CTP N.V.
Material Topics
Sustainability statement, in full
The complete text of CTP N.V.’s FY2025 sustainability statement is held here – 90 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 bodiesReported
The role of the administrative, management and supervisory bodies
Reference: pages 104-105, 175, 182 (incorporated by reference to Section 5.1/175 and Section 5.2.1/182 per the Section 4.2.2.6 incorporation-by-reference table).
CTP's Board of Directors comprises Executive Directors (Remon Vos, founder, CEO; Richard Wilkinson, CFO) and Non-Executive Directors, including the Sustainability Committee Chair Ms. Eickermann-Riepe. The Board delegates oversight to three committees: the Audit Committee, the Nomination and Remuneration Committee, and the Sustainability Committee, "established in 2022 to strengthen and formalise ESG oversight at the Group level," which "meets at least quarterly." Sustainability-related expertise reaches the Board through the Group Head of ESG Management, the Group Head of Risk Management and Modelling, the Group AML Compliance Officer, and the Group HR Director.
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Information provided to and sustainability matters addressed by the administrative bodies
Reference: pages 105, 182.
"The Board meets at least once every quarter... The Board met six times in 2025; all Board members attended all meetings." Risk management reports "containing information about material impacts, risks, and opportunities ('IROs')" reach the Board via the Group Internal Audit Director, the Group Head of Risk Management and Modelling, the Group AML Compliance Officer, the Group Head of ESG Management, and the CFO. "The results and effectiveness of policies, actions, metrics and targets to address these material IROs are addressed in the Audit Committee, the Sustainability Committee, and at Board meetings." The Sustainability Committee advises on actions and targets, "which the Board approves."
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Integration of sustainability-related performance in incentive schemes
Reference: pages 186, 196.
The CFO's 2025 short-term incentive weighted 20% of base salary to an "ESG target (GRESB score)," structured as at-target-or-nothing vesting: "Vesting is subject to CTP receiving a GRESB score in 2025 being equal to or higher than the average 2023 score, i.e., 83 for development and 75 for standing investments." CTP scored 84 (development) and 75 (standing investments) in 2025, so "the ESG target was met," generating a EUR 83,600 payout to the CFO within a total STI of EUR 252,183 (60.33% of base salary, after a loan-to-value downward modifier). The CEO, Mr. Vos, "was not entitled to receive a pay-out under the annual cash bonus plan in 2025."
GOV-3(was GOV-4)Statement on due diligenceReported
Statement on due diligence
Reference: pages 151-152.
CTP describes "a comprehensive approach to due diligence with respect to vendor selection," run through three stages: "Integration of sustainability in corporate policies" (Code of Conduct, Supplier Code of Conduct, Anti-Bribery and Corruption Policy), "Vendor selection and risk assessment" against sustainability criteria including "market reputation, past collaborations, and contractual reliability," and "Compliance monitoring and enforcement" led by the Group AML Compliance Officer, who is "central to the due diligence process" and ensures suppliers "comply with the Suppliers Code of Conduct." Post-selection, CTP applies "routine monitoring," covering occupational health and safety and other ESG requirements.
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Risk management and internal controls over sustainability reporting
Reference: page 106.
"CTP deploys a multi-layered structure for identifying and managing risks throughout the Group's activities, including ESG-related risks." Within CTP's risk taxonomy, "49 unique risks, actual and potential (Level 3), were identified and organised into 19 Risk Groups (Level 2)... and ultimately into four risk areas (Level 1)." For sustainability data specifically: "reporters and approvers do not have overlapping rights," approved data is "randomly checked against evidence," collected data is "compared against different periods" with outliers verified and corrections mandated, and "once a year... CTP invites an external party, different from the statutory assurer, to review the collected data."
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: page 107.
CTP is "the developer, long-term owner, and operator of a network of business parks and premium office and mixed-use projects at over 250 locations" across European countries "from the North Sea to the Black Sea," serving clients in e-commerce, logistics, high-tech manufacturing, and R&D. The business model has two interconnected core units: Developer (investing in new, energy-efficient developments) and Growth Engine/Operator (long-term ownership and operation of the standing portfolio, with in-house teams managing each lifecycle stage). The upstream value chain comprises construction-material suppliers and contractors; the downstream value chain is the companies leasing CTP's space.
SBM-2Interests and views of stakeholdersReported
Interests and views of stakeholders
Reference: pages 109-110.
CTP's 2025 DMA "reassessed its relevant stakeholders and established different engagement methods for each type," documented in a stakeholder table covering shareholders/bondholders, banks, rating agencies, clients and their employees, suppliers and vendors, local authorities and communities, construction-site neighbours, employees and contractors, NGOs/industry bodies, and regulators, each with its own method and frequency of engagement. Clients are engaged through annual qualitative interviews ("In 2025, 52% of clients were interviewed"). "The 2025 DMA shows that stakeholder views are generally in line with the Company's strategy and business model," so no short-term strategic changes resulted; the Board is informed of, and approves material topics in light of, stakeholder feedback.
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
Material impacts, risks and opportunities and their interaction with strategy and business model
Reference: pages 111, 369.
Based on the 2025 DMA, CTP discloses five material ESRS topics: "E1 Climate change, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, G1 Business conduct." "No changes have been made to material IROs compared to 2024"; the last full DMA, integrating CSRD requirements, was run in 2024, led by a third party, combining desktop research (ESRS topic screening, peer review) with stakeholder interviews and surveys. "Currently, CTP does not foresee material effects on its value chain." The full per-IRO breakdown, with positive/negative, actual/potential and time-horizon classification, sits in the Materiality Appendix (Section 7.3.1).
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Description of the processes to identify and assess material impacts, risks and opportunities
Reference: pages 111-112.
The 2025 DMA followed EFRAG's May 2024 Materiality Assessment Implementation Guidance in three steps: (1) understanding the business context (mapping activities, value chain and stakeholders); (2) identifying and scoring the long list of IROs via topic-specific working groups, engaging "employees, clients, investors, and suppliers," led by external experts; (3) determining the material short-list via stakeholder-engagement analysis and workgroup validation. Impacts were scored 1-4 (insignificant to extreme) on scale, scope, irremediability and likelihood; risks and opportunities were scored 1-5 on likelihood and financial magnitude, with thresholds "consistent with thresholds used in CTP's risk management." "The material topics were verified and approved by the Board of Directors."
IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statementReported
Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reference: page 111, with the full index at Section 7.4/389-392.
CTP states: "See Section 7.4 for the full ESRS content index." That index (the "ESRS Index," pages 389-392) lists each disclosure requirement from ESRS 2, E1 and E5 against the paragraph and page where it is addressed, and marks ESRS E2 Pollution, ESRS E3 Water and marine resources, ESRS E4 Biodiversity and ecosystems, ESRS S3 Affected communities, the S2-5 targets datapoint and several G1 sub-datapoints (G1-5 political influence, G1-6 payment practices for one entry) "Not Material" or "Not applicable to CTP." This index is the basis used throughout this record for what CTP itself classifies as reported, not material, or out of scope.
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation
Reference: pages 116-117, 120-122.
CTP's strategy pillar "Striving to Be Climate Positive" sets the ambition "to become climate-positive in all its activities, including development, property management, and corporate operations by 2050," sharing "the ambition to be compatible with the Paris Agreement." Decarbonisation levers are rooftop solar PV, renewable-energy procurement, green leases, EPC (Energy Performance Certificate) upgrades, and low-carbon construction materials. Financing includes a dedicated EUR 200 million European Investment Bank loan for renewable-energy systems and ongoing green bonds/sustainability-linked loans. Locked-in emissions are identified as embodied carbon in building materials, targeted via low-carbon procurement. "CTP is not excluded from EU Paris-aligned Benchmarks."
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysisReported
Identification of climate-related risks and scenario analysis
Back-filled from the E1 climate-change chapter and ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 117-119). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Using a third-party platform and IPCC Representative Concentration Pathway models, CTP "considered the results of the least and most extreme scenarios (RCP 2.6 with a 1.5°C limit and RCP 8.5 with a 4.3°C limit) with a time span up to the year 2050" to assess physical risk (flooding, heat, inclement weather). Transition risks identified are new GHG taxation (EU ETS2, from 2028) and CBAM (postponed to 2027, a carbon tax on embodied carbon in imported construction materials), and growing market pressure for lower-emission buildings. Inputs included "MCSI climate models and the European legal landscape"; uncertainty stems from model inaccuracy and evolving EU legislation, both "being monitored."
E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate changeReported
Resilience in relation to climate change
Back-filled from ESRS 2 IRO-1/SBM-3, where this content is disclosed in the FY2025 report (pages 117, 119). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
"The resilience of CTP's business model and strategy is assessed through the monitoring of climate risks and ongoing conversations with clients," which feed new business-opportunity identification across time horizons. CTP cites its diversified base of "more than 1,500 clients" across "250 parks in 11 countries" as the source of resilience, concluding it sees "no major risks that could affect its value or profitability." The strategic assumption is that the shift to a low-carbon economy continues; CTP "deploys existing technologies," assumes "gradual improvements in efficiency," and "does not consider unproven technologies."
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: page 120.
CTP's Environmental Policy, updated in 2025, has "the objective [to] create a systemised approach towards environmental matters and propose relevant actions," covering "climate change mitigation, climate change adaptation, energy efficiency, and renewable energy." It applies to "all operations and activities of the Group and environmental aspects in its value chain, including materials and buildings in the portfolio," addressing suppliers regardless of geography, and clients "through cooperation on the improvement of energy efficiency." The ISO 14001 and 50001 management systems are part of the policy. "The Board of Directors is responsible and accountable for implementing the policy."
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: pages 120-122.
CTP names four decarbonisation levers with quantified 2025 progress: solar PV ("16MWp of new PV generating capacity installed during the year, for a total of 154MWp"; CTP "spends €750,000 to develop one MWp"; financed partly via the €200 million EIB loan); renewable energy procurement ("enabled CTP to achieve 81% renewable electricity consumption at year end," no dedicated CapEx); EPC upgrades ("75% of CTP's GLA was covered by EPCs with a level C rating or higher," CapEx "considered, to a great extent, as business as usual"); and green leases (an "enabler," no direct CapEx) plus ongoing work with suppliers on low-embedded-carbon materials, "financed by green bonds and sustainability-linked loans."
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: page 122.
CTP's CLIMATE TARGETS table sets five 2030 targets against base years: Scope 1&2 revenue-intensity reduction -30% (2024 base 0.000014 tCO2e/EUR, 2025 actual 0.000011); embodied-carbon intensity -20% (2023 base 476 kgCO2e/m2, 2025 actual 560, a reported increase the company attributes to "aligning LCA calculations with BREEAM requirements"); renewable share of electric-energy mix 90% (2023 base 64%, 2025 actual 81%); installed PV capacity 400MWp (2023 base 100, 2025 actual 154); EPC C+ coverage 90% (2023 base 72%, 2025 actual 75%). Targets are absolute for PV/renewables/EPC and intensity-based for Scope 1&2; no SBTi validation is stated.
E1-7(was E1-5)Energy consumption and mixReported
Energy consumption and mix
Reference: pages 123, 378-379.
CTP reports energy "inside the organisation" (Scope 1 fuel 24,099 MWh in 2025 vs 16,818 in 2024, Scope 2 district heating 7,977 MWh, Scope 2 electricity including corporate offices and CTParks) and "outside the organisation" (Category 13 downstream leased assets: 1,555,580 MWh in 2025, split natural gas 475,516, district heating 64,863, electricity 1,015,201, of which purchased renewables 483,282 and CTP Energy-supplied renewables 17,872). Country-level segmentation (EPRA Fuel/DH&C/Electricity tables) is given for all 10-11 countries of operation. The 2025 renewable share of CTP's and tenants' electric-energy mix reached 81%, up from 64% in the 2023 base year.
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scopes 1, 2, 3 and Total GHG emissions
Reference: pages 123-129, 131.
"Despite a decrease in energy related GHG emissions, an increased intensity is presented. This is driven by increased emissions in Scope 3 category 1 (Purchased Goods and Services)." CTP reports emissions by scope, with Scope 1&2 revenue intensity falling from 0.000014 tCO2e/EUR (2024) to 0.000011 (2025), against a -30% by-2030 target. Energy-inside-the-organisation fuel consumption rose to 24,099 MWh (from 16,818 in 2024), reflecting portfolio growth. The company's combined Scope 1&2 target covers 100% of those scopes; Scope 3 is managed through two proxies it can influence: embodied-carbon intensity (category 1) and EPC coverage (category 13).
E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunitiesReported
Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Reference: pages 131, 156.
Since 2022, CTP has run an annual physical-climate-risk assessment using a third-party tool and IPCC RCP models, plus the CRREM tool for transition-risk screening. "The climate-related risks identified as potentially the most impactful to CTP are coastal flooding and rising sea levels." The company "concludes that five of its properties [in NUTS areas NL3, DE8, DE9] are at risk, representing, at most, 1.1% of the portfolio's value," and treats this as "long-term and chronic, and non material." "CTP has not identified transition risks that are financially material to the portfolio over the short and medium term," and a client analysis "confirms that none of its clients operate in the coal, oil, or gas-related sectors."
E5 – Resource Use and Circular Economy
E5-1Policies related to resource use and circular economyReported
Policies related to resource use and circular economy
Reference: page 133.
CTP's material E5 sub-topics are "resource inflows, including resource use" and "waste." Policy coverage comes from the Environmental Policy: "waste management practices" are incorporated into construction activities, but the policy "applies to CTP's own operations and activities... clients' operations are not covered," and "the waste hierarchy is not addressed in the current version of the policy, nor are other material matters such as transitioning away from use of virgin resources or sustainable sourcing." Internal waste-management requirements exist for new construction and refurbishments. "CTP has yet to develop policies related to resource inflows." The Board of Directors is accountable for the policy.
E5-2Actions and resources related to resource use and circular economyReported
Actions and resources related to resource use and circular economy
Reference: page 133.
"Selective waste collection, which includes recycling, is an integral part of the BREEAM New Construction certification process for CTP's buildings," supporting the Company's target to raise waste diversion from landfill. CapEx and OpEx for these actions are treated "as part of business as usual"; resources for managing material impacts are "part of normal business operations." CTP also "implements requirements for its construction and refurbishment activities to obtain EU taxonomy alignment that include waste management," and is "currently collecting data on the inflow of materials, which will enable the creation of informed actions," including promotion of materials with Environmental Product Declarations.
E5-3Targets related to resource use and circular economyReported
Targets related to resource use and circular economy
Reference: page 133.
CTP's only quantified circular-economy target: selective waste collection on construction activities, from a 2023 base of 21% of projects to a 2030 target of 95% (2025 actual 87%). "This target applies to its own projects, independent of location, size, or building type," measured annually via external reporting. "CTP has not yet developed targets related to resource inflows, use and recycling of materials," citing limited inflow data as the reason; it states it "decided to first focus on the promotion of waste-handling practices" before setting further targets, taking financial-institution, client and regulatory requirements into account for the targets it has set.
E5-4Resource inflowsReported
Resource inflows
Reference: page 134.
CTP's MATERIAL INFLOWS table reports construction material tonnage for completed buildings, estimated from a sample and extrapolated to 100% of 2025 gross floor area (sample GLA 466,701 sqm against 1,325,492 sqm completed): steel/iron 433,914t (10%, 2024) to 804,978t (6%, 2025); concrete and related products 3,547,333t (86%) to 13,063,515t (94%); asphalt 153,878t (4%) to nil in 2025; biological materials not available ("CTP has no available data related to biological materials"). The data excludes recycled-content share and secondary/reused materials: "the weight in both absolute value and percentage of secondary reused or recycled components... is not available."
E5-5Resource outflowsReported
Resource outflows
Reference: pages 134-135.
CTP's resource-outflow disclosure is narrative rather than a separate products/materials mass-flow table: "the waste streams relevant to the sector in which CTP operates is related to construction materials, such as gypsum, plastics, packaging, and insulation. The nature of waste in the construction sector makes it recyclable to a great extent." Building durability is stated generically: CTP's mostly light-industrial and logistics buildings "have an expected average durability of 50-60 years, in line with the industry average." No separate quantification of products/materials put on the market (distinct from the waste table under E5-5-Waste) or of secondary/recycled-material content in outputs is given.
