LAMDA Development

The current Board of Directors was elected by the Extraordinary General Meeting on 22 December 2020 for a five-year term ending 22 December 2025. It has eleven members, without employee representation, comprising one executive and ten non-executive directors, of whom five are independent. Women represent approximately 27.27% of the Board, men approximately 72.73%, and independent non-executive directors approximately 45.45%. Members bring expertise in real estate development, infrastructure, corporate governance and strategic management. The Board is the highest governing body and holds ultimate responsibility for strategic management and sustainability performance, approving the corporate purpose, mission, Sustainable Development Strategy, policies and targets. Its role is reinforced by the Sustainable Development Committee (a mix of mostly independent non-executive members and senior executives), the Audit Committee, the Compensation and Nomination Committee, and the Investment Committee. The CFO oversees the Financial Statement including the Sustainability Statement, while the CIO is responsible for the Sustainability Statement. The Sustainability Department operates under the Investment Division. A Training Policy for Board Members and Executives supports ongoing education.

The Sustainable Development Committee meets regularly and oversees bimonthly reports from the Sustainability Department covering performance, risks, opportunities and progress toward objectives, shared with the CIO. The Board of Directors is informed about sustainability matters at least twice a year by the Committee and receives an annual report on the Committee's proceedings. In 2024 the Board reviewed and approved the Committee Rules of Procedure and its update, the Annual Financial Report including the Non-Financial Report 2023 with EU Taxonomy Report and Carbon Measurement, the Double Materiality Assessment process and result for 2023, and the Annual Sustainable Development Report 2023. The Committee, meeting at least every two months, also approved the Group's Decarbonisation Strategy and inclusion of sustainability criteria in new investment proposals, and was informed on EU Taxonomy alignment, Green Bond use of proceeds and GRESB results. The Audit Committee is briefed via the Internal Audit Service. Risk reporting is annual to the Board and quarterly to the Audit Committee by the Risk Management Unit. The 2024 Double Materiality Assessment was validated by senior management and the Committee and presented to the Board.

The remuneration of Board members is set out in the Remuneration Policy, approved by the General Meeting on 21 June 2023 and valid for four years unless revised earlier. It was prepared in accordance with the EU Shareholder Rights Directive as incorporated into Greek law by Law 4548/2018, and also considers Law 4706/2020, the Articles of Association, the Corporate Governance Code and the Internal Regulations. At present the Group does not assess Board performance against specific sustainability-related targets, but states this will be evaluated in coming years with progress reported in future. Executive Directors receive annual variable remuneration directly linked to individual and Group performance and to specific targets aligned with strategic and financial objectives. At the start of each financial year the Compensation and Nomination Committee approves the performance criteria and their weighting for the short-term incentive (Bonus Plan). These criteria include financial and non-financial measures, with sustainability issues incorporated alongside KPIs such as EBITDA, NAV, cash flows and key milestones of The Ellinikon Project, tailored to individual responsibilities and evaluated at year end.

The statement on due diligence maps the five core elements to sections of the Sustainability Statement: embedding due diligence in governance, strategy and business model (GOV-2, GOV-3, SBM-3); engaging with affected stakeholders in all key steps (GOV-2, SBM-2, IRO-1, MDR-P); identifying and assessing adverse impacts (SBM-3, IRO-1); taking actions to address them (MDR-A); and tracking effectiveness and communicating (MDR-M, MDR-T). As part of its commitment to the UN Guiding Principles, the Group conducts continuous human rights due diligence within its own operations and value chain, to assess, address and report on actual and potential human rights risks, reviewing and communicating efforts annually. It is dedicated to eliminating all forms of forced, bonded and compulsory labour, modern slavery and human trafficking, and explicitly prohibits child labour, observing minimum recruitment age limits. The Group strives to provide effective and fair remediation where it has caused or contributed to adverse impacts, paying particular attention to vulnerable groups. To broaden responsible practices across its supply chain, it has begun initiatives such as a sustainability-related questionnaire for evaluating potential Contractors for The Ellinikon Program.

The Internal Control System comprises internal control mechanisms and procedures covering every activity, with the Board ensuring its adequate functioning under Law 4706/2020. The Risk Management System and Regulatory Compliance System are integral parts of it. The Audit Committee assists the Board on the effective operation of internal control including risk management, and supervises the Risk Management Unit. Internal Audit reports functionally to the Audit Committee and administratively to the CEO. Under the digital Enterprise Risk Management system and Risk Management Policy, risk severity is assessed from likelihood and effect to give an inherent risk score, ranked in four levels (Very High, High, Medium and Low), with likelihood ranging from 1% to 99% and effect considering financial, reputational, legal, health and safety, environmental and social factors. During 2024 the risk management and internal control processes for sustainability reporting were outlined in a dedicated Sustainability Statement Reporting Procedure, approved by the Sustainable Development Committee in March 2025, with identified risks integrated into the ERM program. Main reporting risks include insufficient or inaccurate data, unclear understanding of regulatory requirements, missed deadlines, disclosure of confidential information, inadequate collaboration with consultants, and insufficient coordination, each with mitigation strategies. Audits are performed by internal and external auditors.

LAMDA Development S.A., listed on the main market of the Athens Stock Exchange, is a holding company specialising in the development, investment and management of real estate. The Group operates primarily in Greece and in Southeastern Europe, including Serbia, Romania and Montenegro. Its activities focus on The Ellinikon development at the former Elliniko airport, shopping centers (The Mall Athens, Golden Hall, Mediterranean Cosmos, Designer Outlet Athens, and the under-development Ellinikon Mall and Riviera Galleria), marinas (Flisvos, Agios Kosmas and the future Corfu Mega Yacht Marina), and other investments in real estate and energy. The value chain spans upstream partners, own operations and downstream stakeholders such as tenants and visitors. Since the start of its operation, sustainable development has been part of its strategy, aligned with the UN SDGs. In 2024 the Group developed a Decarbonisation Strategy following the Science Based Targets initiative and the Sectoral Decarbonization Approach, complying with the IPCC 1.5 degrees Celsius scenario. Its Ellinikon Program strategy, developed since 2021, rests on three pillars: Decarbonisation, Circularity, and People and Prosperity. The Group is active in NACE sectors F43, G47, H52, L68, K64 and R91. The final Strategy is expected in 2025.

The Group maintains constant communication with stakeholders in its internal and external environment, identifying key stakeholders as individuals or groups whose interests may be positively or negatively affected by its activities and business relationships across the value chain, with special consideration for regions where it operates and owns properties. The main stakeholder groups are employees; customers, buyers, consumers, visitors and end-users; suppliers, partners and contractors; shareholders, investors and capital and finance providers; wider society; local community and authorities; state and regulatory authorities; the business community; and the academic and scientific community. Engagement channels and frequency are documented for each group, ranging from daily to periodic. The Group's understanding of stakeholder interests is integrated into its strategy and business model through continuous engagement and monitoring. For The Ellinikon, the Stakeholder Engagement Plan, revised in 2024 and aligned with EBRD requirements including PR10, sets out identification, mapping, information disclosure, consultation, public participation and a grievance mechanism, monitored through performance indicators. Administrative, management and supervisory bodies receive timely insights from the Corporate Communication, Human Resources and Investor Relations departments, ensuring stakeholder feedback informs the management of sustainability-related impacts.

