Aroundtown

Governance roles

Reference: pages 54-58. Listed in the ESRS content index at pages 54-58 (page 77) and repeated for G1 at page 150.

Board of Directors (7 members) – two executive directors (Frank Roseen, Jelena Afxentiou), one non-executive (Ran Laufer) and four independent directors (Markus Leininger, Simone Runge-Brandner, Markus Kreuter, Daniel Malkin), so 57% independent, four of seven (pages 54, 56).

Management Body (4 members) – Co-CEO/COO Barak Bar-Hen, CFO Jonas Tinelnot (from Q4 2025, succeeding Eyal Ben David who stepped down end of October 2025), CSO Limor Bermann and CCMO Timothy Wright (page 54).

Diversity (page 56): Board and Management Body combined are 73% male (8) and 27% female (3); the Board itself is 71% male, 29% female.

Committees (page 56): Audit (chair Markus Kreuter), ESG (chair Markus Leininger), Risk (chair Markus Kreuter), Remuneration and Nomination. "Each Board committee's responsibilities for sustainability oversight are defined in their Rules of Procedure." The ESG Committee "meets at least once a year on ESG topics" and includes advisory members – the CSO, Head of Energy, COO of the German operations and Group Head of HR (page 58).

Board expertise is set out in a Board Competencies Matrix built from a self-assessment questionnaire, covering real estate, finance/banking/auditing, business management, crisis and risk management, IT and cyber security, environment and sustainability, international experience and M&A (page 55). An Advisory Board with no statutory powers advises the Board (page 55).

Information provided to the administrative, management and supervisory bodies

Reference: page 59.

The Board receives "regular and structured updates" on sustainability impacts, risks and opportunities and on committee activity. The Management Body receives quarterly updates from department heads, including the Chief of Sustainability, Head of HR, Head of Energy and Head of Compliance, plus ad-hoc briefings "regarding pressing issues" (page 59).

Matters actually addressed in 2025 (page 59), starting with a review of the DMA results:

• Impacts – internal processes for managing the Energy Performance Certificate database, to prioritise energy-inefficient assets; portfolio energy management and expansion of Green PPA coverage, including "assessment of large-scale greenfield renewable energy investment opportunities".
• Risks – the recast EU Energy Performance of Buildings Directive and its effect on "high-priority assets (EPC F, G, H-rated properties)"; energy improvement across high-priority assets and alignment with the Transition Plan; "ongoing physical and transition climate risk assessments affecting property portfolios in Germany, the Netherlands and the UK".
• Opportunities – the ATechX Accelerator Program, whose second cohort completed in September 2025, bringing the total to 10 accelerated start-ups, "with approximately 50% focused on enabling reduced carbon emissions and energy costs"; tenant engagement and the Community Involvement and Development Guidelines.

The Group states "No trade-offs associated with those impacts, risks and opportunities were considered" (page 59).

Sustainability in incentive schemes

Reference: page 60, with the climate-specific cut at page 81.

For 2025, 30% of the variable short-term and 30% of the long-term remuneration for the Management Body and Executive Directors "is directly tied to achieving sustainability-related targets" (page 60).

Four sustainability targets sit in the schemes (page 60):

• LTIP Target 4 – Corporate ESG Rating: 20% of LTIP remuneration. The Group "aims to maintain or improve its score in at least scoring criteria areas among its prioritized ESG ratings".
• LTIP Target 5 – Gender Equality: 10% of LTIP remuneration.
• STIP Target 3 – Emission Reduction: 15% of STIP remuneration, measured on "Progress towards Scope 1 + 2 of the emission reductions, aligned with the Group's emission reduction pathway plan".
• STIP Target 4 – Green Building Certification: 15% of STIP remuneration, through "increasing the portion (%) of buildings with green certification".

Terms are approved at Board level on the Remuneration Committee's recommendation, and a Remuneration Report designating the split between financial and sustainability targets is published annually with the AGM materials under Article 7 of the Luxembourg law of 24 May 2011 (pages 60, 81). The policy does not apply to the Advisory Board (page 81).

Statement on due diligence

Reference: page 61.

Table 4 maps the five core elements of due diligence to the sections that carry them (page 61):

• Embedding in governance, strategy and business model – ESRS 2 GOV-5, SBM-1, SBM-2
• Engaging with affected stakeholders – SBM-1, SBM-2, S2.SBM-3, S2-4, G1-2
• Identifying and assessing adverse impacts – S2.SBM-3, S2-1, S2-4, G1-2
• Taking actions – S2.SBM-3, S2-1, S2-4, G1-2
• Tracking effectiveness and communicating – S2-4, S2-5, G1-2

In practice, due diligence is integrated into asset acquisition and financing "through legal, financial, operational and ESG assessments" and into supplier onboarding via KYC and AML checks and the Code of Conduct for Business Partners (page 61). Human rights due diligence for value chain workers is "guided by the Human Rights Policy and Business Partner Code of Conduct, supported by risk assessments, a Business Partner Questionnaire, and where necessary, escalation up to the termination of business relationships" (page 61).

The limited assurance report draws an Emphasis of Matter on this disclosure, noting that GOV-4 and IRO-1 "explain future improvements in the ongoing due diligence and double materiality assessment process" and that the statement "may not include every impact, risk and opportunity" a stakeholder might consider important; the conclusion is not modified (page 162).

Risk management and internal controls over sustainability reporting

Reference: pages 61-63.

A multi-step review and approval process governs sustainability data: information is first reviewed by the head of the relevant department, then verified by the Sustainability Department, then reviewed by the Management Body, "before being presented to the ESG and Audit committees for final approval prior to publishing" (page 61).

Beyond that, the system covers integration with enterprise risk management, named accountability per department (HR, Energy, Compliance), regulatory monitoring by the Sustainability and Compliance Departments, and digital tools – "In 2025, AT adopted an ESRS reporting tool" and ran "a pilot with an energy and emissions data management platform to digitalize, centralize and ultimately improve data quality" (page 62).

Four key reporting risks with mitigations are disclosed (page 62): data accuracy and completeness; regulatory and compliance risk; stakeholder trust; and "Value Chain Intransparency: Limited visibility over ESG performance of suppliers and contractors."

Findings feed back into policy adjustments, operational enhancements, training curricula and the ESG strategy (page 63). The Risk Officer presents sustainability risk findings to the Risk Committee "at least once per year, or as needed", and material departmental risks are escalated to the relevant Board committees (page 63).

Strategy, business model and value chain

Reference: pages 63-66.

Aroundtown is a Luxembourg-domiciled real estate group holding income-generating commercial property (offices in prime European city locations, hotels let to third-party operators, grocery-anchored retail, logistics and industrial) plus a residential portfolio held through its 63% stake in Grand City Properties S.A. ("GCP") (page 63). The footprint is concentrated in Germany, the Netherlands and London, with holdings in Paris, Rome, Brussels, Warsaw and Athens (page 64). "In 2025, no new products or services were introduced, nor were any removed" (page 63).

Workforce: 1,621 employees at 31 December 2025 – 1,299 permanent (80%), 322 temporary (20%), 1,440 full-time (89%), 165 part-time (10%) and 16 on non-guaranteed hours (1%); the figure "excludes external contractors and temporary workers engaged through third-party agreements" (page 64).

Sustainability-related goals: "achieving a 40% reduction in CO2 emissions by 2030 (compared to 2019 levels)", with 70% of the commercial portfolio green-certified, including 79% of offices and 65% of hotels (page 64). Named challenges are high upfront investment, EU Taxonomy compliance effort and "the decarbonization of an aging real estate portfolio, especially in historic city centers" (page 64).

The value chain is set out in nine numbered steps across upstream (asset acquisition; procurement, with 1st-tier services such as architectural planning, engineering and energy auditing and 2nd-3rd tier material sourcing), own operations (property management, asset management, marketing and leasing, ESG/compliance/risk, refurbishment and development) and downstream (consolidated reporting and investor relations; exit strategies) (pages 65-66).

Interests and views of stakeholders

Reference: pages 66-67.

Six key stakeholder groups were identified in the DMA process: tenants, employees, investors, local communities, and suppliers and contractors, categorised as internal (employees) and external (page 66).

Engagement channels are assigned to named owners (pages 67):

• Tenants – continuous feedback through the Customer Service Center and service-agent interaction; community events at GCP residential properties
• Employees – annual satisfaction surveys and HR roundtables
• Investors – quarterly investor meetings, conferences, roadshows and general meetings
• Suppliers – Business Partner and Know-Your-Customer teams evaluating compliance with the Code of Conduct for Business Partners

Stated stakeholder interests: tenants want reliable services and energy-efficient properties, residential tenants affordable housing; employees career development, fair treatment and workplace safety; investors "transparent ESG reporting, compliance, appropriate risk management, and stable returns"; suppliers "working conditions and reliable payments" (page 67).

The Board and Management Body are informed by department heads, with the Sustainability Department presenting the DMA outcome and HR presenting employee survey results (page 67). The Group is explicit about the limits: "While stakeholder feedback plays a crucial role in refining AT's practices, it has not led to major amendments to the Group's overall strategy or business model in recent years" (page 67).

Material impacts, risks and opportunities

Reference: pages 68-74.

