Minor Hotels Europe & Americas

(Section ESRS 2 GOV-1) Minor Hotels Europe & Americas describes its administrative, management and supervisory bodies. Under CSRD, only the Board of Directors and its two delegated committees, the Audit and Control Committee and the Appointment, Remuneration and Corporate Governance Committee, are treated as these bodies. The Management Committee (senior management) is not counted as such a body. At 31 December 2024 the Board had 10 members, with women at 30% (3 directors), 30% independent members, 3 executive and 7 non-executive directors, and 5 nationalities. The Board met 10 times, the Audit and Control Committee 6 times and the Appointment committee 6 times. The company notes the change from NH Hotel Group S.A. to Minor Hotels Europe & Americas S.A. and Minor International as proprietary shareholder, with proprietary directors representing MINT. CEO Ramon Aragones retired at year end and Gonzalo Aguilar took over from 1 January 2025. The Management Committee at year end was 7 men (70%) and 3 women (30%). There are no employee representatives on these bodies. Sustainable Business governance is cross-cutting, overseen by the Board through its two committees and supported by an Executive Sustainable Business Committee that met 3 times in 2024.

(Section ESRS 2 GOV-2) The company sets out the sustainability information provided to and matters addressed by its administrative, management and supervisory bodies during 2024, aligned with the double materiality results. The Board of Directors reviewed the 2023 annual reports including the Non-Financial Information Statement, approved the third cycle 2024-2026 Long-term Incentive Plan, reviewed and approved the 2025 corporate risk map, updated the criminal risk prevention model, and followed the growth strategy. The Audit and Control Committee reviewed the 2023 reports, followed two risks scored material for sustainability (labour and collective agreement legislation and cyberattack positioning), reviewed whistleblowing channel matters and the corporate information control system. The Appointment, Remuneration and Corporate Governance Committee reviewed the same reports and approved the incentive plan and Board evaluation. The Executive Sustainable Business Committee met 3 times and the Executive Compliance Committee met twice. The Management Committee, meeting weekly plus two strategy sessions, monitored SBTi-validated 2030 GHG targets, energy and water consumption, waste management, salary agreements, and the company name change and its implications.

(Section ESRS 2 GOV-3) The company explains how it integrates sustainability performance into incentive schemes. Members of the administrative, management and supervisory bodies who receive variable remuneration have it linked to ESG criteria, as does the Management Committee. Executive Directors are the only Board members entitled to variable remuneration, made up of short-term (annual) and long-term components; non-executive directors receive a fixed allowance and attendance fees. Short-term variable pay uses the Management By Objectives (MBO) programme. In 2024, Executive Director objectives were weighted 50% corporate objectives (25% recurring EBITDA, 25% recurring net profit, 10% Time For You performance) and 40% strategic post-related indicators, into which ESG criteria are embedded. For the Vice Chairman and CEO, 10% of variable pay was linked to annual net emissions targets in the SBT 2030 Plan and to the S&P Global 2024 assessment, with a 4% scope 1 and 2 emissions reduction target for 2024. The COO and the Chief Assets & Development Officer each had 5% of variable pay linked to those emissions targets. Proprietary directors representing Minor International PLC waived attendance and committee remuneration.

(Section ESRS 2 GOV-4) The company provides a statement on due diligence. Due diligence is described as an ongoing management process that lets the company identify, prevent, minimise, eliminate, mitigate and repair actual or potential adverse effects and risks for society and the environment, extending beyond its own operations to cover the entire value chain. The process is based on the Double Materiality Analysis. The disclosure maps the core elements of due diligence to the relevant sections of the sustainability statement. Embedding due diligence in governance, strategy and the business model links to Sustainable Business Governance, the Sustainable Business Strategy and the double materiality supervision and validation stage. Engaging with affected stakeholders links to the double materiality process and stakeholder dialogue. Identifying and assessing adverse impacts links to the IRO identification and evaluation stages and the chapters on material matters. Taking action on adverse impacts links to the chapters on climate change, water, circular economy and waste, sustainable purchasing and team member matters. Tracking effectiveness and communicating links to the chapters on material matters.

(Section ESRS 2 GOV-5) The company describes risk management and internal controls over sustainability reporting. Throughout 2024 it has been implementing an internal control system for sustainability reporting (ICSR). Its purpose is to give Senior Management, the Audit and Control Committee and the Board of Directors a framework that assures the reliability of the company's sustainability reporting and compliance with regulatory obligations. To achieve correct implementation, work is being done to identify the controls and risks that apply to financial reporting and compliance and that may in turn affect sustainability indicators. The company adds that work is under way to define its governance model up to final assessment of the system, covering risk identification, the materiality analysis and the application of controls over reporting to ensure the quality and security of the information. The disclosure presents ICSR as being in an implementation phase rather than fully established.

(Section ESRS 2 SBM-1) The company sets out its strategy, business model and value chain. Minor Hotels Europe & Americas is a consolidated international hotel operator providing short-stay accommodation plus restaurant, MICE and other services. In April 2024 it changed its name from NH Hotel Group S.A. to Minor Hotels Europe & Americas S.A. following a shareholders' vote, reinforcing integration with Minor Hotels; Minor International acquired the group and is the majority shareholder. At 31 December 2024 the company was present in 31 countries, operating 347 hotels and 55,769 rooms across Europe, the Americas and Africa, serving 4.5 million customers, with a workforce of 14,361 FTE team members. Hotels are held under owned (20%), lease (64%), management (14%) and franchise (2%) contracts. The portfolio is 97% urban and 3% resort, with brands including NH Hotels, NH Collection, nhow, Anantara, Avani and Tivoli. In 2024 it opened 9 hotels (1,425 rooms), signed 8 more, and had 12 exits. The value chain is structured into upstream (suppliers, OTAs, meta search engines), own operations (owned and leased hotels) and downstream (B2B and B2C customers). The company states it does not engage in fossil fuels, chemicals, controversial weapons or tobacco.

