URW is not subject to French Law 2017-399 of March 27, 2017, on the duty of care of parent companies and ordering companies, and therefore does not publish a due diligence plan. The Company is preparing for compliance with the forthcoming European Corporate Sustainability Due Diligence Directive ("CS3D") which aims to encourage sustainable development and the incorporation of environmental considerations into corporate activities and governance.

The sustainability approach is fully embedded into the key processes of URW, in line with the Group’s strategic priorities and operational concerns. Relevant management processes have been set up at each stage of the business cycle, along with appropriate KPIs. For example:

• The URW due diligence process for asset acquisitions includes a complete audit of technical, regulatory, environmental, and health and safety ("H&S") risks, including soil contamination;
• The Group Enterprise Risk Management ("ERM") framework includes climate change and sustainability risks. Identified among the main risk factors, they are integrated in the Risk Management Programme overviewed by the Group Risk Committee ("GRC"), which reports regularly to the MB and SB (see section 6.1.2 Group Enterprise Risk Management framework);
• Development projects are regularly reviewed in light of the Better Places targets;
• Managed assets have an environmental action plan, with annual performance reviews;
• The Internal Audit department conducts regular assessments of the management and compliance processes in accordance with the rules set by URW within each business unit;
• All HR processes ensure the promotion of diversity and inclusion and well-being, and learning and development opportunities for employees are a top priority;
• The training path of all employees, including new joiners, includes relevant sustainability content, and specific functions receive in-depth sustainability-related training tailored to their needs (see section 3.2.3.A.3 Policies related to own workforce);
• Individual objectives of Group employees include sustainability objectives (see section 3.2.3.A.3 Policies related to own workforce); and
• The short-term incentive plan (STIP) of the MB and EC as well as the long-term incentive plan (LTIP) of all eligible Group employees specifically integrates sustainability-related performance criteria (see section 3.2.3.A.3 Policies related to own workforce); and
• Standing assets’ and development projects’ business plans integrate sustainability components to ensure alignment with the Better Places targets.

Sustainability risks are integrated in the global Group ERM framework, which provides a specific risk governance and control framework. Related policies and action plans described in the Sustainability Statement reflect the updates made by the Group to mitigate these risks and the associated performance indicators are disclosed. The Group internal control system covers all of the Group’s activities including sustainability. Additionally, as part of its sustainability roadmap, URW has set up a strong and structured governance. The reporting protocol defines the methodology for calculating the environmental, social and societal indicators of the Group. This reporting protocol provides consistent guidance and rules for all Group entities in terms of organisation and indicator definitions. It ensures the continuity of the reporting process and the reported information in case of changes in the reporting teams and the auditability by the independent third party. Annually, the Sustainability Performance Management team keeps the sustainability reporting scope up to date, reflecting the Group’s portfolio evolutions. Sustainability reporting relies on two main tools: the HR Information System and the Sustainability Reporting Tool. The HR Information System is managed by Group HR teams and is used to collect HR related information throughout the Group. The Sustainability Reporting Tool is the main platform for collecting sustainability data at URW. It is linked to other internal Group tools that provide relevant data. Every year, an Annual Reporting Campaign shares useful information on the Sustainability Reporting Tool, important deadlines and how the data will be used. The process, which is communicated before the campaign, describes steps for contributors and validators to report their non-financial data through the URW Sustainability Reporting Tool. User guides are provided to explain the process in detail, including how to use the Sustainability Reporting Tool and their responsibility for gathering and entering the required non-financial data.

In 2023, in anticipation of the EU CSRD, the Group conducted a double materiality analysis covering all URW’s activities, including Viparis. The sustainability topics were defined on the basis of the sustainability priorities highlighted by the Group’s simple materiality analysis (2022 version), the climate risk assessment, the supply chain risk assessment and a benchmark of sustainability topics covered by real estate companies to identify megatrends and sector impacts. The results of the double materiality analysis were integrated to the Group risk management process as reflected in section 6.2.2.C Category #3 Environmental and social responsibility risks. Climate change risks for the Group (physical and transitional) form a core part of the sustainability risks analysis and are integrated in the double materiality analysis. A more detailed overview of climate risk management and, in particular, of the resilience of assets to physical climate risks is provided in section 3.2.2.B.12 Anticipated financial effects from material physical and transition risks and potential climate-related opportunities.

The sustainability topics were defined on the basis of the sustainability priorities highlighted by the Group’s simple materiality analysis (2022 version), the climate risk assessment, the supply chain risk assessment and a benchmark of sustainability topics covered by real estate companies to identify megatrends and sector impacts. The results of the double materiality analysis were integrated to the Group risk management process as reflected in section 6.2.2.C Category #3 Environmental and social responsibility risks. Climate change risks for the Group (physical and transitional) form a core part of the sustainability risks analysis and are integrated in the double materiality analysis. A more detailed overview of climate risk management and, in particular, of the resilience of assets to physical climate risks is provided in section 3.2.2.B.12 Anticipated financial effects from material physical and transition risks and potential climate-related opportunities.

The Sustainability Reporting Tool is the main platform for collecting sustainability data at URW. It is linked to other internal Group tools that provide relevant data. Every year, an Annual Reporting Campaign shares useful information on the Sustainability Reporting Tool, important deadlines and how the data will be used. The process, which is communicated before the campaign, describes steps for contributors and validators to report their non-financial data through the URW Sustainability Reporting Tool. User guides are provided to explain the process in detail, including how to use the Sustainability Reporting Tool and their responsibility for gathering and entering the required non-financial data. Every year, the Sustainability Reporting Tool’s settings are revised to reflect the changes in KPIs, contributors and validators. This step is essential as it ensures that relevant contributors are given ownership and held accountable for the data they provide to the tool, based on their specific asset or department. Validators, meanwhile, play a key role in this process. They oversee the correctness of the data entered by the contributors and ensuring the completeness of the reported data. This systematic approach promotes accuracy, accountability and completeness in URW’s data reporting process.

Sustainability is a core component of URW’s strategy and is at the heart of the Group business model. Sustainability topics are addressed at the SB level in plenary sessions, given its importance and the willingness to associate all SB members in these discussions. Sustainability updates are shared before each SB meeting, and ESG is discussed in depth throughout the year in the presence of the MB and the Group Director of Sustainability, including during the annual strategic seminar, the onboarding programmes of both the SB and MB, and as often as necessary during trainings. In 2023, the SB and the MB respectively met 6 and 12 times to discuss topics linked to the Better Places roadmap. In 2023, the SB dedicated half a day to a sustainability roadmap workshop where the SB and the MB discussed (i) URW’s ambition to embed sustainability at the core of its business model, (ii) sustainability performance against existing targets as well as credential to lead the environment transition, (iii) ongoing transformation and concrete achievements, (iv) the key building blocks of the updated Better Places roadmap and (v) Group sustainability organisation and governance.

In 2023, URW carried out its double materiality assessment for the Group, across all business segments and activities. An external advisory firm supported the Group in this process to ensure the robustness and neutrality of the methodology. The results of the double materiality analysis were directly integrated in the Group’s risk management approach, as presented in section 6.2.2.C Category #3 environmental and social responsibility risks.

The purpose of this double materiality assessment was to assess the materiality of sustainability and ESG topics from 2 complementary perspectives:

• An “impact” perspective, i.e., the negative or positive impacts of the Company and its activities on the environment, the people it works with and the communities it operates in. It considered the scale (level of criticality of the issue), the scope (value chain and affected stakeholders), the remediability (ability to mitigate the impact), as well as the likelihood of the impact.

• A “financial” perspective, i.e., the risks or opportunities that environmental and social issues represent for the Company’s activity and value. It considered the Company’s dependencies towards business relations and stakeholders (i.e., financial partners, tenants or suppliers), as well as the continuity of use or access to resources that are essential for the Company to operate and grow (e.g., raw materials, retention of key talents or development of stricter regulations). The materiality of risks and opportunities has been assessed based on the likelihood of occurrence and the potential magnitude of the financial effects. The financial thresholds considered for the analysis were aligned with the financial impact scales used for the Group risk mapping.

The materiality analysis was conducted in 4 phases:

1. URW identified a list of sustainability topics by conducting a contextual analysis, a sectoral analysis and a selection of applicable international standards that are relevant to the commercial real estate sector and its closest related sectors, such as retail, offices and construction. Key topics of sectors that represent the value chain of URW were integrated in the analysis, including but not limited to, construction materials, engineering, building products and retail.

URW pursued a study of international and sectoral ESG frameworks to understand how sustainability topics impact the Company’s business in terms of risks and opportunities. These sector-specific ESG standards provided detailed information on the financial impact of environmental and social issues on the business model. Complementary frameworks provided URW with a structured approach for assessing the likelihood, magnitude and nature of the effects of identified risks and opportunities, through the lens of the continuity of use or access to resources by URW as well as the Group’s dependence towards business relations. This phase involved evaluating the potential financial implications of each risk and opportunity for URW, considering their probability of occurrence, and understanding their potential impact on the Company’s operations, reputation, as well as its short, medium and long-term prospects. The financial implications were determined in the context of the Group’s risk mapping thresholds. This comprehensive assessment allowed URW to have a preliminary view of which topics were deemed more material for the Company.

URW also conducted an analysis of international and sectoral impact frameworks, to gauge how the Company’s activities directly and indirectly impact the sustainability topics identified. These impact frameworks provided URW with an understanding of how companies of the real estate sector and related sectors can impact the natural or society. During this phase, URW considered a sustainability issue to be significant from an impact perspective if it related to the Company’s tangible or potential influences (influences meaning the impacts associated with URW’s own operations and its value chain, including the services it provides as a real estate company as well as through its business relationships, throughout URW’s value chain.

The results were complemented by the pre-existing simple materiality analysis and sustainability risk analysis.

URW initiated a consultation process involving approximately 20 internal and external stakeholders. The selection of external stakeholders was carried out to ensure a representation of key value chain players for URW. The external stakeholders were: consumer rights organisations, sustainability in real estate experts, representatives from retailers’ associations, as well as significant partners, such as construction companies, with whom URW has collaborated on major projects.

In addition to these external consultations, dialogues were held with internal stakeholders representing various teams and geographies across the Group. These internal stakeholders included members from the Compliance, Operating Management, Development, Sustainability, People and the MPPS departments, along with a member of the MB. Internal consultations actively considered the different activities of the Group and its different subsidiaries, from the core business of retail (Shopping Centres) to mixed-use and offices (Offices), as well as Convention & Exhibition centres. Internal discussions served to supplement and critically evaluate the preliminary drafts of the materiality analysis, thereby ensuring a robust and comprehensive review process.

The purpose of these interviews was to proactively introduce the subjects identified for the materiality analysis, and to discern which areas URW should prioritise. This prioritisation took into account both the impact and financial perspectives previously mentioned. The goal was to ensure that URW’s focus aligns with the most significant topics from a sustainability and economic standpoint.

Following the consolidation of the final results, URW shared a detailed presentation and explanation of the double materiality analysis’ methodology with the AC. This included a clear explanation of the differences between the former simple materiality analysis and the new double materiality analysis.