Fastighets AB Balder

The role of the administrative, management and supervisory bodies

Reference: pages 47, 94.

Balder's Board of Directors consists of five non-executive members and one executive member (the CEO). The Board is 67% independent and 33% non-independent (p.47), and its composition and diversity are presented on page 94 (2 of 6 women in 2025, up from 1 of 5).

Allocation of responsibility (p.47): the Board of Directors is ultimately responsible for the company being managed in the interests of the company and its shareholders, including "guaranteeing long-term work on sustainability." The Board revises and adopts Group-wide policies, including sustainability targets, every year. Balder's Head of Sustainability presents the Board with sustainability information quarterly, usually alongside regular board meetings.

Since 2023, Anders Wennergren, a Board member since 2009, has held special responsibility for ESG-related matters, holding quarterly meetings with the Head of Sustainability. Group Management (100% executive managers) is responsible for running the business sustainably, with day-to-day delegation to the Head of Sustainability. The CFO is responsible for the Sustainability Department and exercises operational supervision over target-setting.

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

Reference: page 47.

Balder's Head of Sustainability presents the Board of Directors with information about the company's sustainability work on a quarterly basis, usually in connection with regular board meetings, covering ongoing projects, upcoming legislative changes, trends in defined targets, outcomes and the Sustainability Report itself.

During the financial year, the Board addressed sustainability topics identified in the double materiality analysis, including (p.47): ensuring CSRD/ESRS compliance; alignment with the EU Taxonomy; updating Group-wide policies; introduction of a Risk and Crisis Committee; climate risk analyses; the EU Energy Performance of Buildings Directive (EPBD); general examination of the sustainability report; green and social financing; environmental certification of buildings; and ESG ratings.

Significant deviations and actions linked to the Sustainability Policy and Code of Conduct are reported to the Board whenever they occur. Anders Wennergren, with special Board responsibility for ESG, holds quarterly meetings with the Head of Sustainability.

Integration of sustainability-related performance in incentive schemes

Reference: page 47.

"Balder does not pay any variable remuneration, and there are consequently no financial incentive schemes linked to sustainability-related targets or other key ratios."

This is a complete, nil disclosure: remuneration at Balder is fixed only, so there is no mechanism by which sustainability performance could affect variable pay for the Board, Group Management or employees. The statement appears directly in the Governance section of ESRS 2, immediately after the description of the Board's ESG oversight arrangements (p.47).

Statement on due diligence

Reference: page 48 (Declaration of due diligence table).

Balder maps the core elements of due diligence to the disclosure requirements that carry the relevant information, in a table headed "Reference to disclosure requirements" (p.48):

• a) Embedding due diligence in governance, strategy and business model – GOV-1-2, SBM-3
• b) Engaging with affected stakeholders in all main stages of due diligence – GOV-2, IRO-1, SBM-2-3
• c) Identifying and assessing negative impacts – IRO-1, SBM-3
• d) Taking action to address negative impacts – MDR-A, and the topical Actions disclosures (E1-3, E3-2, E5-2, S1-3/4, S2-3/4, S4-3/4)
• e) Tracking the effectiveness of these efforts and communicating this – MDR-T, and the topical tracking disclosures (E1-5/6, E3-4, E5-5, S1-6-11/13-17, S2-5, S4-5)

Balder uses the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights as the review basis for due diligence, including when monitoring the EU Taxonomy minimum safeguards.

Risk management and internal controls over sustainability reporting

Reference: pages 47-48.

The Board of Directors is ultimately responsible for setting up systems for risk management and internal control, and has delegated ongoing work to management. Risk assessment uses the ESRS-defined time horizons: short, medium and long term.

The Group function coordinates risk management and internal control over sustainability reporting through a standardised, Group-wide reporting system. "As the absence of automation means that the majority of all reported data is collected or processed manually, this is deemed to be the greatest risk of error." Mitigation takes the form of quality review by the Sustainability Department, including control calculations and random checks, with deviations or fluctuations followed up and documented year on year.

Data collection on the EU Taxonomy, climate risk analyses and energy performance certificates takes place separately, supported by the financial system and other internal functions.

Strategy, business model and value chain

Reference: page 49; incorporated by reference to the Report of the Board of Directors, pages 33-36.

Balder's business concept is "to create value by acquiring, developing and managing residential properties and commercial properties." At 31 December 2025 the Group had 1,151 employees (1,058), operating in six countries: Sweden, Denmark, Finland, Norway, Germany and the UK, through regions of Helsinki, Gothenburg, Stockholm, Copenhagen, East, North and South.

Balder divides its value chain into upstream (materials, products and services for construction and renovation), own operations (owning, managing and developing properties) and downstream (climate emissions, waste, social area development from tenants' use of the properties). Upstream also covers workers at Balder and in the value chain and business conduct; downstream covers carbon emissions and social area development (p.49).

The company is listed on Nasdaq Stockholm, Large Cap segment. Fastighets AB Balder is the Parent Company of a large number of limited liability and limited partnership companies (Report of the Board of Directors, p.33).

Interests and views of stakeholders

Reference: page 50.

Balder's main stakeholder groups are customers, employees, owners and financial actors, business partners in the supply chain, and society (including government agencies, municipalities and the Tenants' Association). Dialogue channels and frequency vary by group: for example customer surveys run on an ongoing basis and through several annual surveys, while investor/analyst dialogue runs once or twice a year depending on need.

Material topics differ by stakeholder group (p.50): employees raise working conditions and diversity; owners and financial actors raise financial stability, risk management and new sustainability requirements such as the EU Taxonomy; partnerships raise responsible business relationships and fair competition in procurement; society raises long-term urban development and social engagement; customers raise well-being, safety and sustainable choices such as waste sorting.

Stakeholder perspectives are analysed and taken into account in the double materiality analysis that underpins targets, policies and this report. See pages 87, 96, 98 and 100 for the topic-specific stakeholder dialogues.

