Echo Investment S.a.GPW: ECH

Capital Group Sustainability Report for 2025

· Issued by Echo Investment S.a.
Echo Investment Capital Group Sustainability Report

2025

This document constitutes an integral part of the Annual Management Board Report on the activities of Echo Investment S.A. and its Capital Group for 2025.



‌Contents

Message from the Chair

of the ESG Steering Committee 3

1

General disclosures

2

For the Planet

5

83 3

For People

139

For Stakeholders

190

4

ESRS 2

General disclosures 6

ESRS E1

Climate change 85

ESRS E3

Water and marine resources 101

ESRS E4

Biodiversity and ecosystems 107

ESRS E5

Resource use and circular economy 114

EU Taxonomy 121

ESRS S1

Own workforce 141

ESRS S2

Workers in the value chain 163

ESRS S3

Affected communities 176

ESRS S4

Consumers and end-users 184

ESRS G1

Business conduct 191

ESRS Index - list of fulfilled

disclosure requirements 204

Echo Investment Capital Group

Contents

General disclosures For the Planet For People For Stakeholders ESRS Index 2

‌Message from the Chair of the ESG Steering Committee

Dear Stakeholders,

We are pleased to present the Echo Group Sustainability Report for 2025. In this report, we outline the actions undertaken in the areas of environmental protection, social responsibility, and corporate governance, as well as the progress we made toward achieving our objectives.

Sustainability is no longer a standalone reporting topic or an add-on to business activities. In the property sector, it means making better investment and project-related decisions that reduce risk, improve project quality, and strengthen the long-term value of assets. Above all, it is a key element in building project stability and the organization's resilience to changing market, environmental, and social conditions.

The property sector is currently undergoing significant changes. Expectations are increasing regarding building energy efficiency, the quality of urban spaces, and the resilience of projects to environmental challenges. Today, spaces are no longer designed without considering factors such as energy efficiency, mobility, the quality of shared areas, and the presence of greenery within the urban environment. Alongside this, responsible project management and stable collaboration across the entire project delivery chain are becoming increasingly important.

In recent years, the Echo Group has developed a solid foundation in this area - we measure our impact, analyze risks, and rely on increasingly precise data. This allows us to move from the stage of plans and declarations to making decisions that have a tangible impact on how our projects are designed, financed, and delivered.

In 2025, this approach was reflected in specific initiatives across these developments. One example is the project of Towarowa 22 in Warszawa -a multifunctional, city-oriented quarter where we implemented solutions to reduce energy and water consumption, support tenant waste segregation, and designed an extensive public space with greenery and new tree plantings. At the same time, as part of the Modern Mokotów residential development, we built a primary school for 450 students on Konstruktorska

Street - the first educational facility in Poland developed through collaboration between local authorities and a private investor under the Polish "Special Housing Act," designed using, among other solutions, photovoltaic panels and a greywater recovery system.

As the Echo Group, we operate in a sector that has a significant impact on the environment and the functioning of cities. Therefore, responsibility for reducing emissions and driving the energy transition is not only an obligation for our organization but also a part of the responsibility of the entire property sector. Calculating our carbon footprint for 2025 is another step in this direction.

We view these changes as a catalyst for further development of our projects and the way we conduct our business. In practice, this means making investment and project decisions that reduce the operational costs of buildings, enhance the safety of construction project execution, and strengthen the stability of collaboration with our partners.

In the report, we present specific actions and results that demonstrate how our sustainability-driven approach translates into our projects and strengthens Echo Group's business foundations. In practice, urban space planning now routinely incorporates considerations of biodiversity and user comfort - including the protection of existing greenery and the principle of appropriate replacement of trees removed during construction projects. In 2025, the tree replacement rate in our projects exceeded a level of 2 -both in terms of the number of new plantings and their quality as well as ecological value.

Alongside this, we consistently strengthen safety standards on our construction sites through audits, training, and close collaboration with contractors and subcontractors. As a result, the number of accidents in 2025 decreased significantly, and no fatalities were recorded on our sites. An important aspect of responsible management is also organizational development - in 2025, women accounted for 47 percent and men 53 percent of our top management team, reflecting our commitment to building teams with diverse experiences and perspectives.

An important aspect of our reporting, which sets us apart in the market, is compliance reporting with the EU Taxonomy. This year, 10 of our buildings were recognized as compliant, including 2 new buildings within the Towarowa 22 project - thus maintaining our consistent approach to managing environmental matters.

Looking ahead, we are convinced that the future development of cities will increasingly rely on the integration of technology, the environment, and people's needs. It is precisely at the intersection of these three areas that we are creating projects today with the greatest potential to generate lasting value - both for residents and space users, as well as for investors.

Therefore, in our operations, sustainability is not an end in itself. It is a natural outcome of a responsible approach to the investments and projects we undertake. We believe that this approach not only enables us to deliver better projects but also allows us to actively contribute to the creation of modern, resilient, and people-friendly cities of the future.

We invite you to explore our 2025 Sustainability Report in detail.

With best regards,

Waldemar Olbryk President of Archicom

Responsible for Sustainability at the Echo Group



Terms and definitions used

Echo Group, Group - all companies directly and indirectly controlled by the parent company, Echo Investment S.A.

Echo Investment - the part of the capital group consolidated by Echo Investment S.A., excluding Archicom S.A. and the companies consolidated by it at all levels. This part of the Group is engaged in commercial property activities.

Archicom - the group of companies consolidated by its parent company, Archicom S.A. It constitutes the residential part of the Echo Investment Group.

Company - the term used in the report to refer to Echo Investment S.A.

Companies - Echo Investment S.A. and Archicom S.A.

Management Board of the Group or Management Boards - the registered management boards of all Group companies acting jointly or in a similar manner. In particular, these include Echo Investment S.A. and Archicom S.A., which act as employers, organize the Group's business activities, and control its assets.

Supervisory Board - the Supervisory Board of Echo Investment S.A.

Supervisory Boards - the Supervisory Boards of Echo Investment S.A. and Archicom S.A.

Echo-Archicom Group Sustainability Strategