Heba Fastighets AB

The role of the administrative, management and supervisory bodies

Reference: pages 84-86.

Heba is listed on Nasdaq Stockholm (Nordic Midcap) and applies the Swedish Code of Corporate Governance. The board of directors "has ultimate responsibility for Heba's organisation and management" (p.84). In 2024 the board decided on new long-term ESG targets for 2025-2030, including climate-neutral property management by 2030, and it confirmed and adopted them this year (p.84). The board takes decisions on setting and monitoring ESG targets, climate and sustainability risk, green investments and financing, and CSRD and EU Taxonomy reporting (p.84). It also acts as the audit committee (p.86).

The CEO and management lead operational sustainability work. The head of sustainability develops and coordinates the program and monitors key metrics (p.84).

The board has five directors, three women and two men, all five listed as independent, with no employee representation (p.85). The management team has eight members, five women and three men (p.85). Sustainability expertise is kept current through ongoing training and updates, and external advisers are used as needed (p.85).

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

Reference: pages 85, 84.

The board is informed about material impacts, risks and opportunities mainly by the CEO, based on "the company's materiality assessment, risk assessments and target monitoring" (p.85). Heba names climate change ("IRO 1") and governance risks tied to business conduct and regulatory compliance (G1) as the significant areas the board monitors (p.85). Oversight uses key metrics linked to targets, non-conformance management and internal audits under the ISO management systems. The board receives a summary of target outcomes and significant non-conformances, and the CEO decides corrective actions (p.85).

Investment decisions weigh cost, climate impact, business opportunities and long-term value, so the board balances financial and sustainability-related impacts (p.85). Input to the board is based on the DMA and includes updates on legal requirements, risks and regulatory changes, and an annual Sustainability Report is presented together with the Annual Report (p.84).

Integration of sustainability-related performance in incentive schemes

Reference: pages 85, 89, 126.

Heba states that it "does not distribute compensation in the form of incentive schemes (bonuses, profit sharing or performance-based schemes)" to directors, management or employees that is directly linked to specific ESG targets (p.85). The climate chapter repeats this: "Heba has no incentive schemes linked to specific sustainability targets" (p.89). No part of remuneration is therefore tied to climate or other ESG outcomes.

The company does offer a general share savings program to all employees (p.85). Its long-term incentive program LTI 2021 covered all employees from 30 September 2021 to 30 September 2025, and 4,400 shares were delivered to 22 participants in 2025 (p.126). The compensation report is published on the company's website (p.85). In the E1 block of the IRO-2 index, GOV-3 is marked N/A (p.107).

Statement on due diligence

Reference: pages 85-86.

Heba's due diligence table maps each step to where it is covered in the report (p.85):

Due diligence is built into the annual risk process and DMA and is designed "in line with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises" (p.86). Compliance with Heba's Code of Conduct is required of all significant suppliers and business partners (p.86).

Risk management and internal controls over sustainability reporting

Reference: pages 85-86, 83.

Sustainability risks and impacts are "identified and assessed annually as part of Heba's overall risk process and DMA", using a method based on probability and impact (p.86). Sustainability reporting sits inside the ISO 9001/14001 certified management system and follows a "three lines of defence" model: operations collect data and manage risk, the sustainability and finance functions follow up and check quality, and internal and external audits give independent review (p.86). The board has overall responsibility for risk management and internal control of sustainability reporting (p.86).

On data quality, Heba lists its estimates: tenants' electricity consumption (estimated above approx. 55%, reliability medium), energy consumption (less than 10% estimated, high) and waste (approx. 35% estimated, medium) (p.83). Uncertainties and assumptions are reviewed annually within the internal control and quality management process (p.83). Identified shortcomings are tracked and used to develop policies, procedures and training, and are reported regularly to the board (p.86).

Strategy, business model and value chain

Reference: page 86.

Heba develops, owns and manages residential properties "from a long-term perspective" (p.86). It offers rental apartments for young adults, families and the elderly and, to a lesser extent, commercial premises, and it owns a number of elderly care facilities. Operations are concentrated in the Stockholm region (Stockholm, Huddinge, Haninge), with properties also in Enköping, Uppsala, Norrtälje and Nynäshamn (p.86).

The model runs from resources (capital, land, construction projects, energy) through execution (new builds, property management, property development) to residential and commercial units and the social, environmental and economic impacts that follow (p.86). Long-term financial targets run from 2025 to 2030, and the main objective is long-term growth with sustainable profitability, with property management climate neutral by 2030 and the whole organization by 2045 (p.86).

Upstream, the value chain includes banks and the bond market, land, building contractors, materials suppliers and energy companies. Downstream it covers tenants, local communities, investors and bondholders (p.86).

Interests and views of stakeholders

Reference: pages 86-88.

Heba engages tenants, local authorities, industry organizations, investors, lenders, suppliers and national authorities to identify the most material sustainability matters (pp.86, 88). The matters raised as central are energy efficiency, safe and secure homes and neighborhoods, climate adaptation and green financing, along with opportunities from digitalization and AI (p.86).

The company says stakeholder views "have had a direct impact on Heba's DMA" and on its strategy (p.87). Examples it gives: tenants' demand for safe and attractive neighborhoods moved safety and security actions up the property management agenda; the focus of local authorities and industry organizations on energy efficiency and climate adaptation fed into the energy target of 40 kWh/m² by 2030 and the requirement that new builds be environmentally certified; employee expectations strengthened sustainability training and dialogues; and investor and lender demand for green financing led to green bonds, commercial paper and sustainability-linked loans (p.87).

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

Reference: pages 87-88, 83.

Heba sets its climate response over three horizons: short term (0-5 years: energy efficiency, renewable energy, green leases), medium term (5-10 years: climate adaptation of existing properties, the F-Gas Directive) and long term (10-50 years: a climate-safe portfolio) (p.87). A resilience assessment was run against IPCC RCP scenarios, with RCP 2.6 (1.5-2 °C) for the shorter term and RCP 6.0/8.5 (3-5 °C) for the longer term (p.87).

Beyond climate, the company has "identified social and governance-related factors as material risks": safety and security in neighborhoods, relationships with suppliers and investor expectations on green financing (p.87). It links these to revenue (rental income tied to customer satisfaction), costs, assets and liabilities, and access to capital through green bonds and commercial paper (p.87).

"Expected long-term financial impacts are not quantified at present, as the company is using the option of phasing in this part. The company plans to be able to produce such calculations from 2027." (p.87). Heba reports ESRS 2, E1 and G1 in full and E5 (waste) and S4 (safety and security) in part; E2 and E3 are judged not material, and E4 and S1-S4 are covered by phase-in (pp.83, 87-88).

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering), and resilience under E1-3.

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

Reference: pages 88, 90.

Heba runs a double materiality assessment (DMA), first conducted in 2024 with a resilience assessment and repeated in 2025 ahead of the coming financial year (p.88). It engaged investors, tenants, local authorities, industry organizations, lenders, suppliers and national authorities, and sought external expertise on climate/RCP data, valuation and risk, and audit and advisory support (p.88).

Results are structured in four matrices, two for impacts (positive and negative) and two for financial effects (risks and opportunities). Each matter is scored on scale, scope, reversibility, probability and time horizon. The cut-offs are a score of 18 or more for adverse impacts, 12 or more for positive impacts and 9 or more for financial impacts (p.88). Because of data gaps upstream and downstream, Heba says it chose to consider "experience-based risks even in cases when the company does not have verified facts" (p.88). Management validated the outcome and the board approved it (p.88). The statement does not print the resulting list of individual IROs.

The climate scenario work run under IRO-1 (three scenarios, pp.90-91) is described in the E1 chapter. Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

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

Reference: pages 107-109, 88, 82-83.

Heba prints an "IRO-2 Index of disclosure requirements, ESRS 2 Appendix B" (pp.107-108). For each DR it shows a mark in one of five columns (phase in, material, partially material, not material, N/A), plus a page reference and a comment. It lists the ESRS 2 DRs (BP-1 to IRO-2), E1-1 to E1-8, E5-1 to E5-5, S4-1 to S4-5 and G1-1 to G1-6, plus a single SBM-3 row for each of E2, E3, E4, S1, S2 and S3 (pp.107-108). E1-9, E5-6 and every topical DR under E2, E3, E4, S1, S2 and S3 are not listed.

