Sirius Sirius Real Estate

Upholding high standards of governance, transparency and ethical business practice is a priority for our business.

Governance and business conduct were identified as key issues in our double materiality assessment, reflecting the value our stakeholders place on these topics, and the expectation that we must work to ensure accountability, risk management and compliance with regulatory developments.

Providing strong ESG oversight and governance structures

We have established a clear and strong governance framework, ensuring ESG oversight at Board and executive levels, and throughout our business. The Sustainability & Ethics Committee, Audit Committee, and the ESG Working Committees provide regular updates on ongoing ESG-related activity, while the CEO and Chief Marketing and Impact Officer (CMIO) report to the Board and senior leadership on ESG priorities and emerging issues. All the work led and implemented by our ESG Department in Germany and the UK management team is incorporated in these updates.

Environmental and social objectives are also embedded within our management review and remuneration frameworks. Executive Directors and eligible staff have ESG targets, which include advancing our net zero strategy, progressing tenant engagement and continuing to support employee learning and engagement.

Our strong governance and reporting practices are reflected in our engagement with and strong ratings by key ESG rating agencies

AA

A

Low Risk

C

MSCI GRESB Public Disclosure Sustainalytics CDP

Engaging our stakeholders on double materiality 

In line with our commitment to robust governance and stakeholder engagement, we finalised our double materiality assessment during FY2024/25. This process enabled us to refine our understanding of the ESG issues that are most material, both to our business, and to how we manage our own impact on the environmental and society. The assessment included targeted engagement with internal and external stakeholders, including tenants, suppliers, investors, and employees. The outcomes have informed our framework and ongoing strategy, risk management, and sustainability reporting. A more detailed overview of the assessment and its outcomes is provided earlier in this report on page 5 and is reflected in our updated objectives and disclosures for this year.

Enhancing regulatory preparedness and reporting

The continuously evolving regulatory landscape presents new compliance and disclosure challenges for many businesses. We have paid particular attention to the IFRS Sustainability Disclosure Standards issued by the ISSB (International Sustainability Standards Board) and have monitored the ongoing developments in relation to the EU’s Corporate Sustainability Reporting Directive (CSRD). We work hard to understand and meet ESG frameworks and legislation and have conducted compliance reviews to understand our readiness for these frameworks.

We have also enhanced our climate risk reporting by updating our scenario analyses and physical risk assessments, which are reflected in our FY2024/25 TCFD report. ESG-related risks have been assessed and continue to be integrated into our corporate risk management framework, ensuring that both transitional and physical risks and opportunities are assessed and managed effectively.

Upholding policies and business conduct

We remain committed to ethical business practices and compliance across all areas of our business. We regularly review Group policies and Committee Terms of Reference to ensure alignment with evolving legal requirements and best practice. This year, we updated our Modern Slavery policy. Our Anti-Bribery and Corruption and Whistleblowing policies remain unchanged, with no incidents reported in the current or prior financial years.

Maintaining cybersecurity and data protection 

Cybersecurity remains a governance priority, with oversight provided by the IT Committee, which meets regularly and reports quarterly to the Board. We continue to strengthen our approach to ensure that potential threats related to data and cyber are identified and mitigated proactively. Recent enhancements to our IT function, including new leadership roles in Germany and the UK, have further strengthened our capacity to address cybersecurity and data protection risks and opportunities across the business.

Our commitment to maintaining a strong cybersecurity framework is also reflected in our annual penetration testing, which supports the renewal of our cybersecurity certification, received most recently in September 2024. Employees receive regular training and are tested annually to reinforce awareness of security best practice, reducing the risk of human error and cyber threats. Compliance with EU and UK GDPR regulations remains a focus, with regular reviews to ensure we meet data protection requirements. We have experienced no material information security breaches in the last year.

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