Neinor Homes SA

Sustainability management at Neinor Homes is carried out by the Sustainability Committee, chaired by the CEO of the company and headed by GRC, Internal Audit and Sustainability management, which reports hierarchically to the Audit and Control Committee, which is the supervisory body in this area, in line with the principles established in the Sustainability Policy. [...] The Governance, Risk and Compliance (GRC) Internal Audit and Sustainability Department is responsible for coordinating the work of various areas of the company and for ensuring the accuracy and completeness of the information reported in the Annual Report. This document is published together with the financial information for the year to allow stakeholders to assess its performance in relation to the company's relevant information.

**4.2 Process for Project Evaluation and Selection**

**4.2.1 Internal governance for sustainable finance**

Neinor Homes has set up a Sustainability Committee ("SC"), bringing together various departments and the following representatives:

- The CEO

- The Deputy CEO and CFO

- The COO

- The Head of Governance, Risk & Compliance (GRC) Department and Sustainability

- The Head of Investor Relations and Capital Markets

- The Head of Product and Innovation

- Senior representatives of one or several of the above-mentioned departments or other external representatives with specific expertise may be invited from time to time, when deemed necessary.

The SC has the following responsibilities:

- Review and certify which assets or projects have funding needs that meet the Green or Social Eligibility Criteria as well as positively contribute to Neinor Homes' wider ESG ambition

- Identify and manage potential material environmental and social risks associated with the projects as detailed in section 4.2.2 below

- Monitor the portfolio of eligible projects as long as any bond or loan covered by this Framework is outstanding, and ensure replacement if a project no longer meets the eligibility criteria

- Review, approve and publish the Allocation and Impact Reports

- Manage any future updates of the Framework.

The Sustainability Committee will meet at least quarterly, whereby the CEO will be present as and when required. All decisions will be made in consensus.

**4.2.2 Overview of Neinor Homes' policies and procedures**

Neinor Homes ensures that all environmental, social and governance risks related to eligible projects or assets are effectively managed.

Internal action plans and guidelines aim to minimise ESG risks potentially associated with Neinor Homes' activities, as illustrated by the Groups' Quality, Environment and Innovation Policy[2].

The objective of Neinor Homes' Quality, Environment and Innovation Policy is to set down the general principles and the common action framework for the integration of environmental protection in the Company's activity, ensuring maximum quality and making use of innovation. It promotes the preservation and protection of and respect for the environment, as well as the prevention of pollution within its field of action. The main lines of action in this respect are: Environmental certifications, Circular economy, Environmental consciousness and awareness, Legal and other requirements. Neinor Homes' Quality, Environment and Innovation Policy includes details about responsibilities and oversights.

In addition, the selection of the eligible projects will leverage on the processes put in place for Neinor Homes' EU Taxonomy-alignment reporting in application of Article 8 of Regulation (EU) 2020/852 to ensure transparency on whether eligible projects respect the DNSH and the Minimum Safeguards.

The DNSH assessment relies on Neinor's existing environmental policies and risks management systems as well as on additional verifications, as described in our Sustainability Report.

Neinor Homes complies with the Minimum Safeguards via the Group's policies on ethics and compliance, and in particular its Human Rights Policy published in 2022, which defines the principles applied for human rights due diligence. Neinor Homes has set a comprehensive list of ethics and compliance policies, which include:

- Code of Ethics[3 ]

- Corporate Governance Policy[4]

- Code of best practices in the real estate mediation services[5]

- Prevention of corruption, fraud and bribery policy[6]

- Diversity and non-discrimination policy[7]

Corporate sustainability policies are available on Neinor Homes' corporate website.

#### 4.3 Management of proceeds

Neinor Homes has established a Sustainable Financing Issuances Register ("the Register") to monitor eligible projects and assets, as well as the allocation of an amount equivalent to the net proceeds from Sustainable Financing Issuances to eligible projects or assets. The Register is managed by the Governance, Risk and Compliance (GRC), Internal Audit and ESG department and reviewed at least annually by the Sustainability Committee

The Sustainable Financing Issuances Register will contain relevant information including:

- Details of the issuance(s): ISIN and pricing date, among others.