(Section ESRS 2 SBM-2) The company describes the interests and views of stakeholders. It defines stakeholders as any individuals or groups that can affect or be affected by its present or future actions, and identifies eight main categories: team members, shareholders/investors and financial community, owners and partners, customers, suppliers, media, regulatory bodies and society. For each it lists dialogue mechanisms (surveys, town halls, whistleblowing channel, roadshows, General Shareholders' Meeting, supplier approval platform, loyalty programmes, forums), relevance ratings and the responsible corporate department. The double materiality analysis was carried out in 2023 and updated in 2024, with stakeholder views gathered through interviews, meetings and questionnaires producing qualitative and quantitative input. Stakeholder views are integrated into the growth strategy to keep the company competitive, responsible and resilient. High-impact sustainability incidents raised by stakeholders are escalated to the relevant Management Committee Chief Officer and assessed against the Sustainable Business strategy pillars. The Management Committee reviews strategy content and achievement quarterly. The disclosure maps five growth strategy pillars to the relevant stakeholders and material matters, and states that no modifications to the model or strategy resulted.

(Section ESRS 2 SBM-3) The company describes its material impacts, risks and opportunities (IROs) and how they interact with strategy and the business model, integrating the double materiality results into its five strategic corporate pillars and the Sustainable Business strategy. For each material matter it presents topics, sub-topics and sub-sub-topics with associated IROs, and links them to strategic pillars such as UP FOR PLANET and UP FOR PEOPLE. Material matters covered include fighting climate change (GHG emissions across scopes 1, 2 and 3, the SBT 2030 Plan validated by SBTi, energy management, physical and transition risks from a TCFD analysis, and access to financing), responsible water management (water stress, extraction and consumption), circular economy and waste, sustainable purchasing, and social matters relating to team members, workers in the value chain, communities, customers and digital transformation. Each matter sets out actual and potential effects on operating costs, operational efficiency and financing. The company states that geographical diversification, brand range and varied contract types strengthen long-term value creation, and that no relevant financial effects were recorded in 2024 from the identified risks and no risk was found that would require a significant adjustment to the carrying amount of assets and liabilities next period.

(Section ESRS 2 IRO-1) The company describes the process to identify and assess material impacts, risks and opportunities. Based on a double materiality approach, it updated in 2024 the analysis first carried out in 2023, applying ESRS 1 and reviewing EFRAG guidance, with no significant methodological variations and unchanged thresholds; a further review is planned for 2025. The analysis was led by the Executive Sustainability Committee with more than 12 corporate departments and an independent consultant, and was verified by an independent third party. It follows six phases: context analysis, identification and definition of topics, identification of IROs, stakeholder involvement and consultation, assessment and prioritisation of IROs, and oversight and validation. External and internal sources, sector trends, six peers and voluntary frameworks (GRI, TCFD, SASB) were considered. The company identified 16 potential material topics, 47 sub-topics and 62 sub-sub-topics, and more than 300 IROs. Impact materiality uses magnitude, scope, remediability and likelihood; financial materiality combines scale, economic valuation and likelihood, with economic bands up to over 20 million euros. Both thresholds were set at 75% of the highest scoring item. The Board annually reviews and approves the corporate risk map, and the Board validates the analysis by signing the statement.

(Section ESRS 2 IRO-2) The company presents the disclosure requirements in ESRS covered by its sustainability statement. It provides a disclosure index table listing, for each ESRS standard, the disclosure requirements and datapoints reported, cross-referenced to the relevant sections of the Consolidated Non-Financial Information and Sustainability Information Statement. The index covers ESRS 2 General Disclosures (including GOV-1 to GOV-5, SBM-1 to SBM-3 and IRO-1 to IRO-2) and the topical standards addressed by the company, such as ESRS E1 Climate Change, E3 Water and Marine Resources, E5 Resource Use and Circular Economy, ESRS S1 Own Workforce, S2 Workers in the Value Chain, S4 Consumers and End-users, and ESRS G1 Business Conduct. Where a matter is not material, the index marks it as not material and refers back to the IRO-2 section. The table also maps datapoints arising from other EU legislation, such as the SFDR and Benchmark Regulation delegated acts, to the relevant disclosures, including board gender diversity under GOV-1 and the due diligence statement under GOV-4. The disclosure functions as the reporting reference index for the statement.

(Section ESRS E1-1) Minor Hotels Europe & Americas frames its climate efforts through the "SBT 2030 Plan", part of the UP FOR PLANET strategic pillar. Updated in 2024, the plan targets a 46.2% cut in absolute scope 1 and 2 emissions by 2030 versus 2019, extending an earlier 2018 commitment to reduce total emissions by at least 20% by 2030. The Company also commits to reducing absolute scope 1, 2 and 3 emissions by 90% versus 2019 by 2050, aligned with limiting warming to 1.5 degrees C, with the Science Based Targets initiative (SBTi) having verified both the 2030 reductions and the net zero by 2050 goal. Four levers drive the plan: control and monitoring, energy efficiency, green energy, and an emission offset strategy. The Company states the transition plan to a sustainable business model is fully integrated with its overall strategy and financial planning, with an annual CapEx item earmarked for energy efficiency. It confirms it is not excluded under EU Paris-aligned benchmark criteria. Locked-in emissions have not yet been calculated.

(Section ESRS E1-2) The report states that details of Minor Hotels Europe & Americas' policies related to fighting climate change can be consulted in the section "Policies for managing the fight against climate change". Elsewhere in the E1 chapter the Company references its Environment and Climate Change Policy, in particular commitment 5.1.1, which drives the adoption of measures to advance the Company's decarbonisation and reach net zero emissions by 2050. The E1-2 disclosure itself is presented as a cross-reference to that dedicated policies section rather than restating the policy content in full.

