Erbud S.A.

Reference: page 143

The ERBUD Group is managed by the bodies of the parent ERBUD S.A. The Management Board is appointed for a three-year term and has three to five members; at end-2024 it had three executive members (Dariusz Grzeszczak as President, Vice-Presidents Agnieszka Glowacka and Jacek Leczkowski), all aged over 51, one woman (33%) and two men. A fourth member, Tomasz Wojak, was appointed effective 1 January 2025. The Supervisory Board, appointed by the General Meeting for a joint three-year term, has eight members: two women (25%) and six men, five independent and three dependent, split evenly between the 30-50 and over-51 age brackets. The Supervisory Board appoints and dismisses the Management Board and approves strategic plans; it is supported by an Audit Committee and a Remuneration Committee. There are no worker representatives. Sustainability oversight sits with the Management Board (Glowacka since December 2024), supported by an ESG Committee chaired by the Head of ESG. The report describes board members' expertise in business conduct and notes ESG training by EY.

Reference: page 151

Issues on material impacts, risks and opportunities and the effectiveness of Group policies are reported to the responsible Management Board members at least twice a year during regular management meetings and, where needed, in direct discussions. The ESG Committee is the coordinating unit informing the Management Board on ESG matters; President Dariusz Grzeszczak was responsible until end-November 2024 and Vice-President Agnieszka Glowacka from December 2024. Where appropriate the Management Board informs the Supervisory Board. In 2024 the Management Board took part in the Double Materiality Analysis (DMA) that identified the Group's impacts, risks and opportunities under the ESRS, and in the ESG Strategy process including setting objectives. DMA results were used to develop the Sustainability Strategy with objectives, actions and indicators. The Group is implementing due diligence components. Selected actions addressed by the Board cover human and labour rights and diversity policies, recruitment and data protection, new remuneration rules including non-financial factors, occupational health and safety analysis, GDPR updates and code and policy updates linked to identified material IROs.

Reference: page 152

In 2024 the ERBUD Group did not have incentive systems or remuneration policies linked to sustainability matters for members of the administrative, management and supervisory bodies. However, in 2023 the Group began work on implementing such a system covering company boards and senior managers. Management Board remuneration is governed by the Remuneration Policy for Members of the Management Board of ERBUD S.A. and the Supervisory Board. It consists of a fixed part and a variable part, the variable being a bonus based on an assessment of work efficiency, with the bonus amount for Management Board members set by the Supervisory Board. Basic remuneration takes into account the function performed, scope of responsibility, professional qualifications and experience, and market competitiveness. Variable remuneration is allocated based on an assessment of effectiveness, with business indicators chosen according to each member's roles and responsibilities. The Group considers the level of remuneration appropriate to attract, retain and motivate individuals able to lead and oversee the organisation.

Reference: page 153

The Group presents a statement on due diligence in the form of a table mapping the core elements of the due diligence process to the places where they are disclosed in the Sustainability Statement. Integrating due diligence into corporate governance, strategy and business model is covered by GOV-5, SBM-3 and policy disclosures (E1-2, E3-1, E4-2, E5-1, S1-1, S2-1, S3-1 and G1-1). Engagement with affected stakeholders at all key stages is covered by SBM-2 and the engagement processes S1-2, S2-2 and S3-2. Identifying and assessing negative impacts is covered by IRO-1 and the remediation and grievance channels S1-3, S2-3, S3-3 and S3-4. Taking measures to mitigate negative impacts is covered by action disclosures E1-3, E3-2, E4-3, E5-2, S1-4, S2-4, S3-4 and G1-3. Monitoring effectiveness and communicating information is covered by the metrics and targets sections for E1, E3, E4, E5, S1, S2, S3 and G1.

Reference: page 156

The risk management and control system over sustainability reporting is defined in the ERBUD S.A. Sustainability Reporting Procedure, covering all functional units involved, with the ESG Committee coordinating preparation for the whole group under the ESG Committee Regulations. The procedure assigns responsibilities to the Management and Supervisory Bodies, ESG Director, Director of Accounting, top management, and directors of HR, OH&S, Environment, Legal and Corporate Governance, plus the internal auditor. Reporting risks are assessed during Sustainability Team meetings by scoring probability and impact from 1 to 5, producing a risk matrix categorising risks as low, acceptable or high. Identified reporting risks include data completeness and integrity, low data quality, lack of comparability, incorrect estimation, methodology errors, supply chain data complexity, untimely provision and evolving regulations. Mitigating actions include data control and automation, internal audit and external verification, staff training, internal control systems, periodic verification, deviation analysis, four-eye checks, auditor pre-testing on three quarters of data, and continuous process improvement. Results are integrated into functions through regular monitoring and reported to the management bodies.

Reference: page 158

The Group runs a diversified business model providing renewable energy contracting, building and industrial construction, timber modular construction and industrial maintenance services across four business areas. It operates in Poland, Germany, Lithuania and Belgium, mostly in Poland, with 2,760 employees (2,086 Poland, 539 Germany, 133 Belgium, 2 Lithuania). Customers are private and public investors in conventional and renewable energy, construction development, chemicals and petrochemicals, woodworking, healthcare and trade sectors. Total revenue in the Construction and civil engineering ESRS sector was PLN 2,980 million against costs of PLN 2,760 million, with no significant activity outside this sector. Pre-tax profit was PLN 55,118.74 in 2024 and a PLN 20 million dividend is recommended. The ESG strategy, integrated with the business strategy, rests on five pillars (climate and environmental care; care for partners, suppliers and subcontractors; care for workforce; care for the community; ethics) with priorities and time-bound targets to 2029, including a 30% Scope 1 and 40% Scope 2 carbon footprint reduction. The Group describes resources, value chain, customer benefits and liquidity and credit risk management.

