TAG Immobilien

At the Management Board level, responsibilities in the past financial year were as follows:

• COO (also Co-CEO): Real Estate Management, Acquisitions and Sales, Strategic Real Estate Management & Marketing, Shared Service Centre, Customer and Quality Management, FM Services, Craftsmen Service, Central Purchasing and Technology, Change Management, Business Apartments, Energy Residential Service, Multimedia Real Estate, Business Development, Environmental Social Governance (ESG), Digitalisation and Human Resources

• CFO (also Co-CEO): Group Accounting, Financing and Treasury, Corporate Finance, Tax, Controlling, Investor & Public Relations, ERP/Data Management, Legal, Judicial Rental Collection, IT, Compliance, Internal Audit and Property Management

The Supervisory Board was able to expand with the election of Ms Gabriela Gryger as a shareholder representative at the Annual General Meeting on 28 May 2024. She has extensive expertise in the Polish residential real estate market. This also further strengthens the diversity of the Supervisory Board, with women making up 50% of the Supervisory Board, as they do of the Management Board, and our Supervisory Board is now internationally positioned, as Ms Gryger has Polish citizenship.

The existing members of the Supervisory Board and new member Ms Gryger have the knowledge, skills and experience required to properly perform their duties. The respective professional expertise of the individual Supervisory Board members complements each other, enabling the Supervisory Board as a whole to comprehensively fulfil its duties. The Supervisory Board's control and advisory function is ensured in accordance with the law, the Articles of Association, the German Corporate Governance Code and the rules of procedure.

The Supervisory Board has formed an Audit Committee and a Personnel Committee. The Audit Committee is responsible for the preliminary audit of the documents relating to the annual financial statements and the consolidated financial statements, as well as the preparation of the adoption or approval of these and the Management Board's proposal for the appropriation of profits. The committee discusses with the Management Board, among other things, the principles of compliance, the risk management system and the appropriateness and functionality of the internal control systems. The tasks of the Audit Committee also include preparing the election of the auditor by the Annual General Meeting and verifying the auditor's independence required for this purpose. The members of the Audit Committee have sufficient expertise in the field of accounting and auditing. Expertise in both areas includes reporting, including its audit on sustainability topics.

The Personnel Committee, which also performs the tasks of a nominating committee, is responsible for all personnel matters related to the Supervisory Board and Management Board, the conclusion and content of Management Board contracts and related advisory matters, including fixed and variable remuneration. Furthermore, the Personnel Committee selects suitable candidates for nomination to the Supervisory Board at the Annual General Meeting.

In the 2024 financial year, the Supervisory Board performed the duties incumbent upon it by law, the Articles of Association, the German Corporate Governance Code (GCGC) and its rules of procedure with due care. It regularly advised the Management Board on the management of the Company and monitored its activities. It was also directly involved in all decisions of fundamental importance to the Company at an early stage. The Management Board reported regularly, promptly and comprehensively on all relevant issues of corporate planning and strategic development. The Management Board's reporting covered the economic and earnings position of TAG and its Group companies, the course of business, the internal control system, the risk situation, risk management, compliance and sustainability issues. Reporting was done in writing and orally. The Management Board was also in regular contact with the Chairman of the Supervisory Board to discuss important business transactions and to exchange information on the general course of business.

Integration of sustainability-related performance in incentive schemes

Roles covered

The members of TAG's Management Board receive non-performance-related fixed remuneration as well as variable remuneration, which is paid partly in cash and partly in the form of TAG shares. The fixed remuneration and the variable remuneration are paid exclusively by TAG Immobilien AG; no remuneration is paid to subsidiaries.

The remuneration system for the Supervisory Board does not include any variable remuneration components.

Sustainability KPIs tied to remuneration

Short Term Incentive Plan (STIP)

The variable remuneration consists of two components: the Short Term Incentive Plan (STIP) and the Long Term Incentive Plan (LTIP). Both the STIP and the LTIP include non-financial targets (ESG targets).

Non-financial targets (STIP):

Achievement of the non-financial target based on the risk assessment by the external ESG rating agency Sustainalytics:

• "Negligible risk": remuneration of TEUR 25
• "Low risk": remuneration of TEUR 15
• "Medium risk": remuneration of TEUR 5
• "High risk" or "Severe risk": no remuneration

Long Term Incentive Plan (LTIP)

The ESG targets in the LTIP also include the climate-related target of reducing carbon emissions within the German portfolio by 10% (weighting: 40%).

The ESG targets are set by the Supervisory Board each year for the next LTIP period, i.e. for the next four years.

Weighting

STIP weighting:

To reach the target remuneration of TEUR 150 p.a., the STIP assumes:

• An average annual increase in the EPRA NTA per share and the FFO I per share of between around 5% and 7%
• A "low" risk assessment in the external ESG rating
• No further adjustment (+/- 10%) based on individual targets

Link to STI and LTI

• STIP (Short-Term Incentive): Includes non-financial targets based on Sustainalytics ESG risk rating
• LTIP (Long-Term Incentive): Includes climate-related target of reducing carbon emissions within the German portfolio by 10% (weighting: 40%)

Performance period

The STIP represents a cash remuneration that is immediately payable following the Supervisory Board's decision on the variable remuneration for the respective financial year.

The ESG targets for the LTIP are set by the Supervisory Board each year for the next LTIP period, i.e. for the next four years.

Threshold/target/maximum performance

STIP - Sustainalytics risk assessment:

• "Negligible risk": remuneration of TEUR 25
• "Low risk": remuneration of TEUR 15
• "Medium risk": remuneration of TEUR 5
• "High risk" or "Severe risk": no remuneration

STIP - Individual targets:

Depending on the degree of target achievement, the STIP remuneration determined on the basis of the financial key figures and the non-financial target can be increased by up to 10%, remain unchanged or be reduced by up to 10%.

LTIP:

Climate-related target of reducing carbon emissions within the German portfolio by 10% (weighting: 40%).

Disclosure of payout against sustainability KPIs in the reporting period

Individual targets for the 2024 financial year:

• Implementation of a personnel development system for TAG employees, so that personnel development is established as a strategically operating unit within the human resources department, in order to minimise employee turnover and to retain employees at all levels in the long term
• The first-time refinancing of completed rental properties in Poland with bank loans with a credit volume of at least EUR 150 million and a loan-to-value (LTV) ratio of at least 50%

Individual targets for 2023:

In 2023, the individual targets concerned the implementation of the sales programme in Germany, which led to a total net cash inflow of around EUR 250m, and the successful refinancing of the financial liabilities expiring in 2023 and early 2024 (bridge financing from the acquisition of ROBYG S.A.). Since the Supervisory Board considered these personnel targets to have been more than fulfilled, the STIP remuneration was modified by +10% at the Supervisory Board meeting to adopt the financial statements, resulting in additional remuneration under the STIP of TEUR 3 per Management Board member.

Reference to remuneration report

For a further description of the remuneration and incentive systems of the Management Board and Supervisory Board, including sustainability-related benefits, please refer to the disclosures in the report on the main features of the Company's remuneration system (remuneration report in accordance with Section 162 AktG - Variable remuneration section) within the combined management report.

Against the background of the existing discussion about simplifying the requirements of the CSRD and the associated legal uncertainty, particularly with regard to the content and scope of the sustainability reporting standards applicable in the future, the Management Board of TAG has decided in favour of partially applying the first set of ESRS as a framework within the meaning of Section 289d HGB for the non-financial Group statement for the 2024 financial year.

The Audit Committee is responsible for the preliminary audit of the documents relating to the annual financial statements and the consolidated financial statements, as well as the preparation of the adoption or approval of these and the Management Board's proposal for the appropriation of profits. The committee discusses with the Management Board, among other things, the principles of compliance, the risk management system and the appropriateness and functionality of the internal control systems.

TAG Immobilien AG (hereinafter also referred to as "TAG" or the "Group) is a property company focused on the residential real estate sector, based in Hamburg. The properties of TAG and its subsidiaries are spread across various regions in Northern and Eastern Germany and North Rhine-Westphalia, and since the 2020 financial year, also in Poland, where the business model includes not only building and managing a residential real estate portfolio but also sales activities. As of 31 December 2024, TAG managed a total of around 82,500 (31 December 2023: around 84,700) of its own residential units in Germany and around 3,200 (31 December 2023: around 2,400) in Poland.

TAG's business model in Germany is based on the long-term rental of residential units. All the functions essential for real estate management are performed by our own employees. In addition, caretaker and craftsman services are provided for TAG's own portfolio. The rental business focuses on affordable housing that appeals to broad sections of the population. The Group's own multimedia company supports the multimedia needs of tenants and expands the range of property management services. Energy management is bundled in a subsidiary and includes the commercial supply of heating to the Group's own portfolio with the aim of optimising energy management. In the medium term, these services are to be further expanded and new services for tenants are to be added.

In Germany, TAG's investments are primarily in medium-sized cities and in the surrounding areas of large metropolitan areas, because we see not only growth potential there, but also better opportunities for returns compared to investments in large cities. The vacancy rates of newly acquired portfolios are regularly higher, but these are then reduced after acquisition through targeted investments and proven asset management concepts. Within Germany, investments are made almost exclusively in the regions already managed by TAG, in order to utilise existing administrative structures. In addition, local market knowledge is essential when acquiring new portfolios.

The expansion of business activities into Poland began in 2020 with the acquisition of Vantage Development S.A. ("Vantage"), a real estate developer based in Wrocław. The acquisition of Warsaw-based ROBYG S.A. ("ROBYG") expanded TAG's platform for developing residential units for its own portfolio in the existing regions of Wrocław, Poznań, and especially Tricity, and also enabled a comprehensive market entry in Warsaw. At the same time, TAG expanded its business model to include the development of residential units for sale.

