Dom Development S.A.

Reference: page 52

In 2025 the Management Board of Dom Development S.A. "comprised five members – three men (60%) and two women (40%). All members (100%) of the Management Board were executive members, with no non-executive roles." Members of the Management Board and Supervisory Board "participate in sustainability training in order to continuously expand their knowledge and competencies in this area," supported by the Non-Financial Reporting Team, which runs the double materiality assessment (pages 52-56).

Reference: page 56

A dedicated Non-Financial Reporting Team sits within the Company's organisational structure, tasked with "advancing the Group's ESG agenda, overseeing the implementation of sustainability commitments, and coordinating the management of the Group's sustainability framework." The Supervisory Board "exercises ongoing oversight of the Company's operations across all business areas, including sustainability matters," though no separate ESG-specific assessment is conducted (pages 56-58).

Reference: page 59

"In 2025, the Group incorporated sustainability-related criteria into the remuneration framework for three Management Board Members. A portion of variable remuneration (5-15%) of those Members of the Management Board is contingent upon the achievement of sustainability-related objectives linked to the business area supervised by the respective individual," tied to the DOM 2030 ESG Strategy (Urban Greenery Programme delivery, taxonomy disclosures, GHG reduction oversight).

Reference: page 59

The statement maps the five core due-diligence elements to specific sections of the report: embedding due diligence is covered in GOV-2/SBM-3/IRO-1; stakeholder engagement in S1-2, S1-3, S1-14, S1-17, G1-1, G1-2; identifying and assessing adverse impacts in SBM-3, E1-3, E1-4, E3-2, E4-3, E5-2, S1-1, S1-3, S1-4, S2, S3, S4, G1; taking action in GOV-2, S1-1, S1-2, S1-4, S1-17; and tracking effectiveness in G1-3.

Reference: page 59

"The Supervisory Board oversees the internal control, risk management, compliance, and internal audit systems within the Group, primarily through the Audit Committee." Key risks to the sustainability reporting process are "data completeness, data integrity, accuracy of estimates, and timeliness of data submission," managed under the internal Non-Financial and Sustainability Reporting Procedure and the "Standard for Risk, Compliance, Audit and Operational Quality Management – DOM 2030" (pages 59-61).

Reference: page 61

"The Group's principal business activity is the development and sale of residential properties, primarily targeting individual homebuyers," delivered in Warsaw, Wroclaw, Krakow and the Tricity (under the Euro Styl brand). "Dom Development S.A. is the largest developer in Poland in terms of total assets, revenue, and profitability" and "Group companies are not engaged in activities related to the fossil fuel sector (coal, oil and gas)" (pages 61-66).

Reference: page 67

Material stakeholder groups identified include employees, subcontractor/value-chain workers, business partners, property managers, capital market investors, lending institutions, insurers, industry organisations, customers and end-users, and local communities. Engagement runs through "meetings, surveys, workshops and public consultations," quarterly management-board meetings on stakeholder impact, NPS and Employee Opinion Barometer surveys, and regular reporting to supervisory bodies (pages 67-75).

Reference: page 75

The materiality assessment table (pages 80-93) sets out the Group's material impacts, risks and opportunities across climate change, water, biodiversity, circular economy, own workforce, value chain workers, affected communities, consumers and business conduct, tagged by value-chain location and time horizon. "Three of the impacts listed below represent additional disclosures specific to the Group relating to ESRS S3." New 2025 items include a risk tied to development in flood-prone areas and a risk on employee burnout (page 78).

Reference: page 94

The double materiality assessment, first run in 2024, followed five phases: "Phase 1: Analysis of the Group's activities," "Phase 2: Identification of key impacts," "Phase 3: Prioritisation of the most material impacts," "Phase 4: Identification and assessment of risks and opportunities," "Phase 5: Approval of material topics by the Management Board." Impacts were scored 0-5 on scale, scope, irremediability/likelihood against stated thresholds (Critical/Significant/Important/Informational/None) (pages 94-108).

Reference: page 107

"The ESRS disclosure requirements applicable to the Group's consolidated sustainability reporting, including references to relevant ESRS clauses and corresponding page numbers, are set out in the table below." The index confirms "the 2024 assessment regarding the absence of a material impact in relation to ESRS E2 matters," since the Group does not produce, use or procure substances of concern, substances of very high concern or microplastics (pages 107-117).