The comprehensive DMA was run in 2024; for 2025 "the Group did not repeat a comprehensive DMA... but instead conducted a review of the 2024 results", adding peer research and industry studies (page 68). "of the 40 topics assessed, four of them were found to be of either environmental, social or governance impact, and nine were found to be double material" (page 68).

The one substantive change is the removal of a topic: "the DMA review in 2025 found that the topic of Pollution (ESRS E2) was not material for the Group and has therefore been removed from this report" (page 68); the removal "was confirmed and approved by the Board in July 2025" (page 77).

Material IROs are tabulated per standard: Table 5 E1 (page 69), Table 6 S1 (page 70), Table 7 S2 and Table 8 S4 (page 71), Table 9 G1 (page 72), with a sub-topic materiality matrix at page 73. Each row carries an IRO category, a value chain location and a time horizon (short-term 12 months, medium-term 1-5 years, long-term over 5 years, page 68).

ESRS S3 is expressly excluded: "the DMA for Aroundtown did not uncover any material IROs in relation to affected communities", and although GCP's own DMA found material impacts "in particular regarding the topic of adequate housing", that topic "is not relevant for Aroundtown as a commercial real estate company and not material on a Group level" (page 68).

Anticipated financial effects are described only qualitatively – climate risks "may affect property valuations and insurance-related exposures" and could require "adjustments to the carrying amounts of certain assets or liabilities" (page 74). Two entity-specific material topics are named: "G1 Business conduct: Investor relations – access to capital and investor relations – reputation" (page 74).

Processes to identify and assess material IROs

Reference: pages 74-76.

The methodology is that of the 2024 DMA, "which is still valid": document the business model, map the value chain, hold a relevance workshop to refine the IRO list, then score each IRO "on dimensions such as likelihood, scale, scope, and irremediability", survey internal and external stakeholders on impact and financial materiality "with weighted inputs based on stakeholder priority", and resolve gaps through interviews and leadership decisions (page 74).

Assumptions are disclosed unusually plainly (page 74):

• Likelihood, scale, scope and irremediability were scored "using a standardized 1-5 scale", assuming "subjective judgments across different stakeholder groups will align sufficiently to ensure consistent results".
• "A threshold of ≥2.5 was set for materiality, despite varying sensitivities across different industries or stakeholder groups."
• "due to lack of accessibility of some stakeholders, internal employees with relevant expertise and regular exposure to these groups represented these external stakeholders. This applies particularly to less accessible groups like communities."
• "a threshold of >30% 'I don't know' indicated the need for expert intervention and leadership decision-making".

The process is anchored on EFRAG IG 1: Materiality Assessment Implementation Guidance and on the Group's Human Rights Policy and Codes of Conduct (page 75). Heightened-risk areas named are construction and maintenance contractors "in regions where labor laws are less stringent", tenant data management and GDPR, tenant energy consumption, and "properties located in regions vulnerable to physical climate risks, such as flooding" (page 75).

The Group concedes an open gap: "Aroundtown is still in the process of developing its methodology for identifying, assessing, prioritizing, and monitoring risks and opportunities with potential financial effects" (page 76).

Disclosure requirements covered

Reference: pages 77-79.

Aroundtown prints a full ESRS content index over three pages, tabulating each disclosure requirement against a page range, split by standard: ESRS 2 and E1 (page 77), S1 and S2 (page 78), S4 and G1 (page 79). Section-level "High-Level Overview of Disclosure" tables repeat the same lists at the head of each chapter (pages 50, 80, 115, 131, 138, 149).

The index covers ESRS 2 BP-1 through IRO-2 (pages 50-79); E1.GOV-3, E1-1, E1.SBM-3, E1.IRO-1 and E1-2 to E1-8 (pages 81-108); EU Taxonomy Disclosures (pages 109-114); S1.SBM-2, S1.SBM-3, S1-1 to S1-6 and S1-9 to S1-17 (pages 117-130); S2.SBM-2, S2.SBM-3, S2-1, S2-4 and S2-5 (pages 132-137); S4.SBM-2, S4.SBM-3 and S4-1 to S4-5 (pages 139-148); and G1.GOV-1, G1-1 to G1-4 and G1-6 (pages 150-157).

Requirements absent from the index: E1-9, S1-7, S1-8, S2-2, S2-3 and G1-5, plus the whole of E2, E3, E4, E5 and S3.

A separate Appendix, "ESRS 2 IRO 2: List of data points that derive from other EU legislation and information on their location in sustainability statement", runs from pages 158 to 160 and flags each datapoint Material Yes/No with a page reference.

The Group applies phase-ins: "Aroundtown has decided to apply the phase-in provisions in accordance with Appendix C of ESRS 1. AT is committed to a full disclosure of these data points in the coming years, as required" (page 50). It also confirms it "has not exercised the option to omit specific information related to intellectual property, know-how, or results of innovation" and has not used the Article 19a(3)/29a(3) exemptions (page 51).

Transition plan for climate change mitigation

Reference: pages 81-84.

The Climate Transition Plan (formerly the CO2 Reduction Pathway) was substantially revised over 2024 and sets out the route to "our published target of 40% reduction in CO2 emissions intensity through 2030 compared against the 2019 baseline". "In 2025, the Group has kept the Climate Transition Plan unchanged as the focus this last year has been on collecting practical experiences and feedback data from implementation of the Climate Transition Plan's pilot projects" (page 81).

It prioritises the least energy-efficient assets by reference to the recast EU Energy Performance of Buildings Directive (EPBD), using property-level energy audits to gather energy savings and cost data, which are then "extrapolated across the portfolio" (pages 81-82).

Paris alignment is expressly denied: "The targets for which the Climate Transition Plan is designed to address are currently not compatible with the limiting of global warming to 1.5°C in line with the Paris Agreement" (page 82). CRREM 1.5°C pathways were nonetheless used as a comparison scenario (pages 82, 89).

Locked-in emissions: "The heating systems in our properties typically have an operational lifespan of up to 30 years. Hence, the investment decisions taken today have an impact on locked-in GHG emissions during this time period" (page 82). No quantification is given. The Group confirms it "has not invested capital expenditure ('CapEx') related to coal, oil, and gas-related economic activities as defined under ESRS E1 paragraph 16f" and is not excluded from EU Paris-aligned benchmarks (page 82).

CapEx: "the Group has estimates of the CapEx required to meet the target but has not yet formally allocated the CapEx over the medium-term", pending pilot project data; "The Climate Transition Plan solely focuses on CapEx measures... thus OpEx plans are not involved in the strategy" (page 83). The plan was "presented to the Management Body" and "the overall Climate Transition Plan were approved", with specific budgets then allocated to pilot projects (page 83).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 E1.IRO-1 and E1.SBM-3, where this content is disclosed in the FY2025 report (pages 85-90). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 85-90.

Risk classification. Only transition risks were found material: "Transition to low carbon economy (incl. Net Zero Carbon)", "Transition legislation" and "Renewable energy deployment" (page 85). Physical risk is explicitly out of scope of the DMA outcome – "climate change adaptation and related physical climate risks are relevant, they have not been classified as material sustainability matters in this year's DMA" (page 80) – though physical climate risk assessments continue for Germany, the Netherlands and the UK (page 59).

Methodology. The Sustainability Department, with the Risk Officer, "conducts an annual resilience analysis of identified climate-related transitional risk factors", presented to the Risk Committee (page 85). Table 11 (pages 86-88) is a TCFD-framed matrix with six risk categories – Policy, Legal, Market, Energy, Technology and Reputation – each with description, impact, timeframe (S/M/L), mitigation strategy and opportunity.

Scenarios (page 85). Qualitatively: the IPCC Shared Socioeconomic Pathways, and IEA STEPS (Stated Policies) and Net Zero GHG Emissions by 2050, in the formulations of the IEA World Energy Outlook 2025. Quantitatively (page 89): a "current policy" scenario built from the 10-year regulatory outlook, compared against CRREM 1.5-degree pathways, "which follows the Sector Decarbonization Approach". "No changes to scenarios were identified in 2025."

Scope (page 89). The quantitative analysis used "a more targeted scope, specifically the operational control portfolio... limited to assets in Germany, with plans to expand this scope over time", including tenant-controlled spaces under Scope 3 Category 13.

Gap worth noting: no global average temperature projection is stated per scenario, and the Group records that "Quantitative scenario analysis of climate-related risks faces challenges due to missing data, as climate scenarios often extend far beyond time horizons conventionally applied in strategic business planning" (page 89).

Resilience in relation to climate change

Back-filled from ESRS 2 E1.SBM-3 and the ESRS 2 SBM-3 resilience passage, where this content is disclosed in the FY2025 report (pages 74, 85, 89-90). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 89-90.

A resilience analysis is performed, and annually. "The qualitative resilience analysis is conducted annually, with the most recent exercise being in 2025, using the previous year's analysis as a baseline and then incorporating observed developments in risk factors in AT's countries of operation over the elapsed year, as well as any material changes in the scenarios used" (page 85). It is run "at the corporate level, i.e. aligned with the financial consolidation scope" (page 85).

Results for strategy and business model (page 89): "our business model of providing commercial real estate in core locations and our subsidiary Grand City Properties' provision affordable residential spaces in urban areas will remain relevant throughout every possible transformation scenario... the most recent resilience analysis leaves the Group confident in its ability to adjust its strategy and business model to climate change should an increase in applicable policy ambitions occur."