In Poland, TAG had c. 3,200 completed residential units in its rental business as of the reporting date (31 December 2023: c. 2,400). A further c. 1,100 (31 December 2023: c. 1,400) rental units are under construction as of the reporting date. In addition, there are land reserves for the future construction of c. 6,100 (31 December 2023: c. 5,700) further residential units.

In the area of sales business, which also includes joint ventures, c. 3,400 residential units (31 December 2023: 4,300) were under construction as of the reporting date (including c. 100 completed residential units not yet sold (31 December 2023: 502)). The land reserve in this business segment includes a further c. 22,000 (31 December 2023: c. 15,600) future residential units. In the past financial year, a total of 1,936 (previous year: 3,586) residential units were sold in Poland and 2,666 (previous year: 3,780) residential units were handed over to the buyers.

TAG's medium-term growth target is to build up a portfolio of c. 10,000 rental units in Poland by the end of 2028. In addition, the existing sales activities in Poland are to be continued in order to support further growth of the rental portfolio with the surplus liquidity generated there. The investment focus is on new-build apartments in large cities with a favourable population development, close to universities and with a well-developed infrastructure.

Interests and views of stakeholders

Key stakeholder groups identified

TAG's most important stakeholders include:

• Tenants (affected stakeholders)
• Buyers of residential units (affected stakeholders)
• Employees (affected stakeholders - own workforce)
• Business partners and suppliers (affected stakeholders - value chain workers)
• Shareholders including banks, financing partners and analysts (users of sustainability information)
• Cooperation partners such as associations (affected stakeholders)
• Local politicians and associations (affected stakeholders - communities)

Engagement approaches by stakeholder group

Tenants

Channels and frequency:

• Personal contact persons available in tenant offices at sites
• Contact via letter, telephone, email, tenant app or online form on residential brand's website and social media
• Centralized customer management for good accessibility and fast processing
• Customer service feedback via tenant app in Germany
• Housing counselling at main locations (focus on senior living and serviced housing)
• Social counselling service
• Show flats or showrooms for new and existing tenants
• Portfolio-wide tenant survey conducted every three years to determine satisfaction with TAG as landlord and housing wishes

Integration into strategy: Tenants are involved in the strategy and business model in a variety of ways, as their satisfaction is material to TAG's business success. Personal contact is maintained and tenant satisfaction is central to business success.

Buyers (residential units in Poland)

Channels and frequency:

• Customer service available for all matters from sale to support, after-sales service, and property takeover
• Customer satisfaction survey conducted during and after each disposal

Integration into strategy: TAG uses the results of satisfaction surveys to continuously optimize processes and services.

Employees (own workforce)

Channels and frequency:

• Various communication channels: intranet, e-mail distribution lists, brochures, and flyers
• Project groups for cross-site, cross-disciplinary and cross-hierarchical dialogue
• Regular team meetings and jours fixes
• Annual appraisal interviews
• Regular employee surveys
• Regional works councils and general works council meet at regular intervals
• Team events, ideas workshops, joint celebrations or sports competitions
• Special workshops
• Statutory co-determination through works council and representation on Supervisory Board (two employee representatives)
• Individual discussions with managers, HR department and works council

Integration into strategy: Continuous dialogue with employees is a material part of TAG's corporate culture. Focus on ensuring employee integrity through active participation at all levels and open communication on all material topics of corporate development. Involvement of workforce in topics material to TAG's strategy takes place in Group-wide projects. Any employee can apply to participate in projects. Company-wide surveys supplement employee involvement.

Suppliers and service providers (value chain workers)

Channels and frequency:

• Long-standing relationships with craftsmen, commercial and other partners
• Direct contact with TAG contact persons in person on site, by telephone or by e-mail
• Connection continuously improved through optimization of digital processes by Central Purchasing department and Group-wide digitalisation project "Mission Future"

Integration into strategy: Fair, resource-conserving and socially responsible procurement practices are integral part of business strategy and procurement policy, anchored in TAG's Declaration of Human Rights. Business Partner Code sets out requirements and fundamental principles for business partners.

Shareholders, investors, banks, and analysts

Channels and frequency:

• Regular dialogue through international conferences, roadshows, and property tours
• Annual General Meeting
• Regular bank and capital market days

Local communities, politicians and associations

Channels and frequency:

• Direct and personal presence on site through tenant support and neighbourhood management
• Organization of campaigns and events in neighbourhoods (e.g. in active meeting places or meeting centres)
• Support for local initiatives, interest groups, associations and social organisations at sites
• Politician visits to neighbourhoods at main locations for on-site appointments
• Active participation in neighbourhood conferences and round-table discussions on housing topic
• In Poland: collaboration with local authorities on infrastructure expansion (access roads, cycle lanes, parking spaces, charging stations for electric vehicles, green spaces)

Integration of stakeholder interests into strategy and business model

General approach: Insofar as the interests and positions of material IROs were analysed in the course of identifying them, these are comprehensible from TAG's perspective. The results of these analyses are generally taken into account in business policy and, where relevant, in strategy and business model. The Management Board and Supervisory Board are informed about relevant stakeholder interests and viewpoints at regular Management Board and Supervisory Board meetings.

Own workforce: According to the Management Board's assessment, the impacts on TAG's own employees identified as part of the materiality assessment are of a fundamental nature and are not specifically related to TAG's business activities.

Consumers and end-users: A high level of tenant and customer satisfaction as well as continuous neighbourhood involvement through social projects in neighbourhoods in the regions managed by TAG are central components of social commitment ("S").

Workers in the value chain: TAG is committed to respecting and complying with human rights, based on the United Nations Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the eight core labour standards of the International Labour Organization (ILO). TAG expects business partners to behave in compliant and ethical manner, observe established principles of cooperation, and ensure these principles are observed by their business partners.

Distinction between affected stakeholders and users of sustainability information

Affected stakeholders:

• Tenants
• Buyers of residential units
• Own workforce (employees)
• Value chain workers (suppliers, service providers, business partners)
• Communities (local initiatives, associations, social organisations)
• Local politicians and associations

Users of sustainability information:

• Shareholders including banks, financing partners and analysts

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

Overview

The identified material impacts, risks and opportunities arise primarily in the upstream value chain, such as the construction of new residential units in Poland or the maintenance of the existing portfolio in Germany, as well as in TAG's own activities through the active management of the portfolio and the employment of TAG employees. Short, medium and long-term time horizons were considered here.

For a description of the material impacts, risks and opportunities identified as part of the materiality assessment, please refer to the respective topic-specific chapters within this sustainability report.

The results of the materiality assessment are taken into account in the corporate strategy. If the Management Board believes that adjustments to TAG's strategy are necessary, these are analysed and implemented as part of the strategy process. In the reporting period, no adjustments were necessary from the Management Board's perspective. The future influence of the material impacts, risks and opportunities is also currently considered to be low, and no changes to the strategy or business model are currently discernible against this background.

For a description of the risks and opportunities that could have a material impact on TAG's financial position, financial performance and cash flows, please refer to the Opportunities and risk report section in the summarised management report for the financial year 2024.

For a description of the analysis of TAG's resilience with regard to the identified material impacts and risks, please refer to the Risk management – individual risks section in the combined management report for the financial year 2024.

Material IROs by topic

Please refer to the information on SBM-3 in the topic-specific chapters for a description of the material impacts, opportunities and risks identified:

• Climate change (E1): Chapter 3.3 E1.SBM-3
• Resource use and circular economy (E5): Chapter 4.2 E5.SBM-3
• Own workforce (S1): Chapter 5.1 S1.SBM-3
• Workers in the value chain (S2): Chapter 6.1 S2.SBM-3
• Consumers and end-users (S4): Chapter 7.1 S4.SBM-3
• Business conduct (G1): Chapter 9.1 G1.SBM-3

Management Board and Supervisory Board engagement

In the reporting period, the Management Board and Supervisory Board dealt in particular with the following material impacts, risks, and opportunities:

• Results of the tenant survey in Germany (tenant satisfaction)
• Decarbonisation of the existing portfolio in Germany
• Continuation of TAG's social commitment in the context of promoting social projects

Integration with governance structures

The following table provides an overview of where core elements of SBM-3 are located in the report:

Resilience

At this stage, the Management Board assumes that there are no assets that are not compatible with the transition to a climate-neutral economy. TAG has not yet conducted a formal resilience analysis. As part of its climate strategy, TAG is focusing on the gradual implementation of its decarbonisation strategy to ensure the long-term financial performance of the portfolio.

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

Overview of the materiality assessment process

TAG has published its first sustainability report for the 2012 financial year. The previous sustainability reports were also based on an analysis of the material sustainability matters for TAG. The previous materiality analysis was revised as part of an analysis of the material impacts, opportunities and risks (IROs), the double materiality assessment as defined by ESRS 1.

Scope and coverage

The materiality assessment covers all of TAG's business activities and was carried out independently for the two main areas of activity of portfolio development in Germany and project development in Poland.

Step-by-step methodology

Step 1: Stakeholder analysis

In the first step, a stakeholder analysis was carried out and the list of stakeholders from the previous sustainability report was expanded at a granular level. Experts from TAG Germany and the Polish subsidiaries represented the relevant stakeholder groups. Due to their proximity to and close dialogue with the relevant stakeholders, they have a good insight into their interests. For this reason, it was not necessary to conduct an external stakeholder survey.

Step 2: Impact and financial materiality analysis

In a second step, the impact materiality, i.e. the inside-out perspective, and the financial materiality, i.e. the outside-in perspective, were analysed. A distinction was made in the dimension as to whether it was an IRO at company level, portfolio level or both.

Step 3: Consolidation of results

The results of the analyses of TAG Germany and the Polish subsidiaries were then combined.

Inputs to the assessment

Expert groups identified for this purpose, each consisting of the ESG teams and the respective relevant specialist departments, carried out the analysis with the support of external consultants on the basis of the qualitative characteristics of information in Appendix B to ESRS 1 and the respective accompanying information in the individual ESRSs. Environmental concerns, employee concerns, social concerns, respect for human rights and combating corruption and bribery were also included.

Impact materiality assessment

Dimensions assessed:

As part of the impact materiality, the impacts of TAG's business activities on the respective business areas concerned were analysed with regard to the environment, people and/or society. They were assessed with regard to:

• Type of impacts: actual or potential
• Cause of impacts: directly caused by the undertaking or influenced by its business activities
• Location: within the undertaking or in the upstream or downstream value chain
• Time horizon of impacts: short-term as up to one year, medium-term as more than one year up to five years and long-term as more than five years

Scoring criteria:

The dimensions for valuation were the extent, scope, immutability and probability of occurrence. The rating scales were between 0 and 5 for extent, scope and irreversibility and between 1 and 4 for probability of occurrence:

Calculation and threshold:

The quantitative categorisation of impacts results from the product of the severity (sum of extent, scope and immutability) and, in the case of potential impacts, the probability. This results in a value between 0 and 15. Impacts classified as 8 or higher are considered material in the sense of double materiality for the sustainability report.

Special consideration for human rights:

In the event of a potential negative impact on human rights, the degree of severity was given priority over the probability of occurrence.

Financial materiality assessment

Scoring criteria:

The quantitative valuation of the financial materiality of risks and opportunities is based on the valuation dimensions of financial impact and probability of occurrence. The financial impact was assessed on a scale from 0 (no financial impact) to 5 (very high financial impact). The product of the financial impact and the probability results in a quantitative valuation between 0 and 5.

Threshold:

Risks and opportunities with a quantitative valuation of 3 or more are considered material in the sense of double materiality for the sustainability report.

Time horizon and type:

The type and time horizon of opportunities and risks were considered in the same way as the valuation of the impact materiality.

Correlation between IROs

In principle, there are often correlations between the identified risks, opportunities and impacts.

Climate-specific methodology (E1.IRO-1)

The identification and valuation of the material climate-related impacts, risks and opportunities took into account both physical and transitory climate risks.

Physical climate risks:

TAG's climate risk and vulnerability assessment analysed potentially damaging consequences of physical climate risks with a focus on its own business activities for the existing portfolio and project development, as well as possible adaptation solutions to minimise climate risks that are considered material. The upstream and downstream value chain was not explicitly included in the climate risk and vulnerability assessment. The valuation takes into account both external factors (in particular climate projections) and internal factors, i.e. factors that can be influenced by TAG (e.g. structural or portfolio-changing actions).

The climatic impacts of the external impact drivers were analysed from scientific climate projections of the IPCC for four scenarios. The result of the external impact drivers is the site-specific exposure of each building to the seven defined climate risk drivers.

The Company's internal impact drivers can be divided into building-specific and impact-specific factors. The building-specific factors assess the damage that could potentially be caused by the realisation of physical climate risks. For this purpose, the buildings in the portfolio are categorised into damage classes based on their monthly target rent, the turnover to be generated or the construction costs incurred to date. Impact-specific factors categorise the potentially harmful climate impact per risk driver for the property portfolio. The valuation of impact relevance is based on expert assessments by the departments involved. This assessment, together with the damage class, results in the sensitivity of each building to the individual climate risk drivers. The sensitivity represents the gross damage potential.

Implemented adaptation measures describe physical and non-physical actions that can minimise the gross damage potential (= sensitivity). The experts from the various specialist areas have assessed the existing adaptation measures for each climate risk driver. In particular, climate risks and their impacts on the building fabric, the living environment and the tenants were assessed. The combination of these adaptation solutions with the sensitivity results in the vulnerability - the so-called net damage potential. If the vulnerability is combined with the exposure, the result is the qualitative climate risk per building per risk driver per scenario.

Transitory climate risks:

In addition to the physical climate scenario analysis, in 2023 an in-depth analysis of climate-related transitory risks and opportunities and their impact on business activities, strategy and financial planning was conducted on the basis of four representative climate change narratives. The various narratives reflect a range of possible developments and highlight potential risks and uncertainties. Transitory risks arise from the transition to a low-carbon global economy and are limited in time, but can be significant in their scale and intensity.

The material four transitory driver categories comprise society, technology, economy, and regulation, for each of which three to four risk drivers have been analysed. The model focuses on quantifying the influence of these transitory risks on the relevant key performance indicators up to 2030 using the risk drivers. These are parameter-based factors that can have a significant impact on TAG's future business results. They were identified by TAG experts and made measurable using defined parameters for the four different climate change narratives.

The following risk drivers were taken into account in the four transitory driver categories:

Society:

• Demographic change
• Socio-economic framework
• Urbanisation and housing demand
• Reputation and business partners

Technology:

• Renovation wave
• Innovative energy supply
• Digitalisation and networking

Economy: (list cut off in excerpt)

Resource use and circular economy methodology (E5.IRO-1)

As part of the determination of material impacts, opportunities and risks in connection with resource use and circular economy, the material flows of materials along TAG's value chain were identified with regard to assets and business activities and then valued. The valuation was based on the fundamental assumption that the utilisation of resources within the Group is materially focused on the management and refurbishment of the existing portfolio and on new construction activities in Poland.

Materiality issues were identified and valued by the relevant departments such as Central Purchasing, Central Technology, Strategic Property Management and the ESG teams. With regard to the topics of resource use and circular economy, the material stakeholder groups were also involved indirectly via the representatives of TAG's specialist departments, who have a good insight into their interests due to their proximity to and close dialogue with the relevant stakeholders in the course of day-to-day business.

Table of contents of the ESRS disclosure requirements

Transition plan for climate change mitigation

Scope of the plan

A long-term decarbonisation strategy was developed for the existing portfolio in Germany, which was adopted by the Management Board and Supervisory Board in 2021. The strategy covers TAG's German residential portfolio which forms the basis of its business activities.

The strategy was developed with the active involvement of internal and external stakeholders through a dedicated project team (Climate Board) that includes employees from the LIM regions, Strategic Property Management, EWS and Central Technology. External advice from an engineering company supported the data collection, analysis and strategy development.

For business activities in Poland, there is not yet a transition plan for climate change mitigation that is in line with the 1.5-degree target. The adoption of a transition plan for Poland depends on the adoption of the updated integrated national energy and climate plan in accordance with Directive (EU) 2018/1999. TAG is continuously monitoring national developments in Poland and is expected to adopt a transition plan for climate change mitigation for Polish business activities within the next three years following the adoption of the integrated national energy and climate plan.

Target years for net zero / carbon neutral

Germany: TAG's ecological goal is to make its building stock virtually climate-neutral by 2045.

Poland: No net zero target year currently defined.

GHG reduction milestones with baseline years

Germany - Scope 1 and Scope 2 emissions (combined target, location- and market-based methodology depending on data availability):

• Baseline year 2019: 31.9 kg CO₂e per sqm p.a.
• Target 2025: Reduction of c. 10% to 12% to 28 kg CO₂e per sqm p.a.
• Target 2030: Reduction of c. 30% to 22 kg CO₂e per sqm p.a.
• Target 2045: Less than 7 kg CO₂e per sqm p.a.

2024 actual performance: 28.3 kg CO₂e per sqm of usable space (Scope 1 and 2 market-based), representing an approximately 11% reduction compared to the 2019 baseline.

The following table shows the planned emission reductions:

Poland - Rental portfolio (Scope 1 and Scope 2):

• Baseline year 2023: 35.55 kg CO₂e per sqm p.a.
• Target 2028: 31.20 kg CO₂e per sqm p.a. (10% reduction)

The targeted decarbonisation for Poland is materially related to construction activities for the Polish portfolio, which TAG is carrying out as a general contractor.

Scope 3: Not disclosed with specific targets.

Alignment with 1.5°C / SBTi validation status

By reducing carbon emissions, TAG aims to make its contribution to meeting the national climate targets in Germany and thus to achieving the 1.5-degree target. The Federal Climate Protection Act (KSG) stipulates that Germany must produce at least 65% fewer GHG emissions in 2030 compared to 1990 and at least 88% fewer by 2040.

The target values for the building sector in terms of specific carbon emissions in the German portfolio were derived from the national requirements of the Federal Climate Protection Act. According to current calculations and in agreement with housing industry associations, in order to achieve the 1.5-degree target in 2045, a reduction in current carbon emissions to a value of less than 7.5 kg CO₂e per sqm living space p.a. is required.

SBTi validation status: Not disclosed.

In accordance with Commission Delegated Regulation (EU) 2020/1818 and Commission Implementing Regulation (EU) 2022/2453, TAG is excluded from the Paris-aligned EU reference values.

Key levers / decarbonisation pillars

The decarbonisation strategy contains outcome-oriented, measurable targets and interim goals as well as an investment programme. Actions and timelines are integrated into the strategy. The Management Board is responsible for implementing the decarbonisation strategy.