The material impacts, risks and opportunities identified in the Double Materiality Assessment are presented in tables with a description, value chain position, time horizon, and, for impacts, whether actual or potential. Material topics span E1 Climate Change (including climate change adaptation, mitigation and energy), E2 Pollution of air and water, E3 Water and marine resources, E4 Biodiversity and Ecosystems, E5 Circular economy (resource inflows and waste), G1 Business conduct (corporate culture, corruption and bribery, and management of supplier relationships), S1 Own workforce, S3 Affected communities, and S4 Consumers and end-users. The present financial effect of the material risks and opportunities is not significant. As this is the first year of ESRS reporting, the Group has not made quantitative estimations of financial outcomes and has recognized time horizons only for potential impacts. Compared with the 2023 assessment, Pollution of water and Social inclusion of consumers and end-users were newly identified as material, while workers in the value chain, protection of whistleblowers, working time, social dialogue and freedom of association were not identified as material. Most IROs relate closely to the business model and are managed throughout the value chain. One risk, arising from a dependency on manpower shortage, does not stem from an identified impact.

The Group follows a comprehensive Double Materiality Analysis to identify, prioritize and monitor impacts on people and the environment as well as risks and opportunities, in accordance with the CSRD. It is a dynamic, annual process combining financial and impact materiality and integrating data from the internal Risk Registry. The methodology covers the entire value chain, upstream and downstream, plus own operations, and proceeds through understanding the business model and current state, peer benchmarking and sector analysis, stakeholder and value chain mapping, identification of actual and potential IROs, and assessment and scoring aligned with the CSRD and ESRS 1 and ESRS 2. Impact materiality scoring evaluates Scale, Scope, Irreversibility (only for negative impacts) and Likelihood (only for potential impacts). Financial materiality scoring considers Magnitude, Likelihood, and operational, regulatory or legal and reputational effects, across short-term (within one year), mid-term (one to five years) and long-term (five to ten years) horizons. The process is aligned with the ERM framework and Risk Management Registry. External stakeholders were engaged through an online survey, thresholds were applied to determine material topics, and results were validated by top management and the CEO, approved by the Sustainable Development Committee, and reported to the Board.

The Sustainability Statement is prepared on a consolidated basis in accordance with Law 5164/2024, which transposed the CSRD, with sustainability matters determined through the Double Materiality Assessment. Alongside the ESRS 2 General Disclosures (covering general basis of preparation, governance, strategy, double materiality and the IRO process), the statement reports the topical standards found material through the assessment: E1 Climate Change, E2 Pollution, E3 Water and marine resources, E4 Biodiversity and Ecosystems, E5 Circular economy, S1 Own workforce, S3 Affected communities, S4 Consumers and end-users, and G1 Business conduct. Once material matters were identified, the Group assessed the information to be reported for each based on the materiality of information under ESRS 1, applied at the Disclosure Requirement and datapoint level. For the first year of ESRS reporting, a phasing-in approach was applied to certain datapoint disclosures, such as the anticipated financial effects disclosure. Certain disclosure requirements, including GOV-1, GOV-2, GOV-3, GOV-5 and SBM-1, are covered through incorporation by reference to sections of the Corporate Governance Declaration and the Group Financial Position within the Board of Directors Management Report.

LAMDA has measured its total carbon footprint annually since 2022 under the GHG Protocol, externally verified to ISO 14064-1:2018, and built a Decarbonisation Strategy. In 2024 it adopted the SBTi Sectoral Decarbonization Approach (SDA) for buildings, setting near-term science-based targets aligned with a 1.5 degrees C pathway and the Paris Agreement, using a 2022 baseline and 2030 target year. Targets cover in-use operational building emissions intensity (69% cut), non-building operational absolute emissions (42% cut) and value chain intensity (52% cut). LAMDA commits to no new fossil fuel equipment from 2030, 80% renewable electricity by 2029 and 100% from 2030, and plans to submit targets to SBTi for validation in H1 2025. Estimated CAPEX of more than 10 million euros by 2030 supports decarbonization levers across energy efficiency, on-site PV, renewable procurement and value chain measures. LAMDA is not excluded from Paris-aligned benchmarks and invested no CapEx in coal, oil or gas in 2024.

The Group's Sustainable Development Policy, adopted by the Board of Directors, is the basis for managing climate change mitigation and adaptation impacts, risks and opportunities. It integrates the Group's vision and UN SDG commitments and ensures material environmental aspects including climate change are identified, assessed and managed per ESRS requirements. The policy highlights climate change in business activities and materiality analysis but does not specify actions on renewable energy deployment or energy efficiency; it also covers air quality, biodiversity, waste and resource efficiency. The Ellinikon project has its own Sustainable Development Policy addressing net zero, climate resilience, energy efficiency and renewable energy under an Energy and Carbon section. The Ellinikon Strategy, completed in 2021 and approved by the BoD in 2022, has three pillars: Decarbonization, Circularity, and People and Prosperity. Each shopping center also has an Environmental Policy supported by an ISO-certified Energy Management System.

LAMDA implemented energy efficiency measures (upgrading HVAC, central ventilation and lighting), fleet electrification to hybrid and electric vehicles, and increased renewable procurement. Under-development buildings target EPC A+ or at least 10% below NZEB energy consumption, with LEED certification pursued; the Building Complex for People with Disabilities achieved LEED Platinum in 2024. Net-metering rooftop PV was approved for The Mall Athens (0.39 MW), Golden Hall (1.6 MW), Mediterranean Cosmos (0.8 MW) and Designer Outlet Athens (0.346 MW), expected complete by February 2025, with 0.56 MW planned at Flisvos Marina in 2025; a 243 MW wind farm has been under development since 2023. ISO 14001 and ISO 50001 certifications were completed in 2024. Initiatives are funded through own resources, a 2022 Green Bond and the RRF. Under the EU Taxonomy for 2024, Taxonomy-aligned proportions were: turnover 19.88% (132.21m euros), CapEx 50.05% (46.60m euros) and OpEx 32.63% (3.21m euros); eligible proportions were turnover 39.92%, CapEx 78.08% and OpEx 87.95%.

All GHG reduction targets use the SBTi methodology aligned with a sectoral decarbonization pathway and 1.5 degrees C, are gross (excluding removals, carbon credits and avoided emissions), and use a 2022 base year to be updated every five years from 2030. Three near-term 2030 targets cover 100% of GHG emissions: (1) reduce in-use operational building emissions intensity by 69%, from a 62.93 kgCO2e/m2 baseline to a targeted 19.55 kgCO2e/m2, covering Scope 1, Scope 2 and Scope 3 category 13; (2) reduce non-building operational absolute emissions by 42%, from a 999.2 tCO2e baseline to 579.9 tCO2e, covering remaining Scope 1 mobile combustion and Scope 2; (3) reduce all other corporate Scope 3 emissions intensity (excluding category 13) by 52%, from 46.80 kgCO2e/m2 to 22.65 kgCO2e/m2. Future upfront embodied carbon and lifetime in-use operational targets are being monitored, with embodied target-setting not expected until 2026. Targets are to be submitted to SBTi for third-party validation within 2025; 2025 is the first implementation year so no progress is yet tracked.

