Icade

Board and committee oversight

Reference: pages 106, 107, 108; composition and expertise data are incorporated by reference from chapter 5 of the registration document (pages 101, 106).

The statement splits oversight across five bodies (pages 106-107):

• Board of Directors: sets strategy and reviews impacts, opportunities and risks at least annually, including environmental, social and business conduct issues.
• Audit and Risk Committee: assesses material risks, including ESG risks, and internal control.
• Innovation and CSR Committee: relays the priorities of the CSR policy and ranks focus areas.
• Joint Committee of those two committees: reviews sustainability reporting, the double materiality assessment and policy implementation.
• Strategy and Investment Committee: applies sustainability indicators (carbon performance, climate vulnerability, rewilding) to investment evaluation grids.

The CEO and Executive Committee submit sustainability policies and objectives to the Board and approve material sustainability capex and opex (page 107).

Skills (page 108): 73% of directors are proficient in sustainability. At least one director has expertise in each material matter: 47% in climate change, 40% in biodiversity and business conduct, 27% in resource use and the circular economy.

Information reaching the Board

Reference: pages 106, 107, 105, 116, 117.

The Joint Committee (Innovation and CSR Committee plus Audit and Risk Committee) is the main route for sustainability information to the Board (page 106). Items it handled in 2025 (page 106):

• review of the 2024 Climate and Biodiversity Overviews and the 2024 sustainability report
• appointment or reappointment of the sustainability auditors
• regulatory and competitive monitoring of sustainability reporting
• review of the double materiality assessment
• review of internal control systems for sustainability reporting

The Board approved the sustainability objectives on the recommendation of the Innovation and CSR Committee (page 119) and approved the double materiality assessment on the Joint Committee's recommendation (pages 116-117). The internal control framework was presented to the Joint Committee in 2024, which then monitored the 2025 work to strengthen controls (page 105). The sustainability report is formally approved by the Board (page 105).

Sustainability in incentive schemes

Reference: page 109; also page 182; remuneration policy details are incorporated by reference from chapter 5 (page 101).

• Directors, Chairman and Vice-Chairwoman: no financial incentive tied to sustainability targets.
• CEO: the only corporate officer with such an incentive. The 2026 policy, approved by the Board on February 17, 2026, links 25% of annual variable remuneration to sustainability targets.
• Executive Committee members: sustainability objectives are 25% of variable remuneration, split 12.5% low-carbon and 12.5% gender equality.
• Employees: 99% had sustainability objectives in 2025, averaging 21% of their annual goals. Group-level objectives covered carbon performance and the gender equality index.

Other links on page 182: the performance incentive agreement carries two CSR criteria (carbon footprint reduction and customer satisfaction) worth 30% of the total, and the 2025 performance share plan for senior executives weights low-carbon at 20% and employee training at 10%.

Due diligence mapping

Reference: page 110.

Icade has no standalone due diligence section. It gives a correspondence table (page 110) showing where each core element of due diligence sits in the statement:

• Embedding in governance, strategy and business model: sections 2.1, 3, 8.1.1 and 8.2.3.
• Engaging affected stakeholders: sections 4.1 and 5.1.
• Identifying and assessing adverse impacts: sections 5.1, 8.1.1, 8.2.1, 8.3.1 and 9.2.2.
• Taking action: sections 8.1.2.2 (climate mitigation plan), 8.1.4.2 (adaptation), 8.2.5 (biodiversity), 8.3.2.3 and 8.3.3.3 (resource use and waste), and 9.2.6 (value chain workers' concerns).
• Tracking effectiveness and communicating: section 7 (objectives and progress in 2025).

The statement points to existing sections rather than adding a separate due diligence narrative.

Internal controls over sustainability reporting

Reference: page 105.

Icade names four risks: the volume of data to report, inaccurate or missing data, fraud or greenwashing, and IT failures. Controls it lists:

• regulatory monitoring by internal Caisse des dépôts Group working groups with external experts
• reporting based on recognized standards (GRI, GHG Protocol, SBTi)
• centralized production under standardized procedures, with IT systems that process the data
• detailed analysis of indicators with documented controls (tests of details, consistency checks, analytical reviews)
• formal approval of the sustainability report by the Board

A reporting tool introduced in 2019 imports data from business systems and holds manual inputs. Contributors enter data, approvers review it, and the CSR Department is second-level approver. Qualitative data comes from interviews, then cross-review by business experts and the Executive Committee. In 2025 the team ranked information by importance and error risk to decide which controls to strengthen first. Two sustainability auditors have audited the statement since 2025.

Strategy and business model (by reference)

Reference: page 111; also pages 101, 96, 116.

The statement does not reproduce this disclosure. It incorporates by reference two parts of the registration document (pages 101, 111):

• strategy elements that relate to or affect sustainability matters (SBM-1 paragraph 40(a)): chapter 2, section 2
• business model and value chain (paragraph 42): chapter 1, which also covers issues, the strategic plan and the innovation process

The statement adds that workforce size and location are in section 9.1 and that revenue by segment is in the EU Taxonomy report (page 111). It says the statement covers the whole value chain of the two divisions, Property Investment and Property Development (page 96), and that Icade is a French company operating solely in France (page 116). Group revenue was 1,342 million euros in 2025 (page 145).

Stakeholder interests and views

Reference: pages 112, 113, 114, 115.

Icade identifies eight stakeholder categories (page 112): customers and end-users; employees and representatives; the financial and ESG community; local authorities, communities, associations and NGOs; Parliament, government and the professional sector; business partners and suppliers; traditional and social media; universities and schools. For each, a table gives forms of dialogue, expectations and Icade's response (pages 112-114).

Examples of dialogue: satisfaction surveys and environmental committees with tenants; monthly Social and Economic Committee meetings with employee representatives; charters with local bodies such as Plaine Commune; toll-free helplines for residents near construction sites; membership of trade groups (EPRA, MEDEF, AFEP, FEI, FPI, OID).

Stakeholder opinions feed the double materiality assessment, mainly impact materiality, and go to the Board's Joint Committee (page 114). External ESG ratings are on page 115 (for example GRESB 92/100 and an MSCI A rating).

Material sub-topics and business model effects

Reference: pages 117, 118; detail sits in the topical chapters (page 118).

The table on pages 117-118 lists material sub-topics by standard:

• E1 Climate change: mitigation of emissions from construction and operation, low-carbon solutions, customer and supplier engagement, fossil fuel dependence, adaptation of assets
• E4 Biodiversity: rewilding, green space quality, soil sealing, more renovation
• E5 Resource use: pressure on building materials, renovation, construction waste
• Sustainable mobility (specific to Icade): accessibility and mobility infrastructure
• S1 Own workforce: skills development, quality of life, diversity and inclusion
• S2 Value chain workers: health and safety on construction sites, illegal employment
• S3 Affected communities: affordable and inclusive housing
• S4 Customers and end-users: satisfaction, occupant well-being and safety, responsible sales, privacy
• G1 Business conduct: responsible procurement, business ethics, lobbying

E2 Pollution and E3 Water are each marked "The issue was deemed immaterial." (page 117). Five priority issues were set by the Executive Committee and approved by the Board (page 118): climate and adaptation, occupant health and well-being, close local ties and inclusion, biodiversity and soil protection, employee skills development.