Main focus areas:

1. Energy-efficient refurbishment of building envelope:

   • Thermal insulation
   • Window replacement
   • Actions to modernise heating systems and building envelopes to save energy

2. Emission-reduced heat supply:

   • Switching to more efficient system control using innovative technologies
   • Converting to lower-emission energy sources, including increasing use of non-fossil fuels
   • Conversion from natural gas to district heating
   • Reduction of primary energy factor and carbon emissions by using existing infrastructure
   • Complete reduction of heating oil systems (currently less than 1% of German portfolio)

3. Renewable energy:

   • Installation of renewable energies (e.g. PV)
   • New heating systems must use 65% renewable energy by law from 2024 onwards

4. Smart technology and digitalization:

   • Remote monitoring technology for heating systems (expected energy savings of c. 3% to 5% per year)
   • Target: connect the majority of heating systems to remote monitoring over the next few years
   • To date, around 40% of EWS heating systems have been equipped accordingly
   • Smart home solutions to network building technology and energy information
   • Remote meter reading for real-time monitoring of system efficiency

5. Serial building refurbishment:

   • Regarded as a key technology for overcoming challenges such as shortage of tradespeople, construction time and cost-effectiveness
   • Innovative technology particularly for converting residential units in energy efficiency classes F, G and H to class E and better

6. Group-internal energy management:

   • TAG's Group-internal energy company (EWS) currently supplies around 54% of the portfolio in Germany with heating energy and hot water (around 44,900 units as at 31 December 2024)
   • Long-term target: 90% of German portfolio to be supplied by EWS
   • Responsible for maintenance and modernisation of heating systems

7. Business travel:

   • Implementation of "green" business travel policies (through public transport, use of electric vehicles, sustainable accommodation, suspension of air travel)

Energy consumption and mix (2024):

• 62.9% of German portfolio units heated with district heating
• 36.4% with natural gas
• 0.7% with heating oil
• Energy intensity: 131.6 kWh per sqm of usable space in 2024

CapEx / investment commitments

Germany:

• Total investment volume: Approximately EUR 690m to achieve virtually climate-neutral building stock by 2045
• Annual modernisation expenditure: Increased average of c. EUR 19 per sqm per year
• 2024 actual investment: Around EUR 123.6m in German portfolio (including maintenance expenses), of which approximately EUR 17.1m for projects to reduce carbon emissions

The implementation of the decarbonisation strategy is continuously developed and managed by the Climate Board operating consistency. The strategy ensures comprehensive assessment of ecological actions not only in terms of their effect, but also with regard to the economic consequences for tenants (e.g. through modernisation levies).

TAG is working on practicable solutions to ensure that rents remain affordable in the long term, as otherwise there is a risk that climate change mitigation measures in existing buildings will lose acceptance among broad sections of the population.

Poland: No specific investment commitments disclosed for transition plan.

Locked-in emissions and stranded asset analysis

Not disclosed.

Use of carbon credits / removals

TAG has not disclosed plans for the use of carbon credits or removals in its transition plan. The focus is on direct emission reductions through energy efficiency, renewable energy, and building envelope improvements.

Policies related to climate change mitigation and adaptation

TAG Immobilien has established written policies to address climate change mitigation and adaptation across its business activities in Germany and Poland.

Environmental Policy and Environmental Protection Policy

Scope:

• Applies to business activities in Germany and Poland
• Covers the entire value chain
• Applies to all employees

Key content and principles:

• Actively contribute to environmental and climate protection and climate change adaptation
• Reduce carbon emissions
• Increase energy efficiency of portfolios
• Use resources sensibly and consciously (e.g. through renewable energy)
• Avoid waste and wastewater
• Protect animals and plants, including their habitats (biodiversity)

Governance:

• The Management Board bears fundamental responsibility for environmental issues within the Group
• Individual actions are assigned to respective specialist and regional departments responsible for operational implementation
• Implementation for the German portfolio is managed centrally in coordination between department heads and Strategic Property Management, supported by the Sustainability Committee and the Climate Board
• The Management Board reviews the achievement of environmental protection targets at least once a year, including monitoring of carbon emissions

Public availability:

• Available on the intranet and website
• Employees can make suggestions for improvement

Implementation and monitoring:

• Planned refurbishment projects are discussed with and approved by the Management Board as part of annual budget discussions
• Specific individual cases are discussed in detail in the Building Committee
• For each action, the use of energy-saving measures must be reviewed in accordance with internal regulations
• Use of subsidies or low-interest financing options is considered
• Energy profiles, environmental impact and potential investment costs for refurbishment measures are taken into account for acquisitions as part of life cycle assessment

Internal regulations:

• Heating systems are modernised based on documented profitability calculations, using technology optimal in accordance with current technical standards and legal requirements
• In purchasing and procurement, products and services are valued over their entire life cycle
• Most energy-efficient, environmentally friendly and longevity solutions are prioritised
• Involvement of local partners is favoured

New construction activities in Poland:

• Solutions used in construction planning in accordance with the ROBYG Green Standard
• Represent greatest possible energy efficiency in accordance with current technical standards and legal requirements

Business Partner Code of Conduct

Scope:

• Applies to cooperation with business partners in both Germany and Poland
• Part of contractual documents

Governance:

• Management Board is responsible for drafting the Business Partner Code

Key content and principles:

• Covers climate change mitigation, climate change adaptation, energy efficiency, and use of renewable energy
• Includes regulations on sustainable and resource-conserving business practices

Public availability:

• Available on the websites of TAG and its Polish subsidiaries ROBYG and Vantage

Link to international standards:

• The policies are committed to respecting human rights based on the UN Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, and ILO core labour standards (mentioned in workforce context but applicable to business conduct)

Decarbonisation strategy:

• Long-term decarbonisation strategy developed for existing portfolio in Germany
• Adopted by Management Board and Supervisory Board in 2021
• Contains outcome-oriented, measurable targets and interim goals
• Investment programme of around EUR 690m for environmentally and climate-friendly portfolio
• Actions and timelines integrated into the strategy
• Management Board responsible for implementation
• Climate Board monitors implementation and develops investment strategy in consultation with Management Board

Actions and resources in relation to climate change policies

Overview of decarbonisation strategy

TAG's ecological goal is to make its building stock virtually climate-neutral by 2045. A long-term decarbonisation strategy was developed for the existing portfolio in Germany, adopted by the Management Board and Supervisory Board in 2021. It contains outcome-oriented, measurable targets and interim goals as well as an investment programme of around EUR 690m (approximately EUR 30m p.a.) for an environmentally and climate-friendly portfolio.

Scope: Own operations (existing portfolio in Germany)

Time horizon: Long-term target 2045, with interim milestones (2030, 2045)

Resources allocated:

• Total investment programme: ~EUR 690m (additional investments compared to previous investment level)
• Annual: ~EUR 30m p.a.

Responsibility: Management Board responsible for implementation; Climate Board (interdisciplinary project team) monitors implementation and develops investment strategy

Links to targets: Climate-neutral portfolio by 2045; reduction of GHG emissions in Scope 1 and 2

Key decarbonisation levers and measures

The strategy focuses on a mix of measures:

• Refurbishing building envelopes and heating systems
• Renewing building technology
• Using bridging technologies and digital measurement and control solutions
• Increasing the use of renewable energies
• Use of subsidies or low-interest financing options

Expected outcomes:

KPIs:

• As at 31 December 2024: average energy efficiency 108.9 kWh/sqm usable space p.a. (2023: 109.8)
• ~63% of residential units have energy rating in efficiency class C or better
• Specific carbon emissions (Scope 1 and 2 market-based): 28.3 kg CO2e per sqm usable space (2023: 28.2; 2019 baseline: 31.9) - representing ~11% reduction vs. 2019

Annual refurbishment programme (2024)

Action: Implementation of annual refurbishment programme including thermal insulation and renewal of heating systems

Scope: Own operations (German portfolio)

Time horizon: Short-term (annual, ongoing)

Resources allocated (2024):

• Total investment in German portfolio: ~EUR 123.6m (including maintenance expenses)
• Carbon emissions reduction projects: ~EUR 17.1m
• Reinvestment rate: approximately one third of rental income

Activities include:

• Major modernisation projects
• Individual modernisations: insulating building shell, replacing windows, renewing heating systems
• Validation of renewable energy use for every major modernisation project

Links to policy: Compliance with legal requirement that new heating systems must use 65% renewable energy from 2024 onwards

Heating systems refurbishment and renewable energy transition

Action: Refurbishment of heating systems with focus on increased use of renewable energy

Scope: Own operations (German portfolio via EWS)

Time horizon: Short-term (2024), ongoing

Resources: Included in annual EUR 123.6m investment

Activities (2024):

• 64 heating systems refurbished at EWS
• Primary focus: switching to district heating
• In locations without district heating network: heat pumps (usually supplemented by natural gas peak load boiler)
• Selection of heat pumps with natural refrigerant (R290, low GWP)

Expected outcomes:

• Long-term target: 90% of German portfolio supplied by Group-internal energy company
• Successive efficiency increases through heating system renewal
• Energy, emission and cost savings

KPIs (as at 31 Dec 2024):

• 62.9% of units heated with district heating
• 36.4% with natural gas
• 0.7% with heating oil (target: complete reduction, though unlikely in next few years due to portfolio acquisitions)

Serial refurbishment pilot project (Merseburg-Süd)

Action: Serial refurbishment pilot project using prefabricated façade elements

Scope: Own operations (Merseburg-Süd, Germany)

Time horizon: Short-term (2024), with further projects planned

Resources allocated (2024):

• Investment volume: ~EUR 2.9m
• Taxonomy-aligned CapEx under activity 7.2 "Renovation of existing buildings"

Activities:

• Insulation of top floor and basement ceiling
• Renovation of balconies and entrances
• Use of large-format prefabricated façade elements (only ~20% of construction work on-site vs. ~95% traditionally)

Expected outcomes:

• Energy efficiency improvement: from class F to class B
• Thermal energy requirement and carbon emissions reduced by over 60%

Links to targets: Compliance with EU Buildings Directive (EPBD) requiring 16% energy consumption reduction by 2030 and 20-22% by 2035

Future plans: Further serial refurbishment projects in Salzgitter and Delmenhorst

Remote monitoring technology for heating systems

Action: Equipping heating systems with remote monitoring technology

Scope: Own operations (German portfolio)

Time horizon: Medium-term (ongoing rollout over next few years)

Expected outcomes:

• Energy savings: ~3% to 5% per year (conservative assumptions)
• Efficient operation of installations
• Faster optimisation measures

Future plans: Connect majority of heating systems to remote monitoring

New construction activities in Poland (ROBYG Green Standard)

Action: Application of ROBYG Green Standard in construction planning

Scope: Own operations (new construction in Poland)

Time horizon: Ongoing (applies to projects at planning stage)

Activities:

• Use of solutions representing greatest possible energy efficiency in accordance with current technical standards and legal requirements at time of project planning

Links to policy: Environmental policies and Business Partner Code of Conduct (see chapters 9.2.G1-1 and 9.3.G1-2)

Governance and monitoring

Climate Board: Dedicated interdisciplinary project team including employees from LIM regions, Strategic Property Management, EWS and Central Technology

Responsibilities:

• Monitor implementation of actions
• Develop investment strategy in consultation with Management Board
• Annual review of sub-targets defined in decarbonisation strategy
• Annual reporting to Management Board

External support: Engineering company provided external advice for data collection, analysis and strategy development

Adoption: Decarbonisation strategy adopted by Management Board and Supervisory Board in 2021

Targets related to climate change mitigation and adaptation

Germany Portfolio – GHG Emissions Reduction Targets (Scope 1 & 2)

Methodology notes:

• Combined Scope 1 and 2 target
• Scope 2 emissions calculated using both location-based and market-based methodology depending on data availability from heating providers
• Target aligned with national Federal Climate Protection Act requirements to achieve 1.5-degree target
• Specific target value of less than 7.5 kg CO₂e per sqm living space p.a. for building sector by 2045
• In FY 2024, carbon emissions included in target represent ~90% of market- and location-based Scope 1 and 2 emissions reported in E1-6

Key assumptions:

• Continuous reduction of emission factors for district heating and electricity by 2045 based on renewable energy use by external suppliers (district heating by 85%; electricity by 90%)
• Development of technical progress from 2030 for generation plants
• Annual price increase assumption of 3%
• No consideration of positive effect from changes in tenant behaviour

Decarbonisation measures and contributions (Scope 1 & 2):

Total investment: c. EUR 690m with increased average modernisation expenditure of c. EUR 19 per sqm per year

Progress to date (as at 31 December 2024):

• Energy intensity: 131.6 kWh per sqm of usable space in 2024 (2023: 130.8 kWh per sqm)
• Specific carbon emissions (Scope 1 & 2 market-based): 28.3 kg CO₂e per sqm of usable space in 2024 (2023: 28.2 kg CO₂e per sqm)
• This represents a reduction of around 11% compared to base year 2019 (31.9 kg per sqm)
• Heating mix as at 31 Dec 2024: 62.9% district heating, 36.4% natural gas, 0.7% heating oil

Poland Rental Portfolio – GHG Emissions Reduction Target (Scope 1 & 2)

Note on Poland transition plan:

• No transition plan for climate change mitigation aligned with 1.5-degree target yet for Polish operations
• Adoption of transition plan depends on adoption of updated integrated national energy and climate plan in accordance with Directive (EU) 2018/1999
• Expected to adopt transition plan for Polish business activities within the next three years following adoption of integrated national energy and climate plan
• Targeted decarbonisation materially related to construction activities for Polish portfolio carried out as general contractor

Energy consumption and mix

Total energy consumption by source

TAG's energy consumption for the financial years 2024 and 2023 is disaggregated by source as follows:

Methodology and scope

Energy consumption was analysed based on actual consumption data for 2023 and extrapolated for 2024, taking into account portfolio changes. Data was climate-adjusted to the base year 2019 using heating degree day data from the Institut Wohnen und Umwelt (IWU) for 2023. The climate adjustment covered heat and electricity consumption of portfolios and company-owned business locations in Germany and Poland, as well as energy consumption of vehicle fleets (determined using actual billing data).

Total consumption of fossil fuels includes stationary combustion of heating oil and natural gas, mobile combustion (vehicle fleet) of petrol and diesel (direct energy consumption), and indirect energy consumption of district heating and electricity (proportionate electricity for heat supply and general electricity) in Germany and Poland. Heat and electricity consumption in rental portfolios relates to the entire portfolio.

As administrative activities in Germany account for only around 0.5% of total property area, no distinction is made in total energy consumption between owner-occupied and rental areas.

Due to Germany's nuclear phase-out in April 2023 and the low share of nuclear energy in the German electricity mix (1.4% of gross electricity generation in 2023 according to the Federal Environment Agency) as well as the lack of nuclear energy in the Polish electricity mix, the share of energy from nuclear sources is estimated to be insignificant. The exact share of nuclear power cannot be broken down to TAG's consumption; therefore, an estimate of this share has been suspended.

Total consumption of renewable energy includes certified green electricity for administrative locations in Poland, self-generated solar power from Polish subsidiaries Vantage, and the energy suppliers' reported share of the district heating mix for rental portfolios.

Energy intensity per net revenue

TAG operates in high climate impact sectors (Section L, Class 68.10: purchase and sale of own land, buildings and residential units; Section L, Class 68.20: rental and leasing of own or leased land, buildings and residential units).

Net revenue represents total revenue according to the consolidated income statement, including revenues generated through services in addition to rental revenues, rental-related services, and sales proceeds.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 and Scope 2 GHG emissions

TAG reports Scope 1 and Scope 2 emissions in accordance with the GHG Protocol Standard, applying the operational control approach. The emissions are based on energy consumption data and are adjusted for vacant space in the portfolio. Both location-based and market-based methodologies are used for Scope 2.

Methodology and scope notes:

• Scope 1 emissions relate to direct energy consumption (oil, gas, petrol and diesel). Carbon emission factors from utilities, BAFA and environmental agencies were used.
• Scope 2 emissions relate to indirect energy consumption (district heating, general electricity, proportionate electricity for heat supply and charging electricity for electric vehicles).
• Energy consumption data for 2023 was used as basis and extrapolated for 2024, taking into account changes in the portfolio. Data was climate-adjusted to the base year 2019 using heating degree days.
• Administrative activities in Germany account for around 0.5% of total property area, so no distinction is made between owner-occupied and rental areas.
• Scope 1 and 2 emissions in the entire portfolio were included, adjusted for vacant space for 2023.

Scope 3 GHG emissions

For the 2024 reporting year, Scope 3 emissions are not reported in full accordance with ESRS requirements. TAG reports voluntarily in accordance with the GHG Protocol Standard on Scope 3 categories relevant to TAG's business model. TAG expects to report in accordance with ESRS from the 2025 reporting year onwards.

Methodology and scope notes:

• Category 3.1 Purchased goods and services: Includes emissions from new construction for sale in Poland. Calculation based on floor space completed in the financial year (sqm), considering emissions from LCA phases A1–A3. Emission factor of 365 kg/sqm over a lifetime of 50 years was used (based on DGNB study).
• Category 3.2 Capital goods: Includes emissions from new construction for rental business in Poland and investments (CapEx measures) in the existing portfolio in Germany and in the vehicle fleet. Calculation based on internal calculations of reference projects, extrapolated to total CapEx actions.
• Category 3.13 Downstream leased assets: Includes emissions from tenants' electricity consumption (Germany and Poland). For Polish rental portfolio, also includes tenants' water and waste consumption. German electricity consumption estimated based on Federal Statistical Office data, converted using emission factor for German electricity mix (Federal Environment Agency). Polish electricity consumption based on actual consumption data from let residential units, converted using supplier-specific emission factors. Water and waste emissions use emission factors from UK Defra and UK Department for Energy Security & Net Zero.

GHG intensity based on net revenue

Total GHG emissions per net revenue as at 31 December 2024. Net revenue represents total revenue according to the consolidated income statement:

Note on intensity metric: TAG does not focus on this metric as it is of limited relevance to TAG's business model. The specific characteristics of the property portfolio (size, age, energy efficiency) are not taken into account. TAG uses specific carbon emissions (kg CO₂e/sqm p.a.) as the relevant metric for calculating emissions efficiency. In the reporting year, this was 28.3 kg CO₂e per sqm of usable space for Scope 1 and 2 emissions (market-based).

Biogenic CO₂ emissions

Not disclosed separately.

Regulated emissions (EU ETS)

0.0% of Scope 1 emissions are from regulated emission trading schemes.

Internal carbon pricing

Internal carbon pricing systems were not applied in the financial year 2024.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Phase-in exemption applied

TAG Immobilien has applied the phase-in exemption for ESRS E1-9 disclosures. The following specific disclosure requirements are marked as "phase-in":

• ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks paragraph 66
• ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a)
• ESRS E1-9 Location of significant assets at material physical risk paragraph 66 (c)
• ESRS E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes paragraph 67 (c)
• ESRS E1-9 Degree of exposure of the portfolio to climate-related opportunities paragraph 69

No quantified financial effects, time horizons, methodologies, or specific asset implications are disclosed in the current reporting period due to the phase-in exemption.

Policies related to resource use and circular economy

TAG has established several policies addressing resource use and circular economy principles across its operations.