- Details of eligible use of proceeds per green, social and sustainability issuance. It will include:

o Project categories
o Eligibility categories
o Amount of allocation made
o Estimate of impact of the eligible use of proceeds
o Details on taxonomy-alignment of projects

Neinor Homes aims to allocate proceeds from any sustainable financing instruments within 2 years from issuance. In case of divestments or if a project ceases to meet the Eligibility Criteria or is subject to a material ESG controversy, it will be removed from the Register and the proceeds will be reallocated to other eligible projects, as soon as reasonably practicable.

Prior to full allocation, proceeds will be held in line with Neinor Homes' general liquidity management practices in cash, cash equivalents, and/or other liquid marketable instruments. Any unallocated proceeds will not knowingly be placed in investments that include greenhouse gas intensive assets, inconsistent with the transition towards a low carbon economy.

**4.2 Process for Project Evaluation and Selection**

**4.2.1 Internal governance for sustainable finance**

Neinor Homes has set up a Sustainability Committee ("SC"), bringing together various departments and the following representatives:

- The CEO

- The Deputy CEO and CFO

- The COO

- The Head of Governance, Risk & Compliance (GRC) Department and Sustainability

- The Head of Investor Relations and Capital Markets

- The Head of Product and Innovation

- Senior representatives of one or several of the above-mentioned departments or other external representatives with specific expertise may be invited from time to time, when deemed necessary.

The SC has the following responsibilities:

- Review and certify which assets or projects have funding needs that meet the Green or Social Eligibility Criteria as well as positively contribute to Neinor Homes' wider ESG ambition

- Identify and manage potential material environmental and social risks associated with the projects as detailed in section 4.2.2 below

- Monitor the portfolio of eligible projects as long as any bond or loan covered by this Framework is outstanding, and ensure replacement if a project no longer meets the eligibility criteria

- Review, approve and publish the Allocation and Impact Reports

- Manage any future updates of the Framework.

The Sustainability Committee will meet at least quarterly, whereby the CEO will be present as and when required. All decisions will be made in consensus.

**4.2.2 Overview of Neinor Homes' policies and procedures**

Neinor Homes ensures that all environmental, social and governance risks related to eligible projects or assets are effectively managed.

Internal action plans and guidelines aim to minimise ESG risks potentially associated with Neinor Homes' activities, as illustrated by the Groups' Quality, Environment and Innovation Policy[2].

The objective of Neinor Homes' Quality, Environment and Innovation Policy is to set down the general principles and the common action framework for the integration of environmental protection in the Company's activity, ensuring maximum quality and making use of innovation. It promotes the preservation and protection of and respect for the environment, as well as the prevention of pollution within its field of action. The main lines of action in this respect are: Environmental certifications, Circular economy, Environmental consciousness and awareness, Legal and other requirements. Neinor Homes' Quality, Environment and Innovation Policy includes details about responsibilities and oversights.

In addition, the selection of the eligible projects will leverage on the processes put in place for Neinor Homes' EU Taxonomy-alignment reporting in application of Article 8 of Regulation (EU) 2020/852 to ensure transparency on whether eligible projects respect the DNSH and the Minimum Safeguards.

The DNSH assessment relies on Neinor's existing environmental policies and risks management systems as well as on additional verifications, as described in our Sustainability Report.

Neinor Homes complies with the Minimum Safeguards via the Group's policies on ethics and compliance, and in particular its Human Rights Policy published in 2022, which defines the principles applied for human rights due diligence. Neinor Homes has set a comprehensive list of ethics and compliance policies, which include:

- Code of Ethics[3 ]

- Corporate Governance Policy[4]

- Code of best practices in the real estate mediation services[5]

- Prevention of corruption, fraud and bribery policy[6]

- Diversity and non-discrimination policy[7]

Corporate sustainability policies are available on Neinor Homes' corporate website.