Reference: page 118

"The Group does not have a transition plan. Developing a transition plan is not expected before 2030." E1-3 (actions) nonetheless records that in 2025 the Group purchased "12,385 MWh of renewable energy" and applies climate-adaptation measures (flood risk assessment, permeable surfaces, SUDS, waterproofing) at the design and construction stage, implemented within project budgets rather than a dedicated transition-plan budget line (pages 118-120).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 98-99, 103). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk was assessed using "climate change scenarios for Poland in the 21st century, prepared by the IEP-NRI as part of the Climate 2.0 project in the RCP 8.5 scenario compared with the 2011-2020 decade," plus Urban Adaptation Plans for Gdansk, Krakow, Warsaw and Wroclaw, run "for the time horizon extending to 2050" (page 99). Transition risk was assessed "on a qualitative basis" (page 103), with no named 1.5°C-aligned scenario. No global-average-temperature projection per scenario is given. Climate-specific risk identification is also presented under E1-1/E1-3 (2025 ESRS numbering).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 IRO-1 section, disclosed in the FY2025 report (pages 78, 99). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Regarding identified climate change impacts, the Group has conducted a resilience assessment of its strategy and business model to determine its capacity to mitigate material impacts and risks and to leverage significant opportunities" (page 78). "Effective planning of the allocation of financial resources, human resources, technology and IT resources increases the Group's resilience to physical and transition risks" (page 120). No quantified capacity-to-adjust metric or uncertainty disclosure is given.

Reference: page 118

"The Dom Development Group does not have a policy addressing energy efficiency, climate change mitigation, or climate change adaptation. The climate change objectives and actions are set out in the DOM 2030 ESG Strategy. The development of a dedicated policy is not planned before 2030." The absence of a standalone policy is itself the disclosed position, not an omission.

Reference: pages 118-120

In 2025 the Group purchased "12,385 MWh of renewable energy" and plans continued emissions-reduction initiatives to at least 2030 (guarantees of origin, building energy efficiency, fleet transition). A long table of climate-adaptation measures by hazard (flood, storms, water stress, heat stress, ground subsidence) lists specific design responses, e.g. "site planning, flood risk assessment and flood hazard maps before development" and "installing rooftop photovoltaic (PV) systems," funded within development-project budgets (Note 7.35).

Reference: page 120

"The Group has set a carbon reduction target of 30% (for Scope 1 and Scope 2 emissions) per unit under construction by 2030, compared with 2021 as the base year. The Company has not set a target for Scope 3 emissions." The target is gross (no removals/credits) and "is not science-based and does not align with the 1.5°C global warming limit." 2025 intensity was 1.81 tCO2e/unit against a 2030 target of 1.87 tCO2e/unit (+5.8% y/y), tracked via the GHG Protocol.

Reference: pages 120-121

"The Group operates in a high climate impact sector. Given the current business model and the Group's activities, all revenue was classified as generated in high climate impact sectors." Energy demand arises from electricity/heat for construction works, office operations, and the vehicle fleet. Energy mix and consumption tables on pages 120-121 break down non-renewable vs. renewable and nuclear sources; renewable share rose year on year (figures on pages 120-121).

Reference: pages 121-123

Scope 1 covers stationary and mobile combustion; biogenic CO2 from fuel combustion is separately identified at "43.969 tCO2" (page 122). Scope 2 is reported on both "market-based and location-based" methodologies using guarantees of origin. "The Group does not account for any purchased, sold or transferred carbon credits or GHG allowances" in either scope. Scope 3 is reported as the largest category, consistent with a developer whose footprint sits mainly upstream (pages 122-123).

Reference: pages 123-124

"The Group does not have a separate policy addressing water resources management, including the sustainable development of oceans and seas. The development of a dedicated policy is not planned before 2030." Using the Aqueduct Water Risk Atlas, "the assessment confirmed that none of the Group's projects are located in areas of water stress or high-water stress," and the Group does not purchase water from, or operate within, such areas.

Reference: page 124

Water is used mainly for "concrete mixture bonding, masonry and plastering processes or the curing of concrete," sourced from municipal supply. "The companies do not withdraw water from surface water sources, including marine waters," and do not discharge wastewater directly into the environment; garage-floor wastewater passes through "oil and hydrocarbon separators." No dedicated Capex/Opex action plan exists since the Group is not exposed to water-stressed locations.

Reference: page 125

"The Group has not set any measurable, outcome-oriented targets for water management," a deliberate choice given that concrete curing is a "water-intensive process" integral to construction. "The Group will set targets in the area of water management no earlier than in 2030."

Reference: page 125

Water consumption is "compiled based on actual water supply volumes stated in billing invoices," calculated as withdrawals less discharges, with the 2024 figure corrected. Total water consumption was 25,463.83 m3 in 2025 versus 43,322.35 m3 in 2024 (page 126 data table); water stress level is rated "Low (<10%)" for the Group's locations, using the WRI Aqueduct tool.