E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunitiesReported
Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Reference: page 135.
"CTP's 2025 DMA process did not identify any risks or opportunities related to circular economy; therefore, CTP does not foresee a financial impact." This nil return is consistent with the Materiality Appendix, where CTP's only E5/circular-economy IRO rows are two actual negative impacts (waste generated during construction; depletion of natural resources from resource use) rather than financially quantifiable risks or opportunities.
E5-5(was E5-5-Waste)WasteReported
Waste
Reference: page 134-135.
CTP's WASTE table, estimated from completed-building samples (360,781 sqm against 1,325,492 sqm completed in 2025): total construction waste generated fell from 8,416.97 (2024) to 3,988.89 (2025); diverted from landfill (recycled) fell from 3,103.19 to 1,988.53, but the diversion rate rose from 37% to 50%, which CTP calls "underestimated due to limited data availability." "The available data does not inform on whether waste is hazardous or non-hazardous," and "no radioactive waste can be expected" given the nature of CTP's buildings. No data is available for asphalt waste. Beyond CTP's assurance provider, no other external validation took place.
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies related to own workforce
Reference: pages 137-138.
"All IROs identified during the DMA... are covered through the policies mentioned below," monitored by the Group AML Compliance Officer. CTP's material S1 sub-topics (working conditions, equal treatment, corporate culture overlap) are addressed through its HR Policy, Code of Conduct, Anti-Discrimination and Harassment Policy, and Whistleblower Policy, each publicly available on CTP's website. Policies cover secure employment, adequate wages, diversity, training, and violence/harassment in the workplace, applying to CTP's own employees across its countries of operation.
S1-2Processes for engaging with own workforce and workers' representatives about impactsReported
Processes for engaging with own workforce and workers' representatives about impacts
Reference: page 138.
CTP's own employees are engaged through the annual Employee Engagement Survey, introduced in 2024 to "better understand the overall engagement levels of employees and gather valuable insights into their experiences, attitudes, and satisfaction." "All CTP full-time employees were asked to complete the survey," with the Group HR Director responsible for execution and communicating results at country level. Because "the survey was conducted only twice and no clear trends have been identified, no procedure exists to assess the engagement's effectiveness," and it "does not currently enable the Company to gain insight into the perspectives of its particularly vulnerable employees."
S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concernsReported
Processes to remediate negative impacts and channels for own workforce to raise concerns
Reference: pages 138-139.
CTP operates a grievance system "overseen by the Group AML Compliance Officer," run by an external provider "to ensure anonymity," covering "all non-compliance concerns, including ESG matters." Effectiveness of remediation is assessed "on a case-by-case basis." A report "on the handling and resolution of these issues is regularly presented to the Audit Committee/Board." The Whistleblower Policy underpins non-retaliation protections; access and channel awareness are communicated through CTP's policies.
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Taking action on material impacts on own workforce
Reference: pages 139-140.
The 2025 DMA "did not identify any negative impacts relating to own employees," so CTP reports positive-impact actions: the Employee Engagement Survey, the Employee Share Purchase Plan (launched 2024, granting shares "equal to one monthly salary at the date of issue" to strengthen "secure employment, adequate wages, and recruitment"), and health/safety/well-being measures (training, sports-event subsidies, private medical care). "CTP has no actions for the material topics of work-life balance, social dialogue, gender equality and equal pay for work of equal value, and diversity," beyond standard policies applicable to all new joiners.
S1-4(was S1-5)Targets related to own workforceReported
Targets related to own workforce
Reference: pages 139-140.
CTP's SOCIAL TARGETS table: framework for employee-satisfaction monitoring "In Place" (2025 and 2026 target); framework for client-satisfaction monitoring "In place"; and a gender-split target of "no larger than 45-55%" for 2026 (2025 actual: 53% male, 47% female). "CTP has not yet developed targets for" secure employment, adequate wages, social dialogue, works councils, work-life balance, health and safety, gender equality/equal pay, training and skills, recruitment, and violence/harassment, stating it is "currently collecting data to enable the development of targets" for these. "In the 2025 DMA, no related risks or opportunities were identified, and therefore no risk-related targets have been created."
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of the undertaking's employees
Reference: pages 141-143.
"As of 31 December 2025, CTP had 969 persons employed, totalling 950.6 Full-Time Equivalents" (2024: 889 headcount, 873.6 FTE). By gender (headcount): female 453 (2025) vs 404 (2024); male 516 vs 485. By contract type (FTE): 841.8 permanent, 108.8 temporary, 25.0 non-guaranteed-hours, 924.0 full-time, 26.6 part-time. Country breakdown covers Austria, Bulgaria, China, Czech Republic, Germany, Hungary, Italy, Netherlands, Poland, Romania, Serbia, Slovakia, UK, led by the Czech Republic (387.8 FTE). "No CTP employee identified as a gender other than male or female." Turnover rate: 20.5% (2025) vs 21% (2024), with 192 leavers.
S1-6(was S1-7)Characteristics of non-employee workersReported
Characteristics of non-employee workers
Reference: page 143.
"On 31 December 2025, a total of 58 people were active as non-employee workers at CTP," defined as self-employed individuals "pursuing a gainful activity for their own account, under the conditions laid down by national law" — up from 51 in 2024. "There are no specific metrics related to non-employee workers. No estimations were made." Data is "centrally maintained through software," reported in headcount since FTE calculation is not possible "due to the nature of their relationship with CTP."
S1-7(was S1-8)Collective bargaining coverage and social dialogueReported
Collective bargaining coverage and social dialogue
Reference: page 143.
"CTP does not have employee representatives operating within the Company, therefore no employees are covered by worker representatives. No collective bargaining process or collective agreement has been implemented, so no employees are covered by this process or agreement." CTP instead "follows local legislation" on worker-company dialogue. "There are no specific metrics related to collective bargaining and social dialogue against which CTP measures its performance." This nil coverage is CTP's complete, reported answer, not an omission.
S1-8(was S1-9)Diversity metricsReported
Diversity metrics
Reference: pages 143-144.
TOP-LEVEL MANAGEMENT GENDER DISTRIBUTION (Board of Directors, senior management, staff as defined — Executive Directors, COO, and Country MDs/CFOs across CTP's countries): female representation rose from 27.8% (5 of 18) in 2024 to 31.5% (6 of 19) in 2025; male fell from 72.2% to 68.5%. Employee age distribution by FTE: under-30 122.4 (2025) vs 117.3 (2024); 30-50 699.8 vs 645.2; over-50 128.5 vs 111.2. Figures come from CTP's HR software with no assumptions applied; no additional external validation beyond the statutory assurer took place.
S1-9(was S1-10)Adequate wagesReported
Adequate wages
Reference: page 144.
"As CTP operates in a highly competitive environment, it provides an attractive compensation package to current and new employees. The wages included in this package are competitive and adequate to market standards." CTP states it operates "in countries where there is a minimum salary indication," and concludes "all salaries paid by CTP are adequate, independent of country." No specific quantified adequate-wage benchmark or percentage of employees below it is disclosed; this is a qualitative, nil-gap statement rather than a metric.
S1-10(was S1-11)Social protectionReported
Social protection
Reference: page 144.
"All CTP employees' social protections are covered by local regulations, including but not limited to injury, acquired disability, unemployment, parental leave, and retirement. The Company offers no additional protections beyond the local legal requirements." "There are no specific metrics related to social protection that CTP measures its performance against." Beyond CTP's assurance provider, no other validation has taken place. This is a complete qualitative disclosure rather than a quantified metric.
S1-12(was S1-13)Training and skills development metricsReported
Training and skills development metrics
Reference: pages 144-145.
"CTP enabled employees to participate in a total of 7,918 hours of training in 2025" (2024: 9,310), averaging 8 hours per employee overall (2024: 10), split by age (under-30: 9 hrs; 30-50: 8 hrs; over-50: 8 hrs) and gender (female 8 hrs vs male 8 hrs in 2025). Performance reviews: "36% of CTP employees have participated in career performance reviews" in 2025 (2024: 16%; 35.7% of men and 35.5% of women). Figures come from internal HR software using local definitions and have not been externally verified beyond the statutory assurer.
