CPI Property Group

The role of the administrative, management and supervisory bodies

Reference: page 75.

CPI Property Group is governed by a Board of Directors. As at 31 December 2025 the Board comprised four independent non-executive directors, two executive directors and one non-executive director, with independence at 57% (2024: 50%).

The Board has established four committees: the Audit Committee, the Remuneration, Nomination and Related Party Transaction Committee, the Investment Committee and the Environmental, Social and Governance (ESG) Committee, chaired by Omar Sattar. The Audit Committee and Remuneration Committee members are independent; the Investment Committee has two executive and two independent members; the ESG Committee is presided over by an independent member but its membership is majority-executive given its operational role.

"Responsibility for the supervision of the IROs is embedded in the Audit and ESG committees." The Board evaluated each member's competencies and concluded "each individual board member possesses skills that are relevant to the material IROs" and the industry (sustainability expertise table, page 75).

Information provided to and sustainability matters addressed by the governing bodies

Reference: page 75.

The Audit Committee "regularly reviews the Group's impacts, risks, and opportunities, and ensures the implementation of due diligence practices," and is "responsible for evaluating the results and effectiveness of the sustainability policies, metrics and targets," reporting findings to the Board "on a regular basis." In 2025 the Group's Policy Risk Management was approved and implemented.

The ESG Committee is responsible for setting targets tied to material ESG impacts, risks and opportunities and monitoring progress, and recommends target-setting methodologies later approved by the Board. Progress is tracked through KPI reviews and periodic internal/external reporting, with "periodic reviews" of targets and "risk management adjustments" when progress deviates from expectations.

A full list of the material ESG IROs addressed by the Audit Committee is referenced under the SBM-3 Materiality and targets table (pages 81-82).

Integration of sustainability-related performance in incentive schemes

Reference: page 76.

The Remuneration, Nomination and Related Party Transaction Committee prepares and recommends the Board-approved Remuneration Policy for directors, under Luxembourg law of 24 May 2011.

"The Group's remuneration policy links sustainability matters to executive directors. Five percent of any discretionary annual bonus compensation of the executive directors is linked to the ESG Committee's judgement of whether the executive directors are meeting the Group's short-term and long-term environmental targets: for 2025 GHG intensity reduction was the target."

The ESG Committee's conclusions on fulfilment of the environmental target are communicated to the Remuneration Committee and folded into the overall annual KPI evaluation of the executive directors.

Statement on due diligence

Reference: page 76.

CPIPG maps the core elements of due diligence to sections of the sustainability statement:

This table is the company's own cross-reference rather than a single due-diligence narrative section.

Risk management and internal controls over sustainability reporting

Reference: page 77.

"The Group's risk management and internal control system is organised to identify main risks across all operations including sustainability reporting risks." The Board, ESG Committee and Audit Committee "regularly assess material risks and internal controls associated with the Group's sustainability reporting process."

At least once a year the Risk Management Department together with the ESG and Audit Committees "undertake a general identification and assessment of the Group's risks, including fraud risks," covering "risks of incompleteness and inaccuracy of reported ESG data." Specific control activities are performed by relevant functions over ESG KPIs, and "material weaknesses, omissions and violations are reported to the Executive Management," which in turn reports to the Board via Group Internal Audit per the audit plan.

Strategy, business model and value chain

Reference: page 77.

"CPI Property Group's business model is founded on a diverse, high-quality real estate portfolio, a strategic geographic focus, strong occupancy and rental growth." Established in 1991 in the Czech Republic, headquartered in Luxembourg, the Group is a real estate investor and developer across Central and Eastern Europe, with a portfolio of offices, retail parks and shopping centres, hotels (Clarion, Mamaison, Comfort and other brands), residential real estate, a development pipeline and a landbank concentrated in the Czech Republic, Berlin, Poland and other CEE markets.

Upstream inputs span capital, infrastructure and advisory resources; key suppliers include HVAC, lift, electrical, furniture, roofing and insulation providers. Downstream activities run from development and construction through leasing and property management to tenants, hotel guests and end-users. "Agriculture and aviation are not material part of the business and there are no material sustainability impacts, risks and opportunities identified" (page 79).