Uncertainty is named (page 89): "the degree of severity of transition events can vary significantly due to the gap between current policies and the Paris-Aligned scenario noted several times in the discussion above". At page 86 the Group adds that "The precise level of grant and subsidy programs to be expected as EU member states implement the EPBD leave some uncertainty regarding the financial impact that mitigating actions have on the Group."

Capacity to adapt (page 89-90): distinct investment packages "represent a modular approach tailored to the policy requirements of the scenarios", and "the scenario analysis conducted lays the groundwork for adapting to a potential increase in policy ambitions". Governance is assigned: the Board owns corporate-level climate risk, the Operations Department owns property-level climate risk, and a cross-departmental Building Resilience Taskforce develops action plans and adaptation solutions (pages 89-90).

The ESRS 2 resilience passage adds that access to capital "(green) bonds, bank loans, public funding" is "critical to manage this transition in the most cost-effective way" (page 93) and that the business model is evaluated "against a range of plausible future scenarios" (page 74).

Policies related to climate change mitigation and adaptation

Reference: page 91.

One policy carries the climate topic: the Environmental and Energy Policy, "a concise yet comprehensive policy outlining our activities to mitigate and adapt to climate change. Our Environmental and Energy Policy addresses the need to reduce our operational GHG emissions and includes within our scope the reduction of energy and water consumption, as well as generation of waste and air pollution" (page 91).

• Most senior accountable level: "The Board of Directors is the most senior level at Aroundtown responsible for the implementation of the policy", and the Board also reviews and approves updates. It "was most recently updated in 2024" (page 91).
• Scope: "applies globally to Aroundtown, specifically to its direct operations" (page 91).
• Third-party standards: none – "The policy does not involve third-party standards or initiatives in its implementation, as it primarily focuses on improving environmental impacts through implementing decarbonization levers mentioned in section E1-1" (page 91).
• Availability: "publicly available to all stakeholders through the Sustainability Governance web page on the Group website" (page 91).
• IRO coverage: the policy "responds to all material impacts, risks, and opportunities outlined in our DMA... specifically climate change mitigation, and energy efficiency, while also covering the non-material topics of water, pollution, and waste" (page 91).

The targets set in the policy are quoted in the corresponding sections of the report rather than in E1-2 itself (page 91). Responsibilities under the policy are split "at the asset and company-level between operations and Management Body" (page 91).

Actions and resources in relation to climate change policies

Reference: pages 91-93.

Table 12 (page 91) allocates the whole 40% reduction target across value chain stages and levers, and the three shares sum exactly to the target:

• Upstream 27.63% – renewable energy procurement and grid decarbonization
• Own operations, landlord-controlled 4.64% – connection to district heating and planned decarbonization of heating grids; installing solar PV systems
• Own operations and downstream, tenant-controlled 7.73% – hydraulic balancing, energy monitoring and heating automation; digitalization and optimization of heating systems; air-source and hybrid heat pumps; building envelope improvements (insulation, windows)

Actions taken in 2025 (page 93): new energy audits "covering more than 500,000 m² of floor area across its portfolio", forming "the technical and financial foundation of the Group's residential decarbonization strategy". Targeted intervention on EPC F/G/H residential assets "reduced the number of high-priority assets in the Group residential portfolio by 6 percentage points and increased the share of regulation-ready assets in its residential portfolio from 78% to 84%", regulation-ready meaning assets that "meet the energy-efficiency levels required by EPBD over the next 15 years".

Audits produce modular investment packages across four categories – Heat System Optimization, Heat Pump Installation, Building Envelope intervention and Heat System Replacement – with "low cost and high-impact measures... prioritized for immediate implementation at scale" (page 93).

Table 13 (page 92) maps each lever to EU Taxonomy activities 7.2, 7.3, 7.5 and 7.6.

A candid data limitation is disclosed: past investments "were implemented without the required reporting lines in place to collect data at the granularity required to accurately attribute the proportions of achieved GHG emission reductions to each individual decarbonization lever. Thus, this disaggregation cannot be provided", and "We are not able to provide a timeline for when a fully improved data basis will be achieved" (pages 92-93).

Targets related to climate change mitigation and adaptation

Reference: pages 93-96.

Three targets (page 94):

1. "Achieve a 40% reduction in CO2 intensity through 2030 against the 2019 baseline, measured in CO2-equivalent emissions intensity (kgCO2e/m2)"
2. "Achieve a 20% reduction in energy intensity through 2030 against the 2019 baseline, measured in kWh/m²"
3. "Switch 100% of landlord-obtained electricity to renewable sources, with at least 50% covered by Power Purchasing Agreements ("PPAs") certified renewable electricity from wind, hydro-electric and solar PV sources by the end of 2027, and the remaining percentage covered by Guarantee of Origin contracts"

Table 14 (page 94) – total carbon intensity, kgCO2e/sqm*year: 51.47 (2019) → 33.77 (2024) → 30.20 (2025), against a 2030 target of 30.88. Components in 2025: Scope 1 1.70, Scope 2 4.76, Scope 3 Cat 13 fossil fuels 6.65, Scope 3 Cat 13 grid energy 17.09. "In the year 2025, the Group achieved an GHG emission reduction of 41% compared to its 2019 baseline, meaning the Group has already exceeded its expected emission reduction through the year 2030" (page 91), "sooner than initially planned due to the implementation of efficiency and energy sourcing measures across the portfolio, together with more favorable emissions factors for purchased energy than originally modelled" (page 94).

Table 15 (page 95) – total energy intensity, kWh/sqm*year: 173.61 (2019) → 120.44 (2024) → 123.35 (2025), against a 2030 target of 138.89; the target "had already been achieved in 2023", and 2025 rose on colder German temperatures but "still stays below the 20% reduction target".

Renewable electricity target (page 96): revised in 2025 "as part of a strategic recalibration"; 2025 progress in the German operational control portfolio is 12% of landlord-obtained electricity under PPAs and 61% renewable in total. The Group states this target "did not require science-based consideration and scenario analysis in its target-setting as it was seen as a common-sense decision".

Limitations disclosed: no absolute GHG or energy targets ("normalization by floor area is considered best practice in the real estate sector"), no interim milestones, location-based only, and a constant portfolio assumed between 2025 and 2030 (pages 95-96). 2019 figures "have not been subject to assurance procedures" (page 93).

Energy consumption and mix

Reference: pages 96-101.

Total energy consumption 966,717 MWh in 2025 (2024: 909,337), of which landlord-obtained 751,264 MWh and tenant-obtained/allocated 750,553 MWh across the reported segments (Tables 16-17, pages 97-98). Coverage by area is 7,877,665 sqm.

By carrier in 2025: total electricity 287,318 MWh (landlord-obtained 71,866; tenant-obtained 215,452); landlord-obtained fuels 343,202 MWh (natural gas 63,947 landlord shared services plus 254,423 allocated to tenants; oil 5,513 plus 19,318); district heating and cooling 336,196 MWh.

Renewables: total renewable energy consumption and generation 56,801 MWh (2024: 42,031); 76% of landlord-obtained electricity generated offsite from renewable sources; onsite renewable generation consumed onsite 1,853 MWh with 398 MWh exported. Total energy consumption from fossil sources 909,916 MWh. "The Company does not purchase renewable fuels and the fuel consumption from renewable sources is thus zero" (page 97).

Intensities: total building energy intensity 122.72 kWh/sqm*year (2024: 119.57); landlord-obtained 95.37. Table 18 (page 101) reports energy intensity from activities in high climate impact sectors of 817 MWh per million euro (2024: 770), on net revenue of €1,182.9 million; the Group is classified under "NACE section L Renting and Operating of Own or Leased Real Estate" so "all net revenue falls under this sector and no reconciliation is needed".

Nuclear is a stated gap: "the Group does not have sufficient information to determine this", because imported electricity into Germany "is not broken down by energy source" (page 101).

The increase on 2024 is attributed to "colder average annual temperatures in Germany in the year 2025", plus scope changes in the operational control portfolio (page 96). 96% of the portfolio by floor area holds an Energy Performance Certificate (page 98).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 101-108.

Absolute emissions, 2025 (Table 19, page 102), tCO2e:

• Scope 1: 13,064 (2024: 12,962)
• Scope 2 location-based: 39,205; market-based: 24,495 (2024: 40,273 / 24,996)
• Scope 3 from tenant-controlled energy, location-based: 181,924; market-based: 175,853 (2024: 198,814 / 193,060)
• Total location-based: 234,193; total market-based: 213,412 (2024: 252,049 / 231,018)

Intensities: total building GHG intensity 29.73 kgCO2e/sqm*year location-based and 27.09 market-based (2024: 33.14 / 30.38). Coverage by area 7,877,665 sqm.

Boundary. Aroundtown departs from ESRS on organisational boundary and says so: disclosures on Scope 1, 2 and 3 emissions and energy "follow an operational control approach, as defined by the GHG Protocol and as opposed to the ESRS specific requirements... [ESRS E1.46, AR40, ESRS 1.62]" (page 51). The reasoning is set out at pages 101-102: "the GHG Protocol went through extensive discussions on how to apply the principles in a sector-specific manner", and pending EFRAG sector standards the Group applies Appendix F to the GHG Protocol Corporate Standard, citing joint PCAF/CRREM/GRESB guidance. Only assets under direct operational control are included.