The marks: ESRS 2, E1 (including E1-7 and E1-8) and G1-1 to G1-4 are marked material; E5 and S4 are marked partially material; E2 and E3 are marked not material; E4, S1, S2 and S3 are marked phase in; G1-5 is marked N/A and G1-6 not material; GOV-3 in the E1 block is marked N/A (pp.107-108). Comments include, for E1-6, that Heba reports Scope 3 "even though the disclosure may be omitted under the ESRS phase-in provisions", and, for E5, that E5-1 to E5-5 are reported "as E5-5 has been assessed as material" (pp.107-108). The statement says phase-in for companies with fewer than 750 employees applies to E4, S1, S2, S3 and S4, and that E2 and E3 are assessed as non-material (p.83). Page 109 lists datapoints derived from other EU legislation, with the EU Taxonomy marked "Not reported in the 2025 Sustainability Report" (p.109). For Taxonomy purposes Heba also says it is "not formally covered by the scope of the CSRD" (p.82).

Transition plan for climate change mitigation

Reference: pages 89, 92-93.

Heba has "adopted a climate transition strategy based on a science-based commitment", which "forms the basis for the development of a formal and external transition plan to apply from 2027 onwards" (p.89). Later in the chapter it says it has not "adopted any formal transition plan in the sense referred to in ESRS E1-1" (p.92).

The strategy rests on the 1.5 °C goal and SBTi sector pathways for construction and real estate (p.89). Key actions are energy efficiency in the existing portfolio, climate-improved district heating plus geothermal, climate optimization of new builds (lower-impact materials, smaller quantities, more reuse and recycling), sustainable leases to cut tenants' waste and electricity use, and supplier collaboration (p.89). Residual emissions are to be handled through a long-term carbon removal contract with Stockholm Exergi (pp.89, 99).

Heba names locked-in emissions: life cycle emissions from building materials (concrete, steel), parts of the district heating mix and limited influence over suppliers (p.89). It reports "no separate CapEx or OpEx items specifically linked to climate measures" and points to its Investor Report Green Financing 2025 (pp.89, 92). The text says the strategy "has been validated within the framework of SBTi" (p.89) without giving a validation date or reference.

Identification of climate-related risks and scenario analysis

Reference: pages 90-91, 87.

Back-filled from ESRS 2 SBM-3 (p.87) and the climate IRO-1 section (pp.90-91), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Heba says the scenario analysis "is based on guidance from the TCFD and ESRS" and uses three scenarios: A low emissions (RCP 2.6 / SSP1-1.9, 1.5 °C), B medium (RCP 4.5 / SSP2) and C high emissions (RCP 6.0-8.5 / SSP5) (p.90). SBM-3 gives 1.5-2 °C for RCP 2.6 and 3-5 °C for RCP 6.0/8.5 (p.87). The work ran in stages: identify risks and opportunities; test them against the three scenarios with a focus on energy prices, extreme weather and legal requirements; estimate effects on operating and investment costs, property values and financing terms; then test the strategy and the 2045 climate-neutrality target (p.90). Assumptions draw on Boverket, IVL and internal operating and energy statistics (p.90).

The most material physical risks in own operations are heavy rainfall, flooding and heat stress. In the value chain, extreme weather can affect on-time delivery and materials prices at construction suppliers (p.90). Transition risks include stricter legislation (energy classification, climate declarations) and investor and lender demands (p.90). The report does not say which scenario applies to physical versus transition risk, and p.87 names two scenario families where p.90 names three.

Resilience in relation to climate change

Reference: pages 90, 87-88, 91, 57.

Back-filled from ESRS 2 SBM-3 (p.87), the climate SBM-3 and IRO-1 sections (pp.88, 90-91) and the Operations risk section (p.57). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Heba states: "A resilience assessment of Heba's strategy has been carried out against the IPCC's climate scenarios (RCP)" (p.87). The analysis covers existing properties, ongoing projects, planned new builds and the most significant parts of the value chain (p.90). Its result is that the strategy holds under RCP 2.6 and 4.5. Under RCP 8.5 the main effects are higher maintenance and insurance costs and higher capital needs for new projects, managed through energy efficiency, green financing and adaptation (p.90). The company found no property components or activities "incompatible with or require insurmountable efforts in the long term to transition to climate neutrality", and says the risks "do not require any material adjustments to financial assumptions for 2025 and later" (p.88).