Total energy consumption in 2024 was 55,107.49 MWh. Total fossil energy consumption was 51,389.49 MWh (93.25% of total), comprising 1,592.46 MWh from crude oil and petroleum products, 5,541.57 MWh from natural gas, zero from coal and other fossil sources, and 44,255.46 MWh of purchased electricity, heat, steam and cooling from fossil sources. Consumption from nuclear sources was zero. Total renewable energy consumption was 3,718.00 MWh (6.75% of total), all from purchased renewable electricity, heat, steam and cooling; fuel from renewable sources and self-generated non-fuel renewable energy were both zero. Non-renewable and renewable energy produced were reported as N/A. All 55,107.49 MWh came from activities in high climate impact sectors, against net revenue from those sectors of 621,892,348.60 euros, giving an energy intensity of 0.88 MWh per million euros. Total net revenue per the financial statements was 665,020,633.17 euros.

LAMDA has measured and verified its carbon footprint under ISO 14064-1:2018 since 2022 following the GHG Protocol, using IPCC AR5 100-year GWP values. For 2024, gross Scope 1 emissions were 1,782.02 tCO2e (0% from regulated emission trading schemes). Scope 2 emissions were 11,820.79 tCO2e location-based and 8,446.81 tCO2e market-based. Total gross Scope 3 emissions were 76,561.36 tCO2e, dominated by capital goods (35,694.24 tCO2e) and downstream leased assets (23,630.35 tCO2e), with purchased goods and services 7,097.06, fuel and energy-related activities 7,015.72, waste 2,611.78, employee commuting 299.19, business travel 115.57 and investments 97.45 tCO2e. Total GHG emissions were 90,164.15 tCO2e location-based and 86,790.17 tCO2e market-based. GHG intensity was 0.13 tCO2e per million euros of net revenue (both bases), on total net revenue of 665,020,633.17 euros. There were no biogenic CO2 emissions across the value chain.

The Group manages pollution impacts, risks and opportunities through its Sustainable Development Policies and Environmental Policies rather than a separate standalone pollution policy. The Sustainable Development Policy for The Ellinikon focuses on minimizing air and noise pollution during construction and operation, and its Environmental Policy emphasizes preventing pollution across the value chain. Environmental Policies at the Shopping Centers center on pollution prevention and regulatory compliance, and the policy at Flisvos Marina focuses on pollution prevention with full compliance to local and international legislation. The Ellinikon strategy commits to avoiding and minimizing air, dust and noise pollution, establishing baseline conditions, keeping air pollution below European Environment Agency guideline limits, and keeping noise below approved Environmental Terms. As part of the ISO 14001:2015 certified EMS, an Environmental Monitoring Procedure covers monitoring, evaluation and mitigation of air and water pollution across the development and third parties.

The Group prevents and manages pollution through ISO 14001 certified Environmental Management Systems in place across all entities. At The Ellinikon, actions run during the construction phase, with an Environmental Compliance Team and the Sustainability Department overseeing prevention and working with third-party contractors. Environmental protection clauses are built into subcontractor contracts, mandating compliance, prevention practices and monitoring. An Environmental Management Plan for the Construction Phase applies to all projects and monitors specific air and water pollution indicators. Sites use dust suppression, CE-certified machinery and controlled water discharge management to protect coastal water quality. For soil pollution prevention, the Group allocated 6 million euros for site remediation of contamination from past airport operations, appointing specialized contractors, plus spill prevention equipment and pollution control kits. Air actions include the Air Pollution Reduction Program and Dust Suppression Procedure. Flisvos Marina installed two Seabins, contracted a 24/7 marine pollution emergency response, and holds Clean Marina and Blue Flag distinctions.

The Group has not established measurable, outcome-oriented and time-bound targets to manage its material impacts, risks and opportunities regarding air pollution. However, it has identified specific targets and metrics to systematically monitor the effectiveness of its policies and actions. The primary objective for air and water pollution at construction sites is to comply with national limits and the approved Environmental Terms of The Ellinikon, backed by a strict annual monitoring process. On an annual basis the Group has set objectives to conduct 24-hour air pollution measurements at 100% of active construction sites, achieve 0% quantities of uncontrolled wastewater discharge, and record 0% exceedances of the legislation threshold values for dust emissions (PM2.5 and PM10). For the marine environment, the main objective is to avoid pollution and minimize impacts of construction works on seawater and phytobenthic communities, comparing measurement results against baseline conditions established before works began on the coastal front.

The Group tracks changes in pollution through regular air and water monitoring. For the reporting year it did not record any exceedances of the pollutant limits in Annex II to Regulation (EC) No. 166/2006, so it does not disclose pollutant volumes in mass units. Air monitoring at The Ellinikon runs monthly with calibrated certified equipment, covering daily 24-hour PM10, PM2.5 and PM1 and daily CO, NO2, O3, VOC and benzene measurements. Contractors' 2024 dust measurements covered 100% of sites across 1,313 measurements with 40 exceedances (3%); the Company's own measurements from June to December 2024 at nine points recorded 15 exceedances of 317 (5%), mainly from weather such as strong winds and African dust. Contractors' other air pollutant measurements totaled 842 with 27 exceedances (0.03%), linked to traffic not construction. Water pollution is assessed through dewatering effluent and seawater monitoring, with monthly assessment of about 40 pollutants; across 7 sites and 100% of sites requiring dewatering there were 0 uncontrolled discharges. Marine monitoring by the Hellenic Center for Marine Research found no impacts from construction.

The Group aligns its water management objectives with the development of The Ellinikon, following the Sustainable Development Policy, the Sustainable Development Strategy and the Environmental Management System. For The Ellinikon, the Sustainable Development Policy Statement identifies water and wastewater as one of the 11 objective areas under its sustainability strategy, aiming to maximize water efficiency and minimize wastewater production, positioned as a key objective within the Circularity pillar. The strategy recognizes smart water management as one of the key pillars of the Ellinikon Smart City principles, designed to ensure sustainable resource supply and regenerative systems for the broader region. The Environmental Policy of each operating asset (Golden Hall, The Mall Athens, Mediterranean Cosmos, Designer Outlet Athens) highlights rational use of water and raising public awareness of water conservation. A formal water policy has not yet been adopted, as there has been no need for extensive water-dedicated provisions, but the Group plans to update the Sustainable Development Policy within 2025 to comprehensively manage its water-related impacts, risks and opportunities.

