Covivio Hotels

France|Hotel Real Estate (REIT)|FY2025|Auditor: KPMG S.A. and Ernst & Young et Autres (joint Statutory Auditors)|View original report →

Sustainability statement, in full

The complete text of Covivio Hotels’s FY2025 sustainability statement is held here – 179 pages, captured from the published report. Every disclosure below also links to its own passage.

ESRS 2 – General Disclosures

GOV-1The role of the administrative, management and supervisory bodies
Reported

Governance roles

Reference: pages 9-12.

Covivio Hotels' sustainability governance is run at Covivio Group level. The Board of Directors, assisted by a CSR Committee (created 2021, meets at least twice a year), and the Executive Committee are the two main bodies; the Sustainable Development Department (8 FTE: 5 France, 2 Germany, 1 Italy) coordinates CSR across activities and reports to General Management and the Board via the CSR Committee (p.10).

Covivio Hotels itself has no dedicated CSR Committee; Covivio's Group-wide CSR Committee covers its activities. The Covivio Hotels Audit Committee reviews the CSRD audit methodology (approved 14 February 2025). The Supervisory Board put at least one CSR topic on every 2025 agenda (4 meetings) and approves multi-annual CSR objectives (p.11-12). 54% of Supervisory Board members hold specific CSR skills (environment, social, governance) (p.12).

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

Information provided to governance bodies

Reference: pages 11-12.

In 2025 the Supervisory Board reviewed, among other topics: the non-discrimination and diversity policy and gender balance on management bodies, energy consumption and certification progress of the portfolio, and the new CSRD reporting standard (p.11). At the 15 April 2025 meeting the change in portfolio certification rate and carbon intensity were presented.

The General Meeting of 17 April 2025 was informed of carbon trajectory progress (40% reduction target 2010-2030), portfolio certification (98.5% at end-2024) and the 21-objective Nature strategy (p.12). Shareholders also hold a Say on Climate vote (94.19% approval in 2023), repeated at least every four years through 2030, with annual progress reporting to the General Meeting in between (p.12).

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

Sustainability-related incentive schemes

Reference: page 13.

CSR criteria represent 30% of the Long-Term Incentive Plan for the CEO and Deputy CEO: a permanent environmental criterion (15%, portfolio certification and carbon trajectory) and an alternating social criterion (15%, women in teams / employee commitment). This was approved by shareholders on 20 April 2023.

For the Manager of Covivio Hotels specifically, variable remuneration (20% of fixed salary) is tied to 100% portfolio certification by 31/12/2025 and the annual carbon-intensity objective aligned with the CRREM 1.5°C scenario (21.1 kgCO2e/m2 in 2025); the General Meeting of 15 April 2025 again approved this allocation. A collective performance criterion (7.5% of variable pay, carbon-based) was extended to 30 national Management Committee members in 2025 (p.13).

GOV-3(was GOV-4)Statement on due diligence
Reported

Due diligence statement

Reference: page 14.

Covivio Hotels is not subject to the French 2017 duty-of-care law, but applies voluntary due diligence across the building life cycle (purchase, management, renovation, deconstruction, sale). The Asset and Property Management Department, with Environment, Legal and Sustainable Development support, analyses documentation during acquisitions to identify environmental risks and anticipate remediation costs; an ESG investment grid frames the information collected for acquisitions and developments.

During operation, suppliers are assessed via the EcoVadis IQ+ system (ESRS S2, 3.3.2.3.3), with enhanced human-rights vigilance measures where relevant (3.3.1) (p.14).

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Risk management and internal controls

Reference: pages 13-14.

Group risk mapping (updated 2021 and 2025) covers all subsidiaries; a specific CSR risk mapping exists alongside purchasing-risk mapping (2020/2021) and, in 2025, a supplier CSR risk analysis via the EcoVadis IQ+ platform. The Sustainable Development Department, working with the Audit, Risk, Compliance and Internal Control Department (ACI/CREA), rates risks on reputational impact, frequency and level of control, distinguishing inherent from residual risk.

Summary CSR risks include asset obsolescence, operating-expense control (energy, water, waste), health/environmental/regulatory compliance, fraud/corruption/ethics, and skills/diversity, each mapped to its ESRS chapter. The mapping is validated by the Executive Committee and shared with the Board (p.13-14).

SBM-1Strategy, business model and value chain
Reported

Business model and value chain

Reference: pages 15-17.

Covivio Hotels, listed on Euronext Paris compartment A, is "the leading investor in hotel real estate in Europe": 274 hotels (38,443 rooms) across 11 countries, valued at EUR6.6 billion at end-2025, with 17 hotel operator partners (AccorInvest, IHG, NH Hotel Group, B&B Hotels, Marriott, Radisson, etc.). The portfolio splits 61% lease properties / 39% operating properties; economy/midscale hotels are 67% of the portfolio, upscale 33%.

A 2024 consolidation transaction brought full ownership of 43 hotels in France, Belgium and Germany (~EUR800m) while 16 hotels were sold to AccorInvest. The WiZiU platform manages 24 hotels (3,100+ rooms) directly or via franchise. Strategy rests on three pillars: centrality, hospitality, sustainability; at end-2025, 99.9% of the hotel portfolio was environmentally certified and carbon intensity was down 59% versus 2010 (p.15-16).

SBM-2Interests and views of stakeholders
Reported

Stakeholder engagement

Reference: pages 17-19.

Covivio has mapped stakeholders since 2010 across five categories: commercial community (tenants, suppliers), financial community, human capital, public authorities, and civil society. A dedicated table (p.18) maps each stakeholder group's expectations, dialogue tools and the ESRS chapter covering them, e.g. employees (health/safety, training - ESRS S1), consumers/end-users (environmental performance, service quality - ESRS S4), suppliers (fair practices, payment deadlines - ESRS S2), local authorities/residents (nuisance limitation - ESRS S3).

A Stakeholders Committee, created in 2019 alongside the Group's Purpose, formally brings external views into governance (more in ESRS S3, 3.3.3.3.3). Communication channels include the URD, Nature report, Ethical Charter and Responsible Purchasing Charter (p.19).

SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

Material IROs and business model resilience

Reference: pages 19-21.

The SBM-3 table lists the IROs found material by the dual materiality analysis: a sectoral issue (fight against building obsolescence); E1 (climate adaptation, mitigation, and energy); E3 (water consumption, supply, water risk); E4 (biodiversity); E5 (circular economy, resource and waste management); S1 (working conditions, diversity, human rights); S2 (value-chain working conditions/human rights); S3 (societal involvement in the sustainable city); S4 (information and safety for consumers/end-users); and G1 (business conduct).

Each IRO is described with its value-chain position (upstream/direct operations/downstream), time horizon and whether it is an impact, risk or opportunity, e.g. financial risk of asset obsolescence from poor certification, and the physical/transition risks of climate change on building value (p.19-21). ESRS E2 (pollution) is not listed among the material IROs in this table.

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities
Reported

Double materiality methodology

Reference: pages 21-24.