S1-13(was S1-14)Health and safety metricsReported
Health and safety metrics
Reference: page 145.
"In 2025, CTP had 0 fatalities within its operations" (2024: one fatality, of a CTP contractor, not a CTP employee). CTP recorded "3 cases of a work-related accident" and "0 cases of work-related ill-health, with an accident rate of 1.97," leading to "11 days lost" (2024: 2 accidents, 1 ill-health case, 1.4 accident rate, 28 days lost). "No Group health and safety management systems are in place. Health and safety are managed based on local regulations covering all employees." No assumptions were made; no additional external validation beyond the statutory assurer took place.
S1-14(was S1-15)Work-life balance metricsReported
Work-life balance metrics
Reference: page 145.
WORK-LIFE BALANCE table: percentage of employees entitled to family-related leave fell to 9.7% overall (2024: 35%), split male 1.6% vs female 19.0%; percentage that took family-related leave was 9.7% overall (male 1.6%, female 19.0%). CTP notes "the percentages for people entitled and people taking family-related leave are the same due to reception of information on entitlement being limited. This is also the reason behind the year over year decrease." "CTP does not measure specific metrics related to work-life balance beyond" the family-leave figures, which are taken from internal HR data using local definitions.
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)Reported
Compensation metrics (pay gap and total compensation)
Reference: page 146.
Unadjusted gender pay gap: 30.55% (total compensation, per the ESRS methodology). Adjusted pay gap across seven employee categories, PPP-adjusted: 3.19% (2024: 3.35%; 2023: 4.2%). Pay ratio to the highest-paid individual (annual total compensation, median employee): 13.7x in 2025, down from 19x in 2024. CTP "has identified seven employee categories, considering seniority and job position," weighting the gap by headcount per category and adjusting for purchasing-power parity across its ten countries. Data is drawn from payroll systems with no assumptions made.
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Incidents, complaints and severe human rights impacts
Reference: pages 146-147.
INCIDENTS, COMPLAINTS, AND FINES table: discrimination/harassment incidents fell to 6 (2025) from 10 (2024); complaints filed by own workforce rose to 14 from 11; fines/penalties/compensation were €0 in both years. "In 2025, six work-related or non-work-related incidents were filed through CTP's internal channels," six raised by third parties, none via OECD National Contact Points. "CTP identified no cases of severe human rights incidents." Remedial action in 2025 included "the dismissal of an individual," guidance to employees, and corrective measures escalated to top management via the Group AML Compliance Officer.
S2 – Workers in the Value Chain
S2-1Policies related to value chain workersReported
Policies related to value chain workers
Reference: page 148.
"All IROs identified during the DMA... are covered through the policies mentioned below," monitored by the Group AML Compliance Officer. CTP's construction activities mean it "contracts many workers in the construction industry," whose health and safety "can be influenced... through strict contractual requirements." The Supplier Code of Conduct is "applied to all suppliers," covering labour rights, and requires suppliers to follow health-and-safety and OHS standards. No breach of these standards in CTP's supply chain was identified in the 2025 DMA.
S2-2Processes for engaging with value chain workers about impactsReported
Processes for engaging with value chain workers about impacts
Reference: page 148.
"As CTP contractors took part in the DMA, the views of their employees are part of the results of the DMA." Stakeholder interests are "taken into account through the DMA process, where workers in the value chain are materially impacted by the Company." "The IROs have not led to changes in CTP's strategy or business model." CTP expects access to more such information sources as DMA processes mature across its supply chain.
S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concernsReported
Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reference: page 148.
The availability of channels for "reporting violations, which are open to all in the value chain," is identified as contributing a positive impact on value-chain workers. Grievance channels, overseen by the Group AML Compliance Officer and run through an external provider, are explicitly open to "suppliers, business partners, etc." as well as employees, consistent with CTP's Supplier Code of Conduct framework.
S2-3(was S2-4)Taking action on material impacts on value chain workersReported
Taking action on material impacts on value chain workers
Reference: pages 148-149.
"A limited number of workers in CTP's value chain are materially impacted by the Company," most significantly upstream construction workers and downstream building-occupant workers. "In the 2025 DMA, no negative impacts were identified related to value chain workers"; "only positive impacts have been identified" for health and safety, "established through standard agreements with suppliers including high Operational Health and Safety standards and regular audits." CTP separately "assesses risks related to its buildings'... safety" through "regular building safety checks," including emergency and operational checks, at the operational stage.
