from own operations was 951 m3 per million euros of REIT revenue in 2024 versus 1,163 in 2023, and common-area consumption was 0.97 L/visitors in 2024 versus 1.2 in 2023, with an 87% coverage rate by surface area. Total water consumption of assets located in areas of high and very high water stress was 129,776 m3 in 2024 versus 138,245 m3 in 2023, at 100% coverage. Data concern only Altarea Commerce's own operations and assets in France, collected for the period from 1 November 2023 to 31 October 2024 using the Deepki IT tool, and have not been verified by another external body.

To date the Altarea Group has not defined a transition plan or the consideration of biodiversity and ecosystems in its strategy or business model. For this first year of reporting, the Group prioritised the first phase of the LEAP analysis, namely the "Locate" phase, through use of the IBAT tool. The Group has given itself three years to study the actual impacts on biodiversity and ecosystems at the sensitive sites identified in order to determine whether they are material.

Biodiversity and ecosystem issues are taken into account in the Altarea Group's environmental policy, which aims to address important sustainability matters related to environmental issues. The content of the environmental policy is set out in the annex of the document in Section 4.2.6.

For preserving natural spaces and avoiding artificialisation, actions include deploying new biodiversity indicators in brands, systematising urban renovation and redevelopment, integrating open-air and permeable spaces to promote groundwater recharge, and offsetting the artificialisation of soils from Logistics projects by renaturing spaces. For protecting biodiversity and ecosystems, actions include planting (freshness islands, suitable local species), using independent ecologists to carry out ecological diagnoses, prohibiting the use of phytosanitary products by green space service providers, incorporating low-nuisance building site charters into contracts, raising awareness among shopping centre visitors, and identifying sites located in or near biodiversity-sensitive areas. The actions apply to all regions in which Altarea operates (France, Italy and Spain), though their precise deployment project by project is not yet systematically monitored.

For preserving natural spaces, targets are to increase the proportion of Property Development projects covered by artificialisation data to 50% by 2028 and the share of transactions covered by CBS data to 30% by 2028. For protecting biodiversity, the target is to increase the number of operations with one or more systems to facilitate water infiltration to 50% by 2028. Given the CSRD framework, 2025 will be the reference year for all targets. The targets set by Altarea are not based on and not aligned with the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy or other national biodiversity laws, and are assigned to the "prevention" level of the mitigation hierarchy.

In 2024, 1,225 sites were analysed in the IBAT tool, including 749 sites in operation and 476 sites under construction; 205 sites in operation and 109 sites under construction are located in or near a protected area. Sensitive sites were defined as operating sites located less than 500 meters from a biodiversity-sensitive area and sites under construction located less than one kilometre from one. In Property Development, only 6% of projects reported biotope area factor (BAF) data, 36% of Woodeum brand projects had a smaller sealed surface area post-project, and 25% of Development projects installed one or more systems to facilitate water infiltration; also 82% of Altarea Entreprise projects and 100% of Histoire & Patrimoine projects were renovations. In Retail, the average BREEAM In-Use score for certified shopping centres on the Land Use & Ecology theme was 42% in 2024 versus 16% in 2013, and 100% of BREEAM In-Use certified centres have a biodiversity action plan; in Business Property 44% of projects use an ecologist, i.e. 64% in terms of surface area.

Altarea's approach to resource use and the circular economy is based on an environmental policy aimed at addressing both raw materials consumption and waste management issues. The approach aims to achieve an increase in the use of renewable materials, reuse and rehabilitation; a more rational use of resources (compactness, architectural sufficiency); and an increase in waste sorting and downstream recovery. The Group's commitments on the material impacts, risks and opportunities related to the use of resources and the circular economy are an integral part of the Group's environmental policy (see Section 4.2.6). The policy prioritises waste management methods, promoting reuse and rehabilitation in development to avoid waste production (prevention), the recovery of materials (recycling) for building site waste, and all types of recovery (materials or energy) for shopping centre waste.