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

Reference: pages 51-56.

Balder updated its double materiality analysis (first prepared 2023) during 2025; the outcome was accepted by management and the Board in October 2025. The analysis identified 13 material impact/risk/opportunity rows across E1, E3, E5, S1, S2, S4 and G1 (pp.54-56): two E1 potential risks, two E1 actual negative impacts, one E1 potential opportunity, one E3 actual negative impact (water), one E5 actual negative impact (waste), two S1 and two S2 potential negative impacts (working conditions; equal treatment), one S4 actual negative impact (data security), one S4 actual positive impact (social area development), and one G1 negative impact/risk (corruption and bribery).

Changes versus the prior assessment (p.53-54): environmental certification was added as an E1 opportunity; E4 Biodiversity was phased out on reduced new-production volume; S3 Affected communities was replaced by S4, absorbing prior S3 content plus the data-security impact.

"Balder did not conduct an evaluation for this year of current short-term financial impacts of the material risks and opportunities" (p.51) – SBM-3 paragraph 48(d)-(e) is explicitly phased in (p.46).

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

Reference: pages 51-53.

The 2025 update followed four phases (p.52): (1) value chain and stakeholder analysis; (2) identification of material sustainability topics against those defined in ESRS; (3) assessment of materiality; (4) summary of material topics. Balder used an assessment-based method "in accordance with ESRS and using EFRAG guidelines," covering own operations in all markets plus upstream/downstream, including associated companies and joint ventures where Balder has financial control.

Impact materiality = severity (max of scale, scope, remediability for negative impacts) × likelihood, five-point scale. Financial materiality = scope (profit, total assets, reputational spillover) × likelihood, using financial-accounting materiality figures. Three threshold levels (high/medium/low) determine prioritisation.

Non-material topics: E2 Pollution and E4 Biodiversity were explicitly analysed and found not material: "the company's operations do not cause any significant emissions or impact on biodiversity and do not take place in or in the proximity of protected or ecologically sensitive areas" (p.52-53). Political involvement was also assessed and found not material (p.53).

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

Reference: page 53; Appendix, pages 105-108 ("ESRS Disclosure Requirements" and "Disclosures originating from other legislation").

Balder's Appendix provides a content index of the disclosure requirements it treats as material, with page references, covering ESRS 2 (GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and the topical standards E1, E3, E5, S1, S2, S4 and G1 (pp.105-108). A second table maps datapoints required by other legislation (CSRD Article 8, EU Climate Law, Pillar 3, Benchmark Regulation) to a page or "Not material", covering fossil-fuel/chemical/weapons/tobacco involvement, E1-7 removals/credits, E1-9 physical-risk benchmark items, E2-4 pollutants, and several E3/E4/E5 sub-datapoints (pp.106-108).

A "Phasing-in" table (p.46) lists disclosures using the ESRS "quick-fix" extended phase-in: SBM-3 48(d)-(e), E1-9, S1-7, S1-14 and S1-15. An "Incorporation by reference" table (p.46) points SBM-1 to the Report of the Board of Directors and S1-6 to Note 4.

E2, E4 and S3 carry no material disclosure requirements this year (see IRO-1).

Transition plan for climate change mitigation

Reference: pages 65-66.

Balder's climate roadmap follows the Paris Agreement, targeting to halve emissions by 2030 and achieve net zero emissions by 2045, approved by the Board and Group Management in 2024. It uses the location-based method, broken down to company level, and "takes into account organic annual growth in respect of the total lettable area." Actions are prioritised reduction/reuse, then substitution, then passive actions, across construction and materials, energy, and other actions (travel, waste, investments, vehicles).

"With the current structure of the climate roadmap, the company will not achieve the climate target for 2045 unless the market changes with more climate-smart alternatives in the field of construction" – largely because some actions cannot scale before 2030, though this is "not considered to be due to locked-in emissions" (p.66).

Funding: no investment figures are quantified yet, and the roadmap is "not at present linked to the key ratios or activities" of the EU Taxonomy. Balder has no fossil-fuel CapEx, is not excluded from the EU Paris-aligned benchmarks, and its targets were SBTi-validated in February 2024 as 1.5°C-aligned.

Identification of climate-related risks and scenario analysis

Back-filled from Balder's own E1 Climate change adaptation section (pages 63-64), where scenario and resilience analysis is disclosed directly. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Balder updated its scenario and resilience analysis in autumn 2025, building on prior TCFD reporting. Physical risk uses RCP 2.6 (low-emission, Paris-aligned, emissions negative by 2100) and RCP 8.5 (high-emission, "just over three times higher in 2100 than current emissions"); the same two scenarios frame transition risk (p.63).

Time horizons match the double materiality analysis (1 / up to 5 / over 5 years), extending to 2100 with 2050 as a touchdown point, "as properties have long life times" (p.63).

Physical risks screened: flooding (rainfall, watercourses, sea level), heat, landslides/rockfalls, erosion, forest fire; vulnerability assessed for 18% of properties, with Sweden, Denmark, Finland and Norway covered (UK/Germany, a small share of assets, not yet analysed) (p.64). Transition risks centre on tightening energy legislation, materials-price risk and customer expectations. "The scenarios chosen include inherent uncertainties... Global events, such as conflicts and loss of biodiversity, are not included" (p.63).

Resilience in relation to climate change

Back-filled from Balder's own E1 Climate change adaptation section (pages 63-64), where the resilience analysis is disclosed directly. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Unlike a Group-wide resilience analysis of strategy and business model, which has not been conducted, Balder has performed a resilience analysis specific to ESRS E1 climate change (p.52, 63-64): "a qualitative desktop analysis of the company's current business model, portfolio of policy documents, financing opportunities and outcome of historical sustainability data," using the same RCP 2.6/RCP 8.5 scenarios and time horizons as the DMA.

