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.