Altarea implements actions adapted to the characteristics of each project and asset, all of which have already been implemented and will be continued. Renovation-reconversion actions include using refurbishment and renovation of buildings when the project lends itself to it (systematic at Histoire & Patrimoine and the majority option at Altarea Entreprise), improving building compactness to consume less materials, developing off-site operations (pre-assembly of components), reusing materials (excavated soil, crushed concrete reused in certain backfill operations, plus cable trays and tiles), and developing modular projects. Waste sorting and recovery actions include increasing the number of flows for tenants' waste, awareness-raising among tenants, incorporating recovery requirements into the CCTP (special technical specifications) to contractually commit partners to minimum recovery levels, incorporating low-nuisance building site charters into contracts, establishing partnerships with digital building site waste management solutions, and using environmental project management consultants on large-scale projects. Operating and capital expenditure were deemed significant only for certain actions of the Renovation-Reconversion issue and are studied when defining a project; expenditures on the Waste sorting and recovery issue are not considered significant.

The Group has defined targets beyond 2024 with continuous improvement in mind, and given the CSRD framework, 2025 will be the reference year for all targets. The circularity targets are to keep the vast majority of revenue taxonomy-aligned (increase alignment with the taxonomy on the DNSH design and construction techniques favouring circularity) and to recover (material) more than 70% of Development waste on building sites. For Retail own operations, the targets are to sort over 50% of waste from assets and to recover over 80% of waste from assets (recycling and energy recovery). In addition, no targets have yet been set for compactness, the use of renewable materials in construction (wood, biosourced) or reuse, which are dealt with case-by-case. As an effectiveness measure of renovation targets, in 2024, 82% of Altarea Entreprise projects and 100% of Histoire & Patrimoine projects were renovations, compared with 62% of Altarea Entreprise projects and 100% of Histoire & Patrimoine projects last year.

The main resources used by Altarea are construction materials (concrete, steel, wood, glass, plaster, insulation, etc.) whose main impacts are therefore in the value chain. The weight of these resources used on building sites has not yet been calculated.

Altarea produces high-quality renovated or new buildings, which delays their obsolescence and saves the resources needed to construct new buildings. Increasing attention has been paid to the reparability and dismantling of the Group's projects for the past two years, in particular with regard to the requirements of alignment with the taxonomy, which require construction projects to integrate selective dismantling practices to facilitate reuse and recycling of materials. To date, Altarea does not have a comparison between the sustainability of its products and sector averages and has not yet calculated the proportion of recyclable content in its products. The types of waste generated are construction waste and waste from the operation of its shopping centres; this waste is largely non-hazardous, with the activities also generating some hazardous waste (solvents, paints, etc.) that the Group has given itself three years to report.

In 2024 the Group produced 227,234 tonnes of non-hazardous waste in Property Development (upstream building sites) and 5,407 tonnes in Retail (tenants and visitors). In Property Development, 138,089 tonnes (61%) were recovered, of which 133,334 tonnes (59%) through recycling, 4,368 tonnes (2%) through other recovery and 387 tonnes (0%) by preparation for reuse; 83,830 tonnes (37%) were eliminated, and the disposal method was unknown for 71,481 tonnes (31%). In Retail, 2,782 tonnes (51%) were recovered and 2,257 tonnes (42%) eliminated; comparing with 2023 pro forma (5,653 tonnes produced, 2,376 tonnes recovered), waste management improved with less waste produced (-4%), a higher recovery rate (+17%) and a reduction in disposal (-31%), notably a significant reduction in landfill waste (-83%). In 2024 the majority of waste was recovered (61%), more than 95% through material recovery, while 42% of waste is not recycled (approximately 97,000 tonnes); the Group continues its actions to achieve its objectives of 70% material recovery in Property Development and 80% recovery in Retail. The 2024 figures were based on reporting from 222 development projects (53% of projects under construction) and 18 retail assets (93% of assets by surface area), and have not been verified by an external body.

The Group has developed a human resources policy to manage impacts, risks and opportunities for its employees, based on three essential pillars: "engage", "attract" and "support". The scope of application concerns all Group companies and brands, is approved at the highest decision-making level (the Group's management) and complies with labour law and the rules of the International Labour Organization. All subsidiaries undertake to respect human rights and fundamental freedoms in line with ILO Conventions, the United Nations International Bill of Human Rights and the UN Guiding Principles on Business and Human Rights, and no employee may be subject to discrimination on any of the 26 grounds recognised by law. Altarea was awarded the Happy Trainees and Youth Engagement certificates for the seventh consecutive year, and Top Employers certification for the fifth year, recognising the HR policy for its 2,000 employees.