The Group manages water efficiently across Shopping Centers, marinas and new developments, focusing on monitoring, optimizing and reducing potable water use through water-saving mechanisms, alternative sources and wastewater management. During 2024 it recognized no negative impacts related to water consumption. At The Ellinikon, water is supplied by the EYDAP network and a Water Management Plan within the Environmental Management Plan for the Construction Phase includes a Water Saving Programme and Water Quality Assurance Programme, with measures such as reusing treated water for truck tire washing, self-closing faucets and recycling concrete-batching water; usage is monitored monthly. Projects seeking LEED, SITES or EU Taxonomy alignment set design-phase targets using water-efficient fixtures, smart irrigation, drought-resistant plants and rainwater reuse. A Wastewater Treatment Plant is planned to produce recycled irrigation water for the Metropolitan Park. In operations, Shopping Centers use EMS, flow regulation and leak inspections; Designer Outlet Athens treats wastewater on-site for irrigation, and Flisvos Marina applies automatic irrigation, remote water management and intermediate meters. Operations are in Greece, a water-stressed area.

At present the Group has not established measurable, overall outcome-oriented and time-bound targets to manage its material impacts, risks and opportunities concerning water consumption. However, it recognizes the need for monitoring with specific indicators to systematically assess policy and action effectiveness. In 2024 the Group made significant progress in developing its Sustainable Development Strategy across all operations and plans to establish key performance indicators. The under-development Strategy, set for completion in 2025, focuses on water consumption management and reduction across business activities. Currently the Sustainable Development Strategy of The Ellinikon outlines voluntary primary objectives for water consumption: designing buildings to reduce indoor water usage by installing 100% low-water-demand equipment in all under-development multitenant and commercial buildings; maximizing reuse of non-potable water sources; and meeting 100% of the irrigation needs for The Ellinikon Metropolitan Park with treated wastewater. Two additional voluntary objectives were established for water consumption per surface area and per number of visitors at the Shopping Centers under ISO certification of their EMS.

For 2024 the Group reported total water consumption of 291,823.10 m3 and water recycled and reused of 16,860.00 m3. Against net revenue of 665,020,633.17 euro, the water intensity ratio was 0.43 m3 per million euro. Data is derived from water bills and meters covering all of the Group's activities and has not been audited by an external body apart from statutory auditors. The Group does not store water. Because its operations are located in Greece, considered a water-stressed area, the volumes of total water consumption and total water consumption in water risk areas, including areas with high water stress, are identical.

The Group has not yet conducted a specific analysis of the resilience of its strategy and business model to biodiversity risks, consistent with the non-identification of any material negative biodiversity impact. LAMDA nonetheless recognises the importance of biodiversity and ecosystem resilience in its long-term sustainability strategy. Going forward, its approach will focus on gathering insights and measuring the impact of its activities on biodiversity, particularly in The Ellinikon area. This will include assessing potential biodiversity risks and identifying opportunities to mitigate adverse impacts, so that the business model evolves to be more resilient and aligned with biodiversity conservation goals over the coming years. The Group identified one material impact, one risk and one opportunity related to biodiversity, notably the positive impact of enhancing biodiversity through the redevelopment and greenery of the degraded Ellinikon site, and the risk of potential marine disruptions and pollution incidents.

LAMDA Development does not currently have a specific biodiversity and ecosystem protection policy, nor policies dedicated to sustainable land and ocean practices or deforestation, since no negative impacts have been identified. Its efforts are guided by the Sustainable Development Policy, which commits to minimising impacts on biodiversity, ecosystems, and the well-being of animals, plants and soil. For The Ellinikon, ecosystem preservation is addressed through the Sustainable Development Policy, the Environmental Policy, and the Sustainable Development Strategy, which prioritise restoration and regeneration of natural ecosystems and rehabilitation of green zones. Efforts are supported by an Environmental Management System, audited internally and externally during construction, and Environmental Monitoring Plans covering noise, vibration and air pollution. Contractors and major suppliers are assessed on environmental certifications such as ISO 14001. Material traceability is prioritised through EPDs and LCAs. Stakeholder mapping follows the EBRD environmental and social policy (EBRD PR10).

The Group is committed to preserving and restoring soils and regenerating ecosystem functions, focused on The Ellinikon Metropolitan Pole and its Marinas. A key feature is a Metropolitan Park spanning 2 million square metres. Design of the current phase of The Ellinikon Park began in 2024, engaging local and international experts and using nature-based solutions. Strategies include a vegetation and soil management plan, soil enhancement studies, biomass reinforcement, prioritisation of native plants, and reduction of light pollution. The 75-acre Ellinikon Experience Park showcases over 900 new trees and 80,000 low-vegetation plants, plus 80 transplanted olive trees, and became the first new construction development in Europe to achieve SITES certification at Gold level in 2024. Planting plans include over 44,600 new trees across 59 species (more than 14,000 in the current phase) and temporary hosting of up to 3,000 existing trees. Soil and groundwater remediation at Elliniko is ongoing, with groundwater works estimated to complete in 2025. Flisvos Marina participates in the LifeGate PlasticLess program using Seabins.

Biodiversity and soil conservation are key objectives of The Ellinikon's Sustainable Development Strategy. The central strategic target is to achieve Biodiversity Net Gain (BNG), defined as ensuring biodiversity in the development area is improved compared with baseline conditions before development. The baseline is the pre-development state of land and sea recorded in 2020. Initial biodiversity studies, expected in 2025, will establish a scientific baseline, and BNG achievement will be assessed at key milestones, starting with completion of ongoing development projects in 2027. Supporting objectives include restoring and regenerating natural ecosystems, preserving ecological function, maintaining aquatic life diversity and population, preserving or transplanting existing healthy trees, maintaining and restoring soil characteristics, and remediating soil contamination to international standards. The Group uses qualitative and quantitative indicators such as species richness, habitat quality, soil quality index, and native species coverage. It has not relied on biodiversity offsets, focusing instead on restoration, regeneration, and enhancement of natural habitats.

The Group does not own, lease, or manage any sites located in or near biodiversity-sensitive areas, so there are no sites to disclose in relation to protected areas or key biodiversity areas. It has not identified any negative impacts on biodiversity and ecosystems, nor social consequences from biodiversity-related impacts, so no corrective measures were required. The Group discloses entity-specific metrics on the size of habitats restored. For The Ellinikon Building Complex for People with Disabilities: 8,000 plants and 150 trees (all 150 new), a total vegetated site area of 3,800 square metres (42% of total site area), and 1,580 square metres of green roofs. For The Ellinikon Experience Park: 80,000 plants and 900 trees (820 new trees, 80 transplanted olive trees), and a total vegetated site area of 30,000 square metres (40% of total site area). Data is derived from landscaping studies and has not been audited by an external body, except for the assurance provider.

The Group's Sustainable Development Policy underscores managing the environmental impacts of its operations, focusing on resource efficiency (including raw materials and supplies) and effective waste management while ensuring regulatory compliance. For The Ellinikon, objectives for resource efficiency and circularity align with the Sustainable Development Policy, Environmental Policy, Sustainable Development Strategy and Environmental Management System. Circularity is a core pillar, with objectives to minimise resource consumption and responsibly source materials, and to design out waste and minimise waste to landfill. The Environmental Policy of The Ellinikon emphasises pollution prevention through eco-friendly technologies and promotes recycling, reuse and waste reduction, and is supported by a Waste Management Procedure covering segregation, storage, collection, transportation and disposal of hazardous and non-hazardous waste during construction. Operating assets (Golden Hall, The Mall Athens, Mediterranean Cosmos, Designer Outlet Athens) and Flisvos Marina have Environmental Policies committing to reduced waste generation, sound disposal, and conservation of natural resources through reuse and recycling.