(Section ESRS E1-3) Actions target the decarbonisation levers defined in the SBT 2030 Plan. In 2024 the Company invested 10.2 million euros in works and equipment renewal on energy efficiency criteria. Initiatives included replacing fossil-fuel boilers with electric equipment aimed at decarbonisation, progressive renovation of installations, and expanding centralised building management systems (BMS). By 2024, 19 hotels had photovoltaic energy and 25 had thermal solar energy, alongside LED lighting rollouts. The chapter provides a CapEx and OpEx table by initiative, including cold water production equipment (1,896,252.46 euros), fancoils (1,714,225.55 euros), pumping installations (2,673,102.25 euros), BMS (1,473,729.09 euros), photovoltaic and solar thermal panels (163,845.26 euros), and guarantees of origin OpEx of 1,319,415 euros. The Company notes it does not have a CapEx plan strictly aligned with Commission Delegated Regulation (EU) 2021/2178, but the Management Committee annually approves energy efficiency CapEx; figures are consolidated in Notes 7, 8, 10 and 25.2 of the Financial Statements.

(Section ESRS E1-4) The Company has set a target of reaching zero net emissions across the value chain by 2050, with the Science-Based Targets initiative (SBTi) validating both the net zero by 2050 goal and its more ambitious 2030 target. It commits to reducing scope 1 and 2 GHG emissions by 46.2% versus 2019 by 2030, and scope 3 emissions (from purchased goods and services, capital goods, fuel and energy activities, waste, assets under management and franchise) by 27.50% in the same timeframe, avoiding more than 185,000 equivalent tonnes of CO2. By 2050 it targets a 90% reduction in absolute scope 1, 2 and 3 emissions versus the 2019 base year, chosen because it is the year SBTi goals were first adopted and a pre-pandemic year that avoids COVID-19 distortions. Base year 2019 figures are scope 1 and 2 of 101,241 tCO2eq and scope 3 of 361,658.38 tCO2eq. An interim 4% scope 1 and 2 reduction was set for 2025. The Company reports a 31.4% reduction in scope 1 and 2 emissions achieved versus 2019.

(Section ESRS E1-5) Minor Hotels Europe & Americas monitors energy consumption monthly through an online system covering all hotels. Total energy consumption in 2024 was 587,614.40 MWh, up 7.6% from 546,090.06 MWh in 2023, driven mainly by rising temperatures across operating countries and expansion into more energy-intensive luxury, upscale and resort segments. By grouped source, total fossil energy consumption was 310,232.02 MWh (52.80% of the total, down from 57.26% in 2023) and total renewable energy consumption was 274,135.66 MWh (46.65%, up from 41.75%), with nuclear at 0.55%. Natural gas was the largest single source at 213,243.51 MWh. Of total electricity of 299,810.09 MWh, 85% came from renewable sources: 254,580.94 MWh via guarantees of origin and an estimated 1,097.10 MWh of self-generated renewable electricity. The energy intensity ratio was 0.251 MWh per thousand euros of revenue (down 4.4%) and 0.05 MWh per room night.

(Section ESRS E1-6) Emissions are calculated under the GHG Protocol using the operational control approach, covering owned and leased hotels, with Scope 2 reported on both location-based and market-based methods. In 2024, total Scope 1 emissions were 46,150 tCO2eq (up 6.5% from 43,326). Scope 2 location-based was 76,031 tCO2eq (down 9.7% from 84,189) and Scope 2 market-based was 23,350 tCO2eq (down 42.5% from 40,627); 58% of market-based Scope 2 had an emission factor of zero from electricity with guarantees of origin. Scope 3 totalled 356,601.4 tCO2eq (2023: 351,959), with the largest categories being Category 1 purchased goods and services (221,462) and Category 2 capital goods (89,577). Total GHG emissions were 478,782 tCO2eq location-based and 426,101 tCO2eq market-based. The Company states there are no regulated emissions, fugitive cooling-gas emissions are not significant, and Categories 9-13 and 15 are not relevant to its hotel business model. Biogenic emissions are not published as they fall below the table's minimum unit of measurement.

(Section ESRS E1-7) In 2024 no emissions were removed during the reporting period. Emission offsets were made through internal projects and the acquisition of carbon credits to mitigate residual emissions that cannot be directly reduced, financing external projects such as "Uberlandia landfills I and II". GHG emissions offset through carbon credits totalled 559.00 tCO2eq in 2024 (up 16% from 482.00 in 2023). Avoided emissions from purchasing green energy were 52,681.00 tCO2eq (up 20.9%) and from producing own green energy were 192.15 tCO2eq. Under the Sustainable Meetings & Events carbon neutral programme, the carbon footprint of 554 large events was offset, neutralising 3,934 tonnes of CO2 using the HCMI methodology. The Company acquired 4,000 tonnes of carbon credits from two certified projects: "Uberlandia landfills I and II" in Brazil and "Collecting and Destroying Potent Greenhouse Gases" in Thailand, but does not plan to use them to cancel 2024 emissions. It has not yet defined the scope or methodologies for neutralising residual emissions.

(Section ESRS E3-1) Minor Hotels Europe & Americas states that details of its policies related to water and marine resources can be consulted in the section on policies for "Responsible water management". The Company treats water as a limited resource and identifies responsible water management as a material topic, covering water extraction and water consumption. It notes that suppliers of laundry services stand out as the supplier type that extracts most water. Following its double materiality analysis, aspects related to marine resources were concluded not to be material; the Company's consumption of marine resources derives from the use of such resources for restaurant services, managed within sustainable purchasing. The Company maintains a line of action based on "Sustainable fishing", encouraging legal compliance in relation to consumption of species and responsible procurement of these products, and it does not operate within any protected natural area.

(Section ESRS E3-2) The Company describes measures to reduce the volume of water extraction and to monitor extractions more precisely. Since its first Sustainability Plan in 2007 it has installed aerators, cistern reduction devices, water recovery and reutilisation systems, and efficient dishwasher equipment, and has run training and awareness. From 2014 it progressively installed showers that reduce water volume by 40%, extending this in 2023 with new shower heads installed in 2024 in hotels where fittings are replaced. In 2024 it installed water monitoring technology in 20% of hotels, with associated OpEx of 35,108.00 euros, providing automated reporting and leak alerts. Actions on wastewater reuse and recycling include reuse for WC cisterns at NH Campo de Gibraltar and NH Malaga, and grey water for irrigation at NH Iquique Costa. Four hotels have wastewater treatment systems (three in Venice, one in Milan), and hotels in Milan, Antwerp and Bogota have rainwater storage systems. Using the WRI Aqueduct tool, the Company found 47% of portfolio hotels are in high water-stress areas (139 hotels in 2024).