Social dialogue is one of the main pillars of the human resources policy, placing employees at the heart of decision-making through their CSE-elected representatives. Management and social partners meet monthly in addition to various committees (CSSCT health, safety and working conditions committee, training committee, professional equality, housing, etc.). In 2021 the Group's management and CSEs set up an Inter-Company Social and Cultural Activities Committee (CASCI), and in 2023 management proposed grouping the various CSEs into a "brand CSE" to create an additional level of social dialogue at Group level. Because of the size of the entities in Italy and Spain, formal mechanisms of employee representation are not required under local regulations, so dialogue takes the form of direct discussions between employees, the Deputy Director and the Human Resources Department.

Altarea has set up procedures and channels to receive concerns, involving the reporting line, HR, elected officials, the Ethics officer, members of the Ethics Committee, and harassment and sexism contacts (Group and CSE). The whistleblowing procedure allows employees to report any situation of non-compliance in a confidential manner while guaranteeing the rights of whistleblowers, and a conflict of interest management procedure helps each employee identify and manage conflicts of interest. In the event of reports of harassment and sexist behaviour, an internal investigation is set up and management takes the necessary precautionary measures and then the appropriate sanctions if necessary. The processes for disseminating and monitoring complaints are addressed in ESRS G1-1.

Altarea has defined a corrective action plan covering employer brand, quality of life and working conditions, compensation and benefits, and training and skills development, with actions applied across all Group employees. In 2024, 76% of women promoted benefited from mobility or personalised training, 36 nationalities were represented, and the Group recruited a Graduate intake affecting 5 employees with 13.2% work-study contracts at 31/12. In occupational health and safety, 88% of the workforce was trained, and on training and skills development 87.8% of employees were trained. Internal mobility filled 67.4% of positions, supported by a monthly "ALTAJOBS" newsletter.

The Group has defined targets beyond 2024 for continuous improvement, formally discussed with employee representatives. It aims for zero accidents in workplaces (value 2024: 10 accidents, versus 8 in 2023), and to train and engage all employees in generative AI (24.5% of employees informed in 2024). It targets outperforming the reference value for the percentage of women in management (35.3% of women have more than three open-ended contracts in 2024, versus 34.9% in 2023) and to maintain a sufficient level of internal mobility and promotion at +40% (67.4% in 2024 versus 50.7% in 2023). It also aims to maintain the "gender equality" index at a group average equivalent to year N, with 2024 scores of UES Altarea 89/100, UES Cogedim 86/100, UES Histoire & Patrimoine 90/100 and Woodeum 86/100.

Total headcount at 31 December 2024 was 1,981, comprising 847 men and 1,134 women, with 0 others and 0 not disclosed. Of these, 1,954 employees were on open-ended contracts and 27 on fixed-term contracts, while 1,918 were full-time and 63 part-time. During 2024, 361 employees left the Group, giving an employee departure rate of 17.9% and a staff turnover rate of 12.3%, against 157 hires. France accounted for 1,963 employees on fixed and open-ended contracts, and employees of subsidiaries in Italy and Spain are not recognised as these activities have fewer than 50 employees.

The Group is not currently in a position to centralise the files of its non-employees, so information relating to the characteristics of the Company's workforce is limited to employees on open-ended or fixed-term contracts but not work-study students. Non-employees (service providers, temporary workers, agents, corporate officers and interns) are only a marginal fraction of the workforce compared to salaried employees and are not managed centrally apart from interns. They provide the Group with flexibility during periods of high activity and specific expertise for particular technical needs, and are mainly subcontractors providing various services to the Group.

Collective bargaining coverage for employees in the EEA falls in the 80 to 100% band at 99.9%, and workplace representation in the EEA is also in the 80 to 100% band at 99.9%, for countries with more than 50 employees representing over 10% of total employees. Because of the size of the entities in Italy and Spain, formal mechanisms of employee representation are not required under local regulations, so dialogue takes the form of direct discussions between employees, the Deputy Director and the Human Resources Department.