"Based on the risks and opportunities identified, the company is deemed to have relatively good resilience" (p.64): low reliance on purchased fossil energy; growing self-generated renewable energy; an SBTi-validated net zero target reviewed annually; and a geographically/functionally diversified portfolio spreading risk. Action costs are not quantified; smaller actions come first.

Balder follows the TCFD recommendations, mapping governance, strategy, risk-management and metrics disclosures against them with page references (p.64).

Policies related to climate change mitigation and adaptation

Reference: pages 48, 65, 71.

Climate work is governed by the Group-wide Sustainability Policy, which "clarifies the work and targets regarding climate change mitigation," referencing science-based targets and other emission-reduction-linked targets: phasing out fossil fuels, prioritising renewable sources for energy and transport, achieving environmental certification, and creating conditions for fossil-free transport for customers and employees (p.65). The policy also sets Balder's main climate-adaptation target – to conduct climate risk analyses for the property portfolio (p.60-61) – and its energy targets: prioritising renewable electricity/heating sources, annual energy-use reduction, and increasing renewable-energy production and environmentally certified buildings (p.71).

Two further Group-wide policies apply: the Code of Conduct for Business Partners, which expects partners to "continuously improve their environmental work" including phasing out fossil fuels; and the Transport and Travel Policy, which sets the order of priority for business-travel modes to reduce emissions (p.65). All policies are reviewed annually and adopted by the Board of Directors, and cover all subsidiaries and all tenants, residential and commercial.

Actions and resources in relation to climate change policies

Reference: pages 60-61 (adaptation), 66-67 (mitigation), 71-72 (energy).

Balder has no Group-wide climate action plan and so no significant identified CapEx/OpEx; actions are funded within ongoing operations and vary by country and property.

Adaptation (p.60-61): climate risk analyses via the EU Taxonomy's three-step method (screening, vulnerability, action plan – implementation within five years, first complete by end-2027); climate adaptation in property management (drains, check valves, inspections); ecosystem-service actions (green roofs, cultivation spaces, meadow pilots in Finland's SATO Oy).

Mitigation (p.66-67): company-level climate roadmaps; phasing out fossil heating (target: 0 by 2030); green annexes in commercial leases (697, up from 477); sustainable transport, including 3,985 EV charging points (31.5 MW), up from 3,358 (22.2 MW).

Energy (p.71-72): efficiency retrofits (e.g. Grytan 4/9, Malmö: 110 to 66 kWh/sq.m. since 2019); energy-performance-certificate mapping since 2023; renewable-source transition, including five wind farms; environmental certification of all new production.

Targets related to climate change mitigation and adaptation

Reference: pages 61 (adaptation target), 66-67 (emission targets), 72-73 (energy/certification targets).

Emission target: halve Scope 1 and 2 emissions by 2030 against a 2022 base year, cut Scope 3 by 55% per sq.m. by 2030, and reach net zero across Scope 1, 2 and 3 by 2045 (90% reduction, remaining 10% neutralised). SBTi-validated as 1.5°C-aligned; no sectoral decarbonisation pathway used; Scope 2 tracked on a location-based basis (p.66-67).

Adaptation target: quantitative, relative, entity-specific, no base year – conduct climate risk analyses across the portfolio (p.61); outcome: 44% (37%) of 2,023 properties screened, 357 (283) vulnerability-assessed, 338 (269) with a preliminary action plan (p.62).

Energy targets: 2% per sq.m./year efficiency improvement (6% decrease achieved in 2025, including on a degree-day-corrected basis reported for the first time); increasing renewable production and certified-portfolio share (7% in 2025, up from a corrected 8% 2024 base) (pp.72-73). All 2025 new production (4 buildings, LEED Platinum in Finland) was certified.

Energy consumption and mix

Reference: page 72.

Energy mix (2025): total energy and fuel 628,228 MWh, of which 81% renewable (509,894 MWh), 1% nuclear (8,269 MWh) and 18% fossil (110,064 MWh, of which 96% purchased fossil energy). Fossil fuel breaks down as 59% oil and 41% natural gas, with no coal.

Purchased energy consumption (2025): 616,802 MWh total, of which 496,877 MWh (81%) renewable – 178,567 MWh electricity (92% renewable), 427,877 MWh heating (75% renewable) and 10,358 MWh cooling (100% renewable).

Intensity: 92 kWh/sq.m. (98 in 2024) and 0.04 kWh/SEK of net revenue (0.05 in 2024).

Balder operates in the construction and real estate high-climate-impact sectors, though all reported energy relates to the real estate sector as the company's own operations. Self-generated renewable energy production in 2025 came from 5 wind farms (15,757 MWh, down from 16,719 due to natural conditions) and solar panels (installed capacity 5 MW, 4,534 MWh produced, up from a corrected 3 MW/2,621 MWh in 2024) (p.73).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 67-69.

2025 emissions (tonnes CO2e), location-based method, vs restated 2024 and 2022 base year:

• Scope 1: 1,289 (2024: 1,231; base 2022: 1,484) – own heating, own vehicles, refrigerant leakage
• Scope 2 (location-based): 36,426 (2024: 42,775; base: 58,601)
• Scope 2 (market-based): 30,045 (2024: 33,790; base: 77,037) – c.97% of purchased-electricity Scope 2 emissions are covered by guarantees of origin
• Scope 3: 78,597 (2024: 138,456, restated; base: 176,357) – driven down by lower new-production/refurbishment activity (Category 2) and improved tenant-energy data (Category 13)
• Total, location-based: 116,311 tCO2e, down 36% year on year and 51% against the 2022 base
• Total, market-based: 109,930 tCO2e, down 37% year on year and 57% against the base

Intensity per net revenue fell 41% to 0.008 kg CO2e/SEK (location- and market-based). Scope 3 is calculated using supplier-specific, hybrid, spend or average methods depending on category, per the Swedish Property Federation's recommendations; no Scope 3 category is currently calculated using only primary data. Categories 9 (downstream transport), 10 (processing of sold product) and 14 (franchises) are excluded as not relevant to a property owner. Biogenic emissions totalled 134,751 tCO2e in 2025 (2024: 129,404, restated). Balder received its first CDP climate rating of C for FY2025.

Policies related to water and marine resources

Reference: pages 48, 75.

Water is governed by the Group-wide Sustainability Policy, which is "primarily aimed at reducing the water consumption in its own operations regarding property management" and sets the target to reduce water consumption by 2% per square metre and year (p.75). The policy also links water indirectly to the company's targets for environmentally certified buildings and more resource-efficient materials.

Marine resources have been assessed and found not material, "including in the upstream and downstream value chain, as these are not used by the company to any significant extent." Balder is not considered to operate in areas of high or extremely high water stress, based on an annual assessment against World Resources Institute (WRI) data, and consequently "has not undertaken any consultation" on water stress specifically (p.75).

Actions and resources related to water and marine resources

Reference: page 75.

Balder has no Group-wide water action plan and so no significant identified operating or capital expenditure for water; expenditure is integrated into ongoing operations and actions vary by country and property (p.75).

Smart metering and monitoring of water use: constant-flow valves on mixer taps and shower heads, proactive leak-risk mapping, and continued digitalisation and connection of water meters for better monitoring; individual cold/hot water metering is being installed in all new buildings and rolled out to the existing portfolio.

Support for tenants in reducing water consumption: in Sweden and Denmark, installing water-saving fittings (toilets, washing machines, dishwashers, shower heads) in new or renovated buildings, alongside efforts to change tenant habits and behaviour.

Targets related to water and marine resources

Reference: pages 75-76.

Balder has a quantitative, relative, ongoing, entity-specific target to reduce water consumption by 2% per square metre and year, which is "neither science-based nor linked to external regulations or EU directives," and applies across the consolidated Group to own operations and downstream in the value chain.

Outcome 2025: a 2% decrease, in line with the target (2024, restated: an 11% decrease, corrected from a previously reported 5%). Total water consumption per square metre fell to 0.84 m³/sq.m. (0.86) and per unit of net revenue to 0.00041 (0.00042).

During 2025, 0 m³ of water was recycled, reused or held in storage: "Water reuse, recycling, and storage are not part of Balder's operations as a property owner and manager. Consequently, the company has not considered it necessary to establish specific processes for measuring these flows" (p.75).

Water consumption

Reference: pages 75-76.

Total water consumption in 2025: 5,610,489 m³, up from a restated 5,136,075 m³ in 2024 (originally reported as 5,848,620 m³; corrected due to reporting errors). The increase reflects an expanded property portfolio and the first-time inclusion of an additional Norwegian subsidiary in the 2025 statistics.

Intensity fell to 0.84 m³/sq.m. (0.86 restated) and 0.00041 m³ per SEK of net revenue (0.00042 restated), a 2% per-square-metre reduction consistent with the sustainability target.

Data comes from remote and manual meter readings; where a tenant or property association is directly responsible for utility costs, that water use is excluded from Balder's reported figures, and estimates are used where invoice data is unavailable. One smaller subsidiary reports on a broken financial year (December 2024–November 2025). From 2025 onward, all subsidiaries are included in water-use reporting "due to improved data availability" (p.76).

Policies related to resource use and circular economy

Reference: pages 48, 77.

Under the Group-wide Sustainability Policy, Balder "shall strive to raise awareness and to encourage and make it easier for tenants to make sustainable choices," working to reduce waste volumes, increase sorting rates and promote reuse of materials. The policy does not specifically address sustainable procurement or renewable-resource use, but the report states resource efficiency and reduced waste are "key elements of the company's overarching strategy for reuse and circular economy" (p.77).

The Code of Conduct for Employees commits every employee to help reduce environmental impact and improve tenants' opportunities to sort waste; the Code of Conduct for Business Partners requires business partners to "reduce their environmental impact and climate emissions, and contribute to improving waste recycling." All policies cover every subsidiary and tenant, residential and commercial (p.77).

Actions and resources related to resource use and circular economy

Reference: pages 77-78.

Balder has no Group-wide waste action plan and so no significant identified operating or capital expenditure; actions are country- or property-specific and funded within ongoing operations (p.78).

Environmental certification of buildings: all new production certified to at least Miljöbyggnad Silver, BREEAM Very Good, LEED Gold, DGNB Silver or the Nordic Swan Ecolabel – schemes that specify waste-management space requirements aligned with sorting-at-source and municipal recycling rules.

Green annexes in leases: supplementary commercial-lease agreements under which tenants commit to reduce waste, increase sorting and promote reuse; 697 green annexes were in place in 2025 (477 in 2024), used in Sweden and Norway.

Clear information and well-maintained waste rooms: keeping recycling stations "clean, bright and safe," with sorting requirements adapted to national/local rules and responsibility resting with local property management.

Targets related to resource use and circular economy

Reference: page 78.

Balder's Group-wide target is relative, ongoing and entity-specific: "to reduce waste volumes, increase sorting at source and strive to increase reuse of materials," addressing several steps in the waste hierarchy (minimisation, preparation for reuse, material recovery).

"Balder has not adopted a measurable, outcome-based target in accordance with ESRS linked to resource use, and is not at present following up on the appropriateness of policies and actions." The company instead follows up indirectly via the metrics for environmentally certified buildings and green lease annexes (pp.73, 77) and via Scope 3 Category 5 (waste management in own operations) and Category 12 (waste management of sold product) in the climate accounts (p.69). "Balder does not at present have a Group-wide structure for data collection of tenants' waste volumes, and follow-up therefore only takes place at a local level" – the company states it "has therefore chosen to phase-in collection of data in the value chain, and does not report outcomes on tenants' waste volumes" (p.78). A Group-level method is planned for the future.