Coverage: "In 2025, the Group attained 96% reported data coverage for our operational control portfolio in Germany, the Netherlands, and the UK" (page 101).

Estimation. 100% of tenant-obtained electricity consumption and associated emissions is estimated; landlord-obtained electricity estimation fell from 47% to 10%; total energy estimation fell from 34% to 26% (pages 97-98). BP-2 Table 1 (page 52) documents the estimation approaches and their limits, including "legal data protection barriers prevent landlords from accessing information falling under direct contracts between tenants and utilities" and a 2025 pilot of digital meters "at more than 40 entrances" whose data "is not being used in emissions calculations".

Market-based factors come from invoices, supplier GHG certificates or public supplier statements; where none is available the country mix is used, and Scope 1 is always location-based (page 108).

GHG removals and carbon credits

Reference: page 108. Listed in the ESRS content index at page 108 (page 77) and marked Material "Yes" for the paragraph 56 datapoint at page 158.

A complete nil return: "Aroundtown does not engage in GHG Removals and Storage projects in its value chain, instead we focus on reducing our operational GHG emissions from our own business activities. We are currently not investing in carbon removal projects and do not purchase carbon credits from external partners" (page 108).

This is consistent with the target architecture, which contains no reliance on removals or offsets: the 40% CO2 intensity reduction to 2030 is delivered entirely through the decarbonization levers apportioned in Table 12 (page 91), and the emissions reported in E1-6 are gross figures with no netting for credits (page 102).

Internal carbon pricing

Reference: page 108.

Aroundtown operates a CapEx shadow carbon price: "a carbon pricing that is a CapEx shadow price that reflects the hypothetical cost of its CO₂e. It is not necessarily tied to actual market prices but is used as a decision-making tool" over "the use life of implemented measures" (page 108).

The reference scheme is the German Fuel Emissions Trading Act (Brennstoffemissionshandelsgesetz, BEHG) rather than wider market pricing. Statutory path disclosed: "€30/ton CO₂ through 2023, €45/ton CO₂ in 2024, was set at €55/ton CO2 in 2025, and will increase incrementally to a price corridor of €55-65/ton CO₂ in 2026. From 2027 onward, it will transition to a market-based system for which the rules are yet to be determined, for which the Group assumes a price cap of €125/ton CO₂" (page 108).

The price actually applied is higher than the statutory one: "For 2025 through 2026, AT has already been considering a higher price of €90/ton CO₂ and will increase the price to €120/ton CO₂"; in the Group's view "this is practically applying an assumption of a moderate transition scenario" (page 108). It is fed into the return calculations for refurbishment projects.

Table 23 (page 108) – emission volumes covered by the scheme, tCO2e: Scope 1 12,675; Scope 2 19,005; Scope 3 116,636. These are drawn "directly from the data underlying Table 19 in section E1-6, following the same organizational boundaries", i.e. the German operational control portfolio including downstream tenant-controlled areas. The Group notes "not all these GHG emissions stated below are taxed under the German scheme", with the landlord/tenant split differing between commercial (equal split) and GCP residential properties (split by the property's energy rating).

Policies related to own workforce

Reference: pages 119-120.

Table 25 (pages 119-120) lists eight workforce policies with a description, an accountable owner and an access route for each: Employee Code of Conduct (Chief Compliance Officer); Anti-Discrimination Policy (HR Department); Diversity, Equality and Inclusion Policy (Diversity Board); Human Rights Policy (Management Body and Chief Compliance Officer); Anti-Corruption and Anti-Bribery Policy (Compliance Officer); Whistleblowing Policy (Chief Compliance Officer); Occupational Health and Safety Policy (senior management and regional managers with HR); and the Global Information Security Policy and Acceptable Use Policy (Chief Information Security Officer).

The Human Rights Policy is "aligned with international frameworks, including the UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, ILO Conventions on Fundamental Principles and Rights at Work, and International Bill of Human Rights" (page 119). It "explicitly prohibits forced and child labor as well as modern slavery and human trafficking", and "No material risks relating to forced and child labor were identified in the DMA", reasoning that AT operates in the EU and UK and "is not part of high-risk industry such as manufacturing" (page 120).

The Anti-Discrimination Policy aligns with the German General Act on Equal Treatment (AGG) and "applies throughout the entire employment lifecycle, from recruitment to termination, including promotions and working conditions" (page 120).

The Appendix datapoint list confirms the S1-1 datapoints as material with page references: human rights policy commitments (page 119), ILO due diligence policies (page 119), and workplace accident prevention policy (pages 119-120). "Processes and measures for preventing trafficking in human beings" is marked "No" (page 159).

Engaging with own workforce about impacts

Reference: pages 120-121.

The annual employee satisfaction survey is "the Group's primary tool for collecting feedback" (page 120). Alongside it:

• HR Roundtables – "In 2025, seven sessions were conducted, four with managers and three with employees, covering key topics such as work-life balance, training management and professional development, internal mobility and inclusivity" (page 120)
• Townhall meetings – "Four townhalls were held across key operations in 2025, including Berlin, Amsterdam and Cyprus, focusing on topics such as Energy and Sustainability, ATWorld, and AtechX" (page 120)
• The whistleblowing system, and informal collection by supervisors (page 117)
• The "Activate the Base" programme, launched in a second round in late 2024 with an external coach, whose 2025 employee-led projects included an Innovation Portal, job rotation and shadowing, a professional correspondence platform, wildflower meadows and the "Your Wellbeing is Our Benefit" programme (page 121)

Accountability: "The Group's Head of HR oversees these initiatives, ensuring that employees' feedback is collected and used to shape policies, decision-making and initiatives" (page 121).

Effectiveness is assessed through targeted survey questions "particularly in the sections on Feedback and Communication, as well as Meaningfulness and Participation", examining "whether employees feel their opinions matter, whether feedback is given, received, and used constructively" (page 121). Structured mechanisms for participation in governance are also described – "employee feedback channels, compliance ambassadors, HR roundtables and annual Townhall meetings" (page 54).

Remediation and channels to raise concerns

Reference: pages 121-122.

The grievance route is the Whistleblowing Policy and a third party-managed whistleblowing system: "The third party-managed system ensures confidential and anonymous reporting and allows employees and external stakeholders to report violations confidentially and without fear of retaliation" (page 121). Reports are "tracked and investigated objectively by the Compliance Department, following an internal investigation procedure, as documented in the Group's Investigation Policy" (page 121).

Consequences are graduated: "appropriate disciplinary and corrective measures are taken, ranging from warnings and fines to termination of employment, depending on the severity. For violations by business partners, Aroundtown may require business partners to implement corrective measures within a set timeframe. If violations persist, it reserves the right to terminate the business relationship" (page 121).

Additional channels: employees can approach department heads directly, raise issues in one-on-one check-ins, or use HR Roundtables and Townhall meetings (page 121).

Awareness and trust. Mandatory training on human and labour rights, diversity and anti-discrimination is delivered on Welcome Days and through the e-learning platform, and "Aroundtown training framework makes it mandatory for all employees to pass the tests to confirm their understanding of the training material" (page 122). The Group is candid about the limit: "While there is no specific method to measure employee trust in the grievance and remediation mechanisms, the HR Roundtable provides an open forum for receiving feedback"; the mechanisms are "subject to annual reviews through HR audits, compliance assessments, and employee feedback surveys" (page 122).

The Appendix marks "ESRS S1-3 32 (c) Grievance/complaints handling mechanisms" as material at page 121 (page 159).

Taking action on material impacts on own workforce

Reference: pages 122-124.

Table 26 (page 123) groups initiatives against the impacts identified in the 2024 DMA:

• Violence and harassment prevention; social dialogue and freedom of association – whistleblowing system, annual compliance training, HR Roundtable
• Diversity; employment and inclusion of people with disabilities; gender equality and equal pay – anti-discrimination training, a blended language training programme in English and German, a Diversity Board with a board-level "diversity ambassador", participation in diversity and world food challenges, cultural diversity day
• Working time and work-life balance – flexible and remote work, time tracking via the HR system and QR code terminals, AT-World flexible workspace network, mental health programme
• Health and safety – internal OHS risk assessments, emergency preparedness drills, workplace safety training, flu and COVID vaccinations, eye examinations, a virtual platform for online sports and mental health prevention, gym access at the Berlin headquarters
• Training and skills development – leadership training, performance and career development reviews including 180-degree survey, apprenticeship programme, online learning platform, career paths rollout, mentoring and coaching
• Secure employment and adequate wage – personal and professional development coaching, "Activate the Base"

Resources: "The Group dedicates significant financial, technological, and human resources... Each of the initiatives documented in Table 26 requires a reasonable amount of resources to implement" (page 124); no monetary amounts are given.

Green transition: "the potential negative impacts of the transition to greener and low-carbon operations on employees are recognized but not yet established"; should the risk materialise the Group is "prepared to intensify effort to upskill affected employees through targeted training in areas such as energy-efficient building management, sustainability practices, and compliance" (page 124).

Effectiveness is tracked against KPIs "including gender pay gap and other diversity metrics, average training hours and investment in training, human rights violations, OHS metrics, data breaches" (page 124).

Targets related to own workforce

Reference: pages 124-125.