At 31 December 2024, the headcount by gender was 57% women and 43% men, with women's share increasing and men's share decreasing year on year. In management, 35.3% of women have more than three open-ended contracts in 2024, up from 34.9% in 2023. The Group states this diversity information is provided on a voluntary basis to illustrate its social commitments but is not identified as material information with regard to ESRS S1 requirements.

The Group ensures that employees receive a salary at least equal to or higher than the national minimum wage in the countries where it operates, namely France, Spain and Italy, and complies with its various contractual obligations in this area. The Group pays all employees a living wage, that is a wage that allows employees to meet their basic needs and live in dignity, covering essential needs such as food, housing, clothing, healthcare, education and transportation. Compliance with national minimum wage standards has been prioritised as a fundamental part of its compensation strategy.

All Altarea employees benefit from social protection provided by the Group, offering coverage against the loss of income related to major life events such as illness, unemployment (provided that the employee is employed by the Group), workplace accidents, acquired disability, parental leave and retirement. Specific benefits in kind such as health and provident insurance are included in the compensation plan depending on the position.

In 2024, 1,025 women and 784 men had performance appraisals (57% women and 43% men), and a total of 850 women and 564 men were trained. Total hours monitored were 12,489 for women and 7,469 for men, averaging 15 hours per woman and 13 hours per man. Total expenditure on training was 3,621,421 euros, with 87.6% of employees completing at least one training course during the year, 2,851 training days per year and average training expenditure of 2,561 euros per employee trained. In 2024, 2,853 days of training were provided, representing 2.9% of the payroll, and 100% of new employees had access to onboarding modules on the Digital Academy.

In 2024 the Group recorded 10 workplace accidents, 0 occupational illnesses, 0 deaths related to occupational accidents or illnesses, a frequency rate of workplace accidents with time off of 2.9, and 651 days lost. All employees are covered by the health and safety management system, and the Group maintained a low absenteeism rate of 3.0%. The frequency rate of workplace accidents was 2.9% in 2024, up from 2.1% in 2023, confirming the effectiveness of efforts made to limit occupational risks.

All Group employees are authorised to take leave for family reasons: in 2024, 100% of both women and men were authorised, and 18.15% of women, 17.82% of men and 18.01% of the total Group took at least one period of family leave. Since 2018, Altarea has guaranteed full gross compensation without seniority conditions during maternity leave, and maintains gross compensation from one year of seniority during paternity leave, now 25 days. Since 2018 the Group has had a remote working charter, extended by a new charter in 2021, offering flexibility and taking into account employees' professional and personal situations, and a Group-level charter on the right to disconnect has been published.

The pay gap between men and women is calculated as the difference between the average annual salary of men and the annual salary of women, expressed as a percentage of the average annual salary of men. In 2024 the total remuneration ratio was 22% for the executive segment (25.0% in 2023), -16% for employees (-11% in 2023) and 6% for supervisors (-1% in 2023). In 2024 the ratio of annual compensation between the Group's highest-paid person and the rest of the employees was 788%. Gender equality index scores at 31 December 2024 were Altarea 89/100, Cogedim 86/100, Histoire & Patrimoine 90/100, Woodeum 86/100 and Cogedim Services Exploitation 91/100.

Altarea's approach to workers in the value chain is based on a policy covering human rights, including the fight against forced labour, as well as health and safety. This policy reflects the Group's commitment to comply with the strictest standards in these areas and to promote respect for human rights in its sphere of influence, ensuring the Group's brands are not complicit in violations of these rights. All of the human rights policy commitments are detailed in Altarea's social policy (see section 4.3.5).

As part of its normal conduct of business, the Group maintains regular interactions with workers in its value chain, particularly those on building sites and external staff in shopping centres. Dialogue takes place directly with these workers or their representatives in multiple forms (telephone, email, site meetings for development activities, exchanges with tenants in shopping centres). The issue of impacts on workers (safety, rights and working conditions) may be the subject of dedicated points or included in broader discussions. At present, Altarea has not defined a formal general process for dialogue with workers in its value chain or for assessing the effectiveness of this dialogue.