Resource outflows related to products and services

Reference: pages 77-78.

Balder's most material resource-and-waste impact "is deemed to arise downstream through waste generated by tenants," from both residential properties (household waste) and commercial properties (restaurants, hotels, shopping centres, shops, industrial operations) (p.77). Downstream waste "causes climate emissions in connection with waste management, inefficient resource use when waste is not recycled or reused, and a risk of pollution if the waste is not sorted or managed correctly" (p.77).

The company's Group-wide response is to make sorting, reuse and recycling easier for tenants – through environmental certification requirements, green-lease annexes and well-maintained, clearly signed waste rooms (p.77) – rather than through data collection on outflow volumes; see E5-5-Waste and E5-3 for the phase-in of quantitative waste-volume reporting. Waste is also captured indirectly within the climate accounts as Scope 3 Category 5 (waste management in own operations) and Category 12 (waste management of sold product) (p.69).

Policies related to own workforce

Reference: page 48; page 87.

Balder's work on its own workforce is governed by Group-wide policies: the Work Environment Policy (safe, sustainable work environment supporting employees' professional and personal development), the Health and Safety Policy (preventing and mitigating actual and potential negative impacts on working conditions, with each Group company responsible for annual action planning), and the Equality and Diversity Policy (equal treatment, opportunities and dignity, no discrimination on grounds of gender, gender identity, ethnicity, religion, disability, sexual orientation or age).

The Code of Conduct for Employees requires every employee to help create a "good, healthy work environment," prohibits all discrimination and harassment, and states that the company "distances itself from all forms of forced labour, child labour and human trafficking" (p.87). Balder states it does not operate where it faces a material risk of forced or child labour, given the nature of its activities and the countries in which it operates (Sweden, Denmark, Finland, Norway).

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

Reference: pages 50, 87, 90.

Dialogue with employees runs through direct channels (regular employee performance and career-development reviews) and representative channels (safety representatives, and trade union representatives where collective bargaining agreements exist) (p.87). Employee surveys are conducted across many Group subsidiaries; the 2025 response rate was 91%, with Employee Net Promoter Scores of 53 (Balder Sweden), 64 (SATO, Finland) and 34 (Balder Denmark), against a Swedish real estate sector average of -1.

Workplace representation: 80-100% coverage across Sweden, Denmark, Finland and Norway, with Norway newly reaching this range in 2025 after appointing worker representatives; there are no European Works Council, SE or SCE Works Council agreements (p.90). The HR Manager in each subsidiary owns the employee-survey process; operational responsibility sits with each line manager. DMA insights and the results of engagement inform the identification and prevention of negative impacts on working conditions and equal treatment (p.51).

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

Reference: page 87.

All employees have access to Balder's whistleblowing function, where concerns can be raised anonymously; Balder in Sweden included specific questions on trust and awareness of this channel in its 2025 employee survey. When the company is deemed to have caused or contributed to a negative impact, corrective action and, where necessary, remediation follows established routines: "Corrective actions can include adjustments to working conditions, the work environment or internal processes, while remediation can take the form of financial compensation, for example, or access to support measures, in accordance with applicable legislation and internal guidelines" (p.87).

The HR Manager in each subsidiary is ultimately responsible for the employee-survey channel, with day-to-day responsibility delegated to line managers. Full policies, routines and outcomes for whistleblowing are described under G1 Business ethics (pp.102-104).

Taking action on material impacts on own workforce

Reference: pages 88-89 (working conditions), 92-94 (equal treatment).

Actions on working conditions vary by subsidiary but are grounded in national legal minimums, supplemented by Group policy (p.88): safe employment and working conditions (freedom of association and collective bargaining protected; 40% of the Group covered by collective bargaining agreements; social protection against illness, unemployment, occupational injury, disability, parental leave and pension for all employees); sustainable working life (flexible/hybrid working where locally feasible, statutory vacation and family leave, exit questionnaires in some subsidiaries); and work environment, health and safety (regular H&S training in higher-risk roles, occupational health and safety systems covering 100% of employees, digital wellness/healthcare access in some subsidiaries).

Actions on equal treatment (p.92-93) include training and skills development via the Balder Academy digital platform; regular pay reviews in Balder Sweden and one Finnish subsidiary, plus a new pay follow-up system in Denmark during 2025; and diversity/anti-discrimination measures such as standardised, competence-based recruitment (Balder Sweden) and a dedicated diversity action plan with positive-discrimination provisions in one Finnish subsidiary. Balder has no Group-wide action plan for either topic, so no significant associated CapEx/OpEx is identified.

Targets related to own workforce

Reference: pages 87-88, 93.

"The company currently has no Group-wide target linked to working conditions, but does follow up on the appropriateness of its policies and actions through regular HR and health and safety processes, including employee dialogue, employee surveys, handling of cases via HR and the whistleblowing function, and follow-up within the framework of systematic health and safety work" (p.88) – a tracking-without-a-target approach.

For equal treatment, Balder does have a defined target: "to be a workplace that is free of discrimination and harassment," absolute, ongoing and Group-wide, tracked via the annual count of discrimination incidents brought to the company's attention through the whistleblowing function, HR or line managers (p.93). Outcome 2025: 4 incidents (2024: 0).

Characteristics of the undertaking's employees

Reference: pages 89-90; incorporated by reference to Note 4, Employees and staff costs, pages 122-123.

Total employees at 31/12/2025: 1,151 (1,058 at 31/12/2024) – 700 men, 451 women. By contract type: 1,104 permanent (1,002), 32 temporary (34), 15 non-guaranteed (22); 1,113 full-time (1,023), 38 part-time (35).