Interests and views of stakeholders

Reference: page 78.

Stakeholder input for the double materiality assessment was gathered via "an online survey conducted on the SurveyMonkey platform," coordinated with the Group's Marketing and PR team. "As of 15 October 2024, we received 171 anonymous responses, which we consider to be a sufficient sample size for analysis."

Stakeholder groups and their expectations include: tenants and hotel guests (excellent products/services, via daily operations); investors (solid business model, via reports, roadshows, webcasts); employees (decent work conditions, training, diversity, equality, via surveys and hotlines); authorities and governments (compliance, via industry associations); suppliers and business partners (fair business practices, via contract management); and communities (environmental and social responsibility, via local engagement). No additional stakeholder consultation was carried out during the 2025 reporting year.

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 79, 81-82.

"Through this process, the Group has defined twelve sustainability matters as material... The 2025 Double materiality reassessment confirmed the twelve sustainability matters identified in the previous reporting period as material." There were no changes to the material IROs for the 2025 reporting year compared with those from 2024, and "no impacts, risks or opportunities beyond those falling under the disclosure requirements of the ESRS were identified."

"The current financial effects of the Group's material risks and opportunities on its financial position, financial performance and cash flows are not material," with "no material risks and opportunities for which there is a significant risk of a material adjustment within the next annual reporting period." Strategic resilience "was assessed by the Internal Risk Manager and addressed as part of the Group's risk and opportunity assessment." The Materiality and targets tables (pages 81-82) detail each matter's impact materiality, financial risk/opportunity, time horizon, direction and target.

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 79-80.

The 2024 double materiality assessment (DMA) covered all Group activities and geographies; the 2025 reassessment "closely monitors both internal and external environments" and confirmed no change to the twelve material matters. "There were no changes to the material IROs for the 2025 reporting year compared with those from 2024."

Impact thresholds used severity bands (Critical ≥12, Significant 10-11.9, Important 8-9.9 = material; Informative/Minimal <8 = not material) based on scope, scale and irremediability per ESRS 1 guidance. Risk/opportunity materiality used a relative risk-weight threshold of ≥500 = material, built on the Group's existing risk-management tool.

Per-topic IRO-1 sub-sections assessed E2 pollution and E4 biodiversity as immaterial (see E2/E4 entries), and found material IROs for E1, E3, E5, S1, S4 and G1 (pages 79-80).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: page 74 (List of disclosure requirements); page 84 (Appendix B).

The sustainability statement opens with its own "European Sustainability Reporting Standards (ESRS) List of disclosure requirements," a page-referenced index of every ESRS 2 and topical disclosure requirement the statement covers (pages 75-112).

Appendix B cross-references specific ESRS datapoints to other EU legislation (SFDR, Pillar 3, the Benchmark Regulation, the EU Climate Law) with an explicit Material / Not material marker per datapoint and, where material, a page reference. For example, ESRS 2 SBM-1 fossil fuel/chemical/tobacco involvement datapoints are marked "Not material," while E1-4, E1-5 and E1-6 datapoints are marked "Material" with pages 93-97.

Transition plan for climate change mitigation

Reference: pages 93-94.

"The Group developed a comprehensive climate transition action plan, which has become an integral aspect of our operations." Commitments (from a 2019 base year, by 2030): 46.2% reduction in Scope 1+2 GHG intensity per m² (incl. bioenergy); 76.34% reduction in Scope 1 and 3 GHG emissions per MWh of sold electricity; 27.5% reduction in selected Scope 3 categories' GHG intensity per m²; plus a 10% reduction in energy intensity.

Five named decarbonisation levers: switching electricity to renewable sources, operating efficiency improvements, tenant involvement (green leases since 2023), new developments as net-zero-energy buildings, and energy-efficient CapEx. "Thanks to these actions... a 51.6% reduction of GHG emission intensity compared with the required intensity value for 2025 was achieved in target 1."

The Plan "outlines various objectives and strategies aimed at achieving a reduction in emissions in line with the 1.5°C goal of the Paris Agreement," with "main emphasis... on directly reducing emissions rather than relying on offsetting measures." It was "first approved by the ESG Committee in August 2024," updated and "approved again in August 2025," and forms part of the Group's CDP submission.