Altarea has not created a dedicated channel for workers in its value chain to voice their concerns. Nevertheless, as part of the normal conduct of business, the Group maintains regular interactions with workers in its value chain. Mechanisms such as contractual clauses, supplier questionnaires, on-site audits and regular dialogue with companies help ensure the Group's practices comply with voluntary initiatives such as the United Nations Guiding Principles on business and human rights, the United Nations Sustainable Development Goals, the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work and the OECD guiding principles for multinational companies. These interactions also make it possible to provide or contribute to remedies for any material negative impacts on workers the Group observes in the value chain.

The main prevention actions include the Responsible Purchasing Charter, which contractually commits suppliers to minimum social requirements (no use of forced or illegal labour, non-discrimination) and health and safety requirements, as well as contractual clauses on safety and illegal work. The Group uses the Attestation Legale digital solution to identify at-risk service providers, implements personal access control systems to combat illegal work on building sites, and has random audits done by an independent body. Resources are granted to the health and safety coordinator (HSO), employees are trained on safety and labour law, and building site audits are performed. With regard to remedial actions, Altarea has not defined a specific process; if it identifies a material negative impact on human rights in its value chain, the Group undertakes to analyse it and implement a corrective action plan.

To strengthen its approach to managing potential impacts on human rights and health and safety, the Group has defined targets beyond 2024, with 2025 as the reference year for all targets given the new CSRD framework. The first target is to aim for zero accidents on building sites and in retail assets (0 accidents, an ongoing objective). The second is to systematise accident reporting on building sites (100% of worksite operations with accident reporting, an ongoing objective). The targets were defined in 2024 based on internal analysis, without specifically consulting external stakeholders, but in consultation with the business lines.

Altarea's approach to the affected communities is based on a social policy covering all the communities mentioned above. It reflects Altarea's commitment to offer desirable and sustainable living spaces, contribute to local economic development, create places of discussion and solidarity, and maintain permanent exchanges with the affected communities. These different areas contribute to strengthening the Group's license to operate. All of the commitments in the human rights policy are detailed in the Group's societal policy (see Section 4.3.5).

To date, Altarea is considering the creation of a formal dialogue process for all its brands intended for the affected communities, and the Group does not yet have a formalised procedure for assessing the effectiveness of this dialogue. In Property Development projects, discussions take place at two stages: upstream of operations with ad hoc consultation meetings to present the project to potentially affected communities such as local residents, and during construction with the possibility for communities to interact with operational staff, generally through the display of a contact number on site information boards. With regard to the Retail REIT business, the dialogue is conducted by the teams of the centres, who may be in contact with local communities and their representatives such as local elected representatives. There are occasional exchanges between Altarea's teams and the affected communities.

Potentially negative impacts on the affected communities were not identified as material during the double materiality analysis. Dialogue with affected communities is presented in the previous section on the Dialogue Process (S3-2).

The Group has implemented ongoing actions advancing its social policy, including using local service providers for property development and asset management, encouraging service providers to hire people alienated from the jobs market, and systematising local employment schemes in Retail through employment forums and job dating. Under the third edition of "Tous engages pour vos projets solidaires", the Group financed employees' charitable projects with 4 winning projects in 2024 chosen by a jury of Group employees, and it marked 15 years of partnership with Habitat et Humanisme. It also incorporates the low-nuisance building sites charter into Property Development contracts and develops mixed-use urban projects, projects in priority city neighbourhoods and high-demand areas, managed residences, and heritage rehabilitation via Histoire & Patrimoine. As 2024 is the first year a sustainability report has been produced, the Group has given itself three years to report all its actions in accordance with the publication requirements.

Altarea has no plans to set targets for this ESRS. In 2024, to measure its impact, the Group conducted an in-depth study on the actual impact of its business lines and operations on communities and created social metrics to quantify its social usefulness across key themes: economic dynamism of the region, social and environmental phenomena of urban transformation, and issues of diversity and solidarity. The various social metrics are regularly monitored to analyse the contribution of the Group's activities to the public interest.

Altarea has deployed a social policy that takes into account consumer and end-user issues, seeking in particular to prevent, mitigate and remedy the impacts identified and to make it possible to manage risks and seize opportunities. All commitments and details are described in the Group's social policy, located in Section 4.3.4 of the sustainability report. At 31 December 2024, there were no reported cases of non-respect of human rights relating to consumers and end-users. The two material issues identified are customer purchasing power (high materiality) and information, safety and well-being of occupants and users (limited materiality).