Three long-term targets (page 124):

• "Be among the top ten most attractive employers in the commercial real estate sector by 2030"
• "Maintain the total number of confirmed cases of discrimination under 3%"
• "Offer a minimum of 12hrs of training and development opportunities per FTE"

Two 2026 goals (page 124): continue the Group-wide Social Day volunteering programme, and "Increase health measurements and services offers for employees, including mental health such as psychological support".

The Group is explicit about the character of these targets: "The targets do not constitute quantitative reduction or improvement targets that require numerical baseline, interim milestones, or even defined time-bound trajectory. Instead, they focus on maintaining or achieving qualitative or status-based outcomes and operate on a continuous-performance basis. Performance is monitored annually, with progress assessed directly against the stated target rather than against a predefined multi-year pathway" (page 124).

Target setting runs from internal policies, strategic priorities, regulatory requirements and operational needs, "incorporating direct engagement with its workforce"; targets are set at departmental level then "reviewed and approved by Management Body" (page 124).

Two of the three are measurable against the metrics reported elsewhere in S1: confirmed discrimination cases were zero in both 2025 and 2024 (Table 35, page 130), and average training hours per employee were 16.0 in 2025 against 13.2 in 2024, above the 12-hour floor (Table 31, page 128).

Characteristics of the undertaking's employees

Reference: pages 125-126.

Total headcount 1,621 at 31 December 2025 (2024: 1,668), reconciled to the financial statements: "The total headcount of 1621 in the S1-6 disclosures is also mentioned in the financial statements on p. 238" (page 125).

Table 27 (page 125): female 801 (49.4%), male 820 (50.6%); age under 30 269 (16.6%), 30 to under 50 991 (61.1%), 50 and over 361 (22.3%); 64 nationalities including Germany (2024: 66).

By geography (page 125): Germany 1,320 (81.4%), UK 75 (4.6%), Bulgaria 70 (4.3%), Cyprus 65 (4.0%), Netherlands 57 (3.5%), other 34 (2.1%).

By nationality share (page 125): Germany 63.1% of the workforce and 62.3% of managerial positions; Bulgaria 4.8%; Romania 4.3%; Cyprus 3.9%; United Kingdom 3.6%; Israel 2.9%; others 17.4%.

Contract types are given in SBM-1: 1,299 permanent (80%), 322 temporary (20%), 1,440 full-time (89%), 165 part-time (10%), 16 non-guaranteed hours (1%) (page 64).

Methodology: data is collected through regional offices and exported to the Personnel Management System or payroll, with HR consolidating centrally; "The Group tracks both the headcount of employees and FTE metrics. Unless explicitly stated otherwise, headcount is primarily used as the basis for calculating indicators" (page 125). The scope is all employees; the disclosure "includes all individuals directly employed by Aroundtown" (page 125). No employee turnover rate is presented in this section.

Diversity metrics

Reference: page 127.

Table 30 (page 127):

• Board of Directors: female 29%, male 71% (unchanged on 2024)
• Top management (Management Body, international executives, other top managers such as Managing Directors): female 17% in 2025, up from 11%
• Senior management (heads of departments): female 32%, down from 40%
• Junior management (team leads): female 44%, up from 36%
• All management (junior, senior and top): female 37%, up from 33%
• Revenue-generating management functions: female 39% (2024: 37%)
• STEM-related positions: female 16%, down from 19%
• Employees with disabilities: 39 people, 2.4% of the workforce (2024: 40, 2.4%)

The whole-workforce gender split is reported separately in S1-6: 801 female (49.4%) and 820 male (50.6%) of 1,621 (page 125). Board gender diversity and the percentage of independent board members are marked as material EU-legislation datapoints located at page 56 (page 158).

Gender equality is also incentivised: LTIP Target 5 ties 10% of long-term incentive remuneration to maintaining or improving gender equality metrics against the previous financial year (page 60). Diversity initiatives sit with a Diversity Board comprising "employee representatives from various levels of the Group", with a board member appointed as "the Group's diversity ambassador" (pages 120, 123), and AT is a signatory of the Charta der Vielfalt, the German Diversity Charter (page 152).

Adequate wages

Reference: page 127.

The disclosure is short and unqualified: "All employees of Aroundtown are paid an adequate wage, in line with applicable benchmarks. The Group's compensation structure is designed to offer equitable compensation that reflects individual responsibilities, competencies, and performance. Regular reviews are conducted to maintain competitiveness and compliance with the benchmarks" (page 127).

No employees are therefore identified as being paid below the applicable adequate wage benchmark, and no country breakdown is given because none is required where the answer is complete coverage.

Table 6 of material S1 IROs treats adequate wages as a three-part material matter over short and long term in own operations (page 70): a positive impact ("Policies on adequate wages and compliance with at least relevant legislation"), a risk ("Availability and cost of adequate workforce") and an opportunity ("Employer attractiveness to adequate workforce in relation to provision of adequate wages"), with the Group's footnote that "Adequate wages is defined by ESRS as following minimum wage requirements in the national member states".

SBM-3 adds the strategic framing: "Adequate and fair wages remain a key topic for AT's workforce. Wage competitiveness is structurally linked to the Group's strategy to attract qualified workforce, which include regular wage benchmarking and harmonization" (page 117). Pay-gap outcomes are reported separately under S1-16 (page 129).

Social protection

Reference: page 127.

"Across all AT countries of operation, employees are covered by public social protection programs, providing support for key life events such as sickness, unemployment, employment injury, disability, parental leave, and retirement. These programs ensure protection during periods of incapacity or transition" (page 127). All six ESRS life events are therefore covered for the whole workforce through public systems in Germany, the Netherlands, the United Kingdom, Luxembourg, Cyprus and Bulgaria (workforce locations per page 64).

Company programmes supplement the public ones in three countries (page 127):

• Germany – "a company pension scheme, in compliance with state regulations, through an external insurance provider with employer contributions"
• Bulgaria – "a company-sponsored sickness prevention program to support employee well-being"
• Cyprus – "additional company programs for employment-related injury and acquired disability"

"This approach leverages national systems while enhancing the coverage where needed" (page 127).

No employees are identified as lacking social protection against any of the six events, so the disclosure is a complete positive return rather than a gap analysis. Family-related leave entitlement and take-up are reported separately under S1-15 (page 129).

Persons with disabilities

Reference: page 127.

The metric sits in the diversity table: 39 employees identify as having a disability, 2.4% of the workforce in 2025, against 40 and 2.4% in 2024 (Table 30, page 127). The percentage is reported as a share of employees who identify, so the figure depends on self-identification.

Employment and inclusion of persons with disabilities is one of the material S1 sub-topics, recorded in Table 6 as a positive impact in own operations over short and long term: "Policies and practices regarding employment of persons with disabilities" (page 70).

The supporting policy is the Diversity, Equality and Inclusion Policy, which "advanc[es] equal opportunities and eliminating discrimination based on gender, ethnicity, disability, age, or other personal attributes", overseen by the Diversity Board (page 119). The Anti-Discrimination Policy "explicitly prohibits discrimination based on race, ethnic origin, gender, religion or belief, disability, age, or sexual identity, whether directly or indirectly" and applies "throughout the entire employment lifecycle" (page 120).

SBM-3 flags the group as exposed on health and safety: "Employees with disabilities who may require additional support at the workplace are equally exposed to risks" (page 117). Table 26 places disability inclusion in the same initiative cluster as diversity and gender equality (page 123). No breakdown by gender or by employee category is given.

Training and skills development metrics

Reference: pages 127-128.

Table 31 (page 128):

• Percentage of employees who received regular performance and career development reviews: 37.5% (2024: 35.8%)
• Average training hours, all employees: 16.0 (2024: 13.2); female 18.2, male 13.9
• Management: 25.3 hours (female 34.9, male 19.6); non-management: 18.7 (female 20.4, male 16.8)
• Part-time employees 12.1 hours; FTE employees 20.8
• Average investment in training per FTE: €742 (2024: €675)
• Percentage of FTEs in a leadership development programme: 1.6% (2024: 2.8%)
• Percentage of FTEs in the language programme: 5.7% (2024: 10.7%)

Average hours in every category rose year on year, and the 16.0-hour average sits above the Group's long-term target to "Offer a minimum of 12hrs of training and development opportunities per FTE" (page 124). Female employees receive more training hours than male employees at every level reported.

The Group frames training as a business-resilience matter: "Aroundtown considers continuous investment in training and development of its employees essential for both personal and professional growth, fostering business resilience, innovation, engagement, and long-term retention" (page 127). Training and skills development is a material S1 sub-topic recorded as a positive impact in own operations (Table 6, page 70), delivered through leadership training, an online learning platform, mentoring and coaching, apprenticeships, a career paths rollout and 180-degree performance reviews (Table 26, page 123).

Health and safety metrics

Reference: pages 128-129.

"All employees of Aroundtown are covered by the Group's health and safety management system based on legal requirements", so coverage is 100% of employees (page 128).

Table 32 (page 128):

• Work-related fatalities: 0.0 in 2025 and 2024
• Recordable work-related injuries/accidents: 7.0, unchanged on 2024
• Injury/accident rate: 0.000003 (injuries per total time worked), unchanged
• Lost-Time Injury Frequency Rate (LTIFR): 2.5 per million hours worked, unchanged
• Lost day rate: 0.0001 (2024: 0.00004)
• Absentee rate: 5.4 (2024: 5.5)

Methodology follows EPRA sBPR guidance, tailored: accidents and injuries are tracked "across all international Aroundtown offices" and commuting accidents are excluded "to ensure consistency"; LTIFR is "based on actual employee FTE, adjusted for unpaid absences" and "accounts for the standard working hours in each Aroundtown country of operation (e.g., 7.5 hours per FTE in the UK and 8 hours per FTE in other locations)"; the absentee rate "includes only paid absences due to sickness and workplace accidents, while unpaid sickness and absence days are excluded" (pages 128-129).