Policies related to climate change mitigation and adaptation

Reference: page 94.

Three internal policies govern climate action: the Group Policy on Environment and Corporate Social Responsibility (CSR), which "states the principles... designed to optimise the use of energy and natural resources"; the Group LCA Policy, which "shows how the transformation of business operations towards carbon neutrality can be achieved" and sets life-cycle-assessment calculation requirements; and the CPIPG GHG Recalculation Policy, which "sets the rules for recalculations of the Greenhouse Gas emissions inventory," specified per SBTi requirements.

These policies address the identified material impact ("actual negative impact on the environment through consumption of energy") and are referenced in the MDR-P policy-overview table (page 86).

Actions and resources in relation to climate change policies

Reference: page 94.

The five decarbonisation levers from E1-1 carry quantified expected cumulative GHG reductions to 2030: switching to renewable electricity – 175,000 tCO2e; operating efficiency improvements – 13,100 tCO2e; tenant involvement and cooperation – 6,520 tCO2e; new developments as net-zero-energy buildings – 10,900 tCO2e; energy-efficient CapEx – 13,000 tCO2e.

A named 2025 project, EcoMotion at the GSG econopark, Pankstraße 8, Berlin, is cited as an example: "a transformational energy upgrade... The hybrid energy system now combines high-efficiency heat pump technology with a biomass-based pellet boiler and, solely for peak load security, a modernised natural gas boiler," improving the primary energy factor.

Targets related to climate change mitigation and adaptation

Reference: pages 94-95.

Three quantified, time-bound GHG intensity targets versus the 2019 baseline, by 2030: Target 1 – 46.2% reduction in Scope 1+2 intensity per m² (incl. bioenergy); Target 2 – 76.34% reduction in Scope 1 and 3 emissions per MWh of sold electricity; Target 3 – 27.5% reduction in selected Scope 3 categories' intensity per m².

"Our updated targets were rigorously evaluated and validated by the Science-Based Targets initiative (SBTi) in 2025 and are aligned with the most stringent climate-science-based goal of limiting global warming to 1.5°C. CPIPG is among the first companies in the region to have their targets validated by SBTi." The 2019 baseline "was recalculated at the beginning of 2026" per the GHG Recalculation Policy; 2050 net-zero evaluation is still in progress, pending data granularity improvements.

Energy consumption and mix

Reference: page 96.

The statement provides a full "Energy consumption and mix (inside the organisation)" table, broken out by energy source (including fuel consumption from coal and coal products, among others) for 2025 and 2024, with a country-level split across the Czech Republic, Germany, Poland, Hungary, Romania, Slovakia, Austria and other markets.

The target to reduce energy intensity of the property portfolio by 10% by 2030 versus the 2019 baseline sits alongside this disclosure (E1-1/E1-4), and 2025 performance against it is reported in the SBM-3 Materiality and targets table (page 82) as "6.1% outperformed."

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 97-99.

The statement discloses Scope 1, Scope 2 (location-based and market-based) and Scope 3 (15 GHG Protocol categories) emissions for 2025 and 2024, each broken down across the Czech Republic, Germany, Poland, Hungary, Romania, Slovakia, Austria and other markets, plus total GHG emissions on both a location- and a market-based basis.

Against the three intensity targets in E1-4, 2025 performance is reported as: Scope 1+2, 51.6% outperformed the 46.2% target; sold electricity, 89.2% outperformed the 76.34% target; selected Scope 3 categories, 18.4% outperformed the 27.5% target (SBM-3 Materiality and targets table, page 82), attributed to "the renewable electricity purchased for the vast majority of our properties."

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Reference: page 100.

Transition-risk exposure: "the estimated amount of potentially stranded assets is 38%," based on fair value, using criteria combining GLA >5,000 m², gas consumption >600 MWh (2024) and fuel intensity >50 kWh/m², plus Climate Risk Analysis red flags. Stranded-asset exposure on EPC class F or G is separately put at 6% of fair value, with a breakdown of fair value by Primary Energy Efficiency Class (A through G).