Reference: page 167

The Group identified and selected key stakeholders systematically using qualitative criteria through a dedicated workshop with the Management Board, senior management and sustainability experts, applying a two-sided analysis of the Group's impact on stakeholders and their influence on the Group. Key stakeholder groups are: the Management Board, management staff and Supervisory Board; the workforce (including students and trainees); customers (investors, contracting authorities, private and public); suppliers, service providers and subcontractors; the business community; media; society (associations, NGOs); and the institutional environment (funds, banks, the WSE). Engagement methods and frequency are tailored per group, using in-person and online meetings, written communications, websites and social media. Through the dual materiality process the Group took stakeholder views into account, shaping the 2024 strategy. The report lists key issues raised per group, for example working time and collective bargaining for the workforce, climate change and health and safety for customers, and land degradation and soil sealing for the institutional environment. Management and supervisory bodies are informed of stakeholder views at least annually and on an ongoing basis. Separate subsections cover own workforce, value chain workers and affected communities.

Reference: page 173

Material impacts, risks and opportunities were identified through the dual materiality analysis combining impact and financial materiality. By its nature, construction generates significant negative impacts: greenhouse gas emissions from materials such as cement, steel and concrete; high water consumption; and large waste volumes, alongside energy intensity, biodiversity loss, land degradation and soil sealing. Positive impacts include supporting the energy transition through renewable energy infrastructure, low-carbon timber modular construction, green-certified buildings and district heating modernisation. Financial materiality identified climate adaptation physical risks (heat waves, hurricanes, flooding, precipitation, soil and water effects), transition risks (tighter emission rules, charges, litigation, loss of customers), and risks around energy, water, biodiversity, resource use, waste, working conditions, corruption and supplier relationships, plus opportunities in RES growth, timber modular construction and green building. Social material impacts cover working time, social dialogue, collective bargaining, work-life balance, occupational health and safety, equal treatment, training, privacy, child and forced labour and adequate housing. Governance impacts cover corporate culture, whistleblower protection, supplier payment practices and anti-corruption. The Group reports no material financial adjustment risk and assessed business model resilience across short, medium and long horizons.

Reference: page 188

Impacts, risks and opportunities were identified and assessed through the dual materiality analysis, performed for the first time in 2024 in line with ESRS and EFRAG guidance, using the ESRS 2 AR 16 topic list. The structured process gathered regulatory, strategy, prior-report, EMAS and benchmark information, developed an assessment methodology with a consultant, mapped the value chain and key stakeholders, then assessed each topic. Impact materiality used a 5-point scale for scale, scope, irreversibility and probability, with a materiality threshold above 50% of the maximum and a gross (pre-mitigation) approach; topics could score up to 20 points. Financial materiality scored potential size and probability on a 5-point scale, maximum 10 points, with a threshold of 5 points (the arithmetic mean). Time horizons were short (under 1 year), medium (1-5 years) and long (over 5 years). Questionnaires with 21 questions went to stakeholders, drawing 226 responses (99 employees, 65 management, 21 suppliers). The Group adopted a consolidated approach without country breakdown. Each DMA step was approved by senior management, the Management Board representative and the ESG Committee. Separate IRO-1 subsections describe processes for climate, pollution, water, biodiversity, circular economy and business conduct.

Reference: page 201

Disclosure requirements were determined by identifying material sustainability topics from an impact and/or financial perspective under dual materiality, with thresholds described in IRO-1 per ESRS 1 Section 3.2. A table maps material topics to the disclosure requirements covered. Covered standards are E1 Climate change (adaptation, mitigation, energy), E3 Water and marine resources (water consumption), E4 Biodiversity and ecosystems (land degradation, soil sealing, direct exploitation, pollution as a biodiversity driver), E5 Resource use and circular economy (resource inflows, waste), S1 Own workforce (working conditions, equal treatment, other work-related rights), S2 Value chain workers (working conditions, equal treatment, child and forced labour), S3 Affected communities, and G1 Business conduct (corporate culture, whistleblower protection, supplier relationships and payment practices, corruption and bribery). For each, the relevant ESRS 2 cross-cutting and thematic DRs and metrics are listed. E2 Pollution and S4 Consumers and end-users are not material to the Group. The section also lists data points stemming from other EU legislation (SFDR, CRR, BRR), such as board gender diversity and the statement on due diligence.

Reference: page 229

The ERBUD Group does not yet have a climate change mitigation transition plan and commits to developing one by the end of 2026. Based on its ESG strategy and carbon footprint analysis, it is analysing transition and decarbonisation potential across all GHG scopes, with preliminary, not yet final, emission reduction guidelines. The Group identifies initial decarbonisation levers. For Scope 1 and 2 these are: increasing the share of renewable energy in the energy balance (own renewable installations and purchasing certified energy), improving energy management and efficiency (preparing an energy efficiency plan), and modernising the fleet of construction vehicles and machinery toward low-emission and electric solutions. For Scope 3 the levers are sustainable procurement and supplier selection favouring lower carbon footprint and recycled materials per the Suppliers' Code of Conduct, supply chain efficiency improvements, and construction waste reduction and recovery. Final scope of actions will be set after evaluation under the transition plan. The Group also plans a climate change adaptation plan. No explicit 2050 climate neutrality target is stated; the Climate Policy spans 2023-2050.