Double materiality process

Reference: pages 116, 117.

Inputs (page 116): ESRS 1 Appendix A; Icade's 2018 materiality matrix updated in 2022; a peer benchmark; the Risk Management team's risk range (about a third relates to sustainability); the 17 UN SDGs. About forty themes, four specific to Icade, were selected.

Scoring: the CSR Department scored each impact, risk and opportunity from 1 to 5 on likelihood, scale, scope and irremediable character, then averaged. The materiality threshold was set by the Joint Committee. Scores went to the Executive Committee, then the Board.

Stakeholder input (page 117): 11 external experts were interviewed; two questionnaires went to Property Investment customers and employees.

Risk link: sustainability risks use the Group risk assessment (chapter 4) but are rated gross and over longer horizons.

Water: no impact, risk or opportunity was material. Icade mapped assets and projects with the WWF Water Risk Filter, and none was in a high water stress area at December 31, 2025 (page 116).

2025 update: management found no developments requiring change; the assessment was approved unchanged from the prior year (page 117).

Disclosure requirements covered

Reference: page 118; the company's ESRS index is section 11, pages 210-223.

Section 5.4 sends the reader to the "CSRD correspondence tables" (page 118). Each ESRS 2 and topical disclosure requirement is mapped to a section such as "Chap. 3 § 8.1.2.2", not to a page number. The table also lists datapoints derived from other EU legislation.

What the table says about coverage:

• every E2 and E3 row is marked "Not material" (pages 215-216)
• E5-4 Resource inflows is marked "Not reported" (page 217)
• the E1-9 datapoints on acute and chronic physical risk and on asset locations are marked "Not reported" (page 214)
• S3 appears as MDR-P, MDR-A, MDR-M and MDR-T rows (page 221), and S4 has rows for S4-1, S4-4 and S4-5 only (page 222)

Other statements: Icade applied the "Quick Fix" delegated act 2025/1416, so "certain disclosures relating to standards E4 and S2 are not included" (page 96); it did not use the option to omit intellectual property or know-how (page 96); some governance and strategy content is incorporated by reference (page 101).

Transition plan for climate change mitigation

Reference: pages 129, 130, 131, 132; locked-in emissions and benchmarks on page 156.

Icade set a 1.5°C-compatible pathway approved by the SBTi in 2022 and updated it in 2025 to the SBTi Buildings Sector criteria. The SBTi approved the new goals in January 2026 (page 129). Shareholders vote on the plan each year (Say on Climate).

Goals (pages 129-130):

• absolute GHG emissions down 41% from 2019 to 2030 (28% under the earlier goals)
• carbon intensity: Property Development -48%, Property Investment -61%, Corporate -46% per employee
• no new fossil fuel systems from 2030
• net zero by 2050: -90% on scopes 1, 2 and 3 versus 2019, residual emissions offset

A 145 million euro investment plan covers 2024-2030 for operating assets. Icade says the 2050 measures and investments "have yet to be defined" (page 130). Data centers are excluded from the pathway for now (page 131). Locked-in emissions: gas or fuel-oil boilers (20% of Property Investment GHG) and high-GWP air conditioning (7%) (page 156). Icade is not excluded from the Paris-aligned benchmarks and has no Taxonomy alignment target (page 156).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the climate resilience subsection (section 8.1.1), where this content is disclosed in the FY2025 report (pages 127-128). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 127, 128, 151, 152.

Icade follows the TCFD recommendations and folds climate risk into its Group risk assessment, updated each year. It tests transition risk against a Net Zero Carbon Emission scenario for 2050 and physical risk against the IPCC RCP8.5 scenario for 2050, for all activities (page 127). The transition scenario's source is not named. The RCP8.5 note gives a CO2e concentration (1,000 ppm in 2100), not a temperature projection.

Risks are split into transition (regulatory, technological, market, reputational) and physical (chronic: heat, sea level rise; acute: heat waves, floods, droughts with clay shrinkage and swelling, forest fires) (page 127). For assets, Icade uses the OID's Bat-ADAPT tool at RCP8.5 for 2050, updated significantly in 2025 (page 152). These risks feed the double materiality assessment.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the climate business model subsection (section 8.1.1), where this content is disclosed in the FY2025 report (pages 128, 152-153). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 128, 139, 151, 152, 153.

The statement says the analyses of business model resilience fed the transition plan and the adaptation policy, both part of the ReShapE strategic plan (page 128).

Physical (pages 152-153): 81% of portfolio value is not exposed to very high physical risk by 2050 (66% in 2024; the change is mainly a Bat-ADAPT model update). Of the 19% exposed, 11% has an adaptation plan or resilience analysis and 8% will be covered by 2030. The goal is to adapt all most-exposed assets by 2030 (page 151).

Transition (page 139): 91% of well-positioned offices face no transition risk by 2030; Icade expects more than 96% to meet 2030 goals after the 145 million euro plan.

Property Development has no adaptation policy and relies on regulation such as RE2020 (page 152). Adaptation spending is not tracked separately.

Policies related to climate change mitigation and adaptation

Reference: pages 129, 152; mapped in the index to section 8.1.2.1.

Mitigation policy (page 129): covers mitigation, energy efficiency and renewable energy, in three steps: measure, reduce, contribute to carbon sinks. The Executive Committee members in charge of Property Development and Property Investment supervise it, and the member in charge of HR does so for the Corporate scope. It draws on TCFD, GHG Protocol, SBTi, GRI and EPRA, and affects all stakeholders to varying degrees.

Adaptation policy (page 152):

• Property Investment: a policy to adapt the whole portfolio by 2030, overseen by the division's Executive Committee member, with an annual exposure assessment and in-depth resilience audits for the most exposed assets.
• Property Development: no adaptation policy; teams rely on regulations (RE2020 includes a 2003-type heatwave in summer comfort calculations) and on NF Living Environment certification.
• The CSR Department provides training, analytical tools and a catalog of nature-based solutions. In 2025 Icade signed the OID/PBD Charter of Commitment to Climate Change Adaptation.

Actions and resources in relation to climate change policies

Reference: pages 131, 132, 133, 134, 136, 137.

Property Development (pages 133-134), estimated cuts for 2019-2030: energy performance 29,000 tCO2e, gas phase-out 68,000, design efficiency 22,000, materials 45,000 (including 3,000 from reuse). In 2025, 62% of projects were at least a year ahead of RE2020 thresholds and 89% of heated projects used heat pumps, wood boilers or district heating.