The Appendix confirms the fatalities and accident-rate datapoints (paragraph 88(b) and (c)) and days-lost datapoint (88(e)) as material EU-legislation datapoints located at page 128 (page 159). SBM-3 notes OHS risks "are particularly significant for construction, maintenance and facility management teams" (page 117). Metrics are not disaggregated between employees and non-employees.

Work-life balance metrics

Reference: page 129.

"Family-related leave such as parental leave, paternity leave, maternity leave, caregiving leave among others are within the rights of all Aroundtown employees" – so 100% of employees are entitled to family-related leave (page 129).

Table 33 (page 129) – take-up in 2025:

• Total employees that took family-related leave: 173, 10.7% of the workforce (2024: 179, 10.7%)
• Female: 114, 14.2% (2024: 127, 15.6%)
• Male: 59, 7.2% (2024: 52, 6.1%)

Female take-up fell year on year in both absolute and percentage terms while male take-up rose, narrowing the gap between the two, though female take-up remains roughly double male take-up.

The Group's rationale: family-related leave "allows employees to maintain a healthy balance between professional and personal life, reducing stress, and enhancing overall well-being" (page 129).

Work-life balance is a material S1 sub-topic, recorded in Table 6 as a positive impact ("Existence of flexible working (or similar) policies and procedures"), a risk and an opportunity, all in own operations (page 70). SBM-3 identifies the exposure: employees "in finance, HR, operations, property management, and construction may experience periodic workload pressures, working overtime and irregular hours, which could impact work-life balance and employee wellbeing, if not carefully managed" (page 118). Supporting actions include flexible and remote work arrangements, time tracking via the HR system and QR code terminals, the AT-World flexible workspace network and a mental health programme (Table 26, page 123).

Remuneration metrics (pay gap and total remuneration)

Reference: page 129.

Table 34 (page 129) – gender pay gap, on both the ESRS and EPRA bases. ESRS calculates the gap as the difference in average pay of women against the average pay of men, expressed as a percentage of the male average; EPRA divides the male average by the female average.

Remuneration (salary and bonus) pay gap, ESRS basis:

• All employees: 31.4% in 2025, improved from 33.3% in 2024 (EPRA ratio 1.5)
• Executive 43.6% (2024: 43.9%); management 26.0% (2024: 21.9%); non-management 17.9% (2024: 17.2%)

Salary-only pay gap, ESRS basis:

• All employees: 27.4% (2024: 26.7%)
• Executive 35.0% (2024: 29.8%); management 22.7% (2024: 17.1%); non-management 17.1% (2024: 15.7%)

Total compensation ratio: "Ratio of the highest paid individual to the median annual total compensation for all employees (excluding the highest paid individual)" fell sharply to 34.8 from 68.3 in 2024 (page 129).

The headline all-employee remuneration gap narrowed by 1.9 percentage points, but the gap widened at management and non-management level on both bases, and the salary-only gap widened at every level. The Group reports "pay gap on various levels of aggregation to enhance transparency and align with widely accepted standards" (page 129). The unadjusted gender pay gap is marked a material EU-legislation datapoint at page 129, while "Excessive CEO pay ratio" is marked "No" (page 159). Gender equality and equal pay for work of equal value is a material S1 sub-topic (Table 6, page 70) and carries 10% of LTIP remuneration (page 60).

Incidents, complaints and severe human rights impacts

Reference: page 130.

Table 35 (page 130) reports zero across every line, in both 2025 and 2024:

• Incidents of discrimination (including harassment): 0
• Complaints filed through channels for people in own workforce to raise concerns: 0
• Complaints filed to National Contact Points for OECD Multinational Enterprises: 0
• Severe human rights issues and incidents connected to own workforce: 0
• Of which cases of non-respect of the UN Guiding Principles and OECD Guidelines: 0
• Total fines, penalties and compensation for damages from those incidents and complaints: €0; for severe human rights incidents: €0

Two counting conventions are footnoted and materially narrow the figures: "only discrimination cases that resulted in sanctions or actions towards the accused persons are reported" and "only complaints that resulted in a confirmed compliance case are reported here" (page 130). Reports that were investigated but not confirmed, or that led to no sanction, therefore fall outside the reported zeros.

The nil return is corroborated elsewhere: "In 2025, no cases of human rights violations were reported" (page 134), and no severe human rights issues connected to value chain workers (page 136) or to consumers and end-users (page 146) were reported.

The Appendix marks both the incidents of discrimination datapoint (paragraph 103(a)) and the non-respect of UNGPs and OECD guidelines datapoint (104(a)) as material at page 130 (page 160). The Group's long-term target is to "Maintain the total number of confirmed cases of discrimination under 3%" (page 124).

Policies related to value chain workers

Reference: pages 133-135.

Table 37 (page 133) carries two policies: the Human Rights Policy, which "lists twelve basic human rights, including the right to equality, freedom of speech, thought and religion, and right to a safe work environment", applies "to employees, tenants and workers in the supply chain" and "articulates a zero-tolerance approach to modern slavery, human trafficking and forced labor"; and the Business Partner Code of Conduct (BPCoC), which "includes requirements on worker safety, fair working conditions, and responsible employment practices, and explicitly prohibits child labor and forced labor. It addresses precarious work by requiring compliance with applicable labor laws and alignment with relevant International Labor Organization ('ILO') standards."

Frameworks named: UN Global Compact Ten Principles, ILO Core Conventions, OECD Guidelines for Multinational Enterprises and the UN Guiding Principles (page 133).

Coverage threshold: "All business partners with contracts above €5,000 are requested to sign the BPCoC", with an exemption "only to large corporations, which have their own codes of conduct – provided that they are in line with AT's standards – or to business partners operating within heavily regulated sectors" (page 134).

Four categories of value chain workers are identified as in scope (page 133): construction and renovation workers; property maintenance and facility management personnel; energy, utility and waste management workers; and material and equipment suppliers. A footnote records the Group's geographic reasoning: "AT's operations are entirely located within the European Union and the UK, where strict regulatory frameworks and enforcement mechanisms significantly mitigate the risk of child labor, forced labor, or compulsory labor" (page 133).

A gap is admitted: the BPCoC "currently does not, however, make an explicit reference to trafficking in human beings in its policies, given its limited relevance in the regions where AT operates" (page 134). A six-step human rights due diligence approach is set out at page 135, and the Group concludes it meets the EU Taxonomy minimum safeguards criteria.

Taking action on material impacts on value chain workers

Reference: pages 135-136.

Because "the Group's DMA identified only positive material impacts in relation to working conditions in the supply chain" (page 137), the actions are framed as maintaining and preventing rather than remediating: "Aroundtown continuously works to sustain and strengthen its positive impacts on value chain workers in the area of working conditions, including secure employment, working time, adequate wages, and health and safety" (page 135).

Preventive posture stated (pages 135-136): "While the Group has not identified material risks related to value chain workers, it recognizes that its reliance on subcontractors may give rise to health and safety, labor rights, or supply chain vulnerabilities if not adequately managed. Accordingly, the measures already embedded in the Group's supply chain governance framework – particularly human rights due diligence, contractual safeguards on working conditions, and ongoing monitoring mechanisms – are applied with a preventive objective."

Resources (page 136): dedicated compliance, Know-Your-Business Partner, Operations and Construction teams; "Although supply chain documentation is currently managed largely manually, the ERP system has been updated to improve oversight", and additional supply chain management tools are being assessed.

Three limitations are disclosed candidly (page 136):

• "The actions are part of the Group's ongoing operational activities and, therefore, do not have a defined completion date."
• "Aroundtown does not currently track specific financial allocations for these actions at the level of detail required by this disclosure. The Group is reviewing its reporting processes to enable more granular disclosure in future reporting cycles."
• "The Group has currently not implemented further assessments or monitoring in how far these actions are effective in delivering the intended outcome for value chain workers."

"In 2025, no severe human rights issues or incidents connected to workers in the value chain were reported to AT" (page 136). Three strategic opportunities are named: operational efficiency, competitive advantage and sustainable workforce practices (page 136).

Targets related to value chain workers

Reference: page 137.

Table 38 (page 137) sets one long-term target against the material topic of working conditions and its four sub-topics (secure employment, working times, adequate wages, health and safety):

• Long-term target: "Maintain zero human rights violations in the supply chain and ensure the Group continues to have positive impacts on value chain workers' working conditions." A second long-term line reads "Maintain our high standard of business partner scrutiny."
• 2025 target: "Review Business Partner Due Diligence Process for further improvement."
• 2025 progress: "Reviews of the BPCoC and the Business Partners Due Diligence were conducted. No need for further improvement was identified."
• 2026 target: "Maintain high standards of business partner scrutiny by means of continuous monitoring and consistent enforcement of the BPCoC and the HRDD process, ensuring that only positive material impacts on working conditions are achieved and maintained."