Reference: page 230

ERBUD Group's Climate Policy 2023-2050 is the framework document setting the approach to climate change mitigation and adaptation. Overall objectives include reducing greenhouse gas emissions, increasing energy efficiency, using renewable energy sources and managing climate risks across the value chain. It takes into account TCFD guidelines, the European Green Deal Strategy and Regulation (EU) 2020/852 (EU Taxonomy). The policy covers all Group activities, own operations and the entire upstream and downstream value chain, with no exclusions by activity, geography or stakeholder group. Mitigation actions include progressively reducing emissions, increasing renewable energy share, improving building technologies, modernising the vehicle fleet, and using high thermal insulation materials. Adaptation activities address physical risks (heat waves, heavy rainfall, storms) via resilient building technologies, retention systems and location risk analysis. The policy promotes modular construction and LEED/BREEAM green building standards, supplier evaluation on carbon performance with planned audits and a Suppliers' Code of Conduct, plus employee education. It is monitored by the CEO of ERBUD S.A. and publicly available at https://esg.erbud.pl/polityki/.

Reference: page 231

In 2024 the ERBUD Group implemented activities supporting decarbonisation in line with its Climate Policy. Due to the preliminary nature of activities, the Group does not yet disclose significant capital or operating expenditures. For Scope 1 and 2, it purchased electricity from certified sources (guarantees of origin), continued installing photovoltaic panels on construction containers, purchased an electricity storage system to avoid generator use during power cuts, and changed its energy supplier to one with a more favourable energy mix. Energy management tools were implemented, including electronic metering systems and systematic energy efficiency monitoring in accordance with ISO 50001; an energy efficiency improvement plan is being developed. For Scope 3, the Group worked to minimise supply chain climate impact: analysing greater use of lower carbon footprint and recycled materials per the Suppliers' Code of Conduct (introduced end of 2024), improving delivery efficiency, implementing a virtual warehouse system to reduce oversupply, and applying circular economy principles. The base year is 2024. A phased reduction of operations and supply chain emissions is planned by end of 2029, with the reduction plan defined in the transition plan by end of 2026.

Reference: page 233

The ERBUD Group has set GHG reduction targets under its Climate Policy. For Scope 1 and 2 it commits to: by 2030 (by end of 2029) a 30% reduction in direct emissions (Scope 1) relative to revenue against a 2020 base year; and by 2030 (by end of 2029) a 40% reduction in indirect energy emissions (Scope 2, in relation to revenue, market-based approach) compared to 2020. These targets will be reviewed under the transition plan, including changing the base year reference to 2024; the previously used base year was 2020. A Scope 3 reduction target will be set as part of the transition plan development by 2026. Targets were developed in accordance with best available methodologies; the Group analysed a 1.5C scenario and a high-emissions BAU scenario. No SBTi validation is mentioned. Key decarbonisation levers include enhancing energy efficiency, reducing energy consumption by 10% (per revenue), increasing renewable energy share, improving the renewable energy mix by 10% in relation to total energy costs, optimising the supply chain, selecting low-carbon raw materials, and integrating climate aspects into product design.

Reference: page 235

In 2024 the ERBUD Group's total energy consumption was 54,808 MWh. Total fossil energy consumption was 51,682 MWh, accounting for 94% of the total. This comprised 4,363 MWh from coal and coal products, 30,710 MWh from crude oil and petroleum products, 9,052 MWh from natural gas, 0 MWh from other fossil sources, and 7,557 MWh of purchased electricity, heat, steam and cooling from fossil sources. Nuclear energy consumption was 38 MWh (0.1% of total), based on the national energy mix in Poland and Germany. Total renewable and low-carbon energy consumption was 3,088 MWh, a 6% share, comprising 0 MWh from renewable fuels/biomass, 3,004 MWh of purchased renewable electricity, heat, steam and cooling, and 85 MWh of self-generated renewable (solar) energy without fuel consumption. The Group generated and consumed 85 MWh of solar from its own photovoltaic installations and purchased 1,915 MWh of renewable electricity via guarantees of origin plus 1,089 MWh under a green tariff. Energy intensity in climate-significant sectors was 0.02 MWh per thousand PLN, on net revenues of PLN 2,980 million.

Reference: page 238

For base year 2024, the ERBUD Group reported gross Scope 1 GHG emissions of 10,932 tCO2e (stationary sources 5,154; mobile sources 5,727; fugitive 29; process emissions 23), calculated using DEFRA emission factors and covering the seven Kyoto Protocol gases; biogenic emissions from biofuel blends were 456 tCO2e. Scope 2 gross emissions were 5,016 tCO2e location-based and 3,519 tCO2e market-based (each split into purchased electricity and 1,242 tCO2e of purchased thermal energy); 43% of Scope 2 was covered by contractual instruments. Total gross Scope 3 emissions were 490,568 tCO2e across nine material categories, dominated by purchased goods and services at 304,135 tCO2e and end-of-life treatment of sold products at 166,000 tCO2e (other categories: investment goods 3,740; fuel and energy-related 11,227; upstream transport 1,790; waste 580; business travel 153; employee commuting 2,868; downstream transport 75). Total GHG emissions were 506,517 tCO2e (location-based) and 505,020 tCO2e (market-based). GHG intensity was 0.17 tCO2e per net revenue under both methods. Calculations follow the GHG Protocol with operational control boundaries; 0% of Scope 3 was from primary data.

Reference: page 247

In 2024 the ERBUD Group did not have a policy for managing significant impacts, risks and opportunities related to water and marine resources. The Group plans to develop and adopt such a policy in 2025, after analysing existing water-related documents across companies and identifying priorities and further actions in line with the ESG Strategy. In preparation, the Group analysed its own facilities and investments in 2024 to set targets and plan actions to prevent significant negative water impacts. The Group has at least one site located in an area of significant water deficit. The Group did not have a policy related to oceans and marine sustainability in 2024.

Reference: page 247

The Group's main 2024 actions to reduce negative impacts on water resources include monitoring water consumption at its own facilities and investments on an ongoing basis, digitising and improving water consumption data collection, and reducing water abstraction and consumption, including by installing water-efficient sanitary facilities. The ESG strategy will also include analysis of internal regulations to meet ESRS requirements (planned by end of 2025) and identification of the potential for rainwater use at its own facilities and investments (by end of 2025). Given the nature of the construction sector, the Group cannot avoid water use in its technological processes. Current and future financial resources for water activities were not identified in 2024, and no redress actions were needed as there were no such cases.

Reference: page 248

In 2024 the ERBUD Group set a voluntary target related to water and marine resources: the creation of a policy to organise the use of water and marine resources across the Group, to be achieved in 2025. In addition, the Group set an intermediate target in its ESG strategy to identify the potential for rainwater use, to be achieved by the end of 2027.

Reference: page 248

The total water consumption of the ERBUD Group in 2024 was 9,043.86 m3. The Group had no water storage, recycling or reuse activities in 2024. Total water consumption in water risk areas, including areas of significant water scarcity, was also 9,043.86 m3, as the Group did not have data to separate quantities for exposed and non-exposed water areas. Water intensity in 2024 was 3.04 m3 per PLN 1 million net revenue. The figures derive from meter readings at the Group's own facilities and investments under its control and reflect actual 2024 water consumption. Water consumption data is obtained from all sites, including ongoing construction sites the Group impacts.

Reference: page 249

The ERBUD Group has not undertaken a process to assess the resilience of its strategy and business model in relation to biodiversity, and has not developed a transition plan or specific biodiversity policies. A resilience analysis is planned for 2025. The Group is aware of the interdependence of its business model and strategy with biodiversity and ecosystems and the associated risks. In response, it is implementing and maintaining ISO 14001 and EMAS environmental management systems at ERBUD S.A. and ONDE S.A. The dual materiality analysis identified negative impacts on biodiversity relating to land degradation and soil sealing, with no sites identified as having a significant negative impact on biodiversity-sensitive areas.

Reference: page 249

In 2024 the ERBUD Group did not have organisation-wide uniform policies for managing significant biodiversity impacts, risks and opportunities. Group companies use the Guide to Environmental Management in the ERBUD Group, listing requirements and good practices for each project, including protection of amphibians, birds and tree stands on construction sites. Environmental management systems require analysis of environmental risks and opportunities for each investment. The Group has no formal land policy but follows practices protecting soils from erosion, preserving fertile topsoil for future use, and restoring degraded land where necessary. The Group has not implemented regulations on sustainable oceans and seas, nor an anti-deforestation policy. It is analysing internal regulations and value chains to meet ESRS requirements.

Reference: page 250

Biodiversity actions apply to all Group companies regardless of location, focusing first on own operations then the value chain. Actions to minimise negative impacts include detailed pre-investment studies by environmental specialists including ornithologists and dendrologists, limiting construction site area to the minimum, preferring already developed areas, protecting trees from mechanical damage, minimising tree felling with compensatory planting, temporarily sealing yard surfaces to prevent oil spills, adapting work schedules to natural life cycles, halting work when animals appear, limiting night noise, and restoring used land. One of the largest compensatory plantings, in exchange for felling 370 trees, involved planting 260 trees and 778 shrubs at a cost of PLN 532,190. Records of all mitigation activities were not kept in 2024. Current and future funding for the biodiversity action plan has not been identified.

Reference: page 252

The ERBUD Group's 2029 biodiversity and ecosystem targets fit within the Kunming-Montreal Global Biodiversity Framework and relevant aspects of the EU Biodiversity Strategy, and are based on ESRS, EU taxonomy and associated technical criteria. Ecological thresholds and measures to compensate for biodiversity loss were not used in setting the targets. Targets are defined in the ESG strategy updated in 2024, with internal stakeholders involved through workshops. The two targets are: to implement Group policies addressing significant biodiversity impacts (baseline: no policy; target: develop consistent Group regulation), and to execute all in-house investment projects without causing serious biodiversity damage (baseline to be set in 2025, target 100%). The targets sit at the avoidance level of the mitigation hierarchy. A baseline cannot yet be linked to policy assumptions due to the absence of a policy.

Reference: page 253

Impact metrics related to the Group's significant biodiversity impacts on its own investments are the total area of land in use (the fenced, designated work area) expressed in m2 relative to sales revenue, for land degradation and direct use impacts, and the total area of land used for buildings, structures and roads (including wind farm foundations, covered with impermeable material such as concrete) expressed in m2 relative to sales revenue, for soil sealing impacts. The metrics are verified during annual EMAS audits. In 2024 total land area in use was 2,336,300.53 m2 (783.99 m2 per PLN million on sales revenues of PLN 2,980 million), and total land area occupied by buildings, structures and roads was 471,838.06 m2 (158.33 m2 per PLN million).

Reference: page 255

In 2024 the ERBUD Group did not have a consistent policy across all companies to manage material impacts, risks, dependencies and opportunities related to resource impacts, including resource use and waste. At the same time, the Group began the process of developing a policy in this area. In 2024 it analysed the extent to which existing policies at Group companies address the management of material risks, opportunities and impacts related to resource use and the circular economy.

Reference: page 255

The Group analysed its own facilities and investments to set targets and plan actions avoiding significant negative impacts related to resource use and recycling. Materials and waste data are included in the annual EMAS declarations of ERBUD S.A. and ONDE S.A. and in ESG reports. Actions include implementing eco-design principles (designing for recycling, repair and reuse), investing in timber modular construction designed for easy disassembly and reuse, promoting and using recyclable and recycled materials, reducing material wastage through more efficient storage, and implementing just-in-time procurement. Waste-focused actions include raising awareness, applying the waste hierarchy, reducing waste generated, segregating waste, diverting waste to recycling, keeping records in the BDO register, and processing waste under ONDE's permits at the Torun and Koszalin bitumen plants. Current and future financial resources for resource inflows and waste were not analysed in 2024.

Reference: page 257

In 2024 the ERBUD Group did not have measurable, performance-oriented and time-bound targets related to resource inflows. It initiated an analysis of companies' existing procedures to identify further actions and plans to develop guidelines for monitoring actions in each company. The Group's waste and circular economy target, under the ESG strategy adopted in 2024, is to achieve a level of 70% of its own waste generated on site (excluding soil, land and hazardous waste) ready for reuse, recycling and other recovery processes by 2029. This reflects national legislation and EU taxonomy requirements, including the do no significant harm criteria for new construction. From 2025 construction companies must separate construction and demolition waste. The Group considers the segregation target consistent with investor tender requirements and will set a baseline in 2025 after analysing 2024 quantitative data.

Reference: page 257

Key resource inflows used in the ERBUD Group's ongoing operations and value chain include electrical materials (including photovoltaic cells containing rare earth elements), steel components (construction and reinforcement materials), concrete and precast reinforced concrete, stone mixtures, water used in the value chain (for example in producing construction materials), and construction machinery and equipment such as excavators, loaders, rollers and tower cranes. The total amount of products and technical and biological materials used by the Group in 2024 was 1,379,026.4 tonnes. Due to the nature of its operations, the Group assessed biological materials, reused or recycled components, products and secondary materials used in production and services as intangible assets. The data represent quantities of materials purchased directly from construction sites and purchase documents, and were also used to calculate indirect (Scope 3) emissions.

Reference: page 258

Resource outflows comprise the waste generated by the Group, with a total volume of 19,877.6 tonnes in 2024. The main waste streams are waste from the construction, renovation and dismantling of buildings and road infrastructure, including soil and earth. The composition of waste is linked to the raw materials and materials consumed, including concrete, wood, plastics, and critical raw materials and rare earth metals used in photovoltaic technology. The Group also produces demolition waste including concrete, steel and soil from excavations. Data come directly from public administration systems such as BDO and from waste receivers; where information on treatment is absent, the Group assumes the waste was landfilled. The Group does not report products with durability or recyclability characteristics separately.

Reference: page 258

Total volume of waste generated in 2024 was 19,877.6 tonnes. Of waste directed to recovery, recycling totalled 9,479.8 tonnes and other recovery processes 4,360.4 tonnes (combined 13,840.3 tonnes), of which non-hazardous waste accounted for 9,476.1 tonnes recycling and 4,306.7 tonnes other recovery (13,782.8 tonnes total), and hazardous waste 3.7 tonnes recycling and 53.7 tonnes other recovery (57.5 tonnes total); none was prepared for reuse. Waste directed to disposal totalled 6,037.3 tonnes, comprising incineration 27.4 tonnes and storage 6,009.9 tonnes. Hazardous waste disposal was 44.3 tonnes (0.720 incineration, 43.6 storage) and non-hazardous 5,992.9 tonnes (26.7 incineration, 5,966.2 storage). The total amount of waste not recycled was 10,398 tonnes, a non-recycled rate of 52.31%.

Reference: page 262

The ERBUD Group's leading policies covering its own workforce span working time (Labour Regulations, Code of Ethics, Human and Employment Rights Policy), social dialogue, work-life balance, occupational health and safety (Integrated Management System Policy), training and skills development, diversity (Diversity Management Policy plus a Labour Law Breach Whistleblowing Procedure), privacy (Personal Data Protection Policy) and collective bargaining. The overall approach to human rights, including labour rights, rests on the Human and Employment Rights Policy, aligned with the Labour Code, UN Universal Declaration of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, OECD Guidelines, UN Guiding Principles on Business and Human Rights and UN Global Compact. The policy commits the Group to corrective action where operations violate human rights and directly addresses human trafficking, forced labour and child labour. Policies are made available to employees via internal networks, email, postings at construction sites and the ERBUD website. The OHS management system covers all Group member companies.

Reference: page 265

ERBUD Group companies engage with their own workforce through a dedicated social dialogue platform, employee surveys assessing more than a dozen categories of working-environment perception, and online meetings with the Management Board held every six months. The Group intends to introduce a three-yearly (subsequently biennial) employee opinion survey; previous surveys ran in 2019 and 2023. All people whose work is used by the Group, regardless of form of employment, are invited to participate, and results are discussed in workshops feeding local and central initiatives. Engagement is especially developed around safety, led by the annual Safety Week, the Occupational Health and Safety app, newsletters, and quarterly Health and Safety Committees that serve as a forum for dialogue between employees and the employer; employees take part in occupational risk assessments. In 2024 the Group ran a GDPR audit and data-protection training. Operational responsibility for involving employees and reflecting their views lies with the management of individual Group companies.

Reference: page 265

Where the ERBUD Group causes a material negative impact on its own workforce, it implements remedial measures individually tailored to the nature and scope of each case. The Group has not established formal mechanisms to evaluate the effectiveness of those measures but gathers information informally and assesses whether workers have confidence in the channels for raising concerns. The channels for reporting negative impacts are the dialogue platform implemented across the Group and the channels set out in the whistleblowing procedure for the wider labour law, which forms part of the Diversity Management Policy. That procedure also describes the mechanism for handling labour complaints. Once a report is confirmed to be an actual breach, the Group takes appropriate corrective action in each case. Availability of the complaint channel is communicated through information posters at construction sites and internal communication channels. The dialogue platform was launched in 2024, and the Group began evaluating the usefulness of this channel during the reporting period.