Principles and Guidelines for Ecologically and Socially Responsible Procurement (Green & Social Procurement Policy)

• Scope: Binding for all Group employees; part of the central procurement strategy
• Availability: Available to employees via the intranet; a summary is available on the TAG website
• Key content: Addresses the conscious use of resources; part of separate ESG guidelines
• Governance: The Management Board is generally responsible for monitoring and adapting these policies. In the area of inventory management in Germany, the "Central Purchasing" department is responsible for the strategic direction and management of purchasing processes
• Implementation: The selection of materials and products, the selection of and cooperation with service providers, the implementation of construction actions in the portfolio through to waste disposal are analysed from the point of view of resource conservation, possible reuse or recycling and adjusted if necessary. Awareness of the careful use of resources and the efficient use of materials is raised in work meetings, workshops and training sessions

Principles and Guidelines for Environmental Protection (Environmental Policy)

• Scope: Binding for all Group employees; part of separate ESG guidelines
• Availability: Available to employees via the intranet; a summary is available on the TAG website
• Key content: Addresses the conscious use of resources as part of TAG's environmental protection approach
• Governance: The Management Board is generally responsible for monitoring and adapting these policies
• Implementation: Policies provide for the efficient and responsible use of materials, recycling and waste reduction. Environmentally friendly management of green spaces, including rainwater collection for reuse in irrigation. Construction projects focus on environmentally friendly construction site organisation and waste management in accordance with internal regulations on resource conservation

Business Partner Code

• Scope: Applies to all business partners and their employees; binding component of every business relationship between Group companies of the TAG Group based in Germany and their business partners. Corresponding guidelines also apply to Polish subsidiaries, taking into account country-specific regulations
• Availability: Published on the website of TAG and its Polish subsidiaries
• Foundation: Based on the Business Principles applicable to all employees of the TAG Group
• Key content: Business partners undertake to actively contribute to protecting the environment and the climate, in particular by reducing carbon emissions, using resources such as water and energy sensibly and consciously and avoiding waste and wastewater, and to orientate their purchasing activities towards solutions that are as energy-efficient, environmentally friendly and therefore longevity-friendly as possible
• Implementation: See Chapter 9.3 G1-2 for information on dealing with violations and further details

Central Procurement Strategy

• Key content: Stipulates that regional and recycled building materials are to be prioritised at all sites, provided that this is justifiable from an economic point of view. Focus on gradually switching to higher-quality materials in order to improve living comfort and ensure long-term functionality. Contractors are obliged to minimise the amount of waste generated and ensure proper waste disposal

ROBYG Green Standard (Poland - New Construction)

• Scope: Applies to new construction project developments in Poland
• Key content: Self-developed standard with specifications for low-emission solutions, ecological design, the use of materials and the design of outdoor/green areas. Aims to minimise the use of non-renewable resources throughout the entire construction process (design, implementation, operation). Gives priority to sustainable products and economic efficiency. Uses regional materials that are durable and have good performance characteristics where possible. Emphasizes responsible waste management through waste separation
• Alignment: Corresponds to the guidelines in Germany, taking into account country- and business area-specific regulations

Environmental and Procurement Guidelines (Poland)

• Scope: Applies to the business area of new residential units in Poland
• Alignment: Correspond to the guidelines in Germany, taking into account country- and business area-specific regulations

Actions and resources related to circular economy

Scope and approach

Maintaining the functionality, substance and value of buildings is the basis of TAG's business activities as a housing company. The company maintains its portfolio and ensures its rentability through maintenance and modernisation measures. Efficient use of materials according to circular economy principles such as functional durability, reliability, reusability, retrofitting, repairability and recyclability generally contributes to extending the life cycle of buildings, reducing the consumption of natural resources and waste in particular, and saving costs in the long term. In new builds, these principles are already focussed on in the planning and construction phase.

Scope: Own operations (portfolio maintenance, modernisation, new builds in Poland)

Regulatory framework: Actions are guided by the EU Circular Economy Directives and national regulations, such as the German Circular Economy Act (Kreislaufwirtschaftsgesetz, KrWG) to promote the circular economy and ensure the environmentally sound management of waste.

Product and material specification

TAG has defined the quality and detailed properties for specific products and materials in its overall service catalogue. These specifications are regularly obtained by means of inspection documents. Among other things, it is important that the products are:

• Durable
• Recyclable
• Environmentally friendly
• Biologically harmless
• Safe for health
• Easy to maintain

Reuse and repair of materials and components

Scope: Own operations (portfolio management, rental business in Poland)

The company reuses materials that meet the currently permitted standard wherever possible. Examples include:

• Complete refurbishment of bathrooms: Checking whether bathtubs can still be used
• Rental business in Poland: Checking whether damaged parts of flat fittings such as furniture can be repaired using components from other defective fittings
• Electrical sector: Obligation to install appliances with uniform standards that can be combined with each other, enabling flexible later use

Office and administrative resource conservation

Scope: Own operations (office locations and administrative activities)

Together with employees, TAG endeavours to conserve resources, reduce waste and implement waste separation at office locations. Actions include:

• Sparing use of paper
• Preference for environmentally friendly recycled paper
• Collection of waste paper for recycling
• Digital document management and increasing digitalisation of business processes to save paper

Procurement and supplier management

Scope: Upstream value chain (suppliers and business partners)

TAG is in dialogue with suppliers about the origin and processing of the resources used. The company:

• Reviews procurement practices and makes adjustments where necessary
• Continuously monitors contracts with business and framework agreement partners
• Successively adds further sustainability criteria to supplier contracts

Regional and sustainable sourcing: As far as possible, the company uses regional materials that are durable and have good performance characteristics.

Waste management

Scope: Own operations (portfolio) and downstream (tenants)

Responsible waste management plays an important role in building planning and during the construction phase, for example through waste separation.

TAG attempts to reduce the amount of household waste in its portfolio and increase the proportion of recyclable materials through:

• Professional waste management
• Consistent waste separation
• Systematic re-sorting
• Appropriate advice, notices and information campaigns for tenants and buyers

Planned future expansion of actions

Time horizon: Future (no specific dates provided)

Scope: Poland operations

TAG plans to further expand the actions described above. Planned initiatives include:

• Development of further internal guidelines relating to the circular economy in administrative activities for business in Poland
• Examination of the possibility of selling damaged but still functional furniture instead of disposing of it
• Employee training on the topic of the circular economy

Resources allocated

Financial resources: The Management Board will provide the financial resources required to implement the actions described.

Note: No specific capex or opex amounts are quantified. No specific headcount or non-financial resources are disclosed.

Targets related to circular economy

Germany operations

TAG has set itself the goal of further optimising its internal policies for the transition to a circular economy, particularly with regard to:

• Expanding professional waste management
• Further developing the associated data collection processes with a view to EU Taxonomy-aligned investments

The target is part of the sustainability programme and is regularly validated with the involvement of the ESG/Sustainability, Central Technology and Central Procurement departments. The Management Board is responsible for achieving the target.

Target status: Measurable, outcome-oriented targets may be adopted in the financial year 2025, depending on the further development of internal policies and the availability of appropriate providers for data collection processes on the market.

Poland operations

TAG aims to:

1. Green Standard compliance: Build new construction projects in accordance with the "Green Standard" developed internally, including:

   • Ecological design guidelines for the construction of buildings
   • Use of materials
   • Water and wastewater solutions

2. Construction waste recycling: Increase the proportion of non-hazardous construction waste by weight as defined by the EU Taxonomy Regulation that is sent for recycling or reuse

3. Waste management plan: Implement a waste management plan for business partners in Poland

4. Additional targets:

   • Further digitising business processes in Poland (e.g. converting administrative correspondence to electronic formats)
   • Analysing further potential for avoiding or reducing the consumption of resources in the rental business
   • Training employees to use resources sparingly

Target status: These targets were defined with the involvement of internal departments in Poland as part of the review and update of the ESG strategy. TAG plans to report on the concretisation of the targets and the degree of target achievement in the Sustainability Report for the 2025 financial year.

Responsibility: The Management Board is responsible for following up on the implementation of the targets.

E5-4 – Resource Inflows

Resource inflows are a material sustainability matter for TAG, particularly in connection with refurbishment projects and new construction activities in Poland. Material impacts, opportunities and risks arise primarily from the procurement and use of corresponding construction products and materials in connection with these activities. Construction projects are generally associated with considerable resource requirements. However, this can be minimised by using renewable raw materials, reusable materials and products or resource-efficient technologies. Using regional materials and sourcing from regional suppliers can shorten supply chains and lead to cost advantages.

Based on TAG's own activities, including activities in the upstream value chain (in particular construction and trade companies and construction material suppliers), the purchased quantities and masses of the material products and material groups for 2024 were determined.

The total weight of inflows in the reporting period amounts to approx. 476,341.1 tonnes and includes building materials (e.g. concrete, steel, insulation materials) as material or product groups. Technical equipment and office equipment are not classified as material and are therefore not included.

Certified organic materials and biofuels for non-energy purposes were not used in the reporting period; their percentage share is therefore 0%. No information can be provided on the weight and proportion of reused or recycled components due to a lack of sufficient data from the value chain for the reporting year.

Methodology and Data Quality

The data provided for building materials are estimates and projections based on TAG's internal documentation, such as contracts with construction companies. For example, reference quantities were determined for the inflow of building materials from the construction project activities of empty apartment construction/small-scale maintenance, string refurbishment, complex refurbishment and energy refurbishment and extrapolated to the area affected by these actions in the reporting period. The data used to determine the resource inflows from construction activities in Poland are based on the construction contracts concluded with TAG's business partners in the 2024 financial year.

Note on critical materials: Critical raw materials and rare earths are not of central importance for TAG's business activities, but are contained in certain building technologies such as smart home systems and photovoltaic systems.

Resource outflows

The operation of buildings, modernisation measures in the portfolio and, in particular, the construction of new properties involve considerable consumption of energy and raw materials. Buildings are designed so that their individual elements can be repaired. Actions and regular maintenance ensure the preservation or restoration of their functionality and safety by eliminating defects and repairing damage.