Quantified financial effects: "by 2030 in accordance with Group ESG Strategy, the cost of emission certificates can be considered between €63-85.2 million," against "expected cost savings from climate change mitigation actions... between €30.9-51.5 million," both dependent on the future price of CO2 certificates. "As described in ESRS 2, SBM-3... the direct impact on the Group's Financial Statements resulting from the material transition risks is minimal."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 E1, where this content is disclosed in the FY2025 report (page 79). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Both physical and transition climate risks were assessed. Physical risk used a two-tiered analysis (aggregate Group-level plus per-building) identifying floods, heat stress and water stress as the most common high risks, using an external tool (Climcycle) drawing on Copernicus and ISIMIP data.

Scenarios named: Low – SSP1-2.6/RCP2.6 (peak warming 1.7°C, 1.6°C by 2100); Intermediate – SSP2-4.5/RCP4.5 (2.7°C by 2100); Very high – SSP5-8.5/RCP8.5, explicitly the highest-emissions scenario "in the absence of policies to combat climate change" (satisfying the requirement to use at least one high-emission scenario for physical risk). No scenario is explicitly identified as a "1.5°C, no/limited-overshoot" transition scenario; SSP1-2.6 is the lowest used but projects 1.6-1.7°C, above that threshold. Key transition-risk factors considered: regulation, technology, market and reputation. The assessment was first applied under ESRS methodology in 2024 and reassessed in Q2 2025 with no change in conclusions.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and IRO-1 E1, where this content is disclosed in the FY2025 report (page 79). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The statement does not describe a dedicated, ESRS-defined climate resilience analysis. What it discloses is general: "The resilience of the Group's strategy and business model was assessed by the Internal Risk Manager and addressed as part of the Group's risk and opportunity assessment" (SBM-3, page 79), a statement covering all material topics rather than climate specifically.

The link between scenario analysis and the Group's response is stated in IRO-1 E1: "The scenarios, journeys and green measures identified are considered during the financial assessment as part of the risk evaluations and calculations employed" (page 79), and per-scenario adaptation "journeys" (efficiency upgrades, fuel switching, priority-location adaptation measures) are set out there. No areas of uncertainty in the assessment, and no discussion of capacity to redeploy or adjust financial resources, are disclosed.

Policies related to water and marine resources

Reference: page 101.

Two policies govern the Group's approach: the Group Policy on Environment and Corporate Social Responsibility (CSR), which "designed to optimise the use of natural resources, replacement and savings of potable water," and the Code of Business Ethics and Conduct, covering the Group's "proactive stance on environmental protection and its commitment to efficiency use of resources, where water is one of the critical."

These policies are referenced in the MDR-P policy-overview table. The associated material impact is "actual negative impact on environment through water withdrawal of the company's building portfolio."

Actions related to water and marine resources

Reference: page 101.

Climate risk analyses identified water-scarcity-exposed regions in Germany, Romania and Serbia. Technical measures include flow restrictors, sensor-controlled taps and dual-flush toilet cisterns (often required by LEED/BREEAM certification); rainwater harvesting/storage tanks at properties such as Na Příkopě 14, Prague (toilet flushing) and for garden irrigation elsewhere.

Cooling and humidification systems are identified as major water-demand contributors and are targeted for optimisation, "particularly in our shopping centre portfolio." Technology-water consumption data collection began in 2025. Future actions include evaluating further rainwater-cistern installations and replacing water-intensive grassed areas with biodiversity-supporting planting.

Targets related to water and marine resources

Reference: page 101.

"A target has been set to reduce the potable water intensity of the property portfolio by 10% by 2030, compared with the 2019 baseline," using Aqueduct Water Stress Projections (WRI) geodata to prioritise high-water-stress areas. The intensity target covers the property portfolio, excluding farms, and "is voluntary (not required by legislation)."

"In 2025, total water intensity across the entire portfolio outperformed the 2025 target by 7.1%," against a target trajectory of 0.642 m³/m² (2019 baseline) declining to 0.578 m³/m² by 2030.

Water metrics

Reference: page 102.

"The water withdrawal amounted to 3,887,198.9 m³ in 2025 [2024: 4,915,515.3 m³]," disaggregated across the Czech Republic, Germany, Poland, Hungary, Romania, Slovakia, Austria and other markets, and split between total withdrawal and withdrawal in the Group's own operations.