Property Investment (pages 136-137): retrofits 3,800 tCO2e, energy switches 3,600, renewable energy 4,300, scope changes 3,350 and emission factor changes 3,300 over 2019-2030. Gas use fell about 50% from 2019 to 2025.

Corporate (page 138): business travel and commuting are over 90% of employee emissions; measures should save 1,300 tCO2e by 2030.

Resources (page 137): the 145 million euro plan for 2024-2030 had 38.4 million spent by end of 2025 (15.5 million in 2025). Over 104 million euros has gone to the transition since 2019. Tenants: green lease clauses cover 56% of floor area; 12 tenants (8%) have climate-criteria leases.

Targets related to climate change mitigation and adaptation

Reference: pages 129, 130, 132, 151; mapped in the index to section 8.1.2.2.

Mitigation targets (pages 129-132): 41% absolute cut in GHG emissions 2019-2030; intensity goals of -48% (Property Development, kg CO2e/sq.m), -61% (Property Investment, kg CO2e/sq.m/year) and -46% (Corporate, per employee); net zero by 2050 with a 90% absolute cut.

Progress in 2025 (page 132):

• Property Development: 897 kg CO2e/sq.m, down 36% from 2019
• Property Investment: 7.2 kg CO2e/sq.m/year, down 57%
• Corporate: 2,408 kg CO2e/employee, down 14%

Total emissions across all three scopes are down 52% from 2019 to 2025. Icade says the 2030 absolute goal sits above 2025 performance because it expects activity to recover (page 131).

Adaptation targets (page 151): assess portfolio vulnerability annually and adapt 100% of most-exposed assets by 2030. At end 2025, 58% of those assets (by value) were covered by a plan or analysis (page 122).

Energy consumption and mix

Reference: pages 147, 148, 149; mapped in the index to section 8.1.3.3.

Own operations (Corporate plus common areas of controlled assets), 2025 (page 147):

• total final energy: 66,783 MWh (65,074 pro forma 2024)
• fossil sources: 10,705 MWh; nuclear: 483 MWh
• renewable: 55,595 MWh (629 on-site solar, 52,682 purchased with guarantees of origin, 2,284 biogas)
• energy intensity: 58 kWh per sq.m, and 51 MWh per million euros of revenue from high climate impact sectors (1,298 million euros)

Whole portfolio (sole control scope, page 149): total final energy 413,791 MWh in 2025 versus 402,152 MWh in 2024 pro forma; 68% of total energy consumption is estimated. Renewable share was 66% on a market-based basis and 24% location-based (page 137).

The text says fossil consumption in own operations is gas only, but the table's fossil total equals non-renewable district heating and cooling (10,679 MWh) plus fossil-fuel electricity (26 MWh), with natural gas shown as 0 and biogas as 2,284 MWh. Weather-adjusted data is reported alongside raw data (page 98).

Gross scopes 1, 2, 3 and total GHG emissions

Reference: pages 140, 141, 142, 143, 145; index section 8.1.3.1.

2025 (total scope, operational control): scope 1 market-based 2,362 tCO2e (2,503 pro forma 2024); scope 2 market-based 1,629 (2,076); scope 2 location-based 3,185 (3,704); scope 3 total 270,293 tCO2e (294,751), down 8% (page 145).

Total, scopes 1 and 2 market-based plus scope 3: 274,284 tCO2e versus 299,330 in 2024 pro forma (page 145). Scope 3 is 98% of emissions (page 128). Largest scope 3 lines: purchased goods and services for Property Development 122,787 tCO2e; use of sold products 46,427; investments 20,377.

Intensity (page 145): 204 tCO2e per million euros of revenue (market-based) on revenue of 1,342 million euros.

Restatements: 2019-2024 data were recalculated; 2024 emissions fell 8% on better data (page 130). Icade rates the uncertainty of the inventory as high because much data is estimated (page 96). Biogenic emissions from biogas were 3,271 tCO2 (page 156).

GHG removals and carbon credits

Reference: pages 139, 140, 141; mapped in the index to section 8.1.2.3.

Outside the value chain (pages 139-140): Icade finances carbon sink projects bearing the French Low-Carbon Label, run by STOCK CO2, Société Forestière and Alliance Forêts Bois, all in France. Between 2019 and 2025 it financed forestry projects to sequester 132,000 tCO2e and agricultural carbon reduction projects for 23,000 tCO2e. This matches about 145,000 tCO2e of Property Investment emissions in the SBTi scope (2019-2025) and about 10,000 tCO2e for Corporate (2022-2025).

Accounting: these projects are never deducted from the GHG inventory and are excluded from progress against goals. They are the planned offset for residual emissions at net zero in 2050.

Inside the value chain (page 139): 13% of Icade Promotion's projects (32,027 sq.m) used bio-based or natural mineral materials, storing carbon in buildings. A wooded park at Portes de Paris is expected to sequester 109 tCO2e over 25 years.

Anticipated financial effects from climate risks and opportunities

Reference: pages 138, 139, 152, 153; mapped in the index to section 8.1.4, with the energy-class datapoint at section 8.1.2.2.3.

Transition risk (pages 138-139):

• Asset value by energy rating (5,820 million euros in scope): A 1%, B 22%, C 19%, D 40%, E 5%, F 1%, G 3%, no rating 9%.
• Of 4,536 million euros of well-positioned offices, 91% (4,156 million) are not exposed to transition risk by 2030; 9% (380 million) are, with investment planned for 219 million.
• The 2024 comparison was restated after Icade corrected a two-criteria error (pages 99-100).

Physical risk (pages 152-153): 81% of the 6,127 million euro portfolio (4,948 million) is not exposed to very high physical risk by 2050; 688 million is covered by an adaptation plan; 491 million is to be covered. Adaptation work in 2025 was immaterial in amount.

The index marks the acute/chronic breakdown of physical-risk amounts and the location of significant assets as "Not reported" (page 214).

Biodiversity in strategy and business model

Reference: pages 157, 158, 159; mapped in the index to section 8.2, with the SBM-3 datapoints at section 8.2.1.

Icade frames its biodiversity policy and action plan around the TNFD recommendations and the LEAP method for its own operations (page 157). Goals for 2023-2030 were approved by over 98% of shareholders in April 2023 (page 157). The statement presents an action plan to 2030 (page 160) and does not label any part of it a biodiversity transition plan.

Analysis (page 157): a 2020 study of dependencies, impacts, risks and opportunities across the whole value chain, updated in 2023 with ENCORE and again in 2024-2025 with the Global Biodiversity Score. The score shows impacts driven mainly by Property Development, then Property Investment, mostly upstream (materials and energy).