Each operating asset and under-development project manages ongoing resource use and circular economy actions in coordination with the Group's Sustainability Department. All new Ellinikon developments provide monthly reports on waste consumption, management practices, and material usage. The Group has introduced recycling methods ensuring waste is sorted at source and disposed of responsibly. As of 2024, 98% of total waste produced is diverted from disposal. Waste sorting at source promotes recycling of packaging, glass, plastic, paper and inorganic waste, tracked through the Environmental Management System. At Flisvos Marina, 16 recycling streams are managed and green waste and coffee residues are composted. At The Ellinikon, an Environmental Management Plan for the Construction Phase and a Material and Waste Management Plan apply, with monthly monitoring and internal and external audits. Designer Outlet Athens operates a Wastewater Treatment Plant for irrigation, and a WWTP is planned at The Ellinikon by 2027. Excavation materials are preserved and demolition materials processed by a demolition waste crusher for future reuse on site.

The Group has not established overall measurable, outcome-oriented and time-bound targets for resource use and circular economy. However, sector-specific objectives and KPIs exist. The Sustainable Development Strategy, expected to be completed in 2025, aims to integrate circular economy principles. Shopping Centers' Environmental Management Systems were certified under ISO 14001 in 2024. Voluntary targets per business unit include, for The Ellinikon: net zero waste ambition, managing 100% of generated waste responsibly, reusing on-site materials, and using treated wastewater for 100% of Metropolitan Park irrigation. For LEED/EU Taxonomy projects: at least 30% by cost of installed products meeting responsible sourcing criteria, prioritising EPDs and LCAs, and diverting at least 70% of waste from landfill. Shopping Centers target recycling efficiency increase above 20%, safe CDW disposal, and 100% alternative management of WEEE, batteries and mineral oils. Flisvos Marina targets 100% waste management, 100% paper recycling, recycling efficiency increase above 10%, and production of 21 tons of organic fertilizer from its composting unit.

LAMDA recognises the importance of sustainable use of raw materials and reducing use of materials and natural resources. Resource inflows for real estate investments and operational assets include property and plant, materials for maintenance, renovations and upgrades, and energy and water. For under-development projects such as The Ellinikon, substantial materials and water are required. The Group prioritises responsible sourcing of critical raw materials and minimising virgin and critical materials, and collaborates with suppliers to embed sustainability criteria. At The Ellinikon a dedicated digital platform records and reports material inflows monthly. Reported 2024 figures: total weight of products and technical and biological materials used 235,391.12 t; percentage of sustainably sourced biological materials (and biofuels for non-energy purposes) 0.00%; secondary reused or recycled components, secondary intermediary products and secondary materials used 23,890.20 t, representing 10.15%. Recycled materials consist mainly of metals, followed by aggregates, with a smaller portion of gypsum, all used for The Ellinikon. Data is not audited by an external body other than the assurance provider.

Resource outflows primarily include waste generated from daily operations, maintenance, and construction processes across Shopping Centers, Marinas, other investment properties and The Ellinikon. Waste streams include packaging, food, cleaning and maintenance, green, hazardous, and electronic waste, plus excavation, construction and demolition waste at The Ellinikon (discarded concrete, bricks, metals, timber, plastics, glass, soil, rock and packaging). Reported 2024 figures: total waste generated 1,031,630.46 t; non-recycled waste 1,016,862.55 t (98.57%); total hazardous waste 349.77 t; radioactive waste 0. Non-recycled waste includes large quantities of demolition and excavation materials at The Ellinikon stored on site under preparation for reuse. Data is collected from contracted licensed waste management companies and is not verified by an external body other than the assurance provider. Detailed waste diverted from and directed to disposal figures are summarised under the E5-5-Waste key.

Detailed waste metrics for 2024 (tonnes). Total waste generated 1,031,630.46 t; non-recycled waste 1,016,862.55 t (98.57%); total hazardous waste 349.77 t; radioactive waste 0. Waste diverted from disposal: preparation for reuse 0 t hazardous and 994,380.72 t non-hazardous; recycling 349.77 t hazardous and 14,418.14 t non-hazardous; other recovery operations 0 t hazardous and 13.70 t non-hazardous; total diverted 349.77 t hazardous (0.03%) and 1,008,812.56 t non-hazardous (97.79%). Waste directed to disposal: incineration 13,618.89 t non-hazardous; landfill 8,849.24 t non-hazardous; other disposal operations 0; total directed to disposal 0 t hazardous and 22,468.13 t non-hazardous (2.18%). Construction and demolition materials stored for future incorporation in 2024: concrete 2,976.3 t, mixtures of construction and demolition waste 54,984.2 t, and excavation materials 936,411.7 t, for a total of 994,372.2 t (versus 1,228,932.9 t in 2023). The large preparation-for-reuse volume mainly reflects demolition and excavation materials stored on site at The Ellinikon.

LAMDA Development reports a comprehensive set of policies protecting its own workforce. These include the Human Rights Policy, Health & Safety Policies, the Workplace Non-Discrimination, Anti-Harassment and Violence Prevention Policy, the Code of Conduct, Sustainable Development Policy, Whistleblowing Policy, Supplier's Code of Ethics, Anti-Corruption Policy, Conflicts of Interest Policy and Benefits Policy. The Human Rights Policy is built on the ILO Declaration on Fundamental Principles and Rights at Work, the Universal Declaration of Human Rights, the ICCPR and the OECD Guidelines for Multinational Enterprises, and applies across the value chain. It commits to eliminating forced, bonded or compulsory labour, modern slavery, human trafficking and child labour, and to ongoing human rights due diligence under the UN Guiding Principles. The Non-Discrimination policy prohibits discrimination based on race, colour, nationality, age, religion, sexual orientation, trade union participation, disability and other characteristics. Additional policies cover performance evaluation, training and development, recruitment, and internal job posting. Separate certified Health & Safety Policies apply to the Shopping Centers, Flisvos Marina and The Ellinikon.

The Group engages its workforce through direct communication led by the Human Resources Division, with the Human Resources Chief Officer holding operational responsibility for ensuring engagement methods are effective. Engagement occurs during decision-making and strategy implementation via regular employee surveys, town halls, the Intranet, newsletters, open communication with HR and feedback mechanisms. Feedback is communicated to relevant decision-makers and used to adjust strategy and actions at an operational level. In 2023 an employee engagement survey covering 100% of employees was conducted on topics such as confidence in leadership, customer focus, development opportunities, training, performance management and collaboration, with the next survey planned for early 2025. Structured feedback sessions follow each survey, and annual town hall meetings allow executives to share results and plans. Dedicated personnel and financial resources support engagement activities. The Double Materiality Assessment, led by the Sustainability Department, serves as an additional engagement form. Awareness initiatives, including collaboration with NGOs, help understand the perspectives of vulnerable and marginalized employees, including women and people with disabilities.