The 2025 methodology changed: "water withdrawal is the sum of water consumption and water discharged back to the water environment," versus the prior year's method of "water consumption plus year-to-year positive change in the water stored." Data sources are smart metering, manual reads and utility invoices, with gaps filled by benchmark estimates or, where unavailable, prior-year data; "proportion of electricity estimation is 14%... for heating and cooling 4% of consumption was estimated" (cross-referenced from the energy section).

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

Reference: page 102.

A nil return, stated directly: "In the course of the double materiality assessment as described in IRO-1, no material risks or opportunities in relation to water were identified for our business activities including our assets as well as our value chain. Thus, this section is not relevant to the company."

This is consistent with IRO-1 E3 (page 80), which identifies only an actual negative impact (water withdrawal) as material, with no associated financial risk or opportunity reaching the Group's materiality threshold.

Policies related to resource use and circular economy

Reference: page 103.

Two policies apply: the Code of Business Ethics and Conduct, covering "the Group's proactive stance on environmental protection... use of natural and other resources as a critical component of a circular economy," and the Group Policy on Environment and Corporate Social Responsibility (CSR), designed "to optimise the use of natural and other resources, minimise waste and promote reuse and recycling of raw materials."

The Group's waste-management objectives are stated as consistent with Directive (EU) 2018/851, including its Article 11(2) recycling and reuse targets. Waste-reduction practices are "covered in our internal guidelines for suppliers and tenants."

Actions related to resource use and circular economy

Reference: page 103.

Named circular-economy actions: a new hazardous-recyclables waste category (introduced 2024); waste-stream analyses in selected countries; in-building waste separation infrastructure; waste-prevention education programmes; and an expanding roll-out of green leases with tenant waste-reduction clauses.

A 2025 waste analysis of selected Czech shopping centres found "bio-waste represented approximately 47% of the mixed waste stream." An on-site composting unit ("CompoBot") operates at Balance Hall, Budapest, with its bio-waste volumes included in Group waste data. Poland and Romania began precise weight-based waste measurement in 2025.

Targets related to resource use and circular economy

Reference: page 103.

"The Group has adopted an objective... to eliminate waste sent to landfill whenever feasible, plus the intention to achieve a 55% adjusted recycling rate by year-end 2025 (increasing to 60% by 2030)."

"In 2025 the adjusted waste recycling rate across the entire portfolio was 55.2%," meeting the target; the methodology counts only non-estimated waste and includes reuse, recycling, composting and material-recovery-facility treatment. The report notes that "if the previous methodology were applied, the 2025 target would not have been met," flagging a methodology-driven result.

Resource outflows

Reference: page 104.

The Group's quantified resource-outflow disclosure is built around waste generation and management. "According to the guidelines of the European Sustainability Reporting Standards (ESRS), key figures and performance indicators related to waste have been calculated," based on "waste disposal invoices or, where invoices not available, estimates, reported in tonnes," with data disaggregated by country (Czech Republic, Germany, Poland, Hungary, Romania, Slovakia, Austria, Others) for 2025 and 2024.

The material impact addressed is "actual negative impact on the environment through waste generation" (IRO-1 E5, page 80). The Group identifies the predominant waste challenge as reducing mixed waste volumes, with paper, plastic and biological waste as the most significant recyclable streams and municipal mixed waste as the main non-recyclable stream.

Waste

Reference: page 104.

Total waste generated fell from 88,511.84 t (2024) to 72,591.55 t (2025) across the portfolio, with a country-level breakdown (Czech Republic, Germany, Poland, Hungary, Romania, Slovakia, Austria, Others). Total hazardous waste generated was 1,505.44 t (2025), down from 1,800.32 t (2024), with total hazardous waste recovery of 83.29 t in 2025 (2024: 95.96 t).

The adjusted waste recycling rate reached 55.2% in 2025, meeting the Group's 55% year-end target (E5-3). Methodology: "data are collected based on waste disposal invoices or, where invoices not available, estimates, reported in tonnes," per ESRS guidance.

Policies related to own workforce

Reference: page 105.