Adaptation capacity: stormwater management, roof drainage and moisture protection in new builds and remodels, and a climate-risk inventory of the existing portfolio that feeds maintenance and investment plans (p.91). The Operations section reports that the portfolio analysis found four properties at risk of severely elevated water levels, equal to SEK 84m of annual revenue, 14% of 2025 rental income (p.57). Uncertainty is addressed only in general terms: the strategy "must be gradually adapted to the existing uncertainties" (p.87).

Policies related to climate change mitigation and adaptation

Reference: pages 90-91, 109.

Heba says its policies cover climate mitigation and adaptation, energy efficiency and renewable energy, apply to the whole business, are set by the board, sit inside the ISO-certified management system and are reviewed annually (p.90). Suppliers receive them through the Suppliers' Code of Conduct and procurement documents (p.90).

The ESG policy is the central framework: it commits the company to minimize climate impact through energy efficiency, renewable energy and climate-smart solutions across investment, procurement, property management and new builds (p.91). The Suppliers' Code of Conduct requires suppliers to work on emission reductions and responsible resource use, and Heba calls it important for cutting Scope 3 emissions (p.91). The quality policy ties climate and ESG aspects into ISO 9001 quality management (p.91). The ESG and quality policies were most recently adopted in June 2025, and the Code of Conduct with supplier requirements in December 2025 (p.91).

The company says it has policies "for all material sustainability aspects", while "biodiversity and the circular economy, are under development", with project-based guidelines in the meantime (p.91).

Actions and resources in relation to climate change policies

Reference: pages 91-93.

In property management, Heba uses demand-controlled ventilation, LED lighting, optimized heating systems and digital control and monitoring. Every property has an energy mapping and an individual action plan, and Heba has been buying 100% renewable electricity for the whole portfolio "for several years now" (p.91). New builds must have climate-optimized designs and environmental certification (Miljöbyggnad or the Nordic Swan Eco-label), and since 2025 the ambition is to halve construction-phase climate impact against Boverket's reference level (p.91).

Adaptation actions include stormwater management, roof drainage and moisture protection in all new build and remodeling projects, plus a climate-risk inventory of the existing portfolio (p.91). In the value chain, all key suppliers must sign the Suppliers' Code of Conduct (p.92). Tenants are covered through "sustainable lease" commitments (sorting waste, a green electricity contract, smoke-free) and "green leases" for commercial premises, and EV charging is being installed in car parks (p.92).

On resources, Heba has a green and sustainability-linked financing framework and aims for all external financing to be green by 2030 (p.92). Energy efficiency and renewable energy actions are shown as cutting 389 tCO2e in 2025, with 21 tCO2e expected in 2026 (p.93). The company reports "no separate CapEx or OpEx items specifically linked to climate measures" (p.92).

Targets related to climate change mitigation and adaptation

Reference: pages 92-94.

Heba has two main targets: climate-neutral property management by 2030 and a climate-neutral organization by 2045 (p.92). They are gross targets: "any negative emissions and carbon credits are reported separately and are not used to reduce reported emissions when tracking the targets" (p.92). The base year is 2018, set in line with SBTi, and it is to be reviewed after 2030 and every five years after (p.92).

Scope 1 and 2 (2030): cut total energy use from 75 to 40 kWh/m²; bring 100% of the portfolio to Energy Class C or better; buy carbon removal from 2029 as a complement (p.92). Scope 3 (2045): from 2025 all new build projects must have at least 50% lower construction-phase emissions than Boverket's reference value, and all construction waste must be sorted at source (p.92).

Other targets: climate-risk assessment of all properties and HållFast certification of all existing properties by 2025; 100% green external financing by 2030; EV charging at 100% of parking spaces by 2030; and audits of 100% of significant suppliers against the Code of Conduct by 2028 (p.93).

Progress: energy performance 75 kWh/m² in 2024 and 67 in 2025, and renewable share of energy 89% in 2024 and 94% in 2025 (pp.93-94).

Energy consumption and mix

Reference: pages 94, 93, 98.