The Marketing and Communication Division, with other departments, manages stakeholder engagement and addresses issues, escalating matters requiring senior involvement to the Management Team and Board of Directors under the CEO's oversight. For health and safety issues, the Group investigates root causes, takes corrective actions and reinforces safety measures. Employees can raise concerns through multiple channels, including direct communication with supervisors, H&S managers, the HR department, or the confidential whistleblower system. The Group operates an online public grievance form, and a Whistleblowing Policy with an anonymous and confidential reporting platform (a customised platform and a dedicated email) where all employees, subsidiaries and external partners can report violations such as discrimination, violence and harassment. Reports are managed by the Whistleblowing Committee, which reports to the Audit Committee. Reporting persons are protected from retaliation, harassment, intimidation and unfair treatment, even if a report is proven wrong, and external partners cannot have contracts terminated as a result of a report.

The Group implements actions across benefits, training, health and safety, recruitment and anti-discrimination. Benefits offered to employees include annual bonuses, a health and insurance program, retirement plans, car allowance, fuel card, mobile phone, corporate loans, special leave days, meal vouchers and rewards, plus an Employee Assistance Program; temporary employees receive medical and pharmaceutical coverage and meal vouchers. Training uses the SuccessFactors LMS platform to assign mandatory courses (GDPR, Code of Conduct, Anti-Corruption, Cyber Security, Harassment Policy and others), an e-learning Health & Safety course, First Aid training, and leadership programs. Health and safety actions include appointment of a Safety Practitioner and Occupational Physician, regular inspections, PPE distribution, contractor H&S plans with monthly reporting, Working at Height training, and a twelve-module digital H&S education platform issuing a Safety Training Passport certified by ELINYAE. In 2024 the Group began ISO 45001:2018 certification, completing Golden Hall. Recruitment and repatriation efforts recruited more than 30 employees from abroad since 2021. Effectiveness is tracked through employee surveys, monthly H&S reports, project dashboards, on-site audits and quarterly Board updates.

The Group is developing a comprehensive Sustainable Development Strategy, set to be finalized in 2025, that will encompass objectives, targets, action plans, initiatives and mitigation measures for both employees and non-employees. Engagement outcomes and feedback from previous actions are being integrated into this process to align targets with workforce needs. For 2025 the Group set three targets: to certify 100% of its remaining shopping centers, The Mall Athens and Mediterranean Cosmos, to ISO 45001:2018; to achieve 100% employee participation in performance evaluation; and to reach a total average number of training hours per employee of more than 10. The Group already tracks KPIs such as employee well-being, health and safety compliance metrics and workplace satisfaction, using accident frequency and severity rates, employee retention and performance metrics as baseline indicators. It commits to defining clear, measurable, time-bound and outcome-oriented targets in the coming years. No external body other than the assurance provider was engaged to validate metrics concerning employees.

At 31 December 2024 the Group had 769 employees, comprising 341 male (44.35%) and 428 female (55.65%), with zero reported in the other and not-reported categories. All 769 employees are permanent (341 male, 428 female), while 30 are temporary (10 male, 20 female) and there are no non-guaranteed-hours employees. The employee count was calculated using the headcount methodology as of 31.12.2024, including all employees with an employment contract; the Group has 3 additional employees engaged in its activities abroad. During the reporting period 50 employees left voluntarily, giving a voluntary turnover rate of 7%, and 24 left involuntarily through dismissal, retirement or death, giving an involuntary turnover rate of 3%. Permanent employees are hired on a long-term, open-ended basis; temporary employees are on fixed-term contracts for specific projects or seasonal demand; non-guaranteed-hours employees have no guaranteed minimum hours, such as casual, zero-hour and on-call staff.

Non-employees in the Group's own workforce are workers employed at The Ellinikon (the majority), who are employees of contractors undertaking the construction works; workers from consulting companies with which the Group has business relationships and who work on its premises; cleaning crews, security workers and waste management crews at the Group's headquarters, Shopping Centers, Marinas and offices in The Ellinikon; and self-employed individuals. As of the end of the reporting period, the total number of non-employees within the Group's workforce, including contractors and individuals provided by external consulting companies, is 2,218, the majority of which relates to the development of The Ellinikon. The number of non-employees is reported as the average monthly employees per supplier. The Group expanded its non-employee workforce by 25% compared to 2023, reflecting the intensification of construction activities.

The Group reports diversity metrics for top management and by age group. At top management level, defined per the ESRS definition as two levels below the Board of Directors (the C-suite comprising the CEO and Chiefs), there are 16 individuals: 11 male (68.75%) and 5 female (31.25%), with none in the other category. By age group, of the total workforce 139 employees (18.08%) are under 30 years old, 474 employees (61.64%) are aged 30 to 50, and 156 employees (20.29%) are over 50 years old. Gender is recorded according to employees' own statements.

All Group employees receive fair and competitive wages, reflecting the Group's commitment to equitable compensation practices. The wages provided are consistently above the minimum thresholds defined by Greek legislation, ensuring that all employees are compensated fairly in accordance with legal standards. In addition, no employees earn below the applicable adequate wage benchmark in the countries in which the Group operates.

All employees participated in regular performance and career development reviews, with 100% participation for male, female and total employees. The average number of training hours per employee was 19.45 for male employees, 19.04 for female employees and 19.22 for total employees; figures for the other gender category were not applicable. Under the Group's policies, e-learning training on the SuccessFactors platform was assigned once to all employees as mandatory and remains available in the library for review at any time. The courses cover all sections of the respective policies, including the Code of Conduct, GDPR, Anti-Corruption Policy, Anti-Bribery and Corruption Policy and Whistleblowing.

All Group employees and non-employees are covered by a Health and Safety Management System, which receives external assurance for Flisvos Marina, The Ellinikon and the Shopping Centers (Golden Hall and Designer Outlet Athens). Coverage by the H&S management system on a headcount basis was 59.43% for employees and 100% for non-employees. In 2024 there were 4 recordable work-related accidents among employees and 21 among non-employees, giving rates of 2.79% and 3.76% respectively. There were zero cases of recordable work-related ill health for both groups. Days lost due to work-related injuries from accidents totalled 42 for employees and 453 for non-employees. The Group reports zero fatalities as a result of work-related injuries and work-related ill health for both employees and non-employees. With the intensification of construction activities, the number of non-employees increased significantly during the year, and the majority of recorded accidents affected non-employees working on construction sites.

The Group reports that 100% of total employees are entitled to take family-related leave, which includes maternity leave, paternity leave and carer's leave. The total number of employees entitled to take family-related leave accounts to 41. During the period 14 male employees (1.82%) and 27 female employees (3.51%) applied for family-related leave, giving a total of 41 employees (5.33%) who applied. Of those who applied, 100% took the leave, for both male and female employees. Figures for the other gender category were not applicable.

The Group reports a pay gap between female and male employees of 30.08% for 2024, defined as the difference of average pay levels between female and male employees expressed as a percentage of the average pay level of male employees. The annual total remuneration ratio was 32.50, defined as the ratio of the highest paid individual to the median annual total remuneration for all employees, excluding the highest-paid individual, with all employees included. Total remuneration includes salary, bonus projection, medical benefits, pension contributions, car allowance, mobile phone allowance, meal vouchers, fuel for car and stock options, where applicable. Gross wage is defined as wage excluding variable components such as overtime and incentive pay, and excluding allowances unless they are guaranteed.