By country: Sweden 626 (577), Finland 371 (362), Denmark 125 (95), Norway 29 (24); Balder has no employees outside the EEA. Employee turnover fell to 12% (16%), with 130 people leaving in 2025 (58 women, 72 men) versus 165 in 2024.

Employees exclude those on leave, long-term sick leave or parental leave at year-end, and data is exported and compiled via each subsidiary's HR system. Balder does not report the "Other" or "Not disclosed" gender categories, as it only tracks legal (male/female) gender (p.89-90).

Characteristics of non-employees

Reference: page 90.

Non-employees at 31/12/2025: 84 (75 at 31/12/2024), consisting primarily of consultants and staff hired from placement agencies used to "temporarily replace or supplement the company's existing line roles" (p.90). Data is collected across all subsidiaries from HR systems, employment contracts and invoices, and reported as a headcount.

Partial phase-in: Balder's phase-in table (p.46) lists "Characteristics of non-employees in accordance with paragraph 55(a)" against S1-7 as a disclosure requirement it is phasing in under the ESRS quick-fix provisions, meaning the fuller breakdown (e.g. by employment type or FTE conversion) called for by that paragraph is not yet reported; only the total headcount above is disclosed this year.

Collective bargaining coverage and social dialogue

Reference: page 90.

Collective bargaining coverage: 40% of the Group's employees (39% in 2024), varying by country: 0-19% coverage in Norway and Denmark, 40-59% in Sweden and Finland. The data covers all employees, including Norway, a country of operation with fewer than 50 employees representing under 10% of the Group's total workforce.

Social dialogue / workplace representation reaches 80-100% coverage across all four EEA countries of operation (Sweden, Denmark, Finland, Norway) for countries with over 50 employees representing over 10% of total employees. The majority of employees are represented through safety representatives on work-environment, health and safety matters; employees under collective bargaining agreements are additionally represented by trade union representatives. There are no European Works Council, Societas Europaea (SE) Works Council or Societas Cooperativa Europaea (SCE) Works Council agreements.

Diversity metrics

Reference: page 94.

Board of Directors (31/12/2025): 6 members (5 in 2024), 2 women (33%), 4 men (67%). Group Management: 5 members, 3 women (60%), 2 men (40%). Employees overall: 451 women (39%), 700 men (61%) of 1,151 total.

Age distribution across the Group: under 30 – 181 employees (16%); 30-50 – 673 (58%); over 50 – 248 (22%) (approximate shares from the Group-wide table).

Occupational category: white collar employees make up 76% (74%) of the Group, mainly administrative functions; blue collar employees make up 24% (26%), mainly property managers/caretakers. The Board increased from 5 to 6 members during 2025, with no change to management's composition.

Adequate wages

Reference: page 93.

"Balder ensures that all employees received an adequate wage in line with standard reference wages in the countries where the company operates" (p.93). To prevent and counteract potential wage discrimination, all Balder companies are required to conduct regular pay reviews to identify unexplained pay gaps and correct them; at present these reviews are actively carried out in Balder Sweden and one Finnish subsidiary, with a new pay follow-up system introduced in Denmark during 2025 specifically to detect and reduce unexplained pay-gap deviations. This is a nil/affirmative compliance statement rather than a quantified minimum-wage gap metric.

Social protection

Reference: page 89.

"All employees at Balder are covered by social protection against loss of income due to illness, unemployment, occupational injuries and acquired disability, parental leave and pension. Social protection is offered either through public insurance policies or benefits offered by the company" (p.89) – a complete, affirmative disclosure covering 100% of the workforce across all six risk categories named in the requirement. Other employee benefits described alongside this include wellness allowances, occupational healthcare and, in Balder Sweden, a parental-pay insurance top-up to offset income loss during parental leave.

Training and skills development metrics

Reference: page 93.

Share of employees with a performance/career-development review in 2025: 84% (94% in 2024). Average training hours per employee: 7 (17 in 2024). Training hours are calculated by dividing total completed training hours by the headcount at year-end.

Training is delivered through the Balder Academy digital platform (Sweden, Denmark), covering role-specific onboarding as well as general courses on Group values, policies, IT/cyber security and CPR; Balder Sweden also runs "Roots," an internal rotation programme giving central-function staff hands-on property-management experience to build mutual understanding across roles (p.93).

Health and safety metrics

Reference: page 91.

Employees covered by an occupational health and safety system: 100% (100%). Work-related accidents: 55 (32), a frequency of 26.3 (17.7) per million hours worked. Working days lost: 45 (23). Fatalities: 0 (0). Total sick leave: 3.2% (3.5%), split into short-term (1-14 days, 1.8%) and long-term (≥15 days, 0.9%); some subsidiaries could not report the split, though all reported the total.

"Data reported relates solely to Balder's own employees… During the year, Balder continued its work to collect health and safety-related data for non-employees and workers in the value chain" (p.90) – the reported figures above cover employees only; non-employee and value-chain worker H&S data collection remains in progress (also reflected in the "Characteristics of non-employees" phase-in item against S1-14 in the phasing-in table, p.46). Work-related accidents occur primarily in property management operations.

Compensation metrics (pay gap and total compensation)

Reference: page 94.

Group-wide gender pay gap: 11% (3% in 2024) – men earn 11% more than women on average, widened mainly by the Sjælsø Management acquisition in Denmark (where men hold more senior roles) and a comparable dynamic in Norway; pay levels in Sweden and Finland are broadly comparable between men and women. By country: Sweden 0% (-2%), Denmark 36% (5%), Finland 3% (10%), Norway 47% (56%).

Remuneration ratio (highest-paid individual to median employee total remuneration): 17 (15), ranging from 4-9 within individual countries. Reported pay data excludes variable compensation such as overtime pay, vacation compensation and parental pay, and covers employees active at 31/12/2025 (p.94).