Total energy consumption in 2025 was 20,165 MWh, excluding 905 MWh that district heating suppliers report as neither renewable nor fossil (p.94). Fossil energy was 359 MWh, all purchased electricity or heat from fossil sources; fuel use from coal, oil, gas and nuclear was zero. Renewable energy was 19,806 MWh, including 223 MWh of self-generated solar power, giving a renewable share of 94% (2024: 89%) (p.94). Purchased electricity (7,835,890 kWh) is covered by guarantees of origin, and purchased district heating (13,011,197 kWh) is 90% renewable based on the supplier mix (p.94). Total consumption was about 11% lower than in 2024 (p.94).

Energy performance was 67 kWh/m² Atemp, degree-day corrected, against 75 in 2024, and the 2030 target is 40 (pp.93-94). Energy intensity was 33 MWh per SEK million of net revenue (2024: 42) (p.98). Heba describes property management and new builds as a climate-intensive sector under ESRS (p.94).

Reviewer note: p.94 describes the fall from 92 kWh/m² in 2021 to 67 as a 37% improvement, while the p.93 table says 27%. 92 to 67 is a 27% fall.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 95-98.

Scope 1 is "close to 0" because the whole vehicle fleet is electric (pp.93, 95). Calculations follow the GHG Protocol operational control approach (p.95). The 67% fall in market-based Scope 2 comes mainly from a contract with Stockholm Exergi for climate-neutral district heating (p.97).

Scope 3 is reported voluntarily under the phase-in (pp.82, 108). In 2025 the main categories were waste generated in operations (712 tCO2e, up 273% because more waste types are now included), use of sold products, meaning tenants' electricity and heating (184), upstream transport of district heating (67) and employee commuting (4) (p.97). Categories 1 and 2 have no 2025 data because no projects were completed (p.96). About 50-75% of Scope 3 rests on primary supplier data (p.96). Biogenic emissions were 805 tCO2e location-based and 79 market-based in Scope 2 (p.98). Intensity is stated as 1.68 (location-based) and 0.31 (market-based) tCO2e per SEK million of net revenue (p.98).

Reviewer note: 1.68 and 0.31 equal Scope 2 location-based (1,019) and market-based (188) divided by SEK 605.4m, so Scope 3 is not in the intensity figures.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 99, 98, 92.

Heba cancelled 217 tCO2e of Gold Standard carbon credits for 2025 (571 tCO2e for 2024). All came from reduction projects, none from removal projects or EU projects, and none are subject to corresponding adjustments (p.99). Heba says it does not use offsets to adjust reported emissions: targets are gross and credits are "reported separately" (pp.92, 98).

For future residual emissions Heba has a long-term agreement with Stockholm Exergi on BECCS, with certified negative emissions of about 1,000 tCO2e a year from 2029 for 15 years, stored geologically off the coast of Norway (p.99). The page 99 offset table lists the contract as signed "for 2029-2034", which does not match 15 years from 2029 (p.99). Heba intends to use only credits that meet recognized quality standards (CDR EU Framework or Gold Standard) and are issued within the EU, and to neutralize residual emissions only when verified negative emissions are available (p.99).

Internal carbon pricing

Reference: page 99.

Heba states: "Heba does not currently apply internal carbon pricing." It has not introduced internal shadow prices, internal trading or carbon budgets as decision-making instruments. The company says it is monitoring developments in methods and applications in the sector and may evaluate internal pricing in the future as a complement to other climate governance tools (p.99).

The Operations risk section includes a sensitivity of offsetting costs at SEK 1,500 per tonne, which would cost SEK 326,000 on 2025 Scope 1 and 2 offsets (p.57). That is a scenario calculation, not an internal price.

Policies related to resource use and circular economy

Reference: pages 100, 91, 109.

E5 is "partially material" for Heba, the materiality referring to waste management in property management and construction projects (p.100). Policies that govern the area are the Sustainability Policy, Quality Policy, Code of Conduct and the Climate Transition Strategy (p.100). Heba states that it "does not have a separate policy specifically aimed at waste management"; the matter is handled within the ESG policy, quality policy and climate transition strategy (p.100).