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Business conduct policies and corporate culture
Reference: pages 153-154.
CTP's 2025 DMA identified corporate culture, whistleblowing, corruption/bribery, and sustainable design as material G1 sub-topics. "At the heart of CTP's identity lies an embedded corporate culture based on core values that encompass sustainability, environmental protection, and ethical practices." Governing policies, all public on CTP's website: the Code of Conduct & Suppliers' Code of Conduct, the Whistleblowing Policy (updated after "the full transposition of the EU Whistleblowing Directive... in 2024"), and the Anti-Corruption and Bribery Policy ("consistent with the United Nations Convention against Corruption"). Training is "delivered on a biennial basis to all employees." BUSINESS INTEGRITY TARGETS: green leases rose to 51% (2025) from 45% (2024), 2030 target 90%; Code of Conduct training rate reached 100% (2025), from 70% (2024).
G1-2Management of relationships with suppliersReported
Management of relationships with suppliers
Reference: pages 154-155.
"As a general business practice, CTP has weekly payment runs for each country. CTP does not distinguish between SMEs and other companies. There are no internal policies governing late payments, including SMEs." Supplier vetting assesses "ethical practices, environmental impacts, adherence to labour rights, and overall business conduct," with "rigorous standards, especially for high-risk areas like solar system components procurement or engagement in the arms industry." In March 2025 CTP introduced ScanMarket, procurement software, "to streamline procurement and enhance communications during tender processes." The Supplier Code of Conduct is embedded "in all Purchase Orders and in agreements where applicable."
G1-2(was G1-3)Prevention and detection of corruption and briberyReported
Prevention and detection of corruption and bribery
Reference: page 155.
"To prevent and detect allegations or incidents of corruption and bribery, CTP has implemented specific grievance procedures. Investigations into allegations are conducted by the Group AML Compliance Officer to ensure impartiality... separate from the management chain." "CTP recognises its construction department to be most at risk in respect of corruption and bribery," covered by "a dedicated anti-fraud policy for the construction department." All employees, "including all functions-at-risk," undertake annual Ethics and Compliance training; Non-Executive Directors receive "additional and specific training from the Group AML Compliance Officer." "Annually, a Compliance Report is filed with the Board of Directors."
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct
Back-filled from the G1 chapter's BUSINESS INTEGRITY TARGETS table (page 154), where business-conduct targets are addressed rather than as a numbered disclosure requirement; G1-3 became a standalone targets DR only in the 2025/2026 ESRS.
CTP sets two measurable business-conduct targets: green leases (base-year 2024: 45%; 2025 actual: 51%; 2030 target: 90%) and rate of people trained in the Code of Conduct (base-year 2024: 70%; 2025 actual: 100%; 2030 target: 100%, already achieved). Effectiveness tracking in the absence of quantified targets is also described for incident handling: "CTP promptly, independently, and objectively investigates any incidents related to business conduct," with annual Compliance Reports to the Board and Audit Committee monitoring of corruption and grievance outcomes.
G1-4Incidents of corruption or briberyReported
Incidents of corruption or bribery
Reference: page 155.
"During the 2025 reporting period there were no confirmed cases of corruption and/or bribery at CTP and therefore no convictions of CTP employees, nor were any fines imposed on the Company. As a result, no actions were required. No incidents in the value chain involving CTP employees took place." All local entities report filed cases and updates to the Group AML and Compliance Officer, who reports all cases to the Audit Committee.
G1-6Payment practicesReported
Payment practices
Reference: page 155.
"On average, CTP requires 22.41 days to pay an invoice" in 2025 (2024: 22.2 days). Methodology: "Payment time... was calculated for all invoices," filtering out inter-company transfers and retentions, with "average time of payment... calculated by dividing the total number of days until payment for all invoices by the number of invoices," calculated per country and consolidated at Group level. "CTP's standard payment terms are 30 days for most countries," applied equally "independent of company size." "Currently, CTP has none outstanding proceeding for late payments."