Resilience (page 159): Icade says the study findings are "insufficient to determine the level of resilience" of its business model.

Sensitive areas (page 159): using the BIODI-Bat tool and a 500 meter radius, 11 Property Investment assets, 4 occupied buildings and 8 new projects were in or near sensitive areas; 4, 3 and 11 respectively were near threatened species.

Biodiversity and soil protection policy

Reference: pages 160, 159; mapped in the index to section 8.2.4.

The policy is set out in an action plan for 2030. It includes rewilding commitments with objectives specific to each division, covers all areas where the Group operates, and is supported by the climate transition plan and the resource use policy (page 160). The Executive Committee members in charge of the two divisions supervise implementation.

Who shaped it (page 160): consulting firms, external biodiversity experts, the CSR Department, and the divisions' CSR heads.

Shareholder votes: the 2024 results were approved by over 99% of shareholders at the May 2025 General Meeting under a Say on Biodiversity resolution.

Scope of objectives (page 159): they follow the avoid, minimize, restore and rehabilitate hierarchy. They are not based on ecological thresholds, and off-site restoration is not used to set objectives or assess achievement.

Icade takes part in Committed Companies for Nature, the B4B+ Club, the Cap 2030 biodiversity working group (GT7) and the Institut de la Transition Foncière (page 160).

Biodiversity and soil actions and resources

Reference: pages 160, 161; mapped in the index to section 8.2.5.

The rewilding trajectory to 2030 rests on four pillars: measuring, avoiding and reducing, rewilding, and off-site habitat restoration (page 160).

Property Development (page 160): biodiversity assessments on every project once land is chosen; landscape architects calculate the harmonized Biotope Area Factor (hBAF) before and after each project; 52% of new builds were rewilded in 2025. Solutions include Ville en Vue, AfterWork and the Urban Odyssey start-up Terre Utile.

Property Investment (pages 160-161): a biodiversity performance contract with CDC Biodiversité since 2014, with actions such as zero chemical inputs, a 1.5 hectare wooded park at Portes de Paris, and airborne eDNA monitoring. 77% of controlled buildings outside business parks had a nature-boosting solution.

Off-site (page 161): a partnership with Nature 2050 funds 1 sq.m of habitat restoration per sq.m developed. Since 2016, 267,000 sq.m were restored (31,000 in 2025) for 1.3 million euros.

Expenses of the plan are not tracked separately and cannot be consolidated (page 161).

Targets related to biodiversity and ecosystems

Reference: pages 159, 162, 163, 165; mapped in the index to section 8.2.2.

Targets (page 159):

• rewild 100% of business parks by 2026, with higher goals in 2030; 2025 indicators worsened slightly at Portes de Paris and improved at Paris Orly-Rungis
• add a nature-boosting solution to 90% of controlled buildings outside business parks by 2026 (77% in 2025)
• rewild 75% of new builds by 2026 and 100% by 2030 (52% in 2025, 22 projects)

They are set against the Kunming-Montreal framework, the EU Biodiversity Strategy 2030 and France's national strategy, not against ecological thresholds (page 159).

Business park scoring (pages 162-163): 19 indicators (1 preliminary hBAF, 7 performance, 9 resource, 2 experimental). Rewilding counts as achieved if the hBAF target is met, at least 50% of performance indicators hit target and all resource indicators do. 2025: Portes de Paris hBAF 0.104, 57% of performance and 56% of resource indicators on target; Orly-Rungis hBAF 0.168, 71% and 89%.

Icade lowered the Portes de Paris habitat targets after ecologists found the earlier ones unreachable (page 98).

Impact metrics related to biodiversity and ecosystems

Reference: pages 159, 163, 166; mapped in the index to section 8.2.2.

Metrics Icade gives:

• Proximity to sensitive areas (page 159): within 500 meters of a sensitive area were 11 Property Investment assets, 4 occupied buildings and 8 Property Development projects; near threatened species were 4, 3 and 11 respectively.
• hBAF (pages 163, 165): Portes de Paris 0.104 (0.071 in 2010); Paris Orly-Rungis 0.168 (0.152 in 2010).
• Invasive species (page 163): at Portes de Paris, the area covered by invasive non-native plants was 8.4% of green space in 2025 versus 0.2% in 2024.
• Soil and connectivity (page 166): a first soil quality assessment with the Genesis tool found soil quality good in all business parks. The habitat connectivity indicator scored Orly-Rungis B and Portes de Paris D on a scale from A to E.
• Biodiversity footprint (page 157): a Global Biodiversity Score study, with limits Icade notes: it tends to underestimate land take.

The statement says certain E4 disclosures are not included under the quick-fix delegated act (page 96) without naming them.

Anticipated financial effects (biodiversity)

Reference: pages 158, 161; mapped in the index to section 8.2.5.

The index places E4-6 at section 8.2.5. That section gives no monetary estimate of financial effects.

What the statement does give is qualitative (page 158). Risks: the "no net land take" (ZAN) objective may raise land and project costs and make building permits harder to get, and missing biodiversity goals could damage brand image. Opportunity: Icade owns a developed land bank and can position itself as a renovation and urban transformation partner with no net land take.

On resources, page 161 says expenses of the biodiversity action plan (mainly purchased services, works and staff time) are not tracked separately in Icade's IT systems and cannot be consolidated.

Page 96 states that, under the quick-fix delegated act, certain E4 disclosures are not included, without naming which.

Policies related to resource use and circular economy

Reference: pages 168, 169, 170; mapped in the index to sections 8.3.2.2 and 8.3.3.2.

Resource use (page 168): Property Development focuses on refurbishment solutions; Property Investment converts and repositions assets, favoring renovation and, where possible, reuse. The Executive Committee members in charge of the divisions run it, under the CEO. The policy does not aim to remove virgin materials. Priorities: extend building life, use fewer materials with more compact buildings, diversify virgin materials, and raise the share of renewable (bio-based), recycled and reused materials. It covers the upstream value chain and own operations, and supply sustainability runs through the responsible procurement policy.

Waste (pages 169-170): Property Development follows French rules on construction waste collection, sorting, recovery and traceability and the waste hierarchy (avoid, reduce, reuse, recycle, recover). A Legal Department memo circulates it; project managers apply it; Internal Control assesses it. Property Investment's waste policy covers operating waste and construction waste (page 170).

Actions and resources for resource use and waste

Reference: pages 168, 169, 170; mapped in the index to sections 8.3.2.3 and 8.3.3.3.

Resource use (pages 168-169): Icade co-created the GEMME circular economy assessment tool in 2023 and joined the Cyneo reuse community in 2025. Property Development offers Ville en Vue and AfterWork (office-to-housing conversion), set up a Refurbishment Department in 2025, and let buyers in the Time project in Saint-Denis choose reused materials. In 2025 refurbishments were 4% of new projects (7,608 sq.m) and 28% of projects used a reuse process (52,806 sq.m). Property Investment added reuse clauses to its standard contracts and applied a reuse process to 100% of projects over 1,000 sq.m.