A Group-level dual materiality analysis, covering all activities and the value chain, built on prior risk mappings and materiality matrices. It identified a universe of 20 issues (the 10 topical ESRS plus one sectoral issue), rated 1-4 on impact materiality and financial materiality, weighted by frequency of occurrence (generally a 3-year horizon, longer for climate) (p.22).

Workshops (Q4 2023-early 2024) involved ~40 Group managers including 6 Executive Committee members; external stakeholders were not re-consulted since the prior analysis had already engaged them. The analysis was adapted for Covivio Hotels specifically: S1 merged into one issue (vs 3 at Covivio level) given HR importance in hotels; E3 (water) rated more material given hotel operating risk; E5/waste rated more material (catering, plastics); E4/biodiversity rated less material (fewer developments). Validated by Covivio Hotels' Steering Committee (October 2024) and Supervisory Board (November 2024) (p.23-24).

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reported

ESRS disclosure requirements covered

Reference: pages 24, 163-166.

The double materiality matrix (p.24) plots the 20 identified issues on impact materiality (y-axis) against financial materiality (x-axis), with the note that "the list of data points reported is presented in section 3.5.1" (p.24).

Section 3.5.1 "Cross-reference table" (p.163-166) is Covivio Hotels' ESRS content index: a table listing, for each ESRS disclosure requirement (GOV-1 to G1-5), the internal section number where it is covered, plus cross-references to EPRA, GRI, ISSB and TNFD equivalents. ESRS E2-5 and G1-6 do not appear as rows in this table, and several environmental DRs (E2-6, E4-6) are marked "N/A" or "N.A" in it even where narrative content exists elsewhere in the report.

E1 – Climate Change

E1-1Transition plan for climate change mitigation
Reported

Climate transition plan

Reference: pages 33-41.

Covivio Hotels is "fully integrated into the Covivio Group-wide climate change mitigation transition plan." Group objectives: -40% GHG emissions (Scopes 1-2-3, carbon intensity) 2010-2030; -63% absolute Scope 1-2 emissions 2015-2030 (1.5C-aligned); Well-Below-2C alignment for Scope 3; "Net Zero Carbon" contribution from 2030 on the operational scope (p.33-34).

Covivio uses the CRREM 1.5C trajectory as its baseline scenario (CRREM version of 11 January 2023), reconciled against historical GHG data and the carbon trajectory through 2030. For Covivio Hotels specifically, the portfolio's carbon intensity fell to 20.2-30.6 kgCO2e/m2/year depending on country weighting, against a 2030 CRREM 1.5C hotel pathway benchmark of 14.6 kgCO2e/m2/year (p.34). The baseline year emissions volume for the Group trajectory is 455 ktCO2e.

E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysis
Reported

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (climate-specific subsection "3.2.1.1.12 Description of the process to identify and assess material impacts, risks and opportunities related to climate change"), where this content is disclosed in the FY2025 report (pages 42-44). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

In 2025 Covivio Hotels ran a new climate risk analysis with MSCI Real Assets, covering 282 assets (>EUR5.9bn) at end-2024. MSCI assesses two dimensions: physical risk (financial impact of climate hazards, using localised climate data) and transition risk (cost of low-carbon policy implementation). The analysis favours a 1.5C scenario (REMIND or CRREM) for transition risk and a worst-case RCP 8.5 scenario for physical risk, with outputs at 2030/2050/2100 horizons (p.43). The MDR-P policy table separately cites RCP 2.6 to 8.6 as the scenario range used for the adaptation policy (p.48). MSCI is extending the model by end-2026 to cover landslides, heat waves and tornadoes (p.43).

E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate change
Reported

Resilience in relation to climate change

Back-filled from the same ESRS 2 IRO-1 climate subsection and SBM-3, where this content is disclosed in the FY2025 report (pages 42-44). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Covivio's response to building resilience is twofold: reduce its environmental footprint, and adapt via eco-design that anticipates climate consequences (p.43). Supporting studies: the WRI Aqueduct study found 21.7% / 13.4% of the water-reporting scope in high / very-high water-stress areas (21% / 15% of reported consumption); a biodiversity-proximity study found 42% of sites within 1km of a protected area (p.43-44). These studies feed recommendations to strengthen resilience in due-diligence screening ahead of acquisitions and developments. No standalone, quantified resilience conclusion (financial-effect figure) is given; the analysis remains qualitative.

E1-4(was E1-2)Policies related to climate change mitigation and adaptation
Reported

Climate policies

Reference: pages 47-48.

Governance: the Board/CSR Committee monitors climate risk and CSR performance; the Executive Committee deploys climate objectives (tied to 15% of CEO/Deputy CEO LTIP, ESRS 2 3.1.2.2.4); the Sustainable Development Department coordinates action plans.

The MDR-P policy table (p.48) covers six sub-policies: (a) climate mitigation (-40% carbon intensity 2010-2030, scenarios 1.5C/WB2D/CRREM); (b) climate adaptation (RCP 2.6 to 8.6); (c) energy efficiency (-25% primary energy intensity in the tertiary portfolio, CRREM benchmark); (d) renewable energy deployment (doubling solar 2023-2030); (e) building certification (100% certified by 2025, >=Excellent/Gold for new developments); (f) customer/end-user awareness (100% of new office leases with a green clause). Covivio is a signatory of the EcoWatt Charter and the Charter of commitment to energy efficiency in commercial buildings.

E1-5(was E1-3)Actions and resources in relation to climate change policies
Reported

Climate actions and resources

Reference: pages 48-49.

The MDR-A action table links each policy to metrics and resources: climate mitigation (-40% carbon intensity 2010-2030, linked to taxonomy real estate activities 7.1-7.7+9.3 and the Green Bond framework); climate adaptation (100% of portfolio covered by physical climate risk analysis, study costs, adaptation measures built into project costs); energy efficiency (-25% primary energy intensity 2019-2030); renewable energy (doubling PV capacity 2023-2030); building certification (100% certified by 2025, certification fees); customer awareness (100% new office leases with green clause, HR/satisfaction-survey resources).

Covivio also deploys nature-based solutions: green roofs/terraces for urban heat-island mitigation (green roofs rarely exceed 20C vs 60-70C for concrete), rainwater retention and air-quality benefits (p.49).

E1-6(was E1-4)Targets related to climate change mitigation and adaptation
Reported

Climate targets

Reference: pages 50-53.

Central Group target: -40% carbon intensity per m2 (Scopes 1-2-3) between 2010 and 2030, equivalent to 76.3 to 45.9 kgCO2e/m2/year, built on SBTi-approved absolute targets of -63% Scopes 1-2 (1.5C) and -37.5% Scope 3 (Well-Below-2C) versus a 2015 baseline (433,298 tCO2e Scope 3; 21,242 tCO2e Scopes 1-2). The MDR-T table records progress of -31% at end-2025 against the central target, and contributes to SDG 11 and SDG 13.

For the Hotels Europe sub-portfolio specifically, the 2010/2030 carbon-intensity objective is -70% (target 14.6 kgCO2e/m2); achieved was 20.2 kgCO2e/m2 at end-2025 versus a CRREM 1.5C benchmark intensity of 30.6 kgCO2e/m2 weighted by country (p.50-51).

E1-7(was E1-5)Energy consumption and mix
Reported

Energy consumption and mix

Reference: page 51.

Portfolio energy consumption was stable in absolute terms in 2025 (179.4 to 179.8 kWh(fe)/m2); on a like-for-like basis consumption fell 1%. Coverage rate reached 98.4% (0.9% estimated). Hotels Europe total final energy intensity was 251.3 kWh(fe)/m2/year in 2025 (vs 265.3 in 2024); total direct energy consumption for the whole portfolio was 195,625,771 kWh(fe) in 2025 (204,701,475 in 2024), of which natural gas is the dominant direct-energy source (86,202,021 kWh(fe)).

The Hotels Europe 2010/2030 target is -50% final energy intensity (308 kWh(pe)/m2/year); 2025 final energy intensity for hotels in Europe was 183.4 kWh(fe)/m2/year (184.6 in 2024).

E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Reported

GHG emissions

Reference: page 54.

Hotels-in-Europe carbon intensity: 2010/2030 target -70% (to 14.6 kgCO2/m2); actual was 20.2 kgCO2/m2/year at end-2025 (20.5 in 2024). Total portfolio absolute emissions 2025: Scope 1: 3,671 tCO2e; Scope 2 (market-based): 4,197 tCO2e; Scope 3 downstream leased assets (market-based): 24,073 tCO2e, summing to 31,941 tCO2e (vs 37,150 tCO2e in 2024). Reporting-scope coverage was 100% for Scopes 1-2 and 98% for Scopes 1-2-3 by surface area, with 3.9% estimated data.

Methodology follows the GHG Protocol; Scope 2 is calculated on a market basis, and Scope 3 downstream leased assets cover operation of assets leased to others not already in Scopes 1-2.

E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits
Reported

GHG removals and carbon credits

Reference: page 59.

"To date, Covivio has not implemented systematic mitigation or removals projects through carbon credits, apart from a few occasional tree planting projects (not material) as part of its corporate activities (communication and finance)." The topic is under strategic monitoring with a view to setting net-zero targets beyond 2030 and by 2050 at the latest. Covivio Hotels is not directly subject to the EU Emissions Trading Scheme.

E1-10(was E1-8)Internal carbon pricing
Reported

Internal carbon pricing

Reference: page 60.

"Covivio has explored the possibility of introducing an internal carbon pricing system, but has not considered this a priority compared to other levers of its carbon trajectory," given that carbon considerations are already embedded in decision-making, particularly in investment committees (the governance body for all acquisition or development projects over EUR5 million).

E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Reported

Anticipated financial effects from climate risks

Reference: page 60.

A summary table links risk/opportunity type to affected financial-statement item and quantification source (mainly the MSCI Climate Value at Risk study): physical risks affect asset value (physical damage, liquidity risk); transition risks affect asset value (depreciation from energy-efficiency regulation, MSCI note excludes remediation Capex) and revenues (rising energy costs, loss of attractiveness); opportunities include revenue growth from sustainable-classified activities (32.5% alignment with the mitigation target, 43.3% for real-estate-only activities) and Capex alignment (67% with mitigation target, 83% with adaptation target), plus financing benefits (64% green debt).

E2 – Pollution

E2-1Policies related to pollution
Reported

Pollution policies

Reference: pages 61-63.

"The dual materiality analysis did not show this ESRS to be material with regard to the Group's activities, including the issues related to its value chain. However, Covivio has chosen to document its pollution prevention policies and actions (air, water, soil, hazardous substances) in order to meet the expectations of its stakeholders and strengthen transparency, even outside of a strict CSRD reporting obligation" (p.61).

Four policy areas are set out (p.62): preventing air pollution (low-emission materials, indoor air quality monitoring); protecting water and natural environments (retention systems for hazardous substances, approved treatment providers); ensuring regulatory compliance (ICPE/equivalent diagnostics, the Provexi platform in France); and reducing hazardous substances ("zero pesticides" for green spaces, SVHC substitution commitments under REACH).

E2-2Actions and resources related to pollution
Reported

Pollution actions and resources

Reference: pages 63-65.

Actions detailed by policy area: the low-nuisance construction site charter limits dust/VOC emissions (prohibiting harmful/toxic/very-toxic classified products, mandatory dust-suction equipment); air-quality monitoring uses the Octopus Lab sensor system in ~10 multi-tenant buildings and the IntAirieur label (e.g. the Noeme conversion in Bordeaux); water-pollution prevention requires retention systems, clear/dirty water separation and anti-pollution kits on sites ("No accidental pollution was reported in 2025"); the Provexi platform centralises asbestos/lead/soil diagnostics in France; and a "zero phyto" green-space policy uses biological/biotechnical pest control instead of phytosanitary products.

E2-3Targets related to pollution
Reported

Pollution targets

Reference: page 66.

A targets table sets: deploying a low-nuisance site charter on 100% of new developments by 2028 (in progress); permanently analysing health/environmental risks on new investment projects and acquisitions (Risk and Pollution Statements - ERP - in progress); adopting sustainable green-space management practices across the directly managed portfolio (permanent); and systematically equipping construction sites with anti-pollution kits, containment procedures and emergency protocols (permanent, in place).

E2-4Pollution of air, water and soil
Reported

Pollution monitoring indicators

Reference: page 66.

Under "Indicators and monitoring related to pollution (E2-4, E2-5)", Covivio states it "monitors various key indicators according to the types of assets and the various impacts considered but is not in a position to consolidate the results": number of environmental diagnostics conducted (air, water, soil), indoor air quality indicators (VOCs, CO2, fine particles), number and treatment of pollution incidents on construction/operating sites, and share of sites without phytosanitary products. No consolidated air/water/soil pollutant quantities are reported.

E2-5Substances of concern and substances of very high concern
Not Material
E2-6Anticipated financial effects from pollution-related impacts, risks and opportunities
Reported

Anticipated financial effects from pollution

Reference: page 66.

"To date, Covivio has not yet produced a consolidated quantitative assessment of the financial consequences of the material risks and opportunities arising from the impacts of pollution." Potential financial impacts mainly concern provisions for possible site decontamination, added costs of work (asbestos/lead removal, polluted-waste management) and environmental-damage liability risk. Covivio states it "plans to gradually strengthen the quantitative analysis of financial impacts as part of the CSRD compliance ramp-up" and confirms no provisions are set aside for pollution-related legal proceedings.

E3 – Water

E3-1Policies related to water and marine resources
Reported

Water policies

Reference: pages 67-68.

"The dual materiality analysis highlighted the fact that the issues related to water and marine resources were not material for Covivio, unlike the aspects related to consumption, supply and presence of assets in areas at risk of water stress" (p.67) - i.e. marine resources are not material but water consumption/stress is. Water pollution aspects are addressed under ESRS E2, not as material under E3.