Reference: page 266

The Group defines actions for each material workforce topic, applying to all employees in Poland and Germany. On working time it monitors overtime and communicates with supervisors, aiming by 2029 for at least 90% of employees to have no more than 10 outstanding holiday days. On social dialogue it ran online all-employee meetings with the Management Board and launched the dialogue platform, expanding paper-based channels for line workers, targeting 51% turnout in the Employee Opinion Survey by 2029. It upholds freedom of association and collective bargaining. Work-life balance actions include monitoring leave and the Manager's Desk application, private healthcare, sports packages and the Two Hours for the Family campaign. On health and safety the Group runs regular analyses, sets annual targets and aims to maintain 0 major and fatal accidents on sites through 2029. Training actions include updated skills procedures and an e-learning rollout. Diversity actions include a discrimination-prevention programme, salary reviews and reducing pay disparities by 2029. Privacy targets 80% of relevant staff trained by 2029. These actions do not require significant operating or capital expenditure.

Reference: page 270

The Group's workforce targets, covering all employees including foreign companies, are set in the Group ESG Strategy developed in 2024, with employee representatives involved through strategic workshops and the double materiality analysis. Targets include: at least 90% of employees with no more than 10 outstanding holiday days by 2029 (baseline average 13 days); 51% attendance in Employee Opinion Surveys by 2029 (2023 baseline 41%); at least one quarterly meeting between employer representatives and employees (2024-2029); upkeep of the 2024 collective bargaining level (36% of Group employees covered by company collective agreements); upkeep of 0 severe and fatal accidents on construction sites through 2029 (2023 base year had 0); increasing training hours per employee versus 2024 (baseline set in 2025); 70% of women and 70% of men subject to career reviews; at least 95% of middle and senior management trained in discrimination prevention and a 10% pay-gap reduction against 2023 (2023 unadjusted wage gap 20%); and at least 80% of personal-data handlers trained by 2029 (baseline 0%). All targets are relative. The strategy was adopted at end-2024, so monitoring processes were not yet implemented during the reporting period.

Reference: page 272

The total ERBUD Group workforce as at 31 December 2024 was 2,760 employees. The largest reported country breakdown is Poland with 2,086 employees, comprising 1,573 men and 513 women; of these, 1,689 were permanent (1,284 men, 405 women), 397 were temporary staff (289 men, 108 women), 2,043 were full-time (1,550 men, 493 women) and 43 were part-time (23 men, 20 women). Germany had 539 employees (477 men, 62 women), split into 486 permanent and 53 temporary, with 515 full-time and 24 part-time. Belgium had 133 employees (all men), of which 121 were temporary and 12 permanent, all full-time. Lithuania had 2 employees (both men, temporary). The data are reported as headcount at 31 December 2024. During the reporting period 585 employees left the Group, giving a turnover rate of 21%. The Group notes the headcount differs from the figure in the consolidated financial statements due to a different methodology.

Reference: page 274

The percentage of employees represented by employee representatives in the ERBUD Group was: Poland 97%, Belgium and Lithuania 100%, and Germany 6%. Representation bodies vary by company: employee representatives elected under the agreed procedure at ERBUD S.A., ERBUD International, MOD21, ONDE and ERBUD Shared Services; three trade unions at ERBUD Industry Centrum; and a Works Council at IVT and IKR. Companies with fewer than 50 employees (Satchwell, IDE Projekt, MOD21 GmbH) had no constituted employee representatives in 2024, with consultations conducted without representation. The percentage of employees covered by collective labour agreements was 25% in 2024. Within the EEA, 482 Poland employees (23%) and 202 Germany employees (36%) were covered by collective labour agreements. ERBUD Industry Centrum has a registered company collective agreement covering all its employees, while most IVT, IKR and MOD21 staff are covered by cross-company tariff agreements. The Group has no employees outside the EEA and no European Works Council agreements.

Reference: page 275

The ERBUD Group reports diversity of its top management by gender as at 31 December 2024. Of 145 people in top management, 118 were men (81%) and 27 were women (19%). Top management is defined to comprise the management bodies as well as one and two levels below the management bodies. By age, the Group's total headcount was distributed as follows: 473 employees (17%) below 30 years of age, 1,362 employees (49%) aged 30 to 50, and 925 employees (34%) above 50 years of age. Figures are reported as headcount as of 31 December 2024. The Group also operates the ERWOMAN development programme, launched in 2023, to support women across positions and business areas in a sector where the majority of candidates are men.

Reference: page 277

The ERBUD Group reports health and safety metrics for its own workforce as at 31 December 2024. All 2,910 own employees (100%) were covered by the occupational health and safety management system based on legal requirements or recognised standards. There were 0 work-related fatalities among the Group's own workforce and 0 fatalities among other workers on site. The Group recorded 40 reportable work-related accidents among its own workforce, giving a rate of reportable work-related accidents of 6.27 (number of accidents x 1,000,000 / man-hours worked). There was 1 reportable case of work-related ill-health. The number of days lost due to work-related injuries, fatalities and ill-health was 1,213. Of the workforce, 2,567 of 2,910 employees were covered by an OHS management system subject to internal or external audit or certification, based on ISO 45001:2018 (ERBUD S.A., ERBUD Industry Centrum, CKTiS, ONDE, MOD21, IVT) and SCC-VAZ 2021 (IKR).

Reference: page 279

The ERBUD Group reports its gender pay gap, defined as the difference in the average level of pay between female and male workers expressed as a percentage of the average pay of male workers, at 17%. The ratio of the annual total compensation of the top earner to the median annual total compensation of all employees (excluding the top earner) was 28. The pay gap was calculated using average gross hourly pay, based on base salary from the contract as at 31 December 2024 including fixed allowances and relocation allowances paid in 2024, averaged to monthly amounts, with part-time workers pro-rated to full-time and EUR amounts converted to PLN at the 31 December 2024 exchange rate, using a 168-hour monthly standard. The total compensation ratio used base salary plus allowances multiplied by 12 months and moving allowances paid in 2024, with the same pro-rating, currency conversion and hourly-to-monthly methodology.

