STATEMENT OF NON-FINANCIAL INFORMATION

SUSTAINABILITY

REPORT

2023

Thinking and our

CONTENTS

01 Executive summary

02 Letter from the CEO

03 From CSR to sustainability. Policy and Strategic plan

038.1. Housing Excellence and Quality

11

Management

8.2. Measuring the corporate

Carbon footprint

138.3. Environmental Sustainability and

110

112

04 Transformation of the sector

25

health in housing

120

4.1. Our identity

4.2. A new trajectory, a long journey

4.3. Our purpose and values

4.4. Ownership structure

05 Social impact: Creating value through our responsible business model

  1. Economic and social environment
  2. Developments on the stock exchange
  3. Accessibility to housing / decent housing
  4. Measuring social impact
  5. Industrialised business model with the customer in mind
  6. Sustainability as an internal action framework
  7. The importance of communication with our stakeholders
  8. Social action

06 Our business is based on a model of responsible governance

  1. Principles of corporate governance
  2. General Shareholders' meeting
  3. Board of Directors
  4. A comprehensive Control, Compliance and Assurance model

07 We offer a personalised service tailored to the needs of the customer

  1. Neinor Experience
  2. Complaints and claims handling

08 Environmental Impact.The homes we build will have no added value if we fail to think about the environment we are leaving behind for those we care for.

8.4. Climate risk analysis of our homes

268.5. Urbanisation and activation of the

27environment

298.6. Innovation as an engine of

30transformation

8.7. Life cycle analysis

09 We have a Committed Team

31

9.1. Equality and Diversity

329.2. Professional and personal

33

development of the employees

9.3.Training

359.4. Well-being and work-life balance

469.5. Health and safety of our employees 9.6. Employee communication and

52satisfaction

55 10 We are strategic partners of our suppliers

6210.1. Our supply chain

6410.2. Responsible procurement management 10.3. Selection, approval and evaluation

70

of suppliers

10.4. Health and safety and awareness

71

requirements

7310.5. Communication, satisfaction and

75

cooperation with suppliers

82 11 Sustainable financing and compliance with the European Taxonomy

99 12 Our big sustainability milestones

103

and next steps

  1. 13 About this report
    14 GRI contents
    Annex I. Sustainability plan
  2. Annex II. Updated sustainability plan

125

131

135

146

147

150

156

159

160

163

164

165

166

167

170

172

176

177

196

201

206

210

228

01

EXECUTIVE SUMMARY

WHO ARE WE?

Neinor Homes, the real estate platform with the ambition to transform the sector.

STRATEGIC PILLARS

Environmental

We build homes for tomorrow

Because the homes of today will determine our homes of the future, we want to provide residential solutions that respect the environment, whose consumption of resources is only what is essential and which are energy efficient in their development. Homes that our children and future generations will be proud of.

Social

Our people

and communities

In addition to building the homes where people will live their lives, we are also committed to the social environment and people's safety, health and well-being. Our aim is to increase the supply of accessible, quality residential housing for all segments of the population.

Governance

The value of doing the right things, the right way

We firmly believe that how we do things determines who we are and who we want to be.That is why we live by ethical standards of integrity and transparency, so that our words are consistent with our actions.

PURPOSE

The purpose of Neinor Homes is to provide and facilitate homes for our clients,

ensuring the well-being of people, communities and the environment.

MISSION

Our mission as a company is to develop business models and formulas for the residential sector

that are increasingly sustainable, accessible and at the same time profitable, in order to secure the future of the company and help to alleviate the housing shortage in Spain's main cities.

VALUES

People: We evolve with people in mind, to provide homes that are more sustainable, spacious, high quality and environmentally responsible.

Sustainability: Committed to the future we will leave behind for the next generations, we measure the impact of everything we do. We have a responsibility to conduct our business in an environmentally friendly way.

Employees and talent: People are fundamental to our development as a company. We believe in equal opportunities, with our Equality Plan, as well as in the development of talent. and work-life balance

Benchmarks: We want to be able to inspire all our stakeholders by our example and become a benchmark within and outside the sector.

Responsibility: We are committed to society so that housing is at the heart of a fair and sustainable social growth. We contribute to the regeneration

of urban environments, to the development of the social fabric and the promotion of employment.

Principles: Transparency, Good Governance and Social Commitment guide all our business decisions.

4

HOW DO WE CREATE VALUE?

We create value through a responsible business model.