Reference: page 126

"The Dom Development Group does not have in place a transition plan for biodiversity and ecosystems. The Group does not expect to develop such plan before 2030," and "has not conducted an analysis of the resilience of its business model and strategy in relation to biodiversity and ecosystems." Operations are confined to Poland, which the report frames as keeping its regulatory exposure on biodiversity matters stable.

Reference: page 126

"The Group does not have in place a separate policy specifically addressing biodiversity and ecosystems. The development of a dedicated policy is not planned before 2030." Biodiversity practice instead runs through the internal Green Project Standard (nature-based solutions, mitigation hierarchy) described under E4-3.

Reference: pages 126-127

The Group applies "a sequential model reflecting the mitigation hierarchy... preventing impacts (avoidance), limiting unavoidable harm (minimisation), remedying damage on site (restoration), and only as a last resort, legally required compensation for losses (offsetting)." In 2025 it "delivered more than 1,100 residential units on degraded sites," and allocated "nearly PLN 8 million" to the Urban Greenery initiative (vs. PLN 6 million in 2024), creating over 1.5 hectares of new green space across four cities.

Reference: page 127

"The Group has not set any measurable, outcome-oriented targets specifically for biodiversity and ecosystems," as ambitions sit instead within the DOM 2030 ESG Strategy's Urban Greenery and revitalisation goals (detailed under E4-3). "The setting of such targets is not expected before 2030," and none have been aligned to global biodiversity frameworks or ecological thresholds.

Reference: pages 127-128

Impact metrics include number of planted vegetation units and a project-by-project table of developments near designated nature conservation areas with trees/shrubs removed and compensatory plantings (pages 84-86), e.g. removal of "150 trees" at Wille Biskupin offset by compensatory planting specified by the Municipal Greenery Authority. "In 2025, 25% of developments were located in flood-prone areas" with a low flood risk.

Reference: page 128

In 2025 the Group adopted the "Sustainable Procurement Standard, which constitutes an implementing document to the Sustainable Procurement Policy adopted in 2024," approved by the Presidents of all Group companies' Management Boards, obliging companies "to select suppliers, services and products that are environmentally and/or socially responsible" and to prefer lower-impact materials under the Green Procurement Standard.

Reference: pages 128-129

Circular-economy actions follow the "ReSOLVE model," including increasing recycled steel reinforcement use, waste-segregation training and posters, BIM360-based procurement optimisation, digitalised supplier contracting, and extending IT equipment life ("computers/laptops... for at least five years"). Design and project management run on a single BIM platform used by "more than 1,700 users" in 2025.

Reference: pages 129-130

The Sustainable Procurement Standard sets targets on maintaining asset value, circular design for durability, and integrating ESG criteria into contracting. "In setting its targets, the Company did not refer to ecological thresholds or scientific evidence. The targets established by the Group are voluntary and go beyond actions required by law," set internally without external stakeholder input, with progress reported annually under E5-2.

Reference: page 131

"Throughout its operations and value chain, the Group uses a wide range of material resources," with building materials as the key resource category for construction activity. Resource-inflow data and categories are set out in the accompanying tables on page 131.

Reference: pages 132-134

Resource outflows are addressed through material-efficiency and design-optimisation measures, reducing consumption via "the optimisation of building structures and design solutions aimed at minimising material use" and digital-process efficiency gains, consistent with the company's E5-2 circularity actions.

Reference: pages 133-134

Detailed hazardous/non-hazardous waste tables cover 2024 and 2025, e.g. total non-hazardous waste sent for disposal and total quantity of waste generated (figures on page 133). From 1 January 2025, construction and demolition waste is subject to "the obligation of selective collection, reception, and sorting... covering at least the following waste fractions: wood, metals, glass, plastics, gypsum, and mineral waste."

Reference: page 144

Governing documents are "the Human Capital Management Strategy (adopted in 2025...) [and] the Employment Policy." Priorities include developing competencies, gender-pay transparency, preventing discrimination, prohibiting "human trafficking, forced or compulsory labour and child labour," and preventing workplace accidents. The Employment Policy covers both employment-contract staff and civil-law-contract workers.

Reference: pages 146-147

Engagement runs through transparent recruitment and onboarding, periodic objective-setting with progress reviews, regular team meetings, an "'Open door policy' – encouraging employees to directly reach out to supervisors," and annual training-needs surveys. Channels are two-way rather than one-off broadcast communication.

Reference: pages 147-148

The "Whistleblowing and Misconduct Reporting Procedure implemented in 2024" lets employees report confidentially via dedicated email addresses, mail, telephone or in person, with "safeguards against retaliation." External escalation to the Ombudsman is available for qualifying whistleblowers. Effectiveness is tracked via turnover, absenteeism and the annual Employee Sentiment Barometer; a 2026 awareness campaign on the channels is planned.