Reference: page 282

The ERBUD Group manages material impacts, risks and opportunities affecting value chain workers through a Code of Ethics, a Human and Employment Rights Policy, a Suppliers' Code of Conduct and a Diversity Management Policy, plus the Integrated Management System for occupational health and safety. These policies have no geographical exclusions and cover all value chain workers. The human and labour rights policy commits to respecting human and labour rights and prohibits child labour, aligning with the Universal Declaration of Human Rights, ILO Fundamental Principles, OECD Guidelines, UN Guiding Principles and UN Global Compact. ERBUD S.A. recorded no breaches in 2024 or prior years. The Suppliers' Code of Conduct complies with ILO standards and addresses worker safety, precarious employment, human trafficking and forced or child labour. Subcontractors accept and implement the IMS policy. Policies are available via the website, posters and QR codes at sites.

Reference: page 284

ERBUD Group companies engage with value chain workers through a dedicated dialogue platform allowing all such workers to comment on the organisation's impact, regular health and safety training and education for subcontractor workers including the chance to share safety experiences, and contractual obligations on contractors to provide decent working and wage conditions and to avoid child and forced labour. The Director of the Central Purchasing Division, Commercial Directors, Contract Managers and Site Managers oversee cooperation with value chain workers. The Group gathers opinions and assessments through the communication platform, with data feeding into a biennial review of related policies. The platform was launched in 2024 and its effectiveness in managing dialogue was being analysed during the reporting period. Day-to-day cooperation and dialogue with subcontractor personnel also occurs directly on construction sites through constant ongoing contact.

Reference: page 285

To remediate negative impacts on value chain workers, the Group implements a dialogue platform as a channel for raising and resolving concerns and uses standard contractual clauses requiring contractors to confirm familiarity with the Human and Employment Rights Policy, Code of Ethics and Suppliers' Code of Conduct, and where appropriate to submit to audits. Where company activities cause or contribute to adverse impacts, corrective action is taken as part of legal support; where impacts arise from business relationships, companies assist partners in eliminating or minimising them. The 2024 dialogue platform is the main channel for raising concerns, communicated via QR-code posters at sites, with paper submissions accepted in special boxes. Complaint handling follows the Whistleblowing Policy and provides whistleblower protection. The Group lacks formal mechanisms to assess effectiveness. During the reporting period, not a single report was communicated through the platform.

Reference: page 285

In 2024 the Group acted on material impacts by implementing the dialogue platform, using standard contractual clauses requiring confirmation of familiarity with key policies and audits where warranted, ensuring subcontractors benefit from health and safety training and participate in site OH&S campaigns, and updating the Diversity Management Policy. Key targets for the entire value chain are defined in the ESG Strategy with a 2029 horizon: implementation of the Suppliers' Code of Conduct across all companies, 100% of key suppliers, subcontractors and partners analysed against social and environmental criteria, 70% audited against working conditions criteria, plus zero severe and fatal accidents on sites and training 95% of management in discrimination prevention. Phased supplier analysis runs from 20% in 2025 to 70% by 2028-2029. With no whistleblower reports, no corrective actions were needed in 2024. Initiatives included Safety Week and diversity training. Own resources are used.

Reference: page 288

Targets to counter negative impacts and enhance positive impacts on value chain workers are set in the updated 2024 ESG strategy, are all relative and refer to a 2029 time horizon, covering the entire organisation including foreign companies. Targets include implementing the Suppliers' Code of Conduct across all Group companies, having 100% of key suppliers, subcontractors and partners analysed against social and environmental criteria and 70% audited against working conditions criteria, phased from 20% of suppliers with orders over PLN 20 million in 2025 to 70% with orders over PLN 1 million in 2028-2029. The OH&S target is zero severe and fatal accidents on sites, with a 2023 base year of 3 severe accidents and 1 fatality. The diversity target is training 95% of lower and senior management in discrimination prevention. Value chain workers were involved via a survey. Due to the 2024 strategy revision, monitoring of new targets was not possible during the reporting period.

Reference: page 291

In 2024 the ERBUD Group did not have a stand-alone policy on affected communities, but these issues were directly addressed by the organisation's Human Rights Policy for Downstream and Upstream Value Chains and Stakeholder Relations. This document commits the Group to conducting business with respect for the rights and dignity of all people, including local communities, in line with applicable national and international laws and international human rights guidelines. The Group engages in ongoing cooperation and dialogue with local communities, including a dedicated communication channel allowing members to raise concerns, needs, comments and violations so that effective corrective action can be taken when human rights violations are reported. In line with its ESG strategy the Group is developing a Community Relationship Policy plus best practices, standards and guidelines, to be implemented across the Group by the end of 2026. In 2024 no cases of non-compliance with the UN Guiding Principles, ILO Declaration or OECD Guidelines were reported.

Reference: page 292

The ERBUD Group's primary means of engaging with affected communities is a dedicated communication channel provided for raising concerns, questions and issues about the organisation's impacts. Actions taken and planned to minimise negative impacts are based on the views of affected communities. Members of local communities contact ERBUD Group representatives directly, and cooperation is ad hoc, initiated by a resident or residents reporting a need. In 2024 a dedicated function within the unit was not defined; the supervisors of individual investments are responsible for relations with local communities.

Reference: page 292

Corrective measures for significant negative impacts on affected communities are tailored individually to the situation, scale and type; the Group has not implemented mechanisms to assess their effectiveness. A dedicated online platform reports community concerns and needs (the Group has two whistleblowing platforms, one for ONDE and one for other companies), publicised on site fences, in offices, on the website and ESG service, with the Site Manager's phone number posted on outdoor notice boards. The channel is easily accessible, simple, intuitive and available in up to three languages in multicultural environments, with monitoring, designated coordinators and a defined standard response time. All reports are analysed through thorough impartial internal investigation, with feedback provided to the whistleblower within two weeks covering investigation results, confirmation, and follow-up actions. Whistleblower identity is protected, with ERBUD S.A. as data controller. In 2024 the Group did not assess community awareness or confidence in the channels.