Policies (p.68) rest on the 2023 French water-sobriety plan (-10% withdrawals by 2030), the WRI Aqueduct Water Risk Atlas and CMIP6 climate models. Three pillars: controlling/reducing consumption (monitoring, water-efficient equipment, HQE/BREEAM/LEED integration in 100% of developments); identifying water-stress areas; and involving external stakeholders (Responsible Purchasing Charter, Green Key certification covering water management in hotels since 2024, customer awareness campaigns).

E3-2Actions and resources related to water and marine resources
Reported

Water action plan

Reference: pages 69-72.

Three action areas: (1) controlling/reducing consumption throughout the building life cycle, via systematic consumption monitoring, water-economical fixtures and leak detection; (2) managing water-stressed areas, mapping the portfolio annually against the WRI Aqueduct tool (high water stress = 40-80% of total water abstracted; 21.7%/13.4% of the water scope in high/very-high risk areas per the 2023 Beta Aqueduct map) and, since 2024, the MSCI Climate Value at Risk tool (defined as >=211 days/year above 60% demand-to-supply = high risk, >254 days = very high risk); (3) involving external stakeholders - suppliers (Responsible Purchasing Charter), hotel operators (Green Key certification, launched 2024) and customers (awareness campaigns on showers, laundry, watering).

E3-3Targets related to water and marine resources
Reported

Water targets

Reference: page 72.

Multi-year targets: Hotels real estate Europe <=2 m3/m2/year water intensity (2025 result 1.45, down from 1.51 in recent years, -37% vs 2008); hotels in operation -10% average water intensity 2019-2030 (-22% achieved vs 2019 at end-2025); 100% of hotels with the Green Key label (96% achieved, remainder in progress); mapping the entire portfolio against water-stress risk (2025, done via Aqueduct WRI); monitoring consumption in high/very-high water-stress zones (identified: Lille-Brussels-Amsterdam area and Southern Europe); green water clauses in 100% of new tertiary leases (carried out since 2024).

E3-4Water consumption
Reported

Water consumption data

Reference: pages 72-73.

Total portfolio water consumption (billed basis, CDP methodology) was 2,293,667 m3 in 2025 (2,210,746 m3 in 2024), with intensity of 1.45 m3/m2/year (1.42 in 2024). On a like-for-like basis, Hotels-in-Europe water consumption was 1.46 m3/m2 in 2025 (-0.9% vs 2024). Water intensity of revenue was 0.0069 m3/EUR. Consumption in high-water-stress areas was 200,518 m3; in very-high-water-stress areas, 273,079 m3 (down from 415,999 m3 in 2024). All consumption comes from public mains supply; Covivio does not abstract directly from groundwater.

E3-5Anticipated financial effects from water and marine resources-related impacts, risks and opportunities
Reported

Anticipated financial effects from water stress

Reference: page 71.

Revenue generated in areas at very high risk of water stress is estimated at EUR42 million (11.7% of total water consumption compared against total turnover of EUR359.2 million) (p.71). However, "the risk of water stress is not financialised in the MSCI study, the main risk being a restriction leading to the partial or total cessation of certain activities in the hotel sector for the most at-risk areas" - i.e. the company discloses a qualitative risk characterisation and one exposure metric rather than a quantified financial-effect figure.

E4 – Biodiversity and Ecosystems

E4-1Transition plan on biodiversity and ecosystems
Reported

Biodiversity transition plan

Reference: pages 74-77.

Covivio combines climate and biodiversity in a "Nature" strategy (approved 2024 by the Executive Committee/CSR Committee) built on three pillars: (1) avoid degradation of natural habitats, (2) reduce resource consumption, (3) contribute to improving biodiversity in cities. It follows an "Avoid, Reduce, Transform" framework inspired by the Science-Based Targets Network and the French "ERC" sequence. "Covivio Hotels is fully committed to the deployment of Covivio's Nature strategy," benefiting from Group expertise while implementing hotel-specific actions (p.74).

Context cited: >50% of global GDP depends on ecosystem services; 75% of land altered by human action and wild-animal populations down 69% (1970-2018) per IPBES (p.74).

E4-2Policies related to biodiversity and ecosystems
Reported

Biodiversity policies

Reference: pages 78-79.

Policy references include the SBTN "Avoid, Reduce, Offset/Transform" framework, the Kunming-Montreal Agreement, Act4Nature International, and labels such as BiodiverCity (R) Construction & Life. Only aspects not already covered by E1/E3/E5 are addressed here.

Three policy commitments: avoid habitat degradation (align with a Net Zero Artificialisation trajectory, prioritise urban rehabilitation/densification, integrate biodiversity into project analysis); reduce resource consumption (two-thirds of Covivio's impacts sit upstream in the value chain, so the circular economy and water/energy sobriety are prioritised); and contribute to urban biodiversity (strengthen nature in projects, build staff/partner culture, involve customers).

E4-3Actions and resources related to biodiversity and ecosystems
Reported

Biodiversity actions and resources

Reference: pages 80-81.

Action-plan table ties each policy pillar to KPIs, e.g. monitoring artificialisation indicators (including the Biodiversity Avoidance Factor, BAF) for 100% of the development pipeline, and referencing assets near natural areas for 100% of the operating portfolio. Taxonomy context: the delegated act on the other four environmental objectives (including biodiversity protection) was published June 2023, bringing hotel revenue into taxonomy eligibility; an initial 2023-24 review found "no hotel meets all of the criteria" for alignment, though some are being analysed for potential alignment measures (p.85).

E4-4Targets related to biodiversity and ecosystems
Reported

Biodiversity targets

Reference: pages 82-83.

Targets include: 100% of the development pipeline monitored for artificialisation indicators including the BAF (tested on a hotel operation at Le Touquet) by end-2025 and permanently; contribute to zero net artificialisation on the committed pipeline (cumulative from 1 Jan 2024), permanent; favour refurbishment over demolition (>=30% of development Capex) by end-2028 - status "100% of hotel operations consist of renovations"; Biodiversity Condition Score improvement for 90% of new builds by end-2025; 100% of management trained on biodiversity by end-2025 ("done in 2024 and 2025"); ecologists included in 100% of large-scale projects (>5,000m2) by end-2026.

E4-5Impact metrics related to biodiversity and ecosystems change
Reported

Biodiversity impact metrics

Reference: pages 83-85.

A 2024 UTOPIES study cross-referenced GPS coordinates of 1,641 Covivio sites (510 commercial, 1,131 residential in Germany) against the WDPA protected-areas database within a 10km radius. Results: more than 25% of sites are in or <500m from a protected area, an additional 17% are 500m-1km away - in total 42% of sites are within 1km of a protected area, concentrated in France, Germany, Italy, Spain, the UK, Belgium and Poland. Five sites sit directly within a protected area (three in France, one in the UK, one in Germany). The majority (>900 sites, 58%) are more than 1km away. An earlier GRI G4-aligned study (2015/2017/2020, 157 sites) rated Covivio "Performing" to "Very Performing" on GRI 304-1 to 304-4.

E4-6Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities
Reported

Anticipated financial effects from biodiversity

Reference: page 80.

"At this stage, Covivio has not yet fully quantified the financial impacts related to biodiversity. However, the gradual integration of the ROID diagnostics, the GBS [Global Biodiversity Score] and ENCORE tools, as well as the monitoring of the CBS [Biodiversity Condition Score], are meant to inform a quantified evaluation" feeding future financial planning and risk management. One figure is given: for the Atelier (Paris) renovation, the budget directly allocated to biodiversity was 3% of the total construction amount.

E5 – Resource Use and Circular Economy

E5-1Policies related to resource use and circular economy
Reported

Circular economy policies

Reference: pages 86-87.

The dual materiality analysis found "Waste management on its operational assets" material for Covivio Hotels and "Promotion of the circular economy and resource management in development projects" material for Covivio Group; the two were combined given the importance of both phases in the hotel sector (p.86).

Two policies: accelerating the circular-economy transition in development (integrating circularity from design, promoting reuse/recovery of materials, collaborating with reuse/social-economy partners) and in operations (exemplary waste management, reduced dependence on virgin raw materials via recycled-material use and selective deconstruction) (p.86-87).

E5-2Actions and resources related to resource use and circular economy
Reported

Circular economy actions and resources

Reference: pages 87-92.

Actions span regulatory compliance (Decree 2016-288 requiring 5-stream sorting above 1,100 L/week of hotel waste; AGEC law bio-waste sorting for restaurants >20 seats from 2024; mandatory water-fountain provision and ban on plastic bottle distribution since Feb 2022) and hospitality-specific commitments: no endangered-species menu items, sustainability-labelled/short-supply-chain meat, organic/free-range poultry, at least one vegetarian option, FSC/PEFC-sourced furniture and sustainably-sourced paper products (p.93).

E5-3Targets related to resource use and circular economy
Reported

Circular economy targets

Reference: pages 93-94.

Development targets: test a circular-economy label (CircoLab, Ecocycle, etc.) 2026-2030 (trial underway on a Paris 1st-arrondissement renovation); PEMD diagnosis and 30%-by-mass material conservation/reuse commitment on large demolitions (>5,000m2) by end-2030 (piloted at Le Touquet); traceability process for key materials by end-2026; recovery rate of 80% of waste mass (50% material recovery, 100% inert waste). Operations targets: widespread selective collection (achieved, 100% of sites); zero-plastic objective by end-2026 (widespread in most hotels); multi-year weight/volume waste target via the Green Key label from 2025.

E5-4Resource inflows
Reported

Resource inflows

Reference: page 95.

Covivio states it relies on "a structured set of indicators and resources" covering both incoming flows (water, energy, materials) and outgoing flows (waste), collected at project and Group level (p.95). No total weight of materials/products used, nor a recycled- or biological-input share, is currently quantified in the report; material-inflow monitoring (concrete, glass, steel, aluminium, covering at least 80% of new development operations) is a stated target for end-2026, not yet-reported actual data, and recycled-content targets for steel, aluminium and concrete are marked with a placeholder percentage pending definition (p.94).

E5-5Resource outflows
Reported

Resource outflows - waste reporting

Reference: pages 95-96.

Construction waste splits approximately: inert ~83%, non-hazardous ~13.4%, hazardous ~3.6% (national averages cited). Regulatory sorting covers 7 streams (paper/cardboard, metal, plastic, glass, wood, plaster, mineral fractions) plus bio-waste since 2024. Total portfolio waste generation in 2025: 14,998 tonnes extrapolated (2024: 17,432 tonnes), of which 3,072 tonnes recorded as recycled/reused/composted (28%, down from 39% in 2024 due to wider reporting scope). Waste intensity was 9.3 kg/m2. WEEE is treated as non-material at Group level and excluded from consolidated tables; Covivio is not involved in radioactive waste.

E5-5(was E5-5-Waste)Waste
Reported

Waste management

Reference: pages 95-96.

See E5-5: regulatory sorting obligations (7 streams plus bio-waste from 2024), waste categorisation (inert/non-hazardous/hazardous, with treatment routes - material recovery, recycling, energy recovery/composting, and specialised hazardous channels with mandatory traceability slips), and the 2025 consolidated data (14,998 tonnes total waste extrapolated across the portfolio; 28% recycled/reused/composted; 9.3 kg/m2 intensity; regulatory minimum recovery of 70% exceeded by an 80% target for certified projects including 50% material recovery).

E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Not Material

S1 – Own Workforce

S1-1Policies related to own workforce
Reported

Own-workforce policies

Reference: pages 103-104, 109-110.

Covivio's 2024 Human Rights Policy applies as employer, customer and supplier; it is aligned with the UN Guiding Principles, ILO Core Conventions, OECD Guidelines, UN Global Compact (signed 2011) and the Diversity Charter (signed 2010). A 2024 independent review found the Group's system compliant with the EU Taxonomy minimum safeguards across 10 points of study, with no points of attention (p.104).

Covivio Hotels / WiZiU-specific policies (p.109-110) cover six areas, each linked to IROs: attracting talent; skills development; career development and retention; health, safety and quality of life at work; diversity and inclusion; and engagement/social dialogue. WiZiU's HR policy adds four pillars: equality/diversity/inclusion, a respectful work environment, proactive career management, and stability/recognition.

S1-2Processes for engaging with own workforce and workers' representatives about impacts
Reported

Action plan for own workforce

Reference: pages 111-125.

A Group-wide MDR-A action-plan table (p.111) links each of the six policy pillars to specific actions, the responsible manager (CEO/DCEO/SG/HRD, WiZiU HR Director) and metrics (e.g. turnover rate, % trained, annual-interview completion, absenteeism rate, gender-equality index, % covered by collective agreement). Detailed sub-action-plans follow for attracting talent, skills development, career development/work-life balance, health and safety/diversity, and engagement/social dialogue (pages 111-125), each naming concrete initiatives (annual/mid-year interviews, the WiZiU digitised professional-interview process, the Quality-of-Life-at-Work agreement, the Ex-Aequo mentoring programme).

S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concerns
Reported

Remediation channels for own workforce

Reference: pages 124-125.

Employees and external stakeholders can use Covivio's confidential Group Whistleblowing platform (detailed under ESRS G1, 3.4.4.1) to report fraud, corruption, discrimination, harassment or Human Rights violations, alongside the HR Department as a day-to-day listening channel. WiZiU operates its own internal whistleblowing system for its employees, compliant with the Sapin 2 law; other hotel managers rely on their brand's own alert platforms.

In 2025, complaints on ethics matters (harassment/discrimination) totalled 0 at Covivio Hotels scope / 6 at WiZiU scope (coverage 90%), with 0 fines on ethical or discriminatory grounds (p.122).

S1-3(was S1-4)Taking action on material impacts on own workforce
Reported

Action on material impacts for own workforce

Reference: pages 117-124.