The target is explicitly a maintenance target rather than an improvement trajectory: "Since the Group's DMA identified only positive material impacts in relation to working conditions in the supply chain, both the short- and long-term focus is on maintaining Aroundtown's high standards"; it is "a continuous target, designed to ensure that the Group can respond effectively should future gaps be identified or priorities change" (page 137).

Worker involvement in target setting is limited and disclosed as such: "While direct engagement with workers in the value chain or their representatives is not yet a formalized step; insights are gathered through structured tools such as the Business Partner Questionnaire" (page 137). "During the review and assessment of the BPCoC and the HRDD in 2025, no material gaps were identified" (page 137). No numerical baseline or interim milestone is attached.

Policies related to consumers and end-users

Reference: page 141.

Table 40 (page 141) lists five policies: the Data Protection Policy, which "Defines governance structures for GDPR compliance, ensuring secure collection, storage, and processing of tenant data" and "enforces access controls, encryption protocols, and breach notification mechanisms"; the Business Partner Code of Conduct, under which "Personal data of tenants/customers, employees, and other involved parties must be handled confidentially" and "After the service is completed, all information and documents must be returned or deleted, where legally permissible"; the Tenant Satisfaction Guidelines, which "defines key performance indicators for response times, complaint resolution, and service improvement"; the Human Rights Policy; and the Global Information Security Policy.

Accountable owners are named (page 141): the Management Body and Chief Compliance Officer oversee the Human Rights Policy and BPCoC; "the Chief Information Security Officer ('CISO') is responsible for GDPR compliance, data security governance, and IT risk management"; and "the Chief Operations Officer ('COO') of the German operations leads the Tenant Satisfaction Guidelines".

External standards: GDPR and ISO 27001:2022. "Our ISO 27001:2022 certification for our Information Security Management System at our headquarters in Berlin was maintained for a fourth consecutive year in 2025. The scope of the certification applies to our head office, while the scope of the implementation applies to all local and international offices" (page 141).

"In 2025, Aroundtown reported zero incidents of non-compliance with Group policies related to its consumers and end-users" (page 141). The Appendix marks both S4-1 datapoints – policies related to consumers and end-users, and non-respect of UNGPs and OECD guidelines – as material at page 141 (page 160).

Engaging with consumers and end-users about impacts

Reference: page 142.

Four contact routes are listed (page 142): email and postal services; "Our Service Center, which is available 24/7, in a variety of languages"; "AT's business chat via mobile phone and AT Tenant Portal or, for our residential tenants, also via the GCP Tenant App"; and "In-person tenant consultations... offered by our property managers at property locations on a regular basis".

The GCP Tenant App and Portal gives residential tenants apartment search, account balance, rent payments, official documents and service requests. "Since early 2025, residential tenants are actively guided to the GCP App from the moment a lease agreement is concluded, where they can register and sign their lease digitally", with self-service download of rent certificates and rent-debt-free certificates (page 142).

Accountability: "Access to quality information is ensured through the joint responsibility of the COO and the Head of Quality Assurance & Customer Care for tenant engagement at the highest operational level", with the Data Protection Officer ensuring tenant interactions comply with data privacy rules (page 142).

Effectiveness is monitored "through our ticketing system, which tracks all tenant requests... allow[ing] the monitoring of request types, the resolution process, and the response times"; after resolution "a survey is sent to the relevant tenant" assessing "friendliness, reachability, quality of work and resolution time" (page 142).

Vulnerable groups are identified and accommodated: "low-income residential tenants and digitally excluded individuals, such as elderly tenants who predominantly rely on physical documentation, are especially at risk", so AT provides "alternative communication methods such as physical documentation and in-person service, as well as dedicated support channels" (pages 140, 142).

Remediation and channels for consumers and end-users

Reference: page 143.

Concerns raised through the channels in S4-2 "are integrated into AT's Ticketing System, where they are systematically tracked and addressed. Regular performance evaluations assess response times, resolution efficiency, and tenant satisfaction levels" (page 143). "AT's whistleblowing system is also accessible to our tenants, who can report concerns confidentially and without fear of retaliation", operated through "An independent third-party platform allow[ing] for anonymous reporting" (page 143).

Incident data is given, and it is not a nil return: "We monitor potential security incidents and data protection breaches as an indicator of the effectiveness of our operational procedures. In 2025, there were no confirmed breaches, while three data protection incidents were reported. In the event of any confirmed incident, a response team is formed to immediately investigate the matter and recommend remedial actions to prevent a similar occurrence" (page 143).

Awareness and trust are actively assessed, which is the part of S4-3 companies most often skip: "Tenant feedback surveys, issued after interactions with the Service Center, measure awareness of available support channels and the effectiveness of issue resolution. Direct engagement at community events provides further insights into tenants' experiences with raising concerns. Additionally, usage data from the GCP Tenant App & Portal is monitored to assess accessibility and adoption. These assessments inform ongoing improvements, ensuring that all tenants are aware of and trust the available reporting mechanisms" (page 143).

Effectiveness of escalation is further tested through "internal audits and performance tracking... alongside regular testing such as security drills, breach response exercises, and vulnerability analysis" (page 143), with independent oversight by the Data Protection Officer (page 146).

Taking action on material impacts on consumers and end-users

Reference: pages 143-147.

Table 41 (pages 145-146) sets out key actions against the two material sub-topics, privacy and access to quality information. Named measures include "Implementation of a Privileged Access Management System, which enforces multi-factor authentication, session recording, and access approval for external IT service providers to prevent unauthorized access to tenant data"; document labelling with "an information security classification, from public to restricted, which requires password protection"; encryption of sensitive tenant information; and continuous employee training.

2025 activity (pages 144-145): "we conducted internal audits across our office branches"; oversight "benefits from the expertise of a Director, Markus Kreuter, who has deep knowledge of IT and cybersecurity"; the Information Security and Privacy Strategy "is monitored by the Risk Committee" and led by internal cybersecurity experts working with an Information Security Steering Committee. "Employees sign a commitment to data protection upon joining the Group and are required to complete annual video-based training modules."

Breach response (page 146): "In the event of a data breach, immediate containment and mitigation measures are activated"; "Post-incident reviews ensure that mitigation strategies are continuously refined, while vendor due diligence ensures that all third-party service providers meet security and compliance standards."

Resources are itemised in Table 42 (page 147): personnel ("Dedicated roles such as the Data Protection Officer and tenant engagement teams"), financial investment ("Budgets allocated for IT infrastructure, employee training, and tenant satisfaction surveys") and systems ("Centralized ticketing and tracking system"). No monetary amounts are given.

Tenant experience actions include the GCP Loyalty Program with shopping discounts and loyalty points, partnerships with Vodafone, O2 and Media Markt, and "sustainability incentives encourage tenants to earn points for switching to renewable energy providers"; the Service Center commits to "responding to general tenant queries within 24 hours and urgent requests within one hour" (page 146). "As of 2025, no severe human rights issues or incidents related to consumers and end-users have been reported" (page 146).

Targets related to consumers and end-users

Reference: pages 147-148.

Table 43 (page 147) carries three long-term targets, all tied to the material privacy topic:

1. "Identify risks proactively, to detect and eliminate weaknesses before they can become threats." 2025 target: "Pass our recertification audits for ISO 27001:2022" – progress recorded as "Achieved". 2026 target: "Successfully complete surveillance audit for ISO 27001:2022 (certification valid until 2027)."
2. "Embed a culture of awareness and vigilance throughout our staff, through consistent and regular training." 2025 progress lists phishing email campaigns, roll-up posters in branches and headquarters, regular information security emails, a Welcome Day information session, and security reminders displayed on coffee machines. One item was not delivered: "The introduction of security champions has been postponed due to shifting internal priorities." 2026 target: "Remains the same."
3. "Pursue continual improvement of the security of our digital systems." 2025 progress: "A special bug bounty program was introduced for all our external facing assets. Internal assessments on core applications were conducted, including (but not limited to) core financial systems, email and identity, servers and more."

The measurability split is stated: "The Group has defined one measurable target – the successful recertification of ISO 27001:2022... In addition to this, AT has set two qualitative targets" (page 148). Baseline is 2024 and the targets apply "from 2024 and beyond" (page 148).

Tenant involvement is limited and disclosed as such: "While tenants are not directly involved in setting formal targets, AT gathers tenant insights through various engagement channels"; the Group's targets "relate to broader operational priorities that are defined at the organizational level where tenants have little insight" (page 148). Tenants contribute to tracking through post-resolution surveys and app feedback consolidated in the ticketing system (page 148).

Business conduct policies and corporate culture

Reference: pages 151-153.

Table 45 (pages 151-152) lists twelve governance policies: Business Partner Code of Conduct, Employee Code of Conduct, Whistleblowing Policy, Anti-Corruption and Anti-Bribery Policy, Data Protection Policy, Human Rights Policy, Anti-Discrimination Policy, Diversity Policy, Procurement Policy, Occupational Health and Safety Policy, Investigation Policy and Global Information Security Policy.

Scope is mapped explicitly (page 152): the Employee Code of Conduct, Diversity, Anti-Discrimination, Anti-Corruption and Anti-Bribery, Whistleblowing, Procurement and Human Rights policies "apply to all employees, executives, and members of the Board of Directors"; the BPCoC, Procurement Policy and Human Rights Policy "apply to suppliers, contractors, and external business partners".