Reference: pages 147-148

In 2025 the Group ran training and webinars addressing "burnout, overtime and a lack of work-life balance" ("Managing Yourself in Time," "Emotional Intelligence and Managing Emotions"), plus accessibility measures (ergonomics, first aid, fire-marshal training) and preparation for the Pay Transparency Directive. Effectiveness is monitored via turnover rate, training-needs analysis and the Employee Sentiment Barometer; OHS specifics sit under S1-14.

Reference: page 148

"The Group has not established measurable targets in response to the material matters identified in the double materiality assessment," pending standardisation and automation of HR processes; medium-term (2030) targets will follow that analytical work. Policy effectiveness is nonetheless "monitored on an ongoing basis," and current S1-4 actions are described as continuous.

Reference: pages 149-150

Employee headcount tables cover all Group personnel by contract type, gender and location. The report gives a 2025 employee-turnover calculation basis ("retirements, mutual termination agreements, termination by one of the parties, and expiry of fixed-term contracts... based on the number of employees... leaving the Group... in relation to the headcount as of 31 December 2025").

Reference: pages 149-150

"Wages at the Group companies correspond to the type of work performed and the qualifications of employees. All employees... receive base pay and performance-based bonuses." Pay exceeds "the statutory minimum wage – the commonly used benchmark in Poland," and a 2025 job-evaluation process assigned positions to subgroups to align remuneration with national regulation.

Reference: pages 150-153

"All employees of the Group companies classified as own workforce are covered by an occupational health and safety management system." 2025 activities include OHS e-learning for administrative staff, the "Construction – a Safe Adventure" programme for site personnel, and "Build Safely" competition participation. OHS expenditure reached "almost PLN 4 million," up 9% year on year; accident-rate figures for own workforce and subcontractors are tabulated (pages 151-153).

Reference: pages 152-154

"The gender pay gap is defined as the difference in average remuneration between female and male employees," calculated on total 2025 remuneration components on a full-time-equivalent basis. "The ratio of the annual total remuneration of the highest-paid individual... to the median annual total remuneration of all other employees... for 2025 is 26.97," with the year-on-year change attributed to Management Board changes and the highest-paid individual's remuneration.

Reference: pages 153-154

"In 2025, two complaints were submitted through the reporting channels (including grievance mechanisms) [by] people in the entity's own workforce. None of them concerned discrimination, including harassment, or cases of human rights violations." "No severe human rights incidents related to the Group's employees were recorded," and no penalties, fines or damages were imposed. Data are held in an internal register, not externally validated.

Reference: page 156

The Code of Ethical Conduct "defines the Company's fundamental shared values, including respect for human rights, integrity, respect, responsibility, non-discrimination, transparency, and the prevention of corruption," with whistleblower protection via a dedicated reporting system (etyka@domd.pl and company-specific addresses). The Anti-Corruption, Gifts and Conflict of Interest Policy targets bidding/contract execution, public-sector relations, supply-chain relations and financial settlements as the functions "most vulnerable to corruption and bribery risks" (page 157).

Reference: page 157

Payment-term negotiation with suppliers follows "the Act of 4 November 2022 amending the Act on counteracting excessive delays in commercial transactions," protecting smaller enterprises. In 2025 the Group rolled out the Sustainable Procurement Standard, scoring contractors on "fulfilment of ESG criteria," delivery distance, and Code-of-Conduct compliance; a systematic supplier size classification is planned for 2026. "The Group has not identified the need for a separate policy to prevent late payments."

Reference: page 158

"In 2025, the Group companies did not conduct anti-corruption and bribery prevention training, as the Group's training programme schedules such sessions for 2026." A corruption risk assessment "confirmed that there are no areas where corruption risk is absent." Compliance reports on anti-corruption tasks go "quarterly to the Audit Committee... and semi-annually to the Supervisory Board," overseen by the Chief Risk and Compliance Officer.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Dom Development discloses no measurable business-conduct target. Consistent with MDR-T's other limb, effectiveness is tracked instead: "The criteria used by the Group to assess the effectiveness of its anti-corruption measures include the number of reported incidents related to corruption, the frequency of corruption-related events, and the Group's subjective assessment of its daily business operations" (page 158).

Reference: page 159

"The percentage of payments made in line with standard payment terms, i.e., within 30 days, is 98%," with an average invoice payment period of 20 days across the reporting entities. "No legal proceedings are currently pending against any of the Group companies for late payments," and the Group files its statutory annual report on payment terms in commercial transactions each year by 30 April.