(Section ESRS E3-3) The Company states it is committed to sustainable management of water resources and recognises the importance of acting in areas of high water stress. Work is currently underway on monitoring and evaluation capabilities to ensure efficient and responsible water management in operations. It explains that once it has robust information, targets associated with this matter will be set, and it expects to be able to define public targets in the short to medium term. The Company's approach is aimed at identifying and prioritising opportunities for improvement, working to define clear goals that contribute to the wellbeing of communities and the care of the environment in terms of water extraction. The Executive Sustainable Business Committee follows up and monitors the commitments made in the Environment and Climate Change Policy, reviewing at its annual meetings the actions undertaken and associated KPIs such as total water extracted by region, the water intensity ratio, and the presence of hotels in water-stress areas, as well as issues such as drought-related water restrictions.

(Section ESRS E3-4) The Company reports water extraction based on original source, mainly public or private water suppliers, with monthly monitoring through a corporate reporting and control system. Total water extraction in 2024 was 4,127,044 m3, up 9.1% from 3,783,672 m3 in 2023, split by region as Americas 567,354 m3, Northern Europe 1,548,283 m3 and Southern Europe 2,011,407 m3. It states 99% of water comes from supply sources and the remaining 1% (48,229 m3) from trucks and tanks serving five hotels in the Americas region. Water extraction in high water-stress areas totalled 1,895,934 m3 in 2024, up 11.5%. Water footprint intensity was 1,761.541 m3 per million euros of revenue and 0.225 m3 per guest. Consumption and intensity rose due to increased activity and portfolio changes. The Company does not currently have total volume of water recycled or reused, or robust rainwater storage data (five hotels have tanks), and reports 31,975.5 m3 of treated water in its Venice hotels before discharge.

(Section ESRS E5-1) The Company states that details of its policies related to resource use and circular economy can be consulted in the section on policies for "waste management and circular economy". The material topic identified is circular economy and waste management, focused on responsible waste management and waste treatment, including measures to reduce, reuse and recycle waste across all production stages. The Company explains that the capacity to separate waste at source by type (EWC) assures proper treatment of each waste type and promotes responsible management with a direct impact on the environment. It notes that authorised managers for the treatment of hazardous and non-hazardous waste are necessary, as failure to use them could involve a risk of breaching applicable regulations and could entail economic sanctions, especially in relation to extended producer responsibility. To identify material impacts, risks and opportunities, the Company carried out an exhaustive analysis of ruling legislation on waste management across its regions, covering local, national and international regulations affecting operations.

(Section ESRS E5-2) The Company describes actions on waste management and circular economy. It operates a system of waste separation at source in all hotels, covering paper and cardboard, glass, used cooking oil, packaging and organic waste. In 2024 the implementation phase was carried out in hotels in Spain and Portugal within the consolidated scope, involving compiling information and on-site training, plus digitalisation through a tailored app with QR-code daily waste monitoring; the goal is to extend this to other European countries from 2025. The OpEx for this initiative was 431,041 euros. The Company introduced sustainable amenities to eliminate single-use plastics in room setup, using 100% recycled and recyclable PET packaging and biodegradable wheat straw accessories. Further actions include a zero plastic policy in F&B (biodegradable straws, returnable glass in minibars), the CORK2CORK project with Amorim to recycle corks into insulation material, using waste cooking oil for biodiesel in Spain, a food waste pilot in a Spanish hotel that cut studied food groups by 42% per portion and organic kitchen waste by 10 tonnes, and a Too Good To Go partnership. Regional projects include bottle cap collection (3.6 tonnes collected in the Americas) and the Drip Drop umbrella initiative (11,000 trees planted, 30 hotels).

(Section ESRS E5-3) The Company states it is committed to circular management and the reduction of waste generation, with a project currently in progress for the correct management and monitoring of waste. Its approach is aimed at identifying and prioritising opportunities for improvement and working to define clear goals that contribute to the wellbeing of communities and the care of the environment. It explains that once the Company has robust information, goals associated with this matter will be set, and it expects to define public goals in the short to medium term once it has the first results of the waste project. The Executive Sustainable Business Committee follows up and monitors the commitments made in the Environment and Climate Change Policy relating to waste management, reviewing at its annual meetings the actions undertaken and associated KPIs. Following approval of the zero waste project in 2023, the level of implementation of this project in Spain and Portugal was monitored in 2024, assessing its degree of success.

(Section ESRS E5-4) The Company explains that because of its business model it does not consume raw materials, meaning natural resources transformed into products or services. In MHE&A's operations no such raw materials are transformed to obtain goods and services. Instead, the Company consumes resource inflows, understood as final goods and services that are made available to clients in the hotels for the development of daily operations. The report notes that upstream activities include the resources and actions necessary for MHE&A to operate efficiently, such as the supply chain and suppliers who provide goods (for example Food & Beverages and textiles) or services (such as housekeeping and security). As a hotel chain, the Company does not carry out processing that gives rise to a product that has to be stored and transported to the end customer, so it identifies its customers as the last phase of the value chain. No resource-inflow tonnage or mass figures are reported for this disclosure requirement.

(Section ESRS E5-5) The Company reports resource outflows through its waste data. A waste management and circularity pilot project ran in all Madrid hotels in 2023, automating the waste management process to advance reduction, reuse, recycling and valuation. To estimate 2024 waste, generation data from Madrid hotels or, in some cases, other Spanish hotels in the second half of the year were used, with waste ratios per room night calculated per hotel group (accounting for factors such as number of stars and volume of restaurant services and events) and applied across all hotels. Total waste generated in 2024 was 36,303 tonnes, up 76.66% from 20,549 tonnes in 2023, comprising 153.80 tonnes of hazardous waste (down 23.3%) and 36,149.30 tonnes of non-hazardous waste (up 77.6%). Of non-hazardous waste, 88% was recycled (31,745.69 tonnes) and all hazardous waste was treated through other valorisation processes. The increase in non-hazardous waste is attributed to higher hotel activity and a new monitoring system that adjusted data to actual quantities; hazardous waste fell due to improved segregation and replacement of hazardous cleaning products.