Concrete actions against identified IROs include: structured annual/mid-year performance interviews (90% coverage, 772 of 1,516 eligible employees at Covivio Hotels including WiZiU, p.117); a Quality-of-Life-at-Work agreement (first signed 2014, revised 2023) covering the right to disconnect and psychosocial-risk prevention; WiZiU's 2025 package (75% mutual-insurance coverage, seniority/loyalty and co-optation bonuses, extended sick-leave pay); support on return from long absences via a systematic HR interview; and diversity/inclusion actions (e-learning on sexist-behaviour prevention, inclusive job adverts, the Ex-Aequo mentoring programme with 25 beneficiaries to date).

S1-4(was S1-5)Targets related to own workforce
Reported

Own-workforce targets

Reference: page 126.

2025 Covivio Hotels (full scope) targets and results include: >=75% of employees trained per year in Europe (81% achieved; WiZiU 11.6 training hours/employee); >=75% of annual interviews carried out (WiZiU: 90% achieved, 79% permanent contracts); 100% of employees covered by a collective agreement (94% achieved); roll out accident monitoring at 100% of hotels by 2028 (77% achieved, 15% accident rate; 0.9% work-related illness at WiZiU); >=40% of managers women (49% achieved) and 4% of the workforce with disabilities (3.9% at WiZiU) by 2025/permanent.

S1-5(was S1-6)Characteristics of the undertaking's employees
Reported

Workforce characteristics

Reference: pages 107-108.

Covivio Hotels' own-workforce reporting scope covers all employees for whom it has contractual liability (excludes employees of leased hotels). Total headcount at 31/12/2025: 2,420 employees (1,289 women, 1,131 men), by country: Germany 672, France 1,265, Italy 0, Luxembourg 4, Spain 2, Belgium 375, Ireland 102. By contract type: permanent 1,920 (997 women/923 men), temporary 230 (146 women/84 men), plus German "Minijobs". WiZiU specifically had 24 full-time employees (11 women, 13 men), 22 on permanent contracts.

S1-6(was S1-7)Characteristics of non-employee workers
Reported

Non-employee workforce

Reference: page 108.

2025 non-salaried Covivio Hotels workforce: student interns 28 (17 women/12 men); temporary workers 560 (258 women/302 men); self-employed independent workers/non-salaried executive directors 34 (33 + 1). Total: 622 non-employees, representing 26% of the total combined workforce. All HR indicators relating to Covivio Hotels employees specifically are also presented in the Covivio Group URD as part of the France employer unit (ESU).

S1-7(was S1-8)Collective bargaining coverage and social dialogue
Reported

Collective bargaining and social dialogue

Reference: page 125.

In hotels under lease, staff representation is handled by the operator (not Covivio Hotels); in hotels held as operating properties and at Covivio Hotels head office, collective-agreement/employee-representative-body coverage is 100%. Covivio Hotels (including WiZiU): 100% of employees covered by a collective agreement / 100% covered by employee representatives (GRI 102-41); WiZiU specifically: 95% / 94%. Due to its legal structure, Covivio Hotels has no European Works Council (the same applies to WiZiU). Covivio Hotels/its managers recorded no 2025 convictions related to labour law or trade-union freedom.

S1-8(was S1-9)Diversity metrics
Reported

Diversity metrics - top management

Reference: pages 121-122, 126.

"Covivio defines top management as the members of the Management Committees in France, Germany and Italy (including members of the Executive Committee) (S1-9)" (p.122). Gender breakdown of top management/senior managers (the Covivio Hotels steering committee) is 40% women (p.126). Representation of women on Covivio's broader management bodies: 33% of the Executive Committee and 54% of the Supervisory Board. A breakdown of the total workforce by professional category and gender is also given (manager/non-manager levels), showing women near parity or a majority at non-manager level (p.121-122).

S1-9(was S1-10)Adequate wages
Not Material
S1-10(was S1-11)Social protection
Reported

Social protection

Reference: page 121.

"All employees of the managers of Covivio Hotels are covered by social protection, as part of public programmes or benefits offered by the company, against loss of income due to illness, disability, work accidents, unemployment, maternity and parental leave as well as retirement." In France, WiZiU employees additionally receive company-funded supplementary health cover (75% for non-managers, 100% for managers) and salary maintenance from the first day of sick leave for three months.

S1-11(was S1-12)Persons with disabilities
Not Material
S1-12(was S1-13)Training and skills development metrics
Not Material
S1-13(was S1-14)Health and safety metrics
Reported

Health and safety metrics

Reference: pages 118-121, 126.

Absenteeism rate (GRI 403-2, Covivio real-estate scope, 2025): men 6.8%, women 13.6%, total 9.1% (90% coverage) (p.118-121, figures reconstructed from the absenteeism table). The "Requirement for additional CSRD data" appendix states "(S1-14) Employee health and safety coverage: ESU Covivio France (including Covivio Hotels employees): 100%; WiZiU scope: 100%" (p.126). The S1 targets table (p.126) records an accident rate of 15% and 0.9% work-related illness at WiZiU, with accident-monitoring rolled out to 77% of hotels against a 2028 target of 100%.

S1-14(was S1-15)Work-life balance metrics
Reported

Work-life balance metrics

Reference: page 118.

Work-life balance indicators (GRI 414-2), Covivio Hotels (including WiZiU) 2025: number of employees entitled to parental leave (children under 3) 598 (83% coverage); employees who exercised their right to parental leave (full- or part-time) 47 (79% coverage: 12 at Covivio Hotels head-office scope, plus WiZiU). The Quality-of-Life-at-Work agreement (first signed 2014, revised 2023) introduces the right to disconnect and covers psychosocial risks from new information/communication technologies; WiZiU relies on a disconnection charter within its working-time agreement.

S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Reported

Compensation metrics

Reference: page 122.

Salary information (GRI 405-2, EPRA Diversity-Pay): ratio of basic salary and remuneration of women to men, by professional category, for Covivio Hotels (including WiZiU) - e.g. M/F ratio (excluding CAPs and suspension) -7% / -3.5% across two reported years; M/F manager ratio -8% / 1.9%; non-manager M/F ratio -7% / -4.6%, each at 78-99% coverage. An "Equity ratio - Average" (CEO pay ratio) of 3.88 and 13.03 is also disclosed for Covivio Hotels (including WiZiU) (p.118-119), alongside the definition that a manager is "an employee who supervises at least one person."

S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Incidents and complaints

Reference: page 121.

"No complaints related to discrimination were submitted to the Ethics Officer in 2025 in France (Corporate scope), and Covivio was not found guilty of any offences in the area." Alert-monitoring table, Covivio Hotels (incl. WiZiU) vs WiZiU, 2025: complaints on ethics matters (harassment, discrimination in all forms) 0 / 6 (90% coverage); amount of fines on ethical or discriminatory grounds 0 / 0. Complaints received led to internal investigations, action plans and mandatory training; "no alert was made in 2025 at the hotels managed by WiZiU" under that separate count.