Waste (pages 169-170): environmental clauses in contracts require sorting and tracing of waste; CERQUAL audits check them; the WasteTracker tool has digitized site waste slips since 2023.

Resources: expenses for the resource use and waste plans are not tracked separately and cannot be consolidated (pages 169, 170).

Targets related to resource use and circular economy

Reference: pages 168, 170; mapped in the index to section 8.3.2.1.

Targets (page 168):

• Property Development: refurbishments to be one-third of projects by 2030. In 2025 they were 4% of the floor area of projects launched (9% in 2024). Icade notes there is no legal requirement behind this target.
• Property Investment: a reuse process for 100% of projects over 1,000 sq.m by 2026. Achieved at 100% in 2025; the target goes beyond regulation.

No target (page 170): Icade Promotion has not set quantitative targets for construction waste management.

Voluntary, not material (page 170): for operating office waste, Property Investment aims to recover 100%, with 45% recycled by 2026 and 50% by 2030. In 2025, 93% was recovered and 34% recycled. Icade presents this under "voluntary non-material disclosures expected by ESG rating agencies".

Resource outflows

Reference: pages 169, 170, 171; mapped in the index to section 8.3.3 (non-recycled waste, paragraph 37(d); hazardous and radioactive waste, paragraph 39).

Property Development (pages 169-170): the waste policy and action plan are described, and WasteTracker, rolled out on all new projects between 2024 and 2025, records quantity, type and treatment of demolition and construction waste. Icade says that "in the coming years" the tool will let it report quantitative outflow data for all projects on a consolidated basis, so no consolidated Property Development figure appears. The division generates no radioactive waste.

Property Investment (pages 170-171): operating waste is quantified in EPRA tables, but Icade places them under voluntary non-material disclosures. Total waste was 9,398 tonnes in 2025 versus 10,945 in 2024, 91% recycled or recovered. Waste detail is in the E5-5-Waste entry.

The statement gives no product or material outflow data beyond waste.

Waste

Reference: pages 170, 171, 173; mapped in the index to section 8.3.3.

Icade presents waste data for Property Investment and the Corporate scope under the heading "voluntary non-material disclosures expected by ESG rating agencies" (page 170), because operating waste is less material than construction waste.

Property Investment, total scope (sole control), reported basis (page 171):

• total waste 9,398 tonnes in 2025 versus 10,945 in 2024; 5.5 kg per sq.m versus 6.1
• recycled 25% (20% in 2024); composted or biogas 4% (2%); incinerated with energy recovery 62% (52%)
• recycled or recovered in total 91% (74%)
• hazardous waste 0.2% of the total (0.004% in 2024)
• 13% of the weight is estimated

Office waste (page 170): 93% recovered and 34% recycled in 2025; the office scope is 65% of floor area and 32% of waste tonnage.

Corporate (page 173): 37 tonnes of waste in 2025 (54 in 2024); 100% recycled or recovered.

Property Development construction waste is not quantified in the statement (page 170). Neither division generates radioactive waste.

Policies related to own workforce

Reference: pages 177, 180, 182, 183, 185; mapped in the index to section 9.1.1.3, with workplace accident prevention at section 9.1.4.2.

The Executive Committee member in charge of HR is responsible for workforce policies, which reflect agreements signed with employee representatives and cover all employees (page 177). The Code of Ethics commits Icade to the UN Global Compact, the OECD Guidelines and the ILO fundamental conventions, and states opposition to discrimination and harassment.

Policies by topic:

• Skills development: the 2023 four-year job and career planning and gender equality agreement (GEPPMM), built on attracting talent, training and internal careers (page 180)
• Remuneration: five pillars including internal equity and external competitiveness (page 182)
• Quality of life and working conditions: a three-year agreement signed in 2023, plus the occupational health and safety policy (page 183)
• Diversity: age, gender equality and disability agreements (pages 185-187)

Non-employees are excluded from policies because no material impacts were found for them. Icade treats forced and child labor risk as negligible and has no policy for specific vulnerable groups (page 177).

Actions on material impacts on own workforce

Reference: pages 178, 180, 181, 183, 184; mapped in the index to section 9.1.

HR drafts action plans with in-house and external experts and discusses them with employee representatives. Effectiveness is judged by progress on the related objectives (page 178). Main actions:

• Skills (pages 180-182): 134 hires in 2025 (78 permanent); training spend of 2.5 million euros, 3.27% of payroll; climate training through the Icade Climate School; a ReShapE Management program reaching 90% of managers; a mobility committee and talent reviews for internal careers.
• Quality of life (pages 183-184): annual risk assessment documents (DUERP) per site, a Health, Safety and Working Conditions Committee that met 4 times, a 24/7 mental health helpline, 42 trained well-being ambassadors in 2024-2025, and an e-learning course on psychosocial risks.
• Diversity (pages 185-187): a female leadership program in 2025, early-career recruitment and disability measures.

Icade says spending on these plans is not tracked separately and cannot be consolidated.

Targets related to own workforce

Reference: pages 124, 180, 182, 185; mapped in the index to section 9.1.

Targets and 2025 results (pages 180, 185, 124):

• fill 30% of positions internally on average over 2023-2026: 59% over 2023-2025
• train 100% of managers in the management culture by 2026: 90% in 2025
• CSR training for at least 90% of permanent employees on average over 2023-2026: 70% so far; quality management training starts in 2026
• job-specific training for 90% of eligible permanent employees: 99% so far
• action plan for each team scoring under 5 out of 10 on well-being surveys: after the 2024 campaign, half the teams got support and training, and management changes removed the need in the rest (page 183)
• 40% women managers in 2026: 38% in 2025
• 20% of permanent hires under age 26 by 2026: 18% of 77 hires
• sheltered work sector procurement up 30% from 2022 to 2026: up 56%, over 1 million euros

Icade says its workers were not directly involved in setting these objectives (page 179).

Characteristics of the undertaking's employees

Reference: pages 179, 187, 188.

At December 31, 2025, Icade had 1,007 employees (1,022 a year earlier), all in France; 63% are in the Paris region (page 179). 547 are women and 460 men, with none reported as other or undeclared.

By contract: 937 permanent (510 women, 427 men) and 70 temporary, meaning fixed-term and work-study (37 women, 33 men). 954 work full time and 53 part time; none are on non-guaranteed hours. Nearly 75% are executives. Average age is 43 and average length of service 10 years.

Movement in 2025 (page 188): 134 hires, 144 departures (104 permanent), overall turnover 14.3%, permanent-employee turnover 11.0% (9.9% in 2024) and 12.7% for permanent employees under two years' service.