Three governing policies: the Code of Business Ethics and Conduct; the Human Capital and Employment Policy, revised in 2024, which "covers all material impacts, risks and opportunities related to the Group's own workforce," including diversity and equal treatment, creativity/productivity, accident/injury risk, gender inequality and mental health; and the Diversity and Non-discrimination Policy.

Employees of CPI Poland, CPI Romania, GSG Germany, CPI Europe and S IMMO are organised within works councils. Commitments reference the UN Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights, ILO Fundamental Conventions, OECD Guidelines for Multinational Enterprises and the UN Global Compact.

Processes for engaging with own workforce and workers' representatives about impacts

Reference: page 105.

Engagement channels vary by subsidiary: where works councils exist (CPI Europe, S IMMO, and CPIPG's subsidiaries in Poland, Germany and Romania), elected for up to five-year terms, they communicate workforce interests to management; elsewhere the Group runs regular employee surveys.

"Executive Management is the highest authority for ensuring dialogue with the workforce," conducting quarterly talks and holding final decision-making power on personnel matters. Works-council cooperation "is regulated by relevant national labour laws, which are based on the principles of the European Convention on Human Rights," with representatives carrying special dismissal protection.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: page 106.

Multiple reporting channels exist: designated local public authorities, a Group-designated person, and the Ethics Line, a confidential whistleblowing system "operated by the company BDO Audit s.r.o.," available 24/7/365 in local languages, with anonymous or named reporting.

"All reports of alleged misconduct are investigated by specialist staff or an external independent third party in a fair, impartial and objective manner." Investigations proceed under local-legislation timelines, and confirmed improper conduct triggers corrective action. Further detail on the whistleblowing process sits under the G1 Governance chapter.

Taking action on material impacts on own workforce

Reference: page 106.

2025 actions: appraisal interviews; individual coaching; revision of internal directives; continuous workforce upskilling; an employee satisfaction survey; gender-pay-ratio analysis; flexible/part-time working arrangements; preventive-healthcare-focused wellness programmes; and collective agreements for salaried employees in property-management companies and other Group subsidiaries.

"Effectiveness is tracked via defined metrics and targets," monitored individually at annual appraisal and collectively via the biennial employee-satisfaction survey. The Group also updated its gender-pay-ratio reporting methodology in 2025 (detail under S1-16). 2025 organisational restructuring within top and middle management is noted as affecting current diversity KPI results.

Targets related to own workforce

Reference: page 106.

Three recurring targets, set during the 2023 Groupwide strategy alignment and reviewed annually by the ESG Committee: minimum 33% female senior managers (2025 result: 40%, against a senior-management cohort of 2.1% of total headcount — target met); at least 8 hours of training per employee per year (2025 result: 15.3 hours — target met); and biennial employee satisfaction surveys (completed for the 2024-2025 cycle, with a Group Employee Satisfaction Rate of 7.93/10 across CZ, SVK, RO, GSG Berlin and HU).

Poland and CPI Europe ran complementary but methodologically distinct assessments not folded into the numerical Group rate.

Characteristics of the undertaking's employees

Reference: page 107.

Total Group headcount fell from 2,536 (2024) to 2,138 (2025), with a country breakdown: Czech Republic 1,031 (2024: 1,075); Slovakia 37 (39); Austria 390 (413); Germany 118 (166); Hungary 238 (510); Poland 213 (222); Romania 50 (47); Others 61 (64).

The Hungary decline is explained elsewhere as driven largely by the divestment of external agency staff at the Marriott Hotel Budapest and the integration of S IMMO into CPI Europe reducing reliance on external specialist advisors.

Characteristics of non-employee workers

Reference: page 107.

Self-employed individuals represent "only a very small fraction (1.02%) of the total workforce," mainly project-based workers and consultants, "operating primarily in the Czech Republic and Hungary."

"The significant decrease in the number of non-employees compared with the previous year is mainly driven by portfolio changes and organisational restructuring. A large share of the prior year's non-employee workforce consisted of external agency staff at the Marriott Hotel Budapest, which has since been divested," alongside reduced reliance on external advisors in legal, consolidation and ESG functions following the S IMMO integration into CPI Europe.

Diversity metrics

Reference: page 107.