(Section ESRS E5-5) The Company reports waste generation and treatment. Total waste in 2024 was 36,303 tonnes (153.80 tonnes hazardous, down 23.3%; 36,149.30 tonnes non-hazardous, up 77.6%), against 20,549 tonnes in 2023. 88% of non-hazardous waste was recycled (31,745.69 tonnes), and all hazardous waste was directed to other valorisation processes. By treatment, non-hazardous waste was managed through recycling (31,745.69 tonnes) and other valorisation operations (4,403.61 tonnes), and hazardous waste through other valorisation operations (153.82 tonnes). By waste type, non-hazardous outflows valorised included light packaging 15,878.96 tonnes, glass 6,786.48 tonnes, organic 5,287.33 tonnes, other waste 4,122.70 tonnes and paper and cardboard 3,792.92 tonnes; hazardous types included electrical and electronic appliances 106.75 tonnes and contaminated packaging 28.17 tonnes. On food waste, a pilot in a Spanish hotel cut the main food groups studied by 42% in grammes per portion and reduced organic kitchen waste by 10 tonnes, while the Too Good To Go partnership saved 41,830 food packs (more than 41,830 kg of food), equivalent to avoiding more than 1,129.41 tonnes of CO2eq.

(Section ESRS S1-1) Minor Hotels Europe & Americas (MHE&A) states that details of its policies relating to the workforce are set out across four policy areas: 'Commitment to team members and responsible hiring', 'Culture of equality, diversity and inclusion of team members', 'Health, safety and wellbeing of team members', and 'Training, talent management and career development of team members'. During 2024 the Management Committee approved the Corporate People Policy, described as the global framework that guides actions to create an inclusive working environment. The Company references other governing documents including the Sustainability Policy (adopted 2023), the Human Resources Policy (2024), the Code of Conduct, a zero-tolerance policy on discrimination, a Second Equality Plan approved on 22 December 2022, a protocol against sexual harassment, and a People Policy recognising the right to disconnect from digital devices. The Company reports its identity and essence are communicated to build a single culture for both internal talent retention and external attraction.

(Section ESRS S1-2) MHE&A describes multiple processes for engaging with team members and their representatives. A biennial engagement survey (the 2024 Team Member Engagement Survey / Work Climate Survey) was relaunched, comprising around 50 questions in 11 languages, aimed at permanent and temporary staff with at least three months' service and managed by an external supplier. Participation reached 72%, with 73% of female and 70% of male team members taking part; participation among hotel staff without a corporate email rose from 59% in 2022 to 65% in 2024. Additional listening channels include a Team Member Suggestion Box (anonymous, in 11 languages), onboarding and offboarding surveys, and the WhistleB whistleblowing channel. Employee representatives act as intermediaries who capture and communicate concerns. Internal communication tools include the MyApp employee app, the Tell The World newsletter, online Town Halls, Minor Talks, and the 'Up for Planet and People' channel. Hotel Ambassadors promote participation.

(Section ESRS S1-3) MHE&A states that handling negative impacts and creating effective channels for employees to express concerns or grievances are essential to building trust between team members and the organisation. It says these channels are designed to facilitate transparent communication and reinforce the Company's commitment to team member wellbeing, and refers readers to the 'Loyalty to Team Members' section for more information. The Company acknowledges that it does not currently systematically monitor the quality of its communication channels, which it describes as an opportunity to evaluate their effectiveness and continuously improve the team member experience. Details of the channels and processes for handling grievances or suggestions are cross-referenced to the section SBM-2: Interests and views of stakeholders and, specifically for team members, to section S1-2: Processes for engaging with own workforce and workers' representatives about impacts.

(Section ESRS S1-4) Following its double materiality analysis, MHE&A identified material impacts, risks and opportunities relating to responsible hiring and engagement, culture of equality, diversity and inclusion, training and talent development, and health, safety and wellbeing. To address these it reports actions including a responsible recruitment policy promoting stable employment and avoiding excessive temporary contracts, promotion of social dialogue and collective bargaining, gender equality policies and diversity and inclusion training, and a corporate health and safety approach. Resources cited include specialised industrial relations teams, training in social dialogue and collective bargaining for managers, and digital tools. Specific programmes referenced include the 'All iNH' inclusion initiative, compliance and service training courses, the annual Performance Evaluation programme 'Time For You', and the Team Member Engagement Survey. The Company states it launched and deepened these initiatives throughout the 2024 financial year to enhance positive impacts and minimise negative ones.

(Section ESRS S1-5) MHE&A states it is committed to decent work and a safe working environment and to equal pay and the wellbeing of its team members. It reports carrying out a living wage analysis in all geographical areas where it operates, ensuring pay conditions are in line with current legislation in each country. The Company states that although there are currently no specific targets in this area, it continues to work actively to promote policies supporting pay equity and work-life balance. In addition, the Company reports it has targets to further strengthen the training of its team members and staff of managed and franchised hotels, with the aim of training as many professionals as possible and further increasing the training ratio. It commits to continue actively listening to team members and to promote talent management and career development, ensuring opportunities for growth and a fair and motivating working environment.

(Section ESRS S1-6) MHE&A reports 13,380 team members by headcount at 31 December 2024 (6,850 women and 6,531 men), up 7.6% from 12,436 in 2023. The average number of team members was 14,361 full-time equivalents and 15,222 headcount. The Company notes that, in line with its business model, workforce data from this point onwards corresponds to FTEs, excluding extra employees, non-employees and FTEs in the Brazil region (3 hotels). By region, headcount was 558 at Headquarters, 2,076 in the Americas, 5,060 in Northern Europe and 5,686 in Southern Europe. Team members work across 154 nationalities in 24 countries, with the largest being Spain (3,515), Germany (2,046) and Italy (1,600). Permanent contracts totalled 11,289. In 2024 there were 5,944 new hires (53% aged under 30, 50% women). The total turnover rate was 36.0% and total exits were 5,617.