Reference: page 293

Actions to minimise negative impacts on affected communities in 2024 stemmed from environmental protection procedures across the Group: proper handling of hazardous substances and waste to prevent soil, water and air contamination, equipping sites storing hazardous substances with special tools to minimise accident effects, keeping adjacent public roads clean via washing and vehicle washing areas, carrying out particularly noisy work outside evening hours, reducing dust by limiting vehicle speed and spraying dusty surfaces, and protecting trees, shrubs and amphibian and bird habitats. These relate to the Group's own activities across all geographies, are ongoing and indefinite, and financed from own resources. In 2024 the Group did not undertake additional initiatives for positive impacts and did not track effectiveness. Land-use, land acquisition and operation issues relate to ONDE (wind turbines), which consults municipal authorities and holds community consultations. No serious human rights issues or incidents were reported in 2024. The ESG department and project/construction teams are responsible.

Reference: page 294

The ERBUD Group's strategic objective for reducing negative impacts on affected communities is to cover 100% of its own investments by the community relations procedure. The Group considers any investment may negatively affect local communities, so the process applies to all Group developments regardless of type or location. The target is described in the Group's ESG strategy, planned for achievement in 2026. The base year is 2023 and the baseline was 0%, due to ongoing work to prepare the methodology. No stakeholders were involved in target development; the Group relied on its own experience, publicly available market knowledge and analysis of submissions. No changes were made to the objectives or associated metrics. In 2024, in line with the ESG strategy timetable, the Group began developing a community relations procedure, reviewed existing activities and started developing best practices, standards and guidelines. The Group did not work directly with affected communities or their representatives in setting the target.

Reference: page 296

The ERBUD Group's management of material sustainability issues rests on the Code of Ethics (corporate culture), the Regulations and Whistleblowing Procedure (whistleblower protection) and the Anti-Corruption Policy. Corporate culture is developed partly informally (performance assessments, meetings) and formally (training and onboarding). The Code of Ethics sets principles on human and employee rights, employee relations, diversity, sponsorship, fair competition, business partner relations, environmental protection and safety, applying to all employees, civil-law collaborators, value chain workers and business partners in all locations. It is published online and mandatory reading. The Compliance Officer oversees the Code, procedures and ethics training. Violations can be reported confidentially via dedicated email, mail or directly to the Compliance Officer, with an internal Investigation Committee set up per case. Whistleblowers receive full protection: confidentiality, prohibition of retaliation and minimised information access. A Benefit Register records benefits over PLN 200.

Reference: page 298

In 2024 the ERBUD Group was updating its Integrated Management Systems with supplier relationship management guidelines, effective 1 January 2025, under which suppliers will be verified at several stages including sustainability requirements during pre-qualification. The Suppliers' Code of Conduct, implemented across all Group companies, sets standards on human rights, labour rights, environmental issues and business integrity, prohibiting child and forced labour and requiring safe, discrimination-free workplaces. The Compliance Officer is responsible for implementation. The Group identifies and assesses supply chain risks, implements preventive measures with deadlines and responsible persons, and audits its largest suppliers. Risk management techniques include the uniform Suppliers' Code of Conduct, Supplier Charters, ESG clauses in contracts and supplier diversification. In 2024 the Group lacked a consistent mechanism for considering social and environmental criteria in supplier selection, targeting 100% of suppliers analysed by 2029. The Group did not have formal policies in place in 2024 to prevent late payments.

Reference: page 299

The ERBUD Group's corruption prevention and detection system is based on the Anti-Corruption Policy, which defines corruption and bribery broadly (including influence peddling, managerial bribery and tender rigging) and prohibits any involvement, communicating zero tolerance. It covers employees, value chain workers and all business partners in all locations and references the OECD Anti-Bribery Convention, UN Convention Against Corruption and the Council of Europe Criminal Law Convention on Corruption. Functions most at risk include commercial and Central Purchasing decision-makers, Branch Directors, subsidiary Management Boards and Project Managers. The public policy is translated into English and German, published online and reinforced via posters and induction meetings. New staff confirm awareness, and the Group regularly runs anti-corruption training for all employees, launching a training platform in 2024. Subcontractors must accept the policy. The training table shows 258 functions exposed to risk (145 trained), 11 in management/supervisory bodies (5 trained) and 2,899 other workforce (1,191 trained), all online, one hour, once a year.

Reference: page 301

Information on confirmed incidents of corruption or bribery during the reporting period. The number of convictions for the violation of anti-corruption and anti-bribery laws was 0. The amount of fines for the violation of anti-corruption and anti-bribery laws was 0. The ERBUD Group therefore reported no confirmed incidents of corruption or bribery, no convictions and no fines for the 2024 reporting period.

Reference: page 301

In its payment practices the ERBUD Group adheres to the contractual provisions in individual supplier contracts and has no special payment terms for certain supplier categories. The average time taken to pay an invoice, from the start of the contractual or legal payment term, is 22 days. The Group systematically complies with agreed terms, paying invoices due in a given week on Monday. In Poland the most common term is 30 days (69% paid on time), with 14-day terms 75% on time, 21-day terms 85%, and 7-day terms 60% (more late payments). In Germany standard terms are 10-14 days with a 2-3% discount or 30-45 days net, with 99% of liabilities settled within this timeframe; a separate 14-21 day model with a 2% discount has 70% timely payment. The methodology is based on actual payment dates versus issue dates from the internal accounting system. The number of pending litigation cases for late payment is 0.