S2 – Workers in the Value Chain

S2-1Policies related to value chain workers
Reported

Value-chain worker policies

Reference: pages 128-129.

Three policies: preventing accidents on construction/operating sites (applies to all external service providers, based on "shared vigilance"); implementing the Responsible Purchasing Policy (since 2011, extended to France/Germany/Italy since 2022, applying above EUR200k for works/maintenance and EUR50k for corporate spend, aligned with the Sapin 2 law and UN Global Compact); and selecting/assessing suppliers on CSR criteria via EcoVadis, with de-referencing possible for repeated/serious breaches. The report notes: "Workers across the value chain have not been consulted directly, and to date there is no overarching framework agreement between the Group's various entities (AR-19)" (p.129).

S2-2Processes for engaging with value chain workers about impacts
Reported

Engagement with value-chain workers

Reference: pages 129-134.

Value-chain scope covers upstream construction/renovation workers and downstream hotel-operation workers (maintenance, security, laundry, catering, IT-for-hotel-systems staff) and tenant-company employees (p.127). Engagement happens indirectly through the companies employing these workers: meetings and site visits with construction suppliers (no quantified follow-up, given supplier numbers), and continuous dialogue between hotel management and value-chain service-provider representatives, with some operators using newsletters for CSR reminders (p.134). Covivio has not directly surveyed suppliers' employees on their confidence in its whistleblowing system (p.134).

S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reported

Remediation channels for value-chain workers

Reference: page 134.

Covivio provides all stakeholders, including subcontractors' employees, access to its Group Whistleblowing platform (detailed under ESRS G1, 3.4.4.1), allowing confidential reporting of social, environmental or ethics breaches. This is the stated remediation channel for value-chain workers; the report does not provide separate consolidated statistics on alerts raised specifically by value-chain workers through this channel (distinct from the own-workforce figures reported under S1-3).

S2-3(was S2-4)Taking action on material impacts on value chain workers
Reported

Action on value-chain worker impacts

Reference: pages 129-134.

Actions against the identified IROs (construction-site/operating-site accidents, insecure employment, reputational risk from value-chain incidents) include deploying the low-nuisance construction site charter, applying the Responsible Purchasing Policy's ethics/social/environmental criteria from tender through contracting, and assessing/monitoring suppliers via EcoVadis and the IQ+ CSR-risk platform. Resourcing: ~3 FTE coordinate the system, plus the annual EcoVadis subscription and external CSPS (construction-site safety coordination) missions (p.134).

S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Value-chain worker targets and metrics

Reference: pages 134-135.

Targets: 100% of worksites covered by health and safety procedures (achieved; 90% with accident monitoring; 0 deaths recorded in 2025); annual CSR risk analysis for all suppliers by 2026 (IQ+ analysis covers 78% of expenses / 3,843 suppliers); 66% of expenses assessed via EcoVadis and 100% of tenders by 2026 (48% of Group expenses achieved; France target already met). 2025 EcoVadis metrics: average supplier score 66.1/100 (vs a 49.7/100 global average); Covivio itself scored 74/100 (Silver); Covivio Immobilien GmbH scored 77/100 (Gold). CDP named Covivio a 2025 Supplier Engagement Leader (A-List).

S3 – Affected Communities

S3-1Policies related to affected communities
Reported

Policies for affected communities

Reference: page 138.

Scope covers local/regional residents, local authorities and beneficiaries of Covivio's societal actions (notably via its Foundation); indigenous peoples' rights were assessed and found not material given the nature and location of Covivio's activities (dual materiality analysis, ESRS 2 3.1.2.4.2). Two policies: working with local residents/regions to reduce development-project nuisance (noise, pollution, visual disturbance), and investing in city life / supporting social and societal development through long-term association partnerships, skills-based sponsorship and support for real-estate-sector training.

S3-2Processes for engaging with affected communities about impacts
Reported

Engagement and action for affected communities

Reference: pages 139-142.

Actions include construction-site noise/pollution monitoring, low-nuisance site charters, and dedicated resident-communication tools (e.g. a site-specific app for the Beige project in Paris). Local employment levers include integration clauses in works contracts and preferred use of local suppliers. The Covivio Foundation (created 2020) supports ~20 partner associations across France, Germany and Italy on education, professional integration and support for vulnerable groups; in 2025 it invested EUR328,000 in financial donations and EUR230,000 in in-kind/skills sponsorship, and 437 solidarity missions (1,718 volunteer hours) were carried out by employees.

S3-2(was S3-3)Processes to remediate negative impacts and channels for affected communities to raise concerns
Reported

Remediation channels for affected communities

Reference: page 143.

"Communities that could be affected by Covivio's activities are authorised to use the previously mentioned [whistleblowing] channels to raise concerns or needs... Complaints are handled confidentially... Anonymous reports will be considered provided that the reported facts are sufficiently serious and detailed." Covivio states that "the diverse and highly variable nature of the actions implemented... means that it is not possible to carry out a quantification or consolidated monitoring of the effectiveness" of these remediation processes. A Stakeholders Committee (since 2020) also channels external perspectives into governance.

S3-3(was S3-4)Taking action on material impacts on affected communities
Reported

Socio-economic impact on affected communities

Reference: pages 144-145.

Using the Utopies LOCAL FOOTPRINT(R) model (2024 study on 2023 data), Covivio quantifies its regional socio-economic footprint: 17,000 jobs supported in Group share across Europe (1,000 direct Covivio jobs, 1,500 Hotel operating-properties jobs, 6,700 indirect supply-chain jobs, 4,100 induced jobs from household spending, 3,700 from public-sector spending), generating EUR2.2 billion in direct/indirect/induced GDP. At 100% basis, 23,600 jobs are supported (+56% vs 15,100 in 2018). An additional 375,000 "catalytic" office jobs and 15,000 catalytic hotel jobs relate to tenant companies' own activity (not attributed to Covivio).

S3-4(was S3-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Targets for affected communities

Reference: page 143.

"The socio-economic impact study carried out on all the Group's activities in Europe enables Covivio's contribution to direct and indirect employment to be quantified... The results are based on the volume of operations developed, managed or leased. They cannot be translated into objectives." Covivio therefore states explicitly that no numerical target is set for this topic, in contrast to other ESRS chapters; it relies on the LOCAL FOOTPRINT(R) metrics (S3-4) as its measurement approach instead.

S4 – Consumers and End-users

S4-1Policies related to consumers and end-users
Reported

Consumer/end-user policies

Reference: pages 147-148.

Five policies: promoting digital innovation/cybersecurity (GDPR compliance, R2S/WiredScore/SmartScore labels); ensuring safety/health/well-being within buildings (fire, accessibility, asbestos regulation plus higher internal standards); promoting accessibility (physical, functional/sensory and geographical dimensions for people with disabilities); improving customer satisfaction (transparent offering, consistent service quality); and promoting environmental/societal commitment among customers (shared environmental commitments, cultural/civic engagement). "Covivio Hotels consumers" are mainly corporate tenants/hotel-operating-property managers; "end-users" are hotel guests (p.146).