Icade reports headcount at year-end; note 12.4 of the financial statements uses an average of 983.5 (page 179).

Characteristics of non-employee workers

Reference: pages 179, 188; mapped in the index to section 9.1.1.9.

Icade's non-employees are agency workers and self-employed workers, mainly supporting the IT and accounting teams (page 179). They are counted in annual full-time equivalents, not headcount (page 98).

The workforce table (page 188) shows 1 agency worker FTE in 2025 (3 in 2024), and "ND" for self-employed workers in both years, so total non-employees is 1 FTE.

Icade says no material impacts, risks or opportunities were found for non-employees, so they are left out of the statement's indicators, action plans and policies (page 177). They can still reach HR, the well-being ambassadors and the whistleblowing system (page 178).

Collective bargaining coverage and social dialogue

Reference: pages 177, 178, 188; mapped in the index to section 9.1.1.4.

All employees are covered by employee representative bodies and by collective agreements (page 177), and the table gives 100% coverage in both 2025 and 2024 (page 188). All employees work in France.

For 2023-2027, social dialogue runs under three collective agreements that define the Economic and Social Unit (UES), the governance rules for representative bodies, and their resources (page 177).

Agreements signed: 3 in 2025 (9 in 2024), none on occupational health and safety (page 188). Icade lists the main agreements in force, including those on gender equality, disability inclusion and quality of life (page 178). One was not signed: the 2026 mandatory annual collective bargaining agreement, because management and unions could not agree the 2026 remuneration policy (page 178).

Diversity metrics

Reference: pages 186, 187, 190; mapped in the index to sections 9.1.5 and 9.1.6.

Gender (page 190): women are 54% of the workforce. They are 38% of managers (254 managers; 35% in 2024) and 42% of top management (37%). Women hold 50% of Executive Committee seats (60% in 2024). The top management group is the Executive Committee plus the 38 members of the 2050 Leaders Committee (page 186).

Age (page 190): under 30 are 17% of employees, 30-50 are 51% and over 50 are 32%. Average age is 43. Employees aged 55 and over were 20% of the workforce (19% in 2024), against a goal of 15% on average over four years (page 186).

Hiring (page 185): people under 26 were 18% of the 77 permanent hires in 2025.

Icade scored 95/100 on the French gender equality index (page 186). Disability data are under S1-12.

Adequate wages

Reference: page 183; mapped in the index to section 9.1.3.

Icade reports that 100% of its permanent employees received an adequate wage in 2025 (page 183). The statement table shows 100% of employees earning above the threshold and 0% below, in both 2025 and 2024 (page 189).

Because EU Directive 2022/2041 on adequate minimum wages has not been transposed into French law, Icade uses the French minimum wage (SMIC) as its benchmark (page 183, note).

Context: average annual base salary of permanent employees, excluding sales and leasing staff, was 64,369 euros in 2025, up 1.7% in average monthly salary on 2024 at constant headcount (page 182). Total payroll was about 77 million euros, down 3.6% (page 183).

Social protection

Reference: page 183; mapped in the index to section 9.1.4.2.

Icade says all employees benefit from social protection under public policies against loss of income from sickness, unemployment, work-related injury and acquired disability, parental leave and retirement (page 183). All employees work in France.

Icade adds company-level cover through collective agreements (page 178): an agreement on contingency insurance, agreements on additional reimbursement of medical expenses (the latest amendment signed September 16, 2025), and a supplementary retirement plan agreement of December 21, 2023 with five further agreements on supplementary retirement plans.

Persons with disabilities

Reference: pages 186, 187, 190; mapped in the index to section 9.1.5.2.3.

At the end of 2025, 53 employees were officially recognized as having a disability, 5.3% of the workforce versus 4.4% in 2024 (page 186; table on page 190 shows 45 for 2024). This is the recognition status used in France (RQTH).

Policy: a fifth agreement on professional inclusion and continued employment of people with disabilities, signed in 2023 for three years (page 186). Under it, 50 employees used at least one measure, such as prepaid service vouchers, paid days off or extra funding for transport. Other actions: the Duoday immersion scheme, European Disability Employment Week events, and a three-year sponsorship of Paralympic athlete Pauline Déroulède.

Procurement from the sheltered work sector was 1,014,032 euros in 2025 against 1,089,284 euros in 2024 (page 190). Effectiveness is measured by the number of workers with disabilities (page 187).

Training and skills development metrics

Reference: pages 181, 189; mapped in the index to section 9.1.2.2.2.

• Participation: 98% of employees received at least one form of training in 2025 (page 181).
• Hours: 19,072 hours in total (13,420 in 2024), an average of 19 per employee: 18 for women and 21 for men (pages 181, 189).
• Spend: 2.5 million euros, 3.27% of payroll (2.75% in 2024).
• Performance reviews: 100% of the employees concerned had an annual review, which is 87% of employees at year-end, 87% of women and 87% of men (page 181; the table gives 87% against 94% in 2024).
• Content: CSR training was 9% of hours (1,661 hours); 121 employees joined climate workshops; 422 were trained on avoiding greenwashing; 90% of managers took part in the ReShapE Management program.

Icade-specific indicator: 59% of positions filled internally on average over 2023-2025 (page 182).

Health and safety metrics

Reference: pages 184, 189, 190; mapped in the index to section 9.1.4.2.1.

Employees (pages 184, 190):

• 100% are covered by a health and safety management system
• work-related injuries: 10 in 2025 (9 in 2024), with 1,461 days lost (889)
• frequency rate 6.31 (5.46); severity rate 0.92 (0.54)
• work-related ill health: 1 case, 40 days lost
• commuting accidents: 11 (8)
• fatalities: 0 among employees, non-employees and other workers
• absenteeism 4.13% (3.76%), 15,163 days (14,353)

Icade attributes the 2025 injuries mainly to isolated incidents, not hazardous working conditions (page 184).

Non-employees: the share covered by a management system is "ND", injury counts are "N/Av." and their frequency rate is "ND" (pages 189-190).

Value chain workers on Icade sites are covered under S2: no fatal or serious accidents in 2025 (page 194).

Work-life balance metrics

Reference: pages 184, 190; mapped in the index to section 9.1.4.2.2.

All employees (100%) are entitled to family-related leave. In 2025, 5.0% took it (4.6% in 2024): 6.2% of women (5.1%) and 3.5% of men (4.1%) (page 190).

Measures in place (page 184):

• remote work for permanent and fixed-term employees in eligible positions since 2017, now under a two-year teleworking charter from 2025
• a right to disconnect, set in the 2023 quality of life and working conditions agreement and detailed in a charter
• support for caregivers through a social worker and a leave donation scheme, with training offered to caregivers and managers in 2024
• parent measures from 2024: prepaid childcare service vouchers and the "Lyfe, moi parent" platform (page 186)

Icade says it did not renew the OsmoZ wellness label for its three Paris-region sites after the head office moved (page 184).