(Section ESRS S1-8) MHE&A reports that 93% of the Company's team members are covered by collective agreements, which generally include aspects related to health and safety and vary by region. It describes social dialogue as a fundamental pillar and maintains a responsible labour relations model based on dialogue, consultation and active participation. The Minor Hotels Europe & Americas European Works Council (EWC) was established in October 2015 at the initiative of the European Federation of Food, Agriculture and Tourism Trade Unions (EFFAT), governed by Directive 2009/38/EC, covering all workplaces in the European Economic Area; consequently 100% of team members located in EU member countries are covered by it. Collective bargaining coverage is presented by band: for EEA team members, countries in the 80-100% coverage band include Austria, Belgium, Denmark, France, Germany, Italy, Luxembourg, the Netherlands, Portugal, Romania, Spain and Switzerland. Each region manages social dialogue through local labour relations departments aligned with local legislation.

(Section ESRS S1-9) MHE&A reports diversity metrics for its consolidated perimeter. Women represent 51.2% of staff (2023: 51.0%) and hold 46.1% of management posts (2023: 45.4%). There are 154 different nationalities among the Company's team members, and 26.3% of team members work in a country other than their country of origin (2023: 24.5%). By age, 28.8% are under 30, 50.0% are aged 30 to 50, and 21.2% are over 50. Senior Management (the Management Committee) comprises 10 members: 7 men (70.0%) and 3 women (30.0%). The Company reports 127 team members with disabilities (2023: 113). It references its Second Equality Plan, a zero-tolerance discrimination policy, an LGTBQ+ inclusion project in Latin America (with Human Rights Campaign certification for hotels in Mexico and Argentina), and a protocol against sexual harassment supported by a manual for non-sexist language.

(Section ESRS S1-10) MHE&A reports that throughout 2024 it delivered on its commitment to ensure a decent wage for team members, supported by the Sustainability Policy (2023) and Human Resources Policy (2024). It states salaries are based on transparent and equitable criteria taking into account experience, qualifications, responsibilities and job performance. The Company carried out a living wage assessment using the Application Requirements of ESRS S1-10, distinguishing EEA and non-EEA countries. For EEA countries with a statutory minimum wage it verified salaries were above the minimum using Eurostat data, complying with AR73(a) and AR74 of ESRS S1 and Article 6 of Directive (EU) 2022/2041; for EEA countries without a statutory minimum wage it used collective agreement levels as the reference; and for non-EEA countries it used the monetary value in collective agreements as proposed in AR73. As a result, the Company concluded that none of its team members are paid below the living wage.

(Section ESRS S1-12) MHE&A states it promotes diversity, inclusion and equal opportunities as essential pillars of its working culture, ensuring a safe and inclusive working environment adapted to the needs of team members. Through specific measures it promotes the integration of persons with disabilities by adapting workplaces and ensuring optimal conditions for their performance. At the end of the year, 127 team members with disabilities were employed, representing 0.95% of the global workforce. The Company also reports its commitment to the integration of persons with disabilities through responsible procurement from Special Employment Centres, including laundry service providers. It states the share of procurement from Special Employment Centres will reach 9% in 2024, an approximation based on the workforce in Spain together with the team members of the Special Employment Centres assumed in the purchases of Minor Hotels Europe & Americas.

(Section ESRS S1-13) MHE&A reports that all training projects are managed through its corporate university, 'University'. In 2024, 14,853 team members were trained and the total number of training hours was 216,877. The Company also states total training hours at the University in 2024 was 42,213; the number of training hours increased by 47% compared to 2023 and the number of team members trained rose by 11%. Face-to-face training (including virtual training) accounted for 59% of training hours, delivered with the help of 441 internal trainers. Average training hours totalled 15.66 per person (women 16.00, men 15.30), up 40.83% versus 2023, ranging from 27.65 hours for Top Management to 14.13 for Staff. Participation in the Time For You performance evaluation reached 93.9% (women 94.0%, men 93.8%). More than 400 team members were calibrated in 2024, and internal development programmes (such as Becoming a GM, Crossing Borders and Sales Academy) were run.

(Section ESRS S1-14) MHE&A reports that in 2023 it implemented a Corporate Health and Safety Policy and has begun designing a Corporate Occupational Health and Safety Management System based on ISO 45001:2018 and the WHO Healthy Workplace Model. It currently operates an Occupational Risk Prevention Plan for Spain, with a Joint Prevention Service. In 2024 all business units reported accident and occupational disease data, and none caused the death of a team member. For personnel of owned and leased hotels, 657 accidents with and without sick leave were recorded and 387 with sick leave; occupational diseases with and without sick leave numbered 85. A total of 10,772 lost work days were recorded for team members. The accident frequency rate (AFR) was 24.52 and the occupational disease frequency rate (ODFR) was 3.17 for owned and leased hotels. The Company reports health initiatives including GENERALI Vitality, MHE&A Runners, and health and safety training (185 team members trained face-to-face).

(Section ESRS S1-15) MHE&A describes work-life balance as a fundamental pillar of attracting and retaining talent. It reports that 100% of team members are entitled to paternity/maternity leave, and in 2024 4% of team members exercised this right (5% of women and 2% of men). The Company recognises the right to disconnect from digital devices under its People Policy and has evolved towards greater flexibility through its 'New Way of Working' hybrid model, agreed with workers' representatives; around 200 reservation agents at the Central Reservation Office in Madrid work remotely five days a week. The regional office hybrid model provides a minimum of 3 days in the office and 2 days from home, a meal allowance of 112 euros per month, and additional health and safety measures. Other measures include leave for exams and public duties, assisted reproduction and adoption leave, priority recruitment and mobility for victims of gender violence, a discount programme, Payflow and Payflex flexible remuneration, and language training.

(Section ESRS S1-16) MHE&A reports that during the year it calculated its pay gap by comparing salaries between equivalent job categories, weighting the gaps by category headcount. Average gross hourly earnings were 17.71 euro for men and 16.05 euro for women. The overall unadjusted ratio of hourly wages of women to men (the pay gap) was 9.0% for 2024 (2023: 9.8%), calculated as the difference between men's and women's average gross hourly earnings divided by men's earnings. By category the pay gap was 25.3% for Top Management, 4.4% for Middle Management and 2.4% for Staff. The Company notes the gap is increasing in top management, mainly due to fewer women in that category, and states closing the gap is a priority. Average total remuneration was 30,555 euro (women 29,148, men 32,036). The annual total compensation ratio was 50.61 for 2024 (2023: 45.59). The Company states its remuneration model has no gender bias.

(Section ESRS S1-17) MHE&A reports that no workplace incidents or serious human rights incidents occurred during the year that resulted in material sanctions, fines or compensation. It states that 3 cases related to the working environment were confirmed through the whistleblowing channel. These included complaints about inappropriate comments made by a supervisor to colleagues in the context of sick leave, a report of inappropriate conduct by an employee towards an external contractor, and possible discrimination by a supervisor whose comments caused unease and high staff turnover in certain hotels. The Company refers readers to further information in the sections 'Protection and promotion of Human and Labour Rights', 'Whistleblowing Channel' and 'Whistleblower protection'.

(Section ESRS S2-1) Policies relating to workers in the value chain are covered under the policies for managing impacts, risks and opportunities linked to workers in hotels operated under management and franchise arrangements. The Company has a People policy whose scope applies to all companies within MHE&A, including subsidiaries and dependent companies, in every geographic area where it operates. MHE&A also promotes the adoption of these principles in companies in which it holds a stake, even where it does not control management or hold a majority. As a result, the Company promotes application of this policy across all hotels operating under its brands. MHE&A distinguishes three types of value-chain workers: personnel of managed and franchised hotels, subcontracted services, and other suppliers. Following the double materiality analysis, personnel of managed and franchised hotels were found material under "Training and skills development." The channels described under S2-2 are intended to support transparent communication so that all employees of managed and franchised hotels are heard.

(Section ESRS S2-2) Employees in managed and franchised hotels have access to the same tools as staff in owned and leased hotels for raising concerns. These include the Team Member Suggestion Box, the Engagement Pulse engagement survey, and the Canal de Denuncias (WhistleB) whistleblowing channel. Details of the interests and views of stakeholders are provided in the SBM-2 section. Details of the processes for working with employees of managed and franchised hotels, who are the workers considered material in the value chain, are set out in the section on processes for engaging with the own workforce and workers' representatives about impacts (S1-2). The impacts, risks and opportunities identified for this type of worker arise in relation to training and talent management.

(Section ESRS S2-3, presented as S-3 in the text) Resolving negative incidents and creating effective channels for value-chain workers to express concerns are described as essential to building trust between the employees of managed and franchised hotels and the Company, giving assurance that concerns will be heard and dealt with appropriately. The channels set out under S2-2 are intended to facilitate transparent communication so that all employees in managed and franchised hotels are heard. Details of the channels and processes for remediating negative impacts and the channels for workers to raise concerns about the Company are provided in the SBM-2 section on interests and views of stakeholders.

(Section ESRS S2-4) The dual materiality analysis identified that employees of managed and franchised hotels are material to the Company in terms of training and internal development, which improves service quality and prepares staff to work to brand standards. These employees have access to the corporate platform and can take the courses and training offered by Talent, like colleagues in owned and leased hotels. In 2024, 3,272 employees of managed and franchised hotels used the training platform, achieving 39,234 hours of training, an average of 15.10 hours, in line with the ratio for owned and leased hotels. All actions are accompanied by career plans that promote professional growth, including mentoring programmes and functional rotation. These professionals undergo regular performance reviews (Time For You programme) and workplace climate surveys (Team Member Engagement Survey). Recognition programmes, benefits and activities support satisfaction and motivation. To manage the risk of poor service quality and high turnover, the Company conducts regular assessments and develops retention strategies based on improved working conditions and incentives.

(Section ESRS S2-5) The objectives for employees in the value chain are aligned with the training and development objectives set for the Company's own team members. Priority is also given to maintaining a high level of participation in the climate surveys, both the Engagement Survey and the Engagement Pulse, to ensure continuous feedback that strengthens well-being at work and promotes a positive and motivating working environment.

(Section ESRS S4-1) Details of Minor Hotels Europe & Americas' policies related to consumers and end-users are set out under the policies (MDR-P) for "Customer experience and service quality." These policies address the material topics identified for customers, namely unique and sustainable experiences for the customer, service quality, satisfaction and well-being, and customer health and safety, including responsible business model, quality of experience for individual and professional clients, information-related impacts, health and safety measures, and accessibility. MHE&A states that it provides excellent service and an innovative offering and invites its customers to participate in ethical, social and environmental commitments.

(Section ESRS S4-2) MHE&A recognises the importance of effective cooperation with consumers and end-users in managing incidents. For this reason it operates a dedicated customer service department, an open and accessible communication channel that creates space for two-way communication, promoting transparency and building trust between MHE&A and its customers. Through this channel users can express their concerns and suggestions. The Company highlights its recent use of digital tools to gather information and encourage active participation through internal surveys aimed at users who have stayed at a Company hotel or posted a review on online platforms. Details of stakeholders' interests and views are given in the SBM-2 section, and further detail on working with consumers and end-users is provided in the section on service quality, satisfaction and well-being.

(Section ESRS S4-3) Details of the procedures for remediating negative impacts and the channels through which consumers and end-users can raise concerns about Minor Hotels Europe & Americas are set out in the section on information-related incidents. This covers how the Company handles requests and complaints from customers and end-users.

(Section ESRS S4-4) The double materiality analysis identified material impacts, risks and opportunities for customers and end-users across both business-to-business (B2B) and business-to-consumer (B2C) relationships, covering all stages where MHE&A relates to customers directly or through meta-search engines, travel agencies or other third parties. Priority is given to a commercial strategy defined around customer needs and expectations, loyalty programmes and innovative tools for unique, personalised experiences, alongside monitoring and measuring satisfaction and quality, since good reputation and positive reviews attract new customers. Incident management through the Single Customer Service Centre is key to satisfaction and loyalty. Ensuring customer safety and well-being supports business continuity and avoids legal sanctions. The Company acts through three areas: unique and memorable experiences for customers, service quality, satisfaction and well-being, and customer health and safety. Its commercial model follows a Customer Centric philosophy, with projects including a B2B focus, development of the luxury segment through the Anantara and Tivoli brands, and the NH PRO digital solution for B2B clients. On accessibility, 283 hotels have facilities adapted to special needs, with 97% of hotels having some accessibility feature, and the Company purchases from Special Employment Organisations as laundry providers, reaching a 9.0% rate in 2024 (approximate, relative to the workforce in Spain). Information security and privacy impacts are addressed under Digital Transformation.

(Section ESRS S4-5) The Company's approach for the coming years is based on a balance between technological innovation, personalisation of the experience and operational improvement, always with the customer as the central focus. MHE&A states this commitment will enable it not only to meet but to exceed the expectations of its customers, consolidating its leadership and positioning in the hotel sector.

(Section ESRS G1-1) Minor Hotels Europe & Americas continues to strengthen its culture of compliance and ethical business conduct, stressing that not only what is done matters but also how it is done. Its Code of Conduct, translated into seven languages and published on the website and intranet, is built on three pillars: respect for the law; integrity; and honesty, transparency and trust. It was updated in November 2022 to reflect new legal requirements and emphasise the anonymity of the reporting channel, and all team members must complete mandatory Code training. The Company maintains specific corporate policies, including the Anti-Fraud and Corruption Policy, Human Rights Policy, Purchasing Policy with a Responsible Procurement Commitment, and Policy on the Prevention of Money Laundering and Terrorist Financing. For whistle-blower protection, it operates a Whistleblowing Channel (WhistleB) open to employees, managers, directors, suppliers, customers and other stakeholders, managed by an independent third party, guaranteeing confidentiality, respect at all stages and non-retaliation.

(Section ESRS G1-2) The Company recognises the impacts, risks and opportunities linked to proper supplier management, treated within the material issue of sustainable purchasing, and the importance of avoiding late payment to maintain the financial stability of MHE&A and its business partners. Its Procurement Policy, approved in 2014, sets the global framework for supplier payment terms and was supplemented in 2023 by the Responsible Procurement Commitment, which frames control and management of market, credit, business, regulatory, operational, reputational, cybersecurity and criminal risks arising from purchasing. The procurement process uses approval questionnaires that assess suppliers against ESG criteria, ensuring alignment with sustainability standards and promoting ethical and environmentally friendly practices, including a nomination process for selecting main suppliers. The Company's efforts to promote a responsible value chain were reflected in recognition by CDP as a 2023 Supplier Engagement Leader, for raising the level of climate action throughout the MHEA supply chain. It will continue driving sustainable procurement, prioritising key alliances and increasing consumption from local suppliers.

(Section ESRS G1-3) Based on its enterprise risk map and double materiality analysis, the Company concluded that corruption and bribery per se do not represent an inherent risk for MHE&A, with inherent risk lying in a broader fraud sense; it focuses mitigation on asset misappropriation, supported by internal controls and employee training. The Company applies a zero-tolerance policy towards corruption and bribery, underpinned by the Anti-Fraud and Corruption Policy, the Policy for the Prevention of Money Laundering and Terrorist Financing, and a Criminal Risk Prevention Model with controls designed to mitigate corruption risk, reviewed and updated in 2023 and 2024 with an external party. Oversight bodies include the Compliance Committee (created in 2014, which met twice during 2024), the Compliance Office, the Audit and Control Committee and the Board of Directors. Mandatory training covers criminal risk prevention, anti-money-laundering and anti-fraud; the Company delivered 10,819 hours of corruption and bribery training in 2024, up from 7,304 in 2023.

(Section ESRS G1-4) During the financial year, the Company had no confirmed cases of corruption, in the broadest sense of the definition. However, six cases related to fraud were identified, committed individually by employees and not representing institutional practices of the Company. In five of these cases the Company acted immediately and rigorously, implementing corrective and disciplinary measures and reinforcing control and prevention mechanisms to mitigate future risk. One case, at the end of the financial year, remained under investigation. The Company states that it did not receive any fines or become subject to sanctions related to corruption cases. It refers readers to the Whistleblower Channel and whistleblower protection arrangements for further information.

(Section ESRS G1-5) Minor Hotels Europe & Americas does not permit the use of company funds, property or other resources to make contributions or offer anything of value to political candidates, political parties or their members. Company officers and team members may make political contributions in a personal capacity and take part in political activities outside working hours, provided they do not act on behalf of the Company or implicate it in any way. Under no circumstances will the Company reimburse personal contributions made for political purposes; besides being prohibited by Company policy, such payments could create problems with the Anti-Corruption Programme. The Company is, however, a member of industry associations, chambers of commerce, and public or private foundations and associations at global, regional, national and local levels related to its business or geographic area. Through these sustainable alliances it contributes to the sustainable progress and development of the communities and environment in which it operates, supporting projects aligned with its principles, values and objectives.

(Section ESRS G1-6) The management of payment practices is carried out by several Company departments, in particular the administration team and the finance department, and is treated as a key aspect from a sustainable purchasing perspective. The Procurement Policy sets the global framework for payment terms to suppliers, with terms set by country and defined by the CFO of each region; any terms below the country standard must be approved before the supplier account is created, and the Company does not distinguish between suppliers by workforce size or turnover. In 2024, the average payment to suppliers across all consolidated companies was 43.20 days. Although the Company does not have a specific policy to prevent late payment, it has measures in place to avoid delays, and its Financial Committee reviews cash flow, including supplier payment transactions, at its regular meetings. Standard payment terms vary by region, for example CapEx and OpEx generally ranging from 15 to 120 days depending on country.