For 2024 the Group reports zero across all incident and complaint metrics: zero total incidents of discrimination (including harassment) reported, zero complaints filed through channels, zero complaints filed to National Contact Points, zero total amount of fines, penalties and compensation for damages, zero severe human rights incidents, zero cases of non-respect of the UN Guiding Principles, and zero total amount of fines, penalties and compensation for damages of severe human rights incidents. During the reporting period the Group recorded no work-related incidents or complaints involving severe human rights impacts, including discrimination, violence or harassment, within its own workforce, and no cases of forced labor, human trafficking or child labor. There were no incidents of non-respect of the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises. The Group maintains a strict zero-tolerance policy on discrimination, harassment and violence in the workplace.

LAMDA adopted policies protecting affected communities' economic, social and cultural rights: the Sustainable Development Policy, Human Rights Policy, Health and Safety policies and systems, Code of Conduct, and Whistleblowing Policy. The Sustainable Development Policy includes a focus area on prosperity for society and local communities under its Society (Social) pillar, and The Ellinikon's version prioritizes People and Prosperity. The Human Rights Policy, based on the UN Guiding Principles, ILO Declaration and OECD Guidelines, addresses local communities through land use, natural resource conservation and heritage preservation, commits to Environmental Impact Assessments before construction, safe and inclusive access including for people with disabilities, and effective dialogue and remediation with attention to vulnerable groups. The Health, Safety and Wellbeing Policy protects local communities, visitors and neighboring residents at The Ellinikon. The Corporate Communication Policy stresses transparency and open communication. In 2024 there were no cases of non-compliance regarding affected communities' human rights.

The Group engages in continuous, direct and indirect dialogue with local communities affected by its operations to build trust and address concerns. For The Ellinikon, a Stakeholder Engagement Plan (PR10), aligned with European Bank for Reconstruction and Development (EBRD) requirements, sets out identification, mapping, engagement and information disclosure processes. It was last revised in 2024 to reflect the start of construction in 2021. Engagement principles include providing timely, relevant and understandable information free from manipulation, coercion or intimidation, with frequency tailored to project scale and adverse impacts. Local community meetings explain the project, its impacts, progress and grievance channels. Monitoring uses performance indicators such as communication frequency, number of grievances or suggestions, average resolution time, media coverage and website traffic. The Corporate Communications Department contacts community members who raise requests or grievances. Documentation includes reports, official meetings, studies, consultations, letters, press releases, newsletters, public events and webinars.

The Group operates a grievance mechanism open and accessible to all, aimed at building trust with external stakeholders and managing concerns fairly and transparently. Complaints or suggestions can be submitted through a public grievance form, call center and complaint box. Recorded complaints are collected weekly and forwarded to the Corporate Communications Department. The procedure follows four steps: receipt and recording of the grievance and classification in the grievance log; formal acknowledgement of receipt through meeting, phone call, email or letter within 5 working days on average; investigation and resolution, including forwarding to the relevant department, identifying the category and developing a response; and response and communication of resolution, including implementing actions, recording corrective and preventive actions, communicating with the affected stakeholder and closing the grievance. This process forms part of the Human Rights Policy. The Group investigates and resolves concerns while refraining from action against anyone who reports violations in good faith.

The Ellinikon is developed on integrated design principles, aiming to create jobs, a metropolitan green park, green and recreational areas, and seafront regeneration, alongside high-quality tourist, cultural, sports, educational and social infrastructure. Projects include The Ellinikon Park (over 2 million sqm), a 3.5 km coastal front and 1 km beach, marina modernization, sports facilities, welfare and health facilities, a building complex for people with disabilities, flood protection, bicycle paths, and wastewater and solid waste plants. LAMDA maintains long-term NGO partnerships with financial and pro bono support; in 2024 over 30 NGOs benefited across four Shopping Centers, and initiatives included support for the Hellenic Paralympic Committee, 60 educational programs reaching 3,200 students, accessibility mapping, food donations, and 16,000 free brainy digital subscriptions. Mitigation actions address noise, air pollution, dust and vibrations through an Environmental Management System and monthly audits, and traffic through impact studies, off-peak deliveries and designated access routes. In 2024 no human rights incidents were identified.

Engagement with affected communities is monitored through performance indicators recording the type and frequency of communications, valid grievances, complaints, suggestions and reports, and cases resolved. In 2024 the Group received 40 complaints, reports, questions and concerns in total, of which 38 related to affected communities regarding The Ellinikon. Data was collected through the complaints monitoring process and has not been verified by an external body other than the assurance provider. The Group plans to introduce Customer Relationship Management (CRM) tools for improved recording and resolution. The Group has not yet set specific, measurable targets for affected communities but intends to establish them soon. In 2024 a robust CSR framework and community engagement plan were initiated for launch from the start of 2025, with metrics and a LAMDA Reputation Tracker. Planned 2025 initiatives target the Penteli community after the 2024 wildfires, 12,000 students, around 500 senior citizens, and Ellinikon adjacent communities, plus at least one annual meeting per neighboring municipality and a dedicated website section.

The Group is committed to providing accurate and transparent information to consumers and end-users. The Corporate Communication Policy and Procedure ensures reliable information through announcements, press releases and targeted communication, with crisis management protocols for clear and timely communication. The Human Rights Policy, aligned with the UN Guiding Principles, ILO Declaration and OECD Guidelines, sets out four fundamental rights for consumers and end-users: the right to the highest possible physical and mental health, including health and safety within facilities and compliance with the UN Voluntary Principles on Security and Human Rights; the right to privacy, processing personal data in full compliance with the General Data Protection Regulation and reflected in the Personal Data Protection Policy; the right to be free from discrimination, with a zero-tolerance approach; and the right to an effective remedy. Monitoring and reporting mechanisms, including the grievance mechanism, allow reporting without fear of retaliation. In 2024 there were no cases of non-respect of these international standards involving consumers and end-users.

The Group actively engages with consumers and end-users through various channels and stages to inform its decisions and manage actual and potential impacts. At corporate level, the Marketing and Communications Division ensures engagement with consumers and end-users, while the Commercial Department oversees interactions with buyers, end-users and potential owners or tenants of investment properties. For each operational asset, such as Shopping Centers and Marinas, the respective Operations Department together with Marketing and Communication teams manage implementation. The Group runs a comprehensive 360 degree Media Plan executed annually across multiple channels, including diverse media platforms and in-person interactions, and uses Key Performance Indicators to evaluate effectiveness. It also organizes annual tenant events at its Shopping Centers, gathering feedback through tenant participation and follow-up communications, and conducts a Qualitative Visitors' Survey to understand the profiles, expectations and needs of Shopping Center visitors, incorporating insights into its strategic approach.