Compensation metrics (pay gap and total compensation)

Reference: pages 183, 186, 189; the pay ratio is also covered in chapter 5, section 3.4.

• Unadjusted gender pay gap: 26% in 2025, unchanged from 2024. Icade calculates it on average gross hourly pay and says it does not compare equivalent positions (page 186).
• Gap for equivalent positions: close to 0% in 2025 (0.03% in the table), against 4% in 2024; no employee category had a gap above 5% (3 did in 2024) (pages 186, 189).
• Pay ratio: the highest-paid individual earned 11.16 times the median total remuneration of permanent and fixed-term employees (10.42 in 2024 after Icade restated the figure to include the CEO) (pages 183, 100). Chairman and CEO ratios to mean and median pay are in chapter 5.
• Budget: about 80,000 euros a year, 0.1% of payroll, is set aside to reduce unjustified gaps; 80% was used in 2025 (page 186).

Average base salary of permanent employees (excluding sales and leasing staff) was 64,369 euros, with variable pay averaging 15.5% of base (pages 182-183).

Policies related to value chain workers

Reference: pages 192, 193, 194; mapped in the index to sections 9.2.4 and 10.

The value chain worker policy is defined through the procurement policy, which covers all purchases by Icade staff. A Responsible Procurement Charter is attached to Property Investment service and construction contracts and to Property Development projects. Suppliers commit to business ethics; labor standards, ILO conventions and human rights; employment and professional integration; and health and safety (page 192).

Icade operates only in France and treats forced and child labor risk in its value chain workforce as negligible, but names the issue in its Code of Ethics and the charter. Suppliers must follow both and have access to a whistleblowing system (page 192).

Health and safety (page 193): a Group risk prevention policy sets a goal of "zero accidents". Deputy CEOs and delegated staff, and the Head of Project Management for Property Investment sites, are responsible for it.

Illegal employment (page 194): a zero tolerance policy, owned by the same managers and the heads of project and property management.

Actions on material impacts on value chain workers

Reference: pages 193, 194; the index also lists the human rights incidents datapoint (paragraph 36) as "No incidents" (page 220).

Health and safety, Property Development (page 193): framework agreements with designated coordinators; a safety check at the start of each site meeting; posters of eight key safety principles on all sites since 2023; mandatory training in 2023, 2024 and 2025 for some employees; a 20-point checklist on safety and undeclared work.

Property Investment (page 193): a Health, Safety and Environment team supporting prevention plans, a document management tool for those plans finished in 2025, a Safety and Security Department, and mandatory site-risk training.

Illegal employment (page 194): contractors must register on a document checking platform; coordinators make at least two unannounced inspections on projects over four months; training in 2023 and 2024 for both divisions and in 2025 for Property Development only. Remedies: compliance orders, penalties or contract termination, and withdrawal of subcontractor approval.

Results: no serious or fatal accidents and no illegal employment cases in 2025 (page 194). Spending is not tracked separately.

Targets related to value chain workers

Reference: pages 191, 194; mapped in the index to section 9.2.3.

Icade's single target is "zero accidents" under its health and safety policy for value chain workers. Progress in 2025: no fatal or serious accidents on Icade sites (page 191). The objectives table tracks fatal accidents involving value chain workers on Icade sites, covering 100% of those workers (page 125).

The objective was submitted by the CEO and Executive Committee and approved by the Board on the recommendation of the Innovation and CSR Committee (page 192).

For illegal employment, Icade sets no quantitative target. It says effectiveness is judged by its zero tolerance policy, and no cases were reported in 2025 (page 194).

Policies related to affected communities (affordable and inclusive housing)

Reference: pages 195, 117, 118; the index lists this as S3 MDR-P, policies related to affected communities (page 221).

Icade treats affordable and inclusive housing as a specific topic and reports it under the minimum disclosure requirements, not under S3-1 (page 195). The S3 table of material sub-topics lists "Affordable and inclusive housing" (page 118).

Policy (page 195): Icade drafted a policy to promote affordable and inclusive housing in France, under the Executive Committee member in charge of Property Development, with operational teams across France developing solutions. Target groups are low-income households, students and seniors, and people with reduced autonomy or mobility who need adapted facilities and services. It also shapes the innovation initiatives and the projects chosen by the Urban Odyssey start-up studio.

The index points S3 MDR-P to section 9.3 and marks the human rights incidents datapoint (paragraph 36) "No incidents" (page 221).

Actions on affordable and inclusive housing

Reference: pages 196, 195; the index lists this as S3 MDR-A, actions and resources in relation to affected communities (page 221).

Icade Promotion follows two tracks (page 196).

Affordable homes: long-term partnerships with social housing providers (CDC Habitat, Action Logement Immobilier); and land leases that make ownership affordable (BRS) through the corporate foundation Icade Pierre Pour Tous, the first community land trust created by a French property developer. Icade aims to sell 10% of new housing under such leases by 2026, 600 to 700 homes a year. The first BRS project, in Cognin (Savoie), has 140 planned units with 28 sold about 35% below market price. In 2025 a project in Saint-Denis started with one third of units under a BRS lease.

Inclusive and shared housing: serviced residences for people with disabilities and seniors, and shared housing through Domani, which had 20 facilities in operation at the end of 2025 and aims to open 10 a year and house 1,000 older people by 2030.

Resources are not tracked separately and cannot be consolidated.

Targets on affordable and inclusive housing

Reference: pages 195, 197; the index lists this under S3 indicators and objectives (MDR-M and MDR-T, page 221).

Target (page 195): at least 30% of housing sold each year is affordable and inclusive, starting in 2023. In 2025, 65% of orders for residential units were affordable and inclusive housing. Affordable housing counts social and intermediate units, low-cost and affordable ownership units and BRS land leases; inclusive housing counts living spaces adapted to people with disabilities and seniors (page 196, note).

Icade says the people concerned are not involved in setting the objective, monitoring performance or implementing improvements (page 195). The objective was approved by the Board on the recommendation of the Innovation and CSR Committee.

Voluntary extra, marked non-material by Icade (page 197): the Property Investment Division held 23 social impact activities in 2025 (33 in 2024) against a goal of increasing them over 2022-2026, and sponsorship and patronage came to about 800,000 euros.

Policies related to consumers and end-users

Reference: pages 198, 200, 201, 202; mapped in the index to sections 9.4.3.2 and 9.4.4.2.

All customers and end-users of both divisions were considered in the double materiality assessment, and Icade found no impacts specific to any category of customer (page 198). None are consumers under the SBM-3 paragraph 10(a) categories (i), (iii) and (iv).