Customer satisfaction guides Altarea's actions through a continuous process of listening to and analysing customers' perceptions and expectations, with structured systems for engagement and satisfaction monitoring across each activity. Brands regularly conduct random surveys and mystery shopper campaigns to monitor their Net Promoter Score (NPS), an international indicator for customer satisfaction, and since 2021 the NPS has been included in the calculation of Altarea's profit-sharing agreement. In 2024, more than 450 people among internal and external sales teams were made aware of CSR issues, and Cogedim won the Customer Service of the Year award in the Real Estate Development category for the seventh time and topped the Les Echos customer relations ranking awarded by HCG for the second consecutive year. In Retail, Altarea launched the Tandem approach in 2022 defining five key values (cooperation, clarity, tailor-made, reliability and CSR), assesses NPS with retailers with around 200 retailers involved in surveys each year, and has rolled out the green lease since 2010. Since 2023, Altarea has carried out biennial customer satisfaction surveys at all its retail assets, measuring the satisfaction index of twelve centres.

Altarea's double materiality analysis did not lead to the identification of any negative material impacts on consumers and end-users, but if potential negative impacts were to manifest the Group undertakes to address the issue and resolve any material consequences. In all its brands, Altarea has defined channels enabling customers to express concerns, providing at least contact forms with email addresses easily accessible from their websites, and the internal contact assigned to the customer monitors the processing of their request for as long as the grievance remains unresolved. In Residential, around twenty dedicated employees intervene as quickly as possible, and other channels include online customer areas at Cogedim and Woodeum and the telephone numbers of customer relations managers. In the Retail activity, when a customer expresses dissatisfaction to the retail asset teams, Altarea undertakes to systematically contact them again to remedy the situation when it falls within its remit.

In 2024, in response to the housing crisis, Altarea launched its Access offer for first-time buyers, based on a change in product design and an innovative financing offer (paid notary fees, monthly payments equivalent to the price of rent), relying on partnerships with Credit Agricole Ile-de-France and LCL Habitat. Actions also include developing social housing, diversified commercial spaces adapted to different brands, certification of operations, making customer service accessible to the deaf and hard of hearing through Cogedim's association with Sourdline, developing accessible buildings for people with reduced mobility, and integrating outdoor spaces and islands of coolness into projects. To promote sustainable mobility, Altarea installs bicycle storage and deploys electric vehicle charging points in shopping centres, partnering with Electra for rapid charging. All Altarea employees and corporate officers must comply with the principles established in the Ethics Charter and IT Charter, and as 2024 is the first year of a sustainability report the Group has given itself three years to report its actions in accordance with the disclosure requirements.

Given the new regulatory framework of the CSRD, 2025 will be the reference year for all targets. The Group's ongoing targets are that 100% of the Group's brands have a tool to measure customer satisfaction, 100% of Residential projects are NF Habitat and/or BBCA certified, 100% of office projects are certified at least HQE Very Good and/or BREEAM Very Good, and 100% of shopping centres are at least BREEAM In-Use Very Good certified. A further ongoing target is that more than 95% of Residential and Business Property projects are located less than 500 meters from public transport. The issue of consumer purchasing power is not subject to a quantitative target due to the recent launch of the Access offer, the issue of accessibility for people with reduced mobility is not subject to a quantitative target because it is systematic and governed by French regulations, and comfort and well-being is not accompanied by quantitative targets because certification and label specifications partly cover these matters.

Altarea has a strong entrepreneurial culture driven by its President and Founder, whose family holds nearly 46% of the capital, and is organised as a partnership limited by shares (societe en commandite par actions) with a dual governance structure, referring to the AFEP-MEDEF Code where compatible with this legal form. The Altarea Group Ethics Charter sets out values and principles including probity, loyalty, conflict of interest rules, prevention of and fight against corruption, and zero tolerance for unethical practices, and since 2019 the Group has been committed to the United Nations Global Compact. A professional whistleblowing line, complying with the European Whistleblowing Directive and Sapin II, allows employees and third parties to report unlawful behaviour via the secure address alerte-ethique@altarea.com accessible only to the Group Ethics Officer, with the mailbox protected in a context of ISO 27001 certification. The Group did not detect any form of behaviour that did not comply with its ethical values and regulations, either for this period or the preceding period, and the number of whistleblowing alerts during this period is zero. Business conduct training is delivered at all levels via the Digital Academy e-learning site, and a Conflict of Interest Management Policy and an IT Cybersecurity Policy complete the framework.