Corporate culture is assessed through "employee satisfaction surveys and through direct communication channels between the Compliance Department, other departments and employees", with the Board and Management Body regularly reviewing it (page 151).

Whistleblower protection is quoted from the policy itself (page 153): "an employee who exposes a whistleblower or otherwise retaliates against the whistleblower for their reports [...] may face sanctions under employment law". The channel is "an externally operated whistleblowing channel that enables full anonymity", publicised on the intranet and public website, with training included in Welcome Days.

Alignment with global standards (pages 152-153): UN Convention Against Corruption, GDPR, OECD Guidelines for Multinational Enterprises, ILO Core Conventions and UN Global Compact Principles. AT is "a founding member of the United Nations Global Compact ('UNGC') Network Germany" (page 149) and a signatory of the Charta der Vielfalt (page 152).

Corporate governance code position (page 149): AT "is not subject to any mandatory corporate governance code", is not required to comply with the Luxembourg Ten Principles or the German Corporate Governance Code, but "adheres to recommendations C.10 (pertaining to the Chair of the Audit Committee), D.8, and D.9 of the German Corporate Governance Code". The Appendix marks the UN Convention against Corruption datapoint (pages 151-152) and the protection of whistleblowers datapoint (page 153) as material (page 160).

Management of relationships with suppliers

Reference: page 154.

Signing the BPCoC is mandatory for business partners with contracts above €5,000, "except for large corporations that maintain their own codes of conduct – provided these are consistent with the Group's ethical standards – or for business partners operating in heavily regulated sectors" (page 154).

Supplier profile: "In general, AT works with small and medium-sized, locally operating business partners for construction and maintenance projects, as well as larger national and international suppliers, including facility management companies" (page 154).

Risk-tiered due diligence: suppliers are classified "as low-, medium-, or high-risk according to factors including contract volume, region of activity, and other relevant criteria", with construction and refurbishment/maintenance identified "as particularly exposed to human rights risks"; "The depth of due diligence applied corresponds to this risk level" (page 154).

Four ESG mechanisms in supplier selection and monitoring (page 154):

1. Adherence to the BPCoC – covering environmental, health and safety regulations, international human rights law, fair labour standards and non-discrimination
2. Due diligence screening – the HRDD process "includes KYC and AML screenings", supplemented "by spot checks conducted by the Construction and Operations departments – particularly with regard to health and safety on construction sites"
3. Evaluation methods – project managers oversee construction projects and engage directly with contractors, with a Business Partner Questionnaire verifying adherence
4. Environmental data delivery – standard construction contracts require "recycling data during construction projects, confirming non-usage of prohibited chemical substances to prevent pollution and providing documentation on efficient water appliances installed"

Where issues arise, "Aroundtown carefully evaluates its business relationship and may consider suspension or termination" (page 154). The Procurement Policy "further guides suppliers' selection by incorporating sustainability criteria" (page 154). Payment practices are disclosed separately under G1-6 (page 157).

Prevention and detection of corruption and bribery

Reference: pages 155-157.

The Anti-Corruption and Anti-Bribery Policy is "aligned with the United Nations Convention Against Corruption" and "provides clear guidelines of conduct for handling donations in the private sector, including hospitality, events and gifts; charitable contributions; political engagement; dealing with public officials; and dealing with 'facilitation payments'" (page 155).

Investigator independence is addressed directly: "By involving individuals independent of the management chain related to the matter, the Group uphold fairness and transparency throughout the investigation. This structure ensures that all findings are free from any conflicts of interest" (page 155). Investigation outcomes "are reported directly to the Co-CEO/COO, the CFO and a member of the Board of Directors" (page 155).

Table 46 (page 156) sets out four training programmes with audience, content, frequency and delivery method: mandatory compliance training for all employees (antitrust, anti-money laundering, anti-corruption, "Speak up", annually, e-learning); new employee onboarding; a leadership programme for department heads and leadership; and annual awareness campaigns and refreshers.

Coverage figures, including the gaps (page 156):

• "In 2025, 95.43% of all employees have completed the training, yet it may be that employees left the Group in which case it would show as a missing training."
• Training was updated in 2025: AT "identified employees in roles with higher exposure to corruption risks. All of these employees are now required to complete an additional training module focused on gifts and hospitality."
• "In 2025, the Board of Directors and Management Body did not receive specific training on anti-corruption or anti-bribery. However, they have in the past completed a training on Anti-Money Laundering, which is a component of Anti-Corruption. An anti-corruption and anti-bribery training for the Board and the Management Body is intended for 2026."

Functions at higher risk are named as "business development, construction, and transactions", due to "frequent interactions with public authorities, developers, construction companies, as well as large land and real estate owners and brokers" (page 153). A network of compliance ambassadors outside the Compliance Department operates in the UK, Cyprus and some German regional offices (pages 155-156). The Group also maintains an insider register under Regulation (EU) 596/2014 (page 155).

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, and the FY2025 statement was prepared under the 2023 ESRS.

Reference: pages 155-157.

Aroundtown states no measurable, outcome-oriented business conduct target. The G1 content index (page 79) runs G1.GOV-1, G1-1, G1-2, G1-3, G1-4 and G1-6, with no targets row, and Table 47 (page 156) is headed "Key actions" rather than targets.

Consistent with MDR-T's other limb, effectiveness is tracked in the absence of a target:

• "The Group's risk management framework includes regular audits, compliance monitoring, and risk assessments carried out by specialized teams to identify potential issues and ensure adherence to internal policies and legal requirements" (page 155).
• "As part of ongoing actions, AT ensures its governance and compliance framework is following best practice and international standards. Our annual compliance and risk assessments focus on this" (page 156).
• Training completion is measured and reported: "In 2025, 95.43% of all employees have completed the training" (page 156), against mandatory annual refreshers for all employees (Table 46, page 156).
• Incident review is formalised: all reported violations are monitored and investigated by the Compliance Department under the Investigation Policy, with outcomes "reported directly to the Co-CEO/COO, the CFO and a member of the Board of Directors, ensuring both the Board and the Management Body are promptly informed" (page 155).

Table 47 records the key actions per material sub-topic – a compliance framework with policies in place, HRDD and the whistleblowing system for detection and resolution, e-learning training, and investigation with corrective measures (page 156).

The Group discloses that resource allocation cannot yet be quantified: "Aroundtown does not currently have the available data to provide this disclosure. The allocation of financial resources to the action plan forms a part of the Group's ongoing operational activities, and this information is not tracked at the required level of detail at this stage" (page 157).

Incidents of corruption or bribery

Reference: page 157.

A complete nil return for the reporting year: "In 2025, AT was not subject to any convictions or fines for violations of anti-corruption or anti-bribery laws. The Group also did not experience any incidents of corruption or bribery, nor was involved in any public legal cases related to these matters. This reflects AT's ongoing commitment to upholding the highest ethical standards across our operations" (page 157).

So: zero convictions, zero fines, zero incidents and zero public legal cases. The Appendix confirms both G1-4 datapoints derived from other EU legislation as material and located at page 157 – "24 (a) Fines for violation of anti-corruption and anti-bribery laws" and "24 (b) Standards of anti-corruption and anti-bribery" (page 160).

The result is consistent with the wider incident reporting in the statement: zero incidents of discrimination and zero confirmed compliance complaints in own workforce (Table 35, page 130), "In 2025, no cases of human rights violations were reported" (page 134), and no severe human rights issues connected to value chain workers (page 136) or consumers (page 146).

The detection architecture behind the return is described under G1-3: an externally operated anonymous whistleblowing channel open to employees, business partners and tenants; Compliance Department investigation under the Investigation Policy with findings reported to the Co-CEO/COO, CFO and a Board member; and mandatory annual anti-corruption, anti-bribery and anti-money-laundering e-learning completed by 95.43% of employees in 2025 (pages 155-156). No breakdown of confirmed incidents by type or of actions taken against employees or business partners is required, there being none.

Payment practices

Reference: page 157.

No standalone policy, stated plainly: "Aroundtown does not currently maintain a standalone policy specifically dedicated to payment practices or late payments. However, payment terms are clearly defined at the outset of each contractual relationship to ensure transparency and alignment with suppliers. The Group is committed to complying with the agreed contractual payment terms" (page 157).

Standard terms (page 157):

• Construction suppliers: 30 days as a standard payment term
• Public authorities: usually 10 days
• Other suppliers: generally average 21 days, unless otherwise contractually specified
• For other categories, "payment terms are typically agreed bilaterally between the parties"

Average time to pay (page 157): "Whereas Aroundtown counts 22 average payment days, GCP has an average of 15 payment days."

Legal proceedings (page 157): "In 2025, a total of eight legal proceedings concerning late payments were recorded at Group level, including GCP."

A data limitation is disclosed: "In 2025, Aroundtown introduced analysis and monitoring of late payments, although reports are not yet harmonized across the Group due to differences in payment tracking systems" (page 157). The Group therefore does not report a percentage of payments aligned to standard terms or a breakdown of invoices paid late.

Payment practices sit inside the material G1 sub-topic "Management of relationships with suppliers including payment practices", assessed as double material with a positive impact and a risk in the upstream value chain over short and long term (Table 44, page 150; Table 9, page 72). Suppliers' interest in "reliable payments" is recorded in SBM-2 (page 67).