Under the Corporate Communication Policy and Procedure, the Corporate Communication Department strategically plans and coordinates communication and manages the Group's external image and reputation, with planning reviewed internally and approved by Top Management. Channels include television campaigns, events, conferences, exhibitions, webinars, social media posts and print and online media, through which the Group addresses questions from the public and informs consumers and end-users of available communication channels. It organizes events, workshops and Q&A site visits focused on The Ellinikon and separate updates on accessibility and inclusion. Multiple channels are available for reporting concerns, complaints and suggestions, addressed swiftly, fairly and transparently. Through the whistleblowing mechanism, external stakeholders can anonymously report incidents, including discrimination, violence or harassment. Consumers and end-users have the right to file complaints without fear of retaliation and to seek resolution in disputes. Further details on the grievance mechanism and its steps are in section S3-3.

In 2024 the Group partnered with the NGO Me Alla Matia to conduct an accessibility mapping of its Shopping Centers, focusing on visitors with visual, auditory and physical disabilities, producing a report and an action plan of phased upgrades exceeding regulatory requirements, plus employee training. Stakeholder tour visits at The Ellinikon informed government officials, business leaders, ambassadors, investors and students about the project's social, economic and environmental aspects. On personal safety, health and safety policies apply to customers and visitors, with emergency management procedures and training. Shopping Centers monitor air quality, noise, lighting and evacuation plans, provide first aid areas, lifeguards, defibrillators with child-specific pads and certified staff training, maintain 100% fresh air circulation and check for legionella. Flisvos Marina operates a certified Occupational Health and Safety System with patrols, fire-fighting equipment and Emergency Action Plans. The Ellinikon Phase A applies its Health and Safety Policy with quarterly Compliance Reports. On data protection, the Group complies with GDPR and Law 4624/2019, appointing a Data Protection Officer; in 2024 there were no privacy violations or data losses.

As part of its Corporate Responsibility Strategy (CSR Strategy) approved in 2025, the Group developed a comprehensive process to manage material negative impacts, advance positive impacts, and manage material risks and opportunities. The objectives, targets, action plan and initiatives regarding consumers and end-users will fall under this overarching strategy, and existing processes for monitoring effectiveness, tracking performance and identifying improvements will be integrated into it. Engagement outcomes and feedback from previous actions feed into the strategy to reflect stakeholder needs and expectations. In 2024 the Group conducted a Qualitative Visitors' Survey at its Shopping Centers covering 8 Key Value Areas with 134 participants (8 people per focus group). It also conducted an annual satisfaction survey at Flisvos Marina, showing a 59% participation rate of vessels at berth, 81.5% tenant participation, 99% of visitors intending to revisit, and 79% who would recommend the Marina to third parties. Data was not verified externally beyond the assurance provider.

Since its inception LAMDA Development has built a corporate culture grounded in integrity, ethics, transparency, and personal responsibility. Compliance with legislation and the regulatory framework is mandatory for all employees, who must adhere to the Internal Regulation approved by the Board of Directors, the Code of Conduct, and Management-established Policies, Codes and Procedures. These are accessible on the company website and intranet in Greek and English, covering anti-corruption, conflicts of interest, data privacy, confidentiality, customer relationships, market abuse, insider trading, and discrimination, violence and harassment. Key instruments include the Anti-Corruption Policy, the Conflict-of-Interest Policy, the Code of Conduct (revised 2022), the Internal Regulation, the Employee Training and Development Policy, and a comprehensive Whistleblowing Policy and mechanism allowing employees, suppliers, and external partners to report incidents anonymously or by name. Mandatory e-learning on SuccessFactors covers the Code of Conduct, GDPR, Anti-Corruption, Anti-Bribery, and Whistleblowing, and is automatically assigned to new hires. Policies are reviewed at regular intervals and updated as developments require.

The Group builds constructive, long-term relationships with suppliers, consultants, service providers, contractors, and other partners, managing these throughout the procurement process from selection and contract negotiation to performance evaluation and continued collaboration. It commits to transparent and fair practices, timely payments including to small and medium enterprises, and support for local suppliers. In 2024 the Group introduced new credit terms of 30 days after invoicing. The Pre-Qualification Questionnaire, updated in 2023, evaluates prospective Ellinikon contractors across General Information, Financial Information, and Sustainability, with the Sustainability section requiring disclosure on energy, emissions targets, risk management, environmental compliance, human rights, health and safety, whistleblowing, code of conduct, and corruption and bribery. In total 70 contractors were evaluated for prequalification. The Procurement Policy, revised in November 2023, ensures transparency, objectivity, impartiality and equal opportunities, supported by the SAP ARIBA platform used since September 2023. A Supplier Code of Conduct sets ethical principles suppliers must follow, incorporated into tenders and accepted in writing. Supplier selection considers social and environmental criteria.

The Group shows zero tolerance for corruption. Based on the Regulatory Compliance Policy and procedures manual, the Regulatory Compliance Unit takes preventive, detection, and response actions on business ethics, transparency, and integrity. The Anti-Corruption Policy, approved by the Board of Directors, sets a framework for offering and accepting gifts and other benefits between employees and third parties in the public and private sectors, prohibiting gifts intended to obtain or maintain a business advantage, and setting rules on entertainment, meals, travel and lodging, political and charitable donations, direct or third-party payments, and the employment of individuals associated with state employees and business partners. A Conflict-of-Interest Policy requires all Board-level conflicts to be investigated, notified, and documented to the Audit Committee. The Whistleblowing Committee handles and investigates reports, ensuring confidentiality, objectivity, and independence, and reports to the Audit Committee. Corruption and bribery risks are identified, registered, and managed in the Group's Risk Management platform, covering functions such as cyber security, construction billing, information leakage, bidding manipulation, sustainability reporting manipulation, and financial statements. Residual exposure is evaluated quarterly at minimum. Mandatory anti-corruption and anti-bribery e-learning on SuccessFactors covers five themes and is assigned to all employees, including top management and new hires.

During 2024 the Group recorded no confirmed incidents of corruption and bribery, and no intention to commit such acts came to the attention of relevant officials. There were no relevant convictions or fines imposed, and no formal risks related to bribery were identified or recorded in the Group's operations. Because no specific incidents required corrective action, no corrective actions or additional prevention measures were necessary. The Group states it remains committed to upholding the highest ethical standards, continuously monitors its operations, reinforces compliance with its Code of Conduct, and fosters a culture of integrity and responsible business conduct across all levels. It adopts a zero-tolerance approach against any form of corruption and bribery, ensures and monitors that all employees, contractors, and business partners comply with the Anti-Corruption Policy, and states it aims to set measurable, outcome-oriented targets on related issues in the future.

The Company prioritizes timely payments to suppliers, including small and medium enterprises. In 2024 the Group reduced its standard payment terms following the decision to shorten the payment period to 30 days from the invoice issuance date. For 2024, 91.0% of the company's payments were aligned with these standard terms, 8.97% of invoices were paid in 60 days, and 0.03% in 45 days, due to old contracts that will soon be harmonized with the current process. Reported supplier payment metrics show the average time the Group takes to pay an invoice from when the contractual or statutory payment term starts to be calculated is 28.8 days, the percentage of payments aligned with standard terms is 91.0%, and the number of legal proceedings currently outstanding for late payments is zero. Data was collected by analyzing the Company's invoices, including those paid within standard terms, deviations, and the number of days. The data has not been verified by an external body other than the assurance provider.