#### 4.3 Management of proceeds

Neinor Homes has established a Sustainable Financing Issuances Register ("the Register") to monitor eligible projects and assets, as well as the allocation of an amount equivalent to the net proceeds from Sustainable Financing Issuances to eligible projects or assets. The Register is managed by the Governance, Risk and Compliance (GRC), Internal Audit and ESG department and reviewed at least annually by the Sustainability Committee

The Sustainable Financing Issuances Register will contain relevant information including:

- Details of the issuance(s): ISIN and pricing date, among others.

- Details of eligible use of proceeds per green, social and sustainability issuance. It will include:

o Project categories
o Eligibility categories
o Amount of allocation made
o Estimate of impact of the eligible use of proceeds
o Details on taxonomy-alignment of projects

Neinor Homes aims to allocate proceeds from any sustainable financing instruments within 2 years from issuance. In case of divestments or if a project ceases to meet the Eligibility Criteria or is subject to a material ESG controversy, it will be removed from the Register and the proceeds will be reallocated to other eligible projects, as soon as reasonably practicable.

Prior to full allocation, proceeds will be held in line with Neinor Homes' general liquidity management practices in cash, cash equivalents, and/or other liquid marketable instruments. Any unallocated proceeds will not knowingly be placed in investments that include greenhouse gas intensive assets, inconsistent with the transition towards a low carbon economy.

Sustainability management at Neinor Homes is carried out by the Sustainability Committee, chaired by the CEO of the company and led by the Governance, Risk and Compliance (GRC), Internal Audit and ESG Department, which reports directly to the Board of Directors through its Audit and Control Committee (the supervisory body for this matter in line with the principles established in the Sustainability Policy). [...] The Neinor Homes Sustainability Policy establishes the general principles and the internal action framework for the integration and management of social responsibility with respect to people, operations and the environment, based on the company's strategic pillars: environment, society and governance.

To comply with the evaluation and selection criteria, NEINOR HOMES has created its Sustainability Committee (SC). The committee is integrated by the following representatives: - The CEO - The deputy CEO and CFO - The COO - The Head of Governance, Risk & Compliance (GRC) Department and Sustainability - The Head of Investor Relations and Capital Markets. - The Head of Product and Innovation Responsible. The SC will be responsible for the following purposes: - Review and certify which assets or projects have funding needs that meet the eligible criteria according to the abovementioned use of proceeds, identify and manage potential material environmental and social risks associated with the projects. - Monitor the eligible projects portfolio, during the life of the transaction, specifically during the life of each bond. The SC could decide to replace some eligible projects if an eligible project no longer meets the eligibility criteria. - Manage any future updates of the Framework. This committee will meet at least quarterly and decide upon an eligible investment list. [...] NEINOR HOMES will establish Sustainable Financing Issuances Register for the purpose of monitoring the eligible projects/assets and the allocation of an amount equivalent to the net proceeds from Sustainable Financing Issuances to eligible projects and/or assets. NEINOR HOMES is responsible for ensuring that an amount equivalent to the net proceeds are financing eligible projects/assets in accordance with this Framework. In addition, NEINOR HOMES will ensure there are enough eligible sustainable projects and/or assets in the Register. This Register will be reviewed, at least, annually, and sustainable projects and/or assets can be removed or added, whenever needed, to or from the Register. The Sustainable Financing Issuances Register will contain relevant information including: - Details of the issuance(s): ISIN and pricing date, among others. - Details of eligible use of proceeds per green, social and sustainability issuance. It will include: o Project categories o Eligibility categories o Amount of allocation made o Estimate of impact of the eligible use of proceeds Prior to full allocation, proceeds will be held in line with NEINOR HOMES' general liquidity guidelines in cash, cash equivalents, and/or other liquid marketable instruments. Any unallocated proceeds will not knowingly be placed in investments that include greenhouse gas intensive assets, inconsistent with the transition towards a low carbon economy. NEINOR HOMES promotes a high level of transparency. For such purpose, NEINOR HOMES' management of proceeds is supplemented by an independent third party, which verifies the internal tracking method and the allocation of funds from the proceeds.