Customer satisfaction (page 200): Property Investment's policy is run by the Head of Leasing and Customer Experience; Property Development's by the Head of Quality and Customer Experience. Both cover engagement channels and action plans for occupant health, safety and well-being.

Responsible sales (page 201): Icade Promotion has no dedicated policy and relies on the regulatory framework for off-plan sales and sales with a renovation clause.

Data protection (page 202): the internal "Manifesto for the handling of personal data" sets nine principles for ethical data management. The Data Protection Officer reports to the Head of Compliance.

The index marks the human rights incidents datapoint (paragraph 35) "No incidents" (page 222).

Actions on material impacts on consumers and end-users

Reference: pages 200, 201, 202, 203; the index lists S4-4 and the human rights incidents datapoint as "No incidents" (page 222).

Property Investment (pages 200-201): the Health, Safety and Environment team runs actions on comfort, emergencies and accessibility under a Certivea HQE-certified management system covering 29% of the operating portfolio. Five health and safety incidents were reported in 2025 (minor pollution, falling objects, a small fire). Voluntary HSE audits began in 2023, and an annual external audit program on safety and security has run since 2017. 98% of offices under operational control had indoor air quality measurements.

Property Development (pages 201-202): NF Living Environment certification covered 91% of residential projects (161,197 sq.m), with indoor air quality measures and acoustic comfort set at noise levels half the regulatory maximum. 422 employees were trained to avoid greenwashing. Buyers get a digital user guide.

Privacy (page 203): policy, procedures, training and incident monitoring; no data breaches posing a high risk to individuals were identified in 2025. Spending is not tracked separately.

Targets related to consumers and end-users

Reference: pages 199, 200, 202; mapped in the index to sections 9.4.3.1 and 9.4.4.1.

Targets and 2025 results (page 199, unless noted):

• measure indoor air quality in 100% of offices under operational control from 2025: 98% (845,017 sq.m)
• positive Net Promoter Score for Property Investment tenants, improving on 2021: positive again in 2025 and above the prior year
• positive buyer Net Promoter Score at completion for Property Development: positive in 2025
• indoor air quality measures in at least 75% of residential projects each year: 91%
• wellness label on 100% of office projects over 10,000 sq.m: none started in 2025
• personal data protection training for 90% of employees most at risk, each year 2023-2026: 91% in 2025 (page 202)

Icade says customers and end-users were not involved in setting these objectives, and that satisfaction surveys are the route for suggestions (page 200).

Business conduct policies and corporate culture

Reference: pages 204, 206, 207, 208; mapped in the index to sections 5.1, 10.1.1 and 10.2.2, with whistleblower protection at 10.2.4.

Oversight (page 206): the Audit and Risk Committee oversees business ethics policies and reports to the Board. Compliance procedures face internal controls and internal and external audits each year.

Policy (page 207): the Code of Ethics, in line with the UN Global Compact and OECD Guidelines, applies to all workers and service providers. It is backed by an Anti-Bribery and Corruption Policy (2021) and an IT administrators charter (2022). The Code and anti-corruption policy were updated in 2024 and took effect in 2025. The Head of Compliance reports to the Executive Committee member in charge of Audit, Risk, Compliance and Internal Control.

Whistleblowing (page 207): a secure online system, open around the clock to workers, former employees, job candidates, shareholders, governance members, contractors and subcontractors. Icade commits that no whistleblower will face retaliation; policies were revised in 2025 to prevent conflicts of interest.

Training (pages 207-208): mandatory ethics and Sapin II training for all employees and new hires; the Board and Executive Committee were trained on conflicts of interest and corruption in 2025.

Targets related to business conduct

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

Reference: pages 204, 206, 208.

Ethics target (page 206): train 90% of employees identified as most at risk (134 people in sales, asset management and business development) in the fight against fraud, corruption, money laundering and terrorist financing each year from 2023 to 2026. In 2025, 96% were trained.

Supplier targets (page 204): include CSR criteria in 100% of large requests for quotation from 2023 (78% by value in 2025), and assess 100% of Property Investment's main service providers and Property Development's suppliers from 2024 (100% and 70% in 2025).

Icade says the effectiveness of its ethics action plan is measured by the number of incidents reported (page 208). The objectives were approved by the Board on the recommendation of the Innovation and CSR Committee (page 207).

Incidents of corruption or bribery

Reference: pages 209, 104; mapped in the index to section 10.2.5.

2025 incidents (page 209): an internal fraud report was received. The investigation confirmed the fraud, disciplinary measures were imposed and a recommendation was made to remedy the situation. A conflict of interest investigation still open at the end of 2024 was closed in 2025 and dismissed without further action. Icade records one business ethics incident in 2025, linked to the confirmed fraud.

Proceedings and convictions: no legal proceedings relating to corruption or AML/CFT are pending against Icade, which was not found to have committed any business ethics violations during the year (page 209). In its Taxonomy minimum safeguards review, Icade says it was not convicted of any offense relating to human rights, corruption, business ethics or its tax policy in 2025 (page 104).

Safeguards: each new permanent employee signs a Declaration of No Conflict of Interest, with at-risk categories signing yearly; from 2026 all employees will (page 209).

The statement gives no amount of fines.

Political influence and lobbying activities

Reference: pages 209, 114; mapped in the index to section 10.2.7.

The Head of Communications and Institutional Relations manages dealings with Parliament and ministries, and the CEO oversees lobbying. Icade reports its lobbying activities and spending each year to the French High Authority for Transparency in Public Life (HATVP). It gives no funds or services to any political party, elected official or candidate.

2025 (page 209): 51 lobbying activities reported, with spending between 100,000 and 200,000 euros (19 activities and 50,000 to 75,000 euros in 2024). Sustainability-related topics covered converting offices into housing, redeveloping commercial areas on city fringes into mixed-use neighborhoods, affordable housing through the Intermediate Rental Housing scheme, and support for ambitious RE2020 thresholds. Other lobbying, mainly on tax issues, also took place.

Icade lists its affiliated organizations: AFEP, EPRA, FEI, FPI, IEIF, IFPImm, MEDEF and ORIE. Board members' current and past offices are in chapter 5 (page 209).

Payment practices

Reference: pages 205, 206; mapped in the index to section 10.1.4.

Icade pays under the French LME law, with terms of 30 to 60 days depending on contract. It has no standard payment terms across all contracts. Some contractor invoices carry 45 days from the end of the month. Contractor invoices are issued as work progresses and checked by an external project manager before they reach Icade (page 205).

2025 (page 206):

• average payment period of 32 days from receipt of the invoice and 61 days from its issue date, because of the approval process, especially for construction work
• 73.4% of invoices paid within 60 days of the invoice date, or 94.7% within 60 days of receipt
• no dispute over late payment by Icade pending

Icade has processed supplier invoices electronically for several years and is preparing for mandatory electronic invoicing in 2026 (page 205).