Incidents, complaints and severe human rights impacts

Reference: page 93.

Incidents of discrimination in 2025: 4 (0 in 2024), reported via the whistleblower function and employee surveys and handled under labour law with HR. Reported complaints: 2 (2), none referred to the OECD. Fines, penalties or compensation for discrimination: SEK 0 (0).

"No severe human rights incidents associated with the company's employees were brought to the company's attention during the financial year. This means that no fines, penalties or compensation related to such incidents have been issued" (p.93) – severe human rights incidents: 0 (0), including 0 cases of non-compliance with the UNGP/OECD framework. An incident of discrimination is defined per Swedish legislation (age, gender, gender identity, religion, disability, sexual orientation, ethnic background), extended to include any additional grounds reported by subsidiaries.

Policies related to value chain workers

Reference: pages 48, 95.

The Code of Conduct for Business Partners, produced in 2023, "sets out guidelines that form the basis of collaboration in the supply chain," covering responsible and ethical business relationships, good work environment, human rights and environmental responsibility (p.95). It is based on the UN Global Compact, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights and the ILO Core Conventions.

Business partners must "distance themselves from all forms of human trafficking, child labour and forced labour," safeguard freedom of association, take reasonable steps to avoid human rights violations in the value chain, and improve their own environmental performance. Balder has zero tolerance for corruption in its value chain and can withdraw from a partner relationship where a business partner is unwilling to comply, deviates consciously, or shows no interest in improvement (p.95).

Processes for engaging with value chain workers about impacts

Reference: pages 50, 96.

Balder considers value chain workers' perspectives through dialogue with suppliers, contractors and other business partners who have knowledge of workers' situations and local conditions – contract negotiations, follow-up meetings and procurement processes (p.96). Operational responsibility for ensuring these dialogues inform company decisions rests with the manager responsible for purchasing and procurement.

"The company currently conducts no targeted assessment or structured process for collecting perspectives from these workers in the value chain" directly; assessments instead take place at an overarching level through general supplier follow-up and due diligence (p.95). Particularly vulnerable groups – construction/civil-engineering workers, migrant workers, and workers with temporary or precarious employment – are named as being at higher risk, though no specific geographical region or raw material has been flagged for elevated child- or forced-labour risk (p.95).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 96.

Balder has an external whistleblowing function enabling workers in the value chain to submit anonymous reports of suspected deviations from laws or regulations on working conditions, the environment, business ethics or human rights; Swedish business partners are informed of the function when they sign the Code of Conduct for Business Partners alongside their agreement (p.96).

Where the company has caused or contributed to material negative impacts on human rights or value chain workers, it takes action "with reference to the prevailing circumstances," primarily through requiring corrective action and follow-up dialogue with the affected supplier, contractor or business partner. "Balder has not at present conducted a systematic investigation to assess the extent to which workers in the value chain are familiar with or have confidence in the company's structures or routines linked to whistleblowing" (p.96). Full whistleblowing routines and outcomes are described under G1 (pp.102-104).

Taking action on material impacts on value chain workers

Reference: pages 95-96.

Balder has no Group-wide action plan for value chain workers and so no significant identified CapEx/OpEx; actions instead rest on four focus areas (p.95-96): clear requirements and control (benchmarked major procurements, pre-contract review of tax, ownership, credit and insurance in Sweden, and periodic checks during framework agreements, with fines/termination possible for violations); review of social minimum safeguards (the 2025 EU Taxonomy minimum-safeguards review of all consolidated subsidiaries found the company compliant, with 0 cases of serious human rights violations reported upstream or downstream – pp.80-81); follow-up on suppliers and business partners (the 2023 Code of Conduct for Business Partners, and Norwegian due diligence work under the Transparency Act / Åpenhetsloven); and channels for dialogue and whistleblowing.

"Balder has no formalised process to assess which actions need to be implemented, as the need varies depending on operational activities and local conditions. Some of the actions presented are therefore not currently being measured in terms of metrics" (p.95-96).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 96.

"Balder has not adopted any measurable, outcome-based targets linked to workers in the value chain." Instead, effectiveness is followed up qualitatively – through supplier and contractor dialogues, examination of contractual-term compliance, and handling identified deviations or incidents – with the stated ambition to "identify and address material risks and negative impacts for workers in the value chain." No specific base period is defined for measuring progress (p.96).

Monitored metric: whistleblower cases relating to workers in the value chain reported to the police – 0 in 2025. Broader social-responsibility tracking runs through the minimum-safeguards review (p.96). "Metrics for clear requirements and follow-up on suppliers are currently not in place but will be developed in the future."

Policies related to consumers and end-users

Reference: pages 48, 97, 99.

Local-community and social-area-development work is governed by the Group-wide Sustainability Policy, which sets out how Balder, "as a major property owner, can contribute with a positive local impact and social area development," and the Code of Conduct for Business Partners (p.97).

Information and data security – the other S4 material topic – is governed by the IT Policy (Group-wide security responsibilities, hardware/information handling, online-service use) and the Data Protection Policy for the Handling of Personal Data (GDPR compliance; the Director of Economy is the appointed Data Protection Officer), both applying to employees, customers and suppliers (p.99). All policies are reviewed annually and adopted by the Board of Directors.

Processes for engaging with consumers and end-users about impacts

Reference: pages 50, 98, 100.

For social area development, Balder runs regular customer satisfaction surveys in Sweden, Denmark and Finland covering the whole customer journey – signing, move-in, tenancy and move-out – to identify strengths and improvement areas; customers and the local community can also use customer service or the whistleblowing service (p.98).

For information and data security, customers and stakeholders can raise issues through email or customer service; "there are at present no defined routines for ensuring access to corresponding channels through the company's business relationships" (p.100). Cases are handled within standard customer/case-management routines, and experience is used to keep improving those channels.

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

Reference: pages 99-100.