Average life cycle and service life:

• The average life cycle of buildings is around 50 years; with regular maintenance, their service life or useful life can be extended to 100 years or more
• The useful lives of individual components and technical building installations vary depending on the type of construction and material:
  • Concrete walls: 50 years average service life
  • Composite thermal insulation systems: 20 to 40 years
  • Insulating glazing: 30 to 40 years

Relevant data collections such as the ÖKOBAUDAT data sets or the BBSR tables on service life of building components serve as a basis for the calculation or estimation of life cycle costs and life cycle assessments and support the valuation of the ecological criteria of buildings.

With this in mind, TAG's resource management takes a holistic view of material flows, i.e. across the property life cycle and according to the principle of the circular economy. From planning, procurement and recovery through to waste disposal, attention is paid to the economical and efficient use of resources, longevity and functional stability of products and materials, reuse and recovery and recyclability. This can contribute both to lower resource consumption and to the promotion of innovative waste management solutions and recycling, especially in larger construction projects.

Waste

Waste generation and composition

Resource outflows in the TAG Group relate in particular to products and materials used in portfolio management, modernisation and maintenance measures, new construction and administrative activities, e.g. consumed as fuels or used as construction products, as well as waste generated in this context. The waste generated by TAG in Germany consists materially of waste from construction activities, such as building rubble. TAG's waste volume does not contain any radioactive waste.

Material waste codes from construction activities (European Waste Catalogue - AVV):

Quantitative waste data (01/01 – 12/31/2024)

Methodology and data quality

The data provided on waste volumes are estimates based on TAG's internal records, taking into account current legal regulations and standards as well as relevant waste balances. The assumptions were made against the background that the disposal of construction and demolition waste is carried out by waste disposal companies commissioned by the tied construction companies. Waste disposal companies are required by law to ensure that waste is separated by type. TAG sets out its requirements in this respect to the construction companies via construction or framework agreements.

For the estimates, waste volumes were determined on the basis of a reference project in Germany and then extrapolated to all projects started and completed in the 2024 financial year. The breakdown of the total amount into hazardous and non-hazardous waste and recycling routes is based on the respective waste codes and the relevant waste balances mentioned.

For the business activities in Poland, data is available for resource outflows from the Company's own administration (central divisions as well as sales locations and construction offices), i.e. only waste from the Company's own activities is taken into account and no construction waste is included. TAG plans to expand the data collection processes for waste volumes in the construction process in the future.

Policies related to own workforce

TAG Immobilien has established several policies and internal regulations governing its own workforce. These policies are designed to promote an appreciative and diverse corporate culture characterized by transparency and co-determination, applicable to the entire workforce.

Business Principles

Scope: All employees (entire workforce)

Governance: Adopted by the Management Board

Key content:

• Promotion of equal opportunities, diversity and inclusion
• Prohibition of discrimination and ensuring equal treatment regardless of race and ethnic origin, skin colour, gender, sexual orientation, gender identity, disability, age, religion, political opinion, national origin or social background
• Rules on business relationships, non-competition clauses, conflicts of interest and data protection
• Emphasizes high degree of personal responsibility and pleasant working environment
• Trust, respect and appreciation as core principles

Monitoring: Violations are punished consistently and, if necessary, under labour law. The Compliance department supports implementation and compliance.

Public availability: Mentioned as established internal regulation; specific URL not provided

Anti-Discrimination Policy

Scope: All employees (entire workforce)

Key content:

• Promotion of equal opportunities, diversity and inclusion
• Prohibition of discrimination and equal treatment requirements
• Preservation of diverse and equal corporate culture

Public availability: Mentioned as established policy; specific URL not provided

Declaration of Principles on Respect for and Observance of Human Rights

Scope: All employees

Key content:

• Commitment to respecting and complying with human rights based on:
  • United Nations Universal Declaration of Human Rights
  • UN Guiding Principles on Business and Human Rights
  • OECD Guidelines for Multinational Enterprises
  • Eight core labour standards of the International Labour Organization (ILO) covering freedom of association, prohibition of discrimination, abolition of child labour and forced labour, and occupational health and safety

Link to international standards: Explicitly aligned with UN Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, and ILO core labour standards

Public availability: Mentioned as established declaration; specific URL not provided

Rules of Procedure for Dealing with Information in Accordance with the Whistleblower Protection Act

Scope: All employees and external stakeholders

Key content:

• Whistleblower system available for submitting information about actual or suspected legal or compliance violations
• Can also be used to report human rights and environmental risks under the Supply Chain Due Diligence Act
• Multiple reporting channels: digital whistleblowing system, post, telephone, email, in person, or via compliance confidential counsellor
• Anonymous reporting possible
• Protection of whistleblower identity in compliance with data protection regulations
• No tolerance for discrimination or reprisals against whistleblowers

Governance: Compliance Officer appointed by Management Board, authorized to act independently, not bound by instructions

Monitoring: Incoming reports processed promptly by Compliance Officer; remedial measures include disciplinary or labour law consequences, claims for damages or criminal prosecution

Public availability: Rules of procedure published on website

Workplace Accident Prevention Policy / Occupational Health and Safety Management

Scope: All employees (entire workforce) in Germany and Poland - 100% coverage

Key content:

• Safety regulations, inspections, employee training
• Involvement of external consultants and occupational physicians
• Personal instruction of all employees at least once a year on occupational health and safety topics
• Regular safety briefings for industrial employees
• Protective work clothing provided
• Regular evacuation drills
• Regular workplace inspections
• Occupational Safety Committee (ASA) meetings with Occupational Safety Officer and works councils

Governance: Local occupational safety officers ensure compliance; external specialists responsible for occupational health and safety; Management Board oversight

Monitoring: Compliance monitored and ensured by local occupational safety officers; regular reviews on safety-related topics; annual analysis of actions taken, accidents at work and findings from workplace inspections with external consultants

Company Agreements on Flexible Working

Scope: All employees

Key content:

• Flexible and mobile working options
• Trust-based working hours and flexible working time models
• Guaranteed parental leave
• Home office and mobile working arrangements
• Intended to contribute positively to work-life balance and mental health

Public availability: Internal company agreements in place

Additional workforce-related commitments

TAG also commits to contributing to Sustainable Development Goals:

• SDG 3: Good health and well-being
• SDG 5: Gender equality
• SDG 8: Decent work and economic growth

Employees are supported through modern workplace equipment and internal and external training programmes tailored to their needs, including standard and individual training courses on personal and professional topics.

Taking action on material impacts on own workforce

Overview

TAG assesses identified material negative and positive impacts, risks and opportunities as well as business practices in relation to its own workforce on an ongoing basis as part of quarterly personnel controlling and on an ad hoc basis through workforce feedback to ensure practices do not have material negative impacts.

Actions and Programmes

Flexible Working and Work-Life Balance

• Scope: Own operations (Germany and Poland)
• Description: Flexible and mobile working, trust-based working hours and flexible working time models, including guaranteed parental leave. Company agreements governing home office and mobile working are in place.
• Objective: Positive contribution to work-life balance and (mental) health of workforce
• Status: Already implemented in reporting year and will be continued

Company Health Management System

• Scope: Own operations
• Description: Actions to promote sporting activities and health care through:
  • Training courses
  • Health days
  • "Work Life Portal" health app
  • Organisation of joint sporting events
• Objective: Promote health and well-being of employees and increase satisfaction with TAG as employer
• Resources: Necessary resources are made available (non-quantified)
• Status: Already implemented and ongoing

Employee Benefits

• Scope: Own operations (Germany and Poland)
• Description:
  • Job bike leasing at favourable rate (Germany)
  • Promotion of supplementary health and life insurance (Poland)
• Status: Ongoing support

Training and Professional Development

• Scope: Own operations
• Description:
  • In-house training and further education on specialist topics and personal development
  • Focus on occupational safety on construction sites in Poland due to construction activity
  • Training on occupational safety to minimise injuries and absences
  • Training on company pension schemes
• Approach: Employees asked about training and development needs; regular training programmes provided as required
• Context: Response to shortage of skilled labour
• Resources: Necessary resources are made available (non-quantified)
• Status: Ongoing focus area

Modern Workplace Equipment

• Scope: Own operations
• Description: Support through modern workplace equipment and internal and external training programmes tailored to employee needs
• Status: Ongoing

Effectiveness Assessment

Effectiveness of actions taken is assessed through:

• Active feedback from employees via employee surveys
• Annual staff appraisals
• Monthly personnel controlling by Management Board to assess personnel cost trends and staff turnover

If actions are ineffective, reasons are discussed in detail and appropriate adjustments are made.

Risk and Opportunity Management

Material risks and opportunities arise from:

• Costs resulting from higher employee turnover
• High employee retention and satisfaction

Management Board regularly assesses these through monthly personnel controlling to recognise negative trends early and take countermeasures if necessary.

Time Horizon

All actions described were already implemented in the reporting year and will be continued in the future (no specific end dates provided).

Management Board Assessment

In the Management Board's assessment, no further actions to prevent material negative impacts were necessary in the reporting year. Existing procedures and guidelines to promote equality and inclusion will be continued.

Targets related to own workforce

Employee Satisfaction Target

Target metric: Employee satisfaction rate (percentage of employees satisfied or very satisfied with their current work situation)

Target value: At least 70%

Target year: Not specified (continuous target)

Baseline year: 2022

Baseline value: 69% satisfaction rate achieved in Germany

Scope: Employees in Germany

Target type: Absolute percentage target

Validation status: Internal target (not externally validated)

Review frequency: Three-year intervals

Next review: Planned for 2025

Rationale: Based on results of previous employee surveys, the Management Board set this target to ensure employees feel connected to TAG as an employer and are satisfied with their workplace and work culture. Regular reviews and feedback collection are intended to ensure not only that the target value of 70% is continuously achieved, but that a working environment exists in the long term that is perceived positively by employees.

Personnel expenses increased to EUR 91.4m in the reporting period (prior-year period: EUR 85.6m), due in particular to ongoing salary increases, but also to the higher number of employees required due to growth in Poland. As of 31 December 2024, TAG employed 1,856 people, including employees in Poland, compared to 1,816 employees at the end of the 2023 financial year.

Characteristics of non-employees in the undertaking's own workforce

Disclosure Statement

TAG Immobilien explicitly states that the company does not employ non-employees in its own workforce:

"TAG does not employ any employees, self-employed persons or persons provided by third-party companies that are primarily active in the field of labour recruitment and leasing."

The company notes that in Poland, TAG employs some individuals who provide services as natural persons, but these are classified as employees rather than non-employees.

Future Reporting

The company indicates that it expects to report detailed information on associates from the 2025 reporting year:

"TAG expects to report detailed information on associates from the 2025 reporting year as part of the disclosures on S1-7."

Context on Workforce Composition

As at 31 December 2024, TAG employed 1,725 employees across the Group. The workforce consists of both part-time and full-time employees, with the vast majority on open-ended contracts.

For the construction and maintenance work required in its business operations, TAG works with external service providers through framework agreements and procurement contracts, but these workers are not part of TAG's own workforce as defined under ESRS S1-7.

Collective bargaining coverage and social dialogue

Collective bargaining coverage

As an undertaking not bound by or applying collective bargaining agreements, TAG employs 0% of its employees on the basis of collective labour agreements.

Coverage rates by country and social dialogue arrangements

Workers' representatives

Workers' representatives on the Supervisory Board cover 74.5% of TAG's employees.

European Works Council

There was no agreement on representation by a European Works Council (Societas Europaea (SE) or Societas Cooperativa Europaea (SCE)) in the reporting period.

Additional context

• All property and office management trainees receive the same training allowance, staggered according to the year of training
• Remuneration is based on the collective agreement for the property industry or is slightly higher
• For all other apprenticeships, TAG is guided by the upper end of the pay scale recommended by the Chamber of Industry and Commerce and the Chamber of Crafts
• TAG involves employees directly and works together with representatives such as the works council, the General Works Council, the youth and trainee representation and the Workers' representatives on the Supervisory Board
• Information meetings are held at regular intervals with the local works councils in Germany

This also further strengthens the diversity of the Supervisory Board, with women making up 50% of the Supervisory Board, as they do of the Management Board, and our Supervisory Board is now internationally positioned, as Ms Gryger has Polish citizenship. Following these new elections, the proportion of women on TAG's Supervisory Board, as on its Management Board, is 50%.

Adequate wages

TAG states that "adequate wages are paid to TAG Group employees in line with the applicable reference values."

No specific living wage benchmark is disclosed. No methodology is provided. No coverage percentages are given. No assessment details are disclosed.

The company references "adequate wages" in the context of working conditions in the value chain, noting promotion of "social standards (e.g. working hours, adequate wages, anti-discrimination, no illegal/unethical working conditions)" through the Business Partner Code, but does not specify the benchmark or assessment methodology used to determine adequacy.

Social protection

Company pension scheme

TAG offers a company pension scheme as part of its additional and social benefits, which strengthens the social protection of employees and their loyalty to the undertaking.

Retirement benefit provisions

TAG maintains defined benefit pension plans for a limited number of former Management Board members and employees:

Pension parameters:

• Interest rate: 3.21% (2024), 3.94% (2023)
• Pension adjustment: 2.50% (both years)
• Biometric basis: 2018 G mortality tables by Klaus Heubeck

Defined contribution plans

Employer contributions to statutory pension insurance:

• 2024: TEUR 664.2
• 2023: TEUR 474.5

Supplementary benefits

Poland: The company promotes supplementary health and life insurance as part of employee benefits.

Coverage details

No quantitative data disclosed on:

• Percentage of employees covered by social protection against loss of income
• Coverage by type of life event (sickness, maternity, paternity, disability, unemployment, retirement)
• Breakdown between public vs. private scheme coverage
• Country-specific coverage percentages
• Employee groups or countries excluded from coverage

Health and safety metrics

Coverage of health and safety management system

100% of employees are covered by occupational health and safety and health management actions.

Work-related accidents

In the reporting year, there were 63 accidents at work in the Group, mainly commuting accidents and minor injuries without material downtime, e.g. during work by caretakers and craftsmen, as well as two injuries on construction sites.

Fatalities

There were no work-related fatalities in the reporting year, neither among the Company's own employees nor among other employees working at the Company's sites.

Days lost

Not disclosed.

Methodology note: The accident rate of 21 is disclosed without specification of the calculation basis (e.g. per 200,000 or 1,000,000 hours worked). The excerpts indicate that ESRS S1-14 paragraph 88 (b), (c) and (e) are subject to phase-in arrangements according to the table on pages 89-90.

Compensation metrics

Pay gap

The gender pay gap in the Group was 7.4% in the reporting period, i.e. the average gross hourly earnings of male employees were higher than those of female employees by this percentage.

Remuneration ratio

The ratio of the remuneration of the highest-paid individual to the median total remuneration of all other employees (known as the "total remuneration ratio") is 25.2.

Methodology

The figures relate to the total remuneration of employees in the reporting period. The underlying quantity structure corresponds to the number of employees as at 31 December 2024. The gender pay gap is calculated taking into account all employees, excluding the Management Board.

Incidents, complaints and severe human rights impacts

Incidents of discrimination and harassment

In the 2024 financial year, 4 cases of discrimination, including harassment, were reported to the Compliance Office.

Complaints through grievance mechanisms

12 cases were reported through channels through which own workforce can raise concerns.

Severe human rights impacts

No suspicious activity reports relating to severe incidents of human rights violations or risks were reported.

In financial year 2024, no severe human rights incidents were identified in connection with TAG's labour force.

Fines, sanctions and compensation

No fines, sanctions or compensation payments were made in this connection.

Status of complaints

Not disclosed.

Multi-year comparison

Not disclosed.

Policies related to value chain workers

TAG has adopted policies to manage material impacts associated with workers in the value chain, based on international frameworks and standards.

Business Partner Code

International frameworks referenced:

• United Nations Universal Declaration of Human Rights
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• Eight core labour standards of the International Labour Organization (ILO)

These standards guarantee universal minimum standards for decent work in the areas of freedom of association, prohibition of discrimination in employment and occupation, abolition of child labour and forced labour, as well as occupational health and safety along the upstream and downstream value chain.

Scope:

• All business partners
• Integral part of contractual agreements with business partners
• Separate versions exist for Germany and Poland due to different business models

Key content:

• Compliance with laws and ethical standards
• Avoidance of corruption, bribery and money laundering
• Compliance with antitrust law and fair competition
• Sustainability, environmental protection and material origin
• Data protection, confidentiality and avoidance of conflicts of interest and insider trading
• Occupational health and safety
• Fair treatment of employees and subcontractors (e.g. with regard to forced and child labour)
• Anti-discrimination of workers in the value chain

Governance:

• Management Board of TAG, specifically the COO/Co-CEO, is responsible for the design and application of the Business Partner Code

Implementation:

• All business partners undertake to comply with the Business Partner Code via contractual regulations

Cross-reference: For further description of policies established in connection with the Business Partner Code, refer to Chapter 9.3 G1-2 – Management of relationships with suppliers.

Occupational health and safety policy (Poland new construction)

Scope:

• All persons present on construction sites operated by TAG in Poland
• Applies to all subcontractors

Key content:

• Forms the basis of the occupational health and safety system for new construction business in Poland
• Monitoring occupational health and safety on construction sites
• Prevention of accidents
• Promotion of a healthy lifestyle
• Transparency with regard to accidents at work
• Participation in continuous improvement of workplace management

Implementation:

• Contains strategic basic conditions, compliance with which is required of subcontractors

Taking action on material impacts on value chain workers

Actions are generally implemented with the aim of preventing, mitigating and remedying material negative impacts on workers in the value chain.

Germany – Supplier compliance system

Action description: Maintaining the system already established in previous years to oblige suppliers to comply with certain protective measures with regard to workers in the value chain.

Scope: Value chain (Germany)

Time horizon: Ongoing; TAG plans to maintain the established procedures in the future and expand them further if necessary.

Resources allocated: The Management Board provides the operational departments involved, in particular compliance, with the necessary resources. (No quantified amounts disclosed.)

Effectiveness: No incidents relating to human rights within TAG's value chain were reported in the reporting year.

Poland (ROBYG new construction business) – Health and Safety initiatives

Action 1: "Health and Safety Week" information campaign (2024)

Action description: Information campaign to build a culture and awareness of occupational health and safety on construction sites for main contractors and subcontractors in the value chain.

Scope: Value chain – Poland new construction business

Activities included:

• First aid training
• Fire drills
• Webinar with the Polish labour inspectorate
• Information campaign to promote a healthy lifestyle regarding ergonomics in the workplace

Action 2: Planned initiatives for 2025

Scope: Value chain – Poland construction sites

Planned activities:

• Another "Health and Safety Week" campaign
• Establishment of a separate email address for reporting safety concerns/suggestions for improving safety on construction sites
• Monthly alcohol tests on all ROBYG construction sites

Resources allocated: The Management Board provides the operational departments involved, in particular compliance, with the necessary resources. (No quantified amounts disclosed.)

Link to targets: These actions support the target of zero serious or fatal accidents on construction sites (see S2-5).

Effectiveness: The target of no serious or fatal accidents on construction sites was achieved in the 2024 financial year.

Targets related to value chain workers

Germany

In Germany, there are currently no targets relating to workers in the value chain.

Poland

Target: Zero serious or fatal accidents on construction sites