Altarea is a major customer, a large part of whose purchases are related to construction (structural work, electricity, heating, ventilation, air conditioning, plumbing), with the remainder mainly general operating expenses and shopping centre operating costs. The responsible purchasing approach provides for generalised actions including deployment of a Responsible Purchasing Charter covering minimum social requirements (no forced or illegal labour, non-discrimination) and health and safety requirements, adapted systems by type of purchase (CSR clauses in calls for tenders and contracts, training, audits), and work to forge sustainable partnerships with suppliers. Altarea has launched an assessment process for some of its suppliers (sanitary products, electrical equipment, heating) via the Ecovadis platform, scoring them by topic (environment, social and human rights, ethics and responsible purchasing). The Group also prioritises purchases from local service providers, and notes that there is currently no procedure for assessing suppliers according to CSR criteria.

Altarea's prevention and detection approach is embodied by an anti-corruption policy reflected in the Group's ethics charter, a regularly updated corruption risk mapping (with operational roll-out of the Retail and new business lines mapping in the second half of 2025 and an update of the Group's risk mapping scheduled for the first quarter of 2026), a conflict of interest management policy, integrity assessment of permanent third parties, permanent anti-corruption accounting controls, and anti-corruption clauses always included in all contracts. Anti-corruption law training (Sapin II law) is delivered in-person and online to all human capital on an annual basis, with dedicated ongoing training covering 100% of risk functions and e-learning followed by more than 80% of the workforce. Additional annual modules cover fraud awareness (bank details fraud, fake president fraud), combatting money laundering and the financing of terrorism, and probity and ethics for Property Development entities. Functions more exposed to corruption risk include Purchasing, Retail and land development, Public Affairs and Regional Strategy, and Program Management, and the Group submits an annual declaration of lobbying activities to the HATVP.

No incidents of corruption or bribery were detected or reported during the reporting period, and the Group is not subject to any legal proceedings for corruption and has not paid any fines in this respect. Examples of potential value chain corruption covered during training and awareness sessions include corruption in purchasing (suppliers offering bribes to obtain contracts), corruption in logistics (bribes to speed up processes or avoid inspections), and corruption in production (subcontractors falsifying documents). The Group deploys preventive actions across all its activities, including presentation of the Ethics Charter at onboarding, protection of whistle-blowers, and audits based on risk mapping using external audit firms where necessary.

The Altarea Group refrains from any donations or funding to political parties or associations, and lobbying activities are supervised by the Group's Executive Management. In accordance with the Sapin II law, the Group submits an annual declaration of lobbying actions to the HATVP within the legal deadlines and in accordance with the HATVP guide to lobbying declarations. In 2024, the Group drafted several contributions to inform public decision-makers about national housing policy, leading to meetings with national and local decision-makers and discussions with real estate and commercial federations, in particular the Federation des Entreprises Immobilieres (FEI), the Federation des Promoteurs Immobiliers (FPI) and the Federation des Acteurs du Commerce dans les Territoires (FACT). Altarea is registered in the transparency register of an EU Member State, France, and no member of the management or supervisory bodies has held a comparable position in a public administration.

The Group's standard payment terms are 45 days for works in accordance with the legal terms for payment, and for the vast majority of invoices the payment period is in line with these deadlines. Altarea set up a digital workflow system for validating its invoices and offers suppliers who wish it a reverse factoring solution for real estate development projects, though some invoices may exceed the standard deadlines, often due to incorrectly or partially drafted invoices requiring manual intervention. To date, the Group is not involved in any dispute with its suppliers in respect of payment terms, and specific controls carried out by the DGCCRF over the last two years have not revealed any anomalies. Due to this absence of litigation and significant misstatements, Altarea did not implement specific procedures to determine its average supplier payment period, and the Group will study the possibility of supplementing the information on payment terms in coming years to meet the requirements of the CSRD more precisely.