Customers and stakeholders can report information-and-data-security concerns via the company's contact channels or the external whistleblowing service (available in local languages in every market Balder operates in). Where Balder is deemed to have caused or contributed to a negative impact, "corrective action and, if necessary, remediation is taken as deemed appropriate based on incident management routines" (p.99-100).

An illustrative case: a tenant's data was updated incorrectly in an internal system, misdirecting their contact details; the tenant reported it to customer service, and the IT Department worked with them to resolve it promptly (p.100). "The company has not had any cases of non-compliance with or failure to respect human rights in respect of contact with the company's tenants or other stakeholders downstream."

Taking action on material impacts on consumers and end-users

Reference: pages 97-98 (social area development), 99-100 (data security).

Balder organises its social area development work around five pillars (p.98): (1) Employment – internships, holiday and summer jobs, and collaboration with the charity Mitt Livs Val, including "Future Week" for newly arrived young people in Gothenburg; (2) Education – homework support, forklift/cycling/bee-keeping courses, and the "Handshake for the Future" partnership targeting no particularly vulnerable areas in Gothenburg by 2030; (3) Meaningful leisure time – sponsorship of local sports and youth activities across all four Nordic countries; (4) Safety and well-being – access control, perimeter protection, lighting improvements, safety patrols and Denmark's "Waste Walk" litter-collection initiative; (5) Participation and influence – customer surveys and social housing contracts (3.0% of the Swedish residential portfolio in 2025).

Data security actions (p.99-100): mandatory IT-Policy and GDPR training; 24/7 external monitoring, multi-factor authentication, internal vulnerability analyses and external security audits; and internal incident-management routines escalating to a dedicated incident team where necessary. Balder has no Group-wide action plan for either topic, so no significant CapEx/OpEx is identified.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: pages 98, 100.

Jobs for young people: a quantitative, absolute, ongoing target. Outcome 2025: 594 jobs created (340 in 2024) – 67 summer jobs (78), 527 jobs created through collaboration (262) and 40 internships (28). Customer satisfaction: a qualitative, relative, ongoing NPS target (-100 to +100); Group-wide collection began in 2025 and will be reported externally "in the next few years" (p.98).

Information and data security: "Balder has not adopted any measurable, outcome-based targets"; in 2025 the company "commenced discussions on the formalisation of a target in respect of the number of incidents linked to data protection and the handling of personal data," to be formulated in a future year (p.100). Monitored outcome metrics: 20 identified cases of customer-data leakage/theft/loss (10 in 2024) and 1 substantiated complaint (0 in 2024).

Business conduct policies and corporate culture

Reference: pages 48, 102.

Business conduct is governed by a suite of Group-wide policies: the Sustainability Policy (open, long-term, ethically responsible operations, with targets for zero corruption incidents and full Code of Conduct training); the Code of Conduct for Employees and for Business Partners (responsible internal/external conduct, environmental responsibility, incident reporting); the Whistleblowing Policy (safe, retaliation-free reporting); the Tax Policy (Board-adopted guidelines for responsible tax treatment); the Insider Policy (share-dealing rules going beyond legal minimums); and the Risk and Crisis Management Policy, approved by the Board in February 2025 (p.102-103).

The Code of Conduct for Employees is distributed at onboarding and reinforced through annual training generated for most employees across the Group's consolidated companies. Since founding in 2005, Balder has grown "from being a local real estate company in Sweden to having a diversified property portfolio with more than 2,000 properties in six European countries" (p.102).

Prevention and detection of corruption and bribery

Reference: pages 102-103.

Balder's Group-wide risk assessment in 2025 mapped which departments and roles are most exposed to corruption and bribery risk, identifying functions with significant financial decision-making authority and frequent external contact – above all management and administration, the Finance and Purchasing Department, and the Project and Property Development Department; all employees in exposed departments received anti-corruption, bribery and responsible-conduct training in 2025 (p.103).

Prevention rests on: mandatory Code of Conduct and anti-bribery training (mandatory digital modules in Balder Sweden and SATO, and for the Board and management); requirements flowed down to suppliers and business partners via the Code of Conduct for Business Partners, attached at procurement and contracting; a Risk and Crisis Management Policy (approved February 2025) and a new Risk and Crisis Committee established in 2025 to coordinate Group-wide crisis preparedness; and an external whistleblowing service available in local languages in every market, updated in 2022 to strengthen anonymity protections (p.103).

Targets related to business conduct

Reference: page 104; policy reference page 48.

Balder has adopted two entity-specific targets in support of the Sustainability Policy and Code of Conduct for Employees (p.104): "Balder's objective in respect of corruption is that no incidents of corruption shall occur in the business" – quantitative, absolute and ongoing – and a target that all employees shall be trained in the Code of Conduct – quantitative, relative and ongoing. Both cover every consolidated company and employee in the Group.

Outcome 2025: 0 incidents of corruption (0 in 2024); 0 fines for corruption (0); 82% of employees trained in the Code of Conduct (86% in 2024); 1 whistleblowing case reported to the police (1 in 2024). Progress is followed up internally through Balder's digital sustainability-reporting systems.

Incidents of corruption or bribery

Reference: page 104.

"No incidents of corruption occurred during 2025, and no fines for violations of laws against corruption or bribery were issued." An incident of corruption is defined as a case reported to the police that led to a court conviction, counted by the number of persons involved (p.104).

One whistleblower case led to a police report in 2025, concerning suspicions of bribery received via Balder's external whistleblower service in Sweden. Following an investigation supported by an external agency, a police report was filed and the case was handled under labour law by HR with the affected managers, resulting in two Sweden-based employees leaving the company. (The 2024 case, also reported to police, concerned an employee suspected of exploiting his position for personal gain.) "No cases resulting in a judgement against the company or fine for a violation of laws in respect of corruption or bribery were reported during 2025."