Executive Management: 100% male (2025), unchanged from 2024 (the body comprises three members, two with employment contracts). Consolidated senior management (Executive + Top Management, redefined in 2025 to exclude non-employees): headcount fell from 68 (2.9% of workforce, 2024) to 45 (2.1%, 2025); female share rose from 35% (2024) to 40% (2025).

The Group states the 2025 reclassification "consolidated" the previously separate Executive and Top Management categories "to better reflect the current organisational structure," and attributes the headcount decline partly to management-layer streamlining and partly to portfolio divestment.

Training and skills development metrics

Reference: page 108.

Average training hours reached 15.3 hours per employee in 2025, exceeding the Group's 8-hour annual target (S1-5). The report presents average training-hour figures disaggregated by country for 2025 and 2024 (with a restated 2024 column).

Career-development review participation by gender is also disclosed: male participation rose from 55.6% (2024) to 81.5% (2025); female participation rose from 65.5% (2024) to 81.2% (2025), across the Group's Core Business, Marriott hotels, Crans Montana and the consolidated CPIPG Group.

Health and safety metrics

Reference: page 108.

The statement discloses workplace health-and-safety figures across the Group's reporting segments (Core Business, Marriott hotels, Crans Montana and the consolidated CPIPG Group Conglomerate) for 2025 and 2024.

Health and safety sits within the "Working conditions (Secure employment, Health and Safety)" material matter, where the Group states that "without proper health and safety measures, employees are more likely to experience accidents... Effective health and safety protocols significantly reduce the risk of workplace accidents, which is particularly important in the property sector" (SBM-3 Materiality table, page 81).

Compensation metrics (pay gap and total compensation)

Reference: page 109.

"In 2025, the Group refined its approach to analysing remuneration... Two complementary methodologies are applied": an ESRS-compliant approach, calculating the gender pay gap on the total remuneration of employees within the S1-6 scope without further segmentation, and a weighted-average-by-category approach, splitting the workforce into Top Management, Middle Management, Entry-Level Management and Non-Management "to ensure that employees performing comparable roles" are compared like-for-like across subsidiaries.

This dual-methodology update follows the Group's "inaugural reporting of the Group-wide gender pay ratio in 2022," refined "to ensure regulatory compliance and internal consistency" for FY2025.

Incidents, complaints and severe human rights impacts

Reference: page 109.

Workplace incidents and complaints fell from 1 (2024) to 0 (2025), with the corresponding "Incidents reviewed" status also moving from 1 to 0. This aligns with the single whistleblowing case disclosed under G1-3/G1-4: a 2025 procurement-related report that, "following a thorough internal and external review, was assessed as unsubstantiated."

No severe human-rights incidents connected to the Group's own workforce are reported for 2025.

Policies related to consumers and end-users

Reference: page 110.

The Personal Data Protection Directive "specifies the rules of personal data protection, rights of data subjects and obligations associated with the processing of personal data throughout CPIPG," complying with GDPR (Regulation (EU) 2016/679). Certain Group companies have appointed Data Protection Officers.

The Code of Conduct for Tenants requires tenants to "respect and promote recognised human rights, including appropriate labour conditions and practices," based on the UN Guiding Principles on Business and Human Rights, the ILO Declaration, and OECD Guidelines. Data is classified into confidentiality tiers (public, internal, limited-access, secret).

Processes for engaging with consumers and end-users about impacts

Reference: page 110.

"We endeavour to build a partnership with our customers that operates in a manner consistent with our values... We also pay attention to customers' complaints and inform them about the handling of complaints, including remedial steps and measures to be taken. We always prefer an amicable solution to any disputes," with out-of-court options disclosed where no amicable resolution is reached.

Personal-data-breach handling follows a defined process: a 24/7 hotline and email route to the GDPR team (DPO) and IT department, with the Group committing to the GDPR's 72-hour regulator-notification deadline and direct notification of affected data subjects "without delay" where high risk to rights and freedoms exists.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: page 110.

Asset, centre and property managers are the primary tenant contact points, supported by an app-based "direct feedback tool" for complaints, suggestions, requests or damage reports; hotel guests can raise concerns via in-room forms.