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

Action plan for consumers and end-users

Reference: pages 148-150.

Action-plan table ties each policy to metrics: cybersecurity (cyber-risk training/awareness); safety/health/well-being (regulatory compliance on 100% of assets); accessibility (distance to public transport, building accessibility level); customer satisfaction (customer-satisfaction integration into team objectives, a customer incident/feedback management system); environmental commitment (shared environmental commitments with customers). Specific initiatives detailed include a structured cybersecurity action plan (Group-Offices scope) and labelled well-being/accessibility certification programmes.

S4-2(was S4-3)Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
Reported

Remediation channels for consumers and end-users

Reference: pages 150-151.

Customer comment/complaint management is contracted to hotel operators, with monthly monitoring of response rate and type by Covivio Hotels' teams; contracts can include penalties for non-response and performance-related bonuses tied to customer-satisfaction scores, with some allowing contract termination for persistent underperformance. Customers/users can also escalate via the Group Whistleblowing platform (ESRS G1, 3.4.4.1), open to internal and external stakeholders; "No client alerts were escalated in 2024."

S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions
Reported

Action on consumer/end-user impacts

Reference: pages 150-152.

The dual materiality study found "the security and quality of the information communicated" to be the most material S4 issue (p.146). Actions include the cybersecurity action plan, 100% regulatory-compliance target for buildings, accessibility improvements (97.1% of assets within 500m / 99.6% within 1km of public transport, vs a 95%-within-1km target), and customer-satisfaction management systems including verbatim survey reports routed to site managers, who must propose corrective action plans.

S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Targets for consumers and end-users

Reference: page 152.

Targets: 100% of new cybersecurity-relevant projects labelled (several certified programmes in France, Italy, Germany since 2020); 100% of developments well-being-certified, with Covivio Hotels specifically targeting Green Key on operating properties (61% of pipeline achieved); at least 95% of buildings within 1km walk of public transport (97.1% within 500m / 99.6% within 1km achieved); optimise tenant/end-user satisfaction (France-Offices, 100% achieved); 100% of new hotel leases with environmental clauses/annexes (completed since 2024).

G1 – Business Conduct

G1-1Business conduct policies and corporate culture
Reported

Business conduct policies and culture

Reference: pages 155-156.

The Ethical Charter (Code of Conduct under the Sapin 2 law, revised 2015/2018/2022/2024/2025) sets fundamental principles: legal compliance, anti-corruption, protection of people/environment, asset protection, information transparency and personal-data protection, with "zero tolerance" for corruption/influence peddling. "In 2025 (as in 2024), there were no disciplinary actions against any employees for failure to comply with the Ethical Charter... nor... any convictions on these grounds" (p.156). A dedicated WiZiU Ethical Charter (2018, updated 2024) adds hotel-specific provisions (cash-payment money laundering, fraud, anti-prostitution/paedophilia, customer-data confidentiality, food safety/hygiene). In 2025 Covivio also adopted an AI Charter.

G1-2Management of relationships with suppliers
Reported

Supplier relationship management and payment practices

Reference: pages 160-161.

The Responsible Purchasing Charter (UN Global Compact, Diversity Charter, ILO principles) governs supplier relations, centred on respecting contractual payment deadlines, anti-corruption, anti-money-laundering, limiting economic dependence and preventing conflicts of interest. Payment terms follow France's 2008 Law on the Modernisation of the Economy (LME); figures are calculated at the Covivio financial scope in France and exclude the Covivio Hotels European scope specifically. Group payment terms: transfer within 30 days (direct debit exception for utilities).

G1-2(was G1-3)Prevention and detection of corruption and bribery
Reported

Corruption prevention and detection

Reference: pages 156-159.

An eight-measure Sapin 2 prevention system covers: corruption risk mapping (updated 2024 with an external consultant); customer/supplier probity and accounting-control procedures; the Ethical Charter as code of conduct; the Whistleblowing platform (since 2015, relaunched 2023 across France/Germany/Italy, with a collegial investigation body of the COO and Compliance Director); employee training (mandatory "Process Morning" sessions, Hoguet-law training for 28 affected staff, targeted training for at-risk functions); and an annual monitoring/audit-plan review (p.156-159). "In 2025, two alerts were sent via the platform (none in 2024)" - one closed after investigation found no proven fraud/corruption/human-rights breach, the other still under investigation.

G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conduct
Reported

Targets related to business conduct

MDR-T "other limb": effectiveness tracking in the absence of a stated numerical target. G1-3 is a standalone DR only from the 2025/2026 ESRS; under the 2023 ESRS applied here, business conduct falls to G1-1/G1-2/G1-3/G1-4 and MDR-T.

Covivio Hotels sets no quantified corruption-reduction target (its 2024/2025 incident counts are already zero across convictions, fines and confirmed corruption cases, p.160) but describes how effectiveness is tracked: the eighth of its eight Sapin 2 prevention measures is "System for monitoring and assessing the measures implemented" - "Covivio ensures the proper implementation of its prevention measures through regular checks... included in the annual audit plans, which are validated by the Audit Committee" (p.159), supplemented by annual Process Morning training sessions (p.158) and regular anti-fraud audits approved by the Audit Committee (p.159).

G1-4Incidents of corruption or bribery
Reported

Incidents of corruption or bribery

Reference: page 160.

2024/2025 metrics, both years: 0 confirmed incidents of corruption; 0 convictions for anti-corruption/anti-bribery violations; 0 fines; 0 cases resulting in dismissal/disciplinary action for corruption/bribery; 0 terminated/non-renewed commercial-partner contracts due to corruption-related violations; 0 court cases concerning corruption/bribery. Number of requests to Ethics Officers in 2025: 9 (movements on Covivio/listed-subsidiary shares), 4 (external invitations), 3 (private use of service providers working for the company) - risk-of-conflict-of-interest categories.

G1-5Political influence and lobbying activities
Reported

Political influence and lobbying

Reference: pages 161-162.

Covivio "does not finance any public official, political party, holder of public office or candidate for public office, or any trade union or religious organisation which is not recognised as being in the public interest." 2024/2025 metrics: EUR0 political/financial/in-kind contributions; EUR0 direct internal/external lobbying expenses; EUR184,000 paid in membership fees to lobbying associations (limited to Afep, FEI and EPRA). Covivio Developpement reports its local-authority interactions to the HATVP Register of Interest Representatives; use of any external lobbying firm requires compliance verification against Law No. 2013-907 and HATVP registration.

G1-6Payment practices
Reported

Payment practices

Reference: page 161.

Under the heading "Supplier payment terms indicators (G1-6)", for the France scope in 2025: average time to pay an invoice was 22 days from the start of the contractual/legal payment period; standard Group payment terms are transfer within 30 days (direct-debit exception for utility "fluids" suppliers); 85% of invoices are paid within 30 days or less (from date of receipt); and there were no ongoing legal proceedings for late payments.