Sustainability management at Neinor Homes is carried out by the Sustainability Committee, chaired by the CEO of the company and led by the Governance, Risk and Compliance (GRC), Internal Audit and ESG Department, which reports directly to the Board of Directors through its Audit and Control Committee (the supervisory body for this matter in line with the principles established in the Sustainability Policy). [...] The Neinor Homes Sustainability Policy establishes the general principles and the internal action framework for the integration and management of social responsibility with respect to people, operations and the environment, based on the company's strategic pillars: environment, society and governance.

Sustainability management at Neinor Homes is carried out by the Sustainability Committee, chaired by the CEO of the company and headed by GRC, Internal Audit and Sustainability management, which reports hierarchically to the Audit and Control Committee, which is the supervisory body in this area, in line with the principles established in the Sustainability Policy. [...] The Governance, Risk and Compliance (GRC) Internal Audit and Sustainability Department is responsible for coordinating the work of various areas of the company and for ensuring the accuracy and completeness of the information reported in the Annual Report. [...] The Board of Directors is regularly informed about the management of complaints through the Audit and Control Committee. In 2022, complaints were received in relation to 5 transactions, through the whistleblowing channel or other channels, concerning conflicts of interest, non-compliance with internal procedures, or defects in dwellings affecting their habitability. All complaints were dealt with in the manner and within the deadlines established in the channel's management procedure. [...] Employees and members of the governing body have received and confirmed the commitment to comply with the Code of Ethics and the group's policies, and specific training has been provided in 2022 to employees and Directors.

To comply with the evaluation and selection criteria, NEINOR HOMES has created its Sustainability Committee (SC). The committee is integrated by the following representatives: - The CEO - The deputy CEO and CFO - The COO - The Head of Governance, Risk & Compliance (GRC) Department and Sustainability - The Head of Investor Relations and Capital Markets. - The Head of Product and Innovation Responsible. The SC will be responsible for the following purposes: - Review and certify which assets or projects have funding needs that meet the eligible criteria according to the abovementioned use of proceeds, identify and manage potential material environmental and social risks associated with the projects. - Monitor the eligible projects portfolio, during the life of the transaction, specifically during the life of each bond. The SC could decide to replace some eligible projects if an eligible project no longer meets the eligibility criteria. - Manage any future updates of the Framework. This committee will meet at least quarterly and decide upon an eligible investment list. [...] NEINOR HOMES will establish Sustainable Financing Issuances Register for the purpose of monitoring the eligible projects/assets and the allocation of an amount equivalent to the net proceeds from Sustainable Financing Issuances to eligible projects and/or assets. NEINOR HOMES is responsible for ensuring that an amount equivalent to the net proceeds are financing eligible projects/assets in accordance with this Framework. In addition, NEINOR HOMES will ensure there are enough eligible sustainable projects and/or assets in the Register. This Register will be reviewed, at least, annually, and sustainable projects and/or assets can be removed or added, whenever needed, to or from the Register. The Sustainable Financing Issuances Register will contain relevant information including: - Details of the issuance(s): ISIN and pricing date, among others. - Details of eligible use of proceeds per green, social and sustainability issuance. It will include: o Project categories o Eligibility categories o Amount of allocation made o Estimate of impact of the eligible use of proceeds Prior to full allocation, proceeds will be held in line with NEINOR HOMES' general liquidity guidelines in cash, cash equivalents, and/or other liquid marketable instruments. Any unallocated proceeds will not knowingly be placed in investments that include greenhouse gas intensive assets, inconsistent with the transition towards a low carbon economy. NEINOR HOMES promotes a high level of transparency. For such purpose, NEINOR HOMES' management of proceeds is supplemented by an independent third party, which verifies the internal tracking method and the allocation of funds from the proceeds.