Data-security concerns can also be raised through the third-party Ethics Line whistleblower system, investigated by internal audit or an independent external party "in a fair, impartial and objective manner," with the reporter kept informed of investigation progress per applicable local legislation.

Taking action on material impacts on consumers and end-users

Reference: page 110.

Mandatory employee training is the principal action: "the Group continued to facilitate an interactive biennial online training course covering data protection, the IT directive and cyber security for entire workforce."

"To date, the Group has not identified any substantiated complaints from consumers, third parties or regulatory authorities concerning breaches of customer data protection for the year 2025, and, as such, no remedial actions were deemed necessary." "Over the past few years, there have been no confirmed cases of data breaches, indicating that our current actions are effective and appropriate," and no severe human-rights incidents connected to consumers/end-users were reported.

Targets related to managing material impacts for consumers and end-users

Reference: page 110.

"In 2025, we implemented a new goal: Zero personal data leaks on an annual basis. Its continuity will be added based on the output as of 31 December 2025." For the 2025 reporting year, zero personal data leaks were identified, and the target was achieved.

The target addresses the material matter "Data ethics / Trustworthiness (Privacy)," where the Group states it "collects sensitive data from its tenants, which introduces a risk of potential data leakage" (SBM-3 Materiality table, page 82).

Business conduct policies and corporate culture

Reference: page 111.

Governing policies: the Anti-Bribery, Anti-Corruption and Countering of Bribes Policy; the Anti-Money Laundering and Counter-Terrorist Financing Policy; the Code of Business Ethics and Conduct; the Whistleblowing Group Policy; the Group Competition Law Compliance Policy; the Human Capital and Employment Relationships Policy; the Securities Trading and Inside Information Policy; and Codes of Conduct for Suppliers and for Tenants (introduced Groupwide in 2019).

"The Code of Business Ethics and Conduct serves as the basis for all business activities and internal decisions and includes clear guidelines on respect for basic rights, integrity and fairness, a ban on discrimination and rules for relations with competitors, customers and professional associations." Overall policy responsibility sits with the Board, acting through the Compliance Officer; internal audit reviews compliance regularly.

Prevention and detection of corruption and bribery

Reference: pages 111-112.

CPIPG's Anti-Bribery, Anti-Corruption and Countering of Bribes Policy, based on the UN Convention against Corruption, covers employees, business partners, agents and customers, and is enforced through "employee training, cost comparisons, payment authorisations, internal audits and the possibility for third parties to report possible cases of bribery through the whistleblowing system."

"The Group introduced anti-corruption and anti-bribery training in year 2025 as an integral part of the Code of Business Ethics and Conduct and associated policies training," mandatory for all employees, with tailored Board/Executive Management training delivered in May 2025. Functions-at-risk are defined (purchasing managers, asset/transaction managers, budget-owning middle management, and Executive Management/Board members); "the entire workforce was trained by the end of 2025, resulting in 100% training coverage for functions-at-risk."

Targets related to business conduct

Reference: pages 111-112 (part of MDR-T/GDR-T disclosures).

The Group sets a training-coverage target rather than a separate standalone compliance metric: "The Group sets a clear goal to train its entire workforce, including employees in high-risk functions and all members of the Board of Directors and Executive Management, on an annual basis."

Effectiveness against that goal is tracked and reported: "In line with the Group's plan, the entire workforce was trained by the end of 2025, resulting in 100% training coverage for functions-at-risk." A related objective in the Sustainable development goals table (page 82) — "Group's compliance and governance policies reviewed by law firms" — is reported as "Completed."

Incidents of corruption or bribery

Reference: page 112.

"There were no incidents, convictions or fines for violations of anti-bribery and anti-corruption laws or violations of procedures and standards related to anti-bribery and anti-corruption identified in 2025 as well as in 2024. Furthermore, CPI Property Group has not initiated any legal proceedings for corruption or bribery against us or our employees. Nor has the Group identified any actual effects or incidents of corruption and bribery in which we are directly involved through a business relationship in our value chain."

Separately, S1-17/G1-3 record one whistleblowing case in 2025, procurement-related, which "following a thorough internal and external review, was assessed as unsubstantiated."