Work on resource use and waste runs through the ISO 14001 environmental management system, which includes procedures for resource-efficient material choices in projects, waste management in property management and construction, reuse and monitoring of material and waste flows (p.100). Contractors, suppliers and waste management actors are involved through procurement requirements, supplier dialogues and cooperation (p.100). Elsewhere Heba says the circular economy is among areas "under development", with project-based guidelines for now (p.91).

Actions and resources related to resource use and circular economy

Reference: page 100.

Heba works to minimize waste and increase reuse and recycling, in line with circular principles and legal requirements (p.100). It uses digital waste statistics, reuse requirements in renovations and rebuilds, sorting of waste at source and training in circular principles, tracked in the environmental management system (p.100). Concrete measures include better waste sorting in the properties, where Heba says it has long complied with upcoming rules on property-close waste collection, cooperation with contractors on construction and renovation waste, and information to tenants on source separation (p.100).

"Monthly monitoring of waste statistics will be introduced in future reporting years", and more quantification of material flows in construction projects is planned from 2026 (p.100). Heba reports no separate CapEx or OpEx allocated to resource use and waste measures and "no planned specific future investments or budgeted operating expenses" linked to action plans in the area (p.100).

Targets related to resource use and circular economy

Reference: pages 101, 92.

The stated targets are that waste from construction and demolition projects "must be 100% sorted for reuse or recycling" and that in future projects "all construction materials used in new builds must be approved according to Byggvarubedömningen" (p.101). The company says these targets "are based on industry practice for construction and demolition waste and scientific evidence is not specifically assessed" (p.101). The climate targets add that all construction waste must be sorted at source (p.92).

Heba says it is working to deepen its data collection on building materials in new builds and property management, including refining the measurement of the share of reused materials in new build projects and the waste sorting ratio in existing properties (p.101). No baseline, interim milestone or 2025 outcome figure is stated for these targets.

Resource inflows

Reference: pages 101, 100, 96.

Heba's index marks E5-4 as partially material, and the company describes its reporting here as voluntary: what it discloses "on a voluntary basis, for example under E5-4 Resource inflows" is included because there may be industry interest in its approach (p.100). The content is qualitative. An internal Hebahuset concept is used "to identify, monitor and reduce resource use in new build projects", and requirements for sorting and reuse are set in its own construction projects (p.101). All new build and major renovation projects are monitored and will be evaluated against indicators for resource use: share of reused or recycled materials, share of sorted construction waste, volume of hazardous waste per m² gross floor area in demolition and remodels, and share of building materials with an environmental product declaration (p.101). A data collection routine for waste and reuse "will be implemented in 2026" and "will form the basis for quantitative key metrics from 2026 onwards" (p.101).

No 2025 quantities of materials purchased, recycled content or share of renewable materials are reported. Building-materials emissions in Scope 3 rest on standard values per m² of completed surface, and no projects were completed in 2025 (p.96).

Resource outflows

Reference: pages 101, 100.

Heba's index lists this requirement as "E5-5 Resource outflows - waste" with the comment that "Waste volumes are the element within ESRS E5 assessed as material" (p.108). The section reports on waste only. Heba says waste is "the sub-area that Heba reports on within the standard when it is deemed necessary", with data from contractors and waste receipts (p.101). The data refer mainly to operational waste from tenants, and waste streams from construction and renovation projects are described as also relevant to the company (p.101). No data on products, materials or product durability as outflows are reported. See E5-5-Waste for the waste figures.

Waste

Reference: pages 101, 83.

Non-recycled non-hazardous waste is 933,591 kg, about 60% of the total (p.101). Heba also collected 49,916 kg of textiles in 2025 (2024: 39,304; 2023: 17,000) (p.101). The standardized share of waste volume is estimated at 35% and data quality is rated medium (p.83, 101).

Reviewer note: the printed sub-lines do not add to the parent lines. Recycling plus other recovery is 823,559 kg against 615,081 kg stated, and the three disposal lines sum to 926,212 kg against 933,591 kg stated. The totals do add up (615,081 + 933,591 + 2,940 = 1,551,612).

Policies related to consumers and end-users

Reference: pages 102-103.

Heba treats its tenants as the end users covered by the standard: private individuals, commercial tenants and the providers running activities in its elderly care facilities (p.102). S4 is "partially material", the materiality referring to tenants' safety and security in their homes, tracked through the security index (p.102). The ESG policy, the quality and environmental management systems and the Code of Conduct govern how the company acts toward tenants (p.102).

Heba "shall offer tenants good service" and says it complies with the GDPR, with procedures for data protection, access control and information security, so that tenants' personal data is handled in line with the UN Guiding Principles and OECD guidelines (p.102). Fault reports and complaints are treated as valuable information. The CEO has overall responsibility, the head of property management and property managers have operational responsibility, and customer service supports follow-up (p.103).

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: page 103.

Material risks: the risks tenants may meet relate to the indoor environment (ventilation, moisture, radon, temperature and thermal comfort), and tenants' health and safety may be affected by slip hazards, lighting and fire protection deficiencies (p.103). Drinking water comes from the municipal network and is checked under the law. Heba's responsibility is limited to pipes and installations within the property, and it can shut off the main pipes at short notice (p.103).

Material opportunities: tenants currently experience a high sense of safety and security, ensured mainly by preventive work such as walkthroughs, quick correction of faults, maintenance, lighting and perimeter protection (p.103). Energy-optimizing investments cut long-term operating costs and improve indoor climate, physical security actions create safer living environments, and Heba sees further potential in digitalization, IT and CCTV monitoring of common areas as a supplementary security action (p.103).

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

Reference: page 103.

The CSI Service sub-index was 85.3 in 2025, with the target of being at or above the average for housing companies in major cities (p.103). The Security index, described as a key indicator, was 87.9, "the highest score since measurement according to this model began over ten years ago", against an industry average of 82.4 and 83.2 for Stockholm (p.103). The target is that the Security index does not fall below 80 in any property, and the few properties below it have a documented action plan (p.103). Another target is that 100% of fault reports are communicated back to the tenant within 48 hours (p.103).

Heba says that during the phasing-in period it reports qualitative and quantitative data that will be developed further, and that the next step is to structure data collection so that more quantitative indicators can be reported in future years (p.103). It states that this reporting "meets all disclosure requirements based on current conditions" (p.103).

Business conduct policies and corporate culture

Reference: pages 104-105, 109.

The board has overall responsibility for governing and monitoring business conduct and regulatory compliance, including the Code of Conduct, anti-corruption work and the whistleblower function (p.104). Bribery, conflicts of interest and market abuse are covered in the risk process (p.104). The CEO implements board decisions, and the head of sustainability coordinates analysis of risks and opportunities within material IROs (p.104).

Culture is built on the core values "commitment, consideration, and professionalism" (p.105). All employees receive annual training in the Code of Conduct, which covers anti-corruption, and Heba logs persons with access to inside information (p.105). Its board adopted an insider policy during the year (p.105). The whistleblower function runs on an external platform with anonymous reporting. Cases are received by an independent external party and reported to a committee that includes the board chair, and Heba states it complies with Swedish whistleblower protection legislation (p.105). Material policies are listed in the policy overview on p.109.

Targets related to business conduct

Reference: pages 105-106, 93.

Back-filled from the business conduct chapter, where targets are not set out as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

The G1 chapter states no target labelled as such, but it describes how effectiveness is tracked. Heba monitors training participation "to ensure that 100% of employees have read and understood the information", achieved by having all employees sign the Code of Conduct (p.105). It audits 20% of its most significant suppliers each year (p.105), and the climate targets add that 100% of significant suppliers are to be audited against the Code of Conduct by 2028 (p.93). The board receives updates annually and as needed on the Code of Conduct, insider rules and whistleblowing (p.105), and ESG outcomes are reported to management and the board based on key figures and status against targets (p.106). The reported outcome is no confirmed incidents of corruption or bribery (p.106).

Incidents of corruption or bribery

Reference: page 106.

Heba states it "has not identified any confirmed cases of corruption or bribery and no legal proceedings, fines, or sanctions have been directed at the company" (p.106). Incoming cases go through internal control, whistleblowing and reporting procedures under the ISO management system, and no incident was assessed after investigation as corruption or bribery (p.106). Heba defines an incident as a case that, after investigation, is assessed as corruption or bribery under applicable law or its Code of Conduct. The information draws on internal control, financial reconciliations, HR and compliance, and case logs from the whistleblower function (p.106). No judgments or fines were identified in the reporting period.