EMPLOYMENT GENERATION

516 6.142

direct jobs1

indirect jobs2

ECONOMIC

VALUE

GENERATED

599

million euros

EBITDA

136

million euros

More than 6,000 homes in various phases of production: 3,679 homes in the launch phase

and 2,524 in the execution phase for development.

1Considers the entire perimeter of the Neinor Homes Group at 31 December 2023, including the employees of Renta Garantizada and Quabir Construcción.

2According to the Association of Real Estate Developers of Madrid (ASPRIMA), 2.4indirect jobs are generated for each dwelling.

We take into account for this calculation the homes delivered (2,559), given the fluctuation of homes under construction throughout the year.

INDUSTRIALISED MODEL

Promotion of first and second homes,construction,rental management of own and third-party homes.

Systematisation

Standardisation

Rigour

Environment

Innovation

Technology

Management of of the residential development process of the residential development process.

1.72 million m2

84 developments and

2,559 homes

land bank

13,125 homes for sale

delivered in 2023

QUALITY AND ENVIRONMENTAL MANAGEMENT

Environment,

ISO Certificate 14001 of

247,327 KWh

1,553 kg

1,501m3

12.54%

16.28%

5.48%

Quality and

Environmental Management

consumed

of paper

of water

energy

paper

water

Innovation Policy

ISO Certificate 9001

Consumption reduction

of Quality Management

5

CORPORATE SOCIAL RESPONSIBILITY AS

AN INTERNAL POLICY FRAMEWORK

SUSTAINABILITY POLICY

Objectives

Lead the transformation of the sector

Define the commitment to good governance, environment and society

Provide a basis for integrating sustainability into business strategy

Deliver a quality product

Care for employees

2022 - 2025 Sustainability Plan

Environmental (A)

  • Sustainability and

eco-efficiency of housing

  • Consideration of climate change
  • Protection and improvement of the environment
  • Circular economy

Social (S)

  • Access to housing
  • People's safety, health and well-being
  • Customer relations and protection
  • Commitment to the team and to society

Governance (G)

  • Ethics, integrity and transparency
  • Good corporate governance practices
  • Responsible supply chain
  • Sustainable financing
  • Innovation

WHAT IS OUR GOVERNANCE MODEL BASED ON?

Our business is based on a model of responsible governance

GENERAL

SHAREHOLDERS'

MEETING OF

BOARD

OF DIRECTORS

  • In 2023: quorum 78.62% of share capital

· 12 meetings in 2023

1 executive

· 9 directors in total

4 proprietary

4 independent

Audit

and Control

Committee

  • 6 meetings
  • 5 members
  • 40% proprietary directors
  • 60% independent directors

Appointments

and Remuneration

Committee

  • 9 meetings
  • 5 members
  • 40% proprietary directors
  • 60% independent directors

Land

Investment

Committee

  • 4 meetings
  • 7 members
  • 14% executive directors
  • 57% proprietary directors
  • 29% independent directors

6

A COMPREHENSIVE MODEL OF CONTROL, COMPLIANCE AND ASSURANCE

GOVERNANCE, RISK AND COMPLIANCE MODEL (GRC)

Based on best practices of companies in the industry and other sectors

CORPORATE SOCIAL RESPONSIBILITY

CORPORATE GOVERNANCE

Fraud

and corruption

Data

AML/CFT

protection

WHISTLEBLOWING

RISK

PREVENTION

MANAGEMENT

OF CRIMINAL LIABILITY

CHANNEL

GRC MODEL

Conflicts

of interest and ICFR related parties

Whistleblowing Channel

  • Code of Ethics
  • Whistleblowing Channel
  • Ethical channel management procedure
  • Code of Conduct for third parties
  • Code of best practices in the real estate mediation services
  • Human Rights Policy

Risk Management Model

  • Integrated Internal Control System
  • Corporate Risk Map
  • Risk Plan (Covid 19)

Prevention of criminal liability

  • Criminal Risk Policy
  • Criminal Risk Prevention Manual
  • Internal rules of conduct
  • General economic-financial and corporate communication policy
  • Internal manual for the disclosure of privileged and other relevant information

Zero tolerance for corruption

Conflict of Interest Management

Anti-Corruption, Fraud and Bribery Policy

Conflict of interest and related party transactions policy

  • Instructions on gifts, invitations and donations
  • Controls in place

Data protection, confidentiality

System of internal control over financial

and information security

and non-financial reporting

Privacy Policy on Personal Data Protection

Internal control and risk management systems

Procedure for the enforcement of the rights of data subjects

in relation to the financial reporting process (ICFR)

and non-financial reporting (SICNFR)

ISO 27001

Information

Security

Certification

ISO 9001

Quality

Management

Certification

ISO 14001

Environmental

Management

Certification

UNE 166002

R&D&I Management

Certification

7

WHAT ADDED VALUE DO

WE OFFER OUR CUSTOMERS?

We offer a personalised service tailored to customer needs

BETTER KNOWLEDGE OF

NEINOR EXPERIENCE

OUR CUSTOMERS

Exclusive customer service Neinor

CRM and Customer Centric

Experience Manager in each development

tools implemented

Neinor Responds Channel

20,980

43,958

1,037

36,800

38,290

24

customers

sessions

APP downloads

contacts

incidents

hours

on the web

Neinor Experience

through all

average response

its channels

time

WE BUILD HOMES WITH ADDED VALUE

QUALITY HOUSING

Research + Listening + Development Process

FAMILY HOMES

BREEAM

NEINOR

Standardisation White Book

Climate Risks study

PROTECTION

STAMP

MOBILITY

Personalisation alternatives

INSURANCE

PACK

Sustainability: BREEAM® certified

INNOVATION AS A DRIVER OF TRANSFORMATION

NEINOR NEXT

  • Collaboration with start-ups to test their products/services and see if they generate added value for Neinor Homess

PROCESS INNOVATION

  • Analysis of the integration and optimisation
    of the construction white book in the adaptation to the technical code

COOPERATIVE INNOVATION

  • Participation in forums and working groups: Basque Construction Cluster, Building Cluster, PTEC (Spanish Construction Technology Platform) and Cemex

DIGITAL TRANSFORMATION

  • Digital Transformation Plan
  • Digital initiatives that add value

In 2023, 260 customers have

Nearly 80 BREEAM®

Cooperation

Participation in forums and

been insured by Neinor

certified developments at

with start-ups to test their

working groups in the real estate

Homes so they are able to

source

products/services

and construction sector

pay for their new homes

8

WHO ARE WE

AT NEINOR HOMES?

We have a committed team

People management

Equality and diversity

Strategic Human Resources Plan Loyalty plan Protection of employees in pandemics

Professional and personal development

Internal Promotion

Welcome Pack

Attractive and flexible remuneration

Well-being and work-life balance

Work-life Balance Plan

Work-life balance measures

Diversity and non-discrimination policy Equality Plan

Code of Ethics

Code of Conduct for third parties Human Rights Policy

Training

Training platform

31.41 h. of training per employee and 17 training courses given to employees

Health and safety

Occupational Risk Prevention (ORP) audits

Life insurance: inclusion of cover for Absolute Permanent Disability due to illness in common for all the employees

Work site safety

Health and safety policy

Communication, satisfaction

and initiatives to engage employees

Social initiatives Work climate survey

Regular communications from Management Team building activities

2831

44.88%

0.31%

26

employees

women

absenteeism rate

hirings

45,05

55.12%

1

average age

men

promoted

employees

1Analysis performed for employees of Neinor Homes parent company, excluding RG and QC in the process of integrating the HR control areas.

9

HOW DO WE WORK

WITH OUR SUPPLIERS?

We are strategic partners of our suppliers

Responsible purchasing management

Purchasing management procedure

Mandatory clauses

Tendering procedure for construction companies

FRAMEWORK

Safety and awareness

AGREEMENTS

requirements

with manufacturers

Good practice manual

to achieve a mutually

Safety coordinator

beneficial relationship

Health and safety audits

and to be

Training days

strategic partners

Approval /

Evaluation of suppliers

  • Demanding accreditation and selection process
  • Annual re-approval of construction companies
  • Evaluation of suppliers and subcontractors

Communication, satisfaction and cooperation

  • Bilateral communication
  • App. to evaluate the perception of Neinor Homes
  • Cooperative initiatives

20

approved

164

63%

212

suppliers,

5

suppliers

local

million euros

Architecture and

in 2023

suppliers

of expenditure

2

in 2023

on purchases

Engineering

Studios in 2023

435

114

91.02%

38.32

subcontractor

health and

comply with the

accident

evaluations

safety audits

Good

frequency rate

Practice Manual

10

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Disclaimer

Neinor Homes SA published this content on 15 March 2024 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 16 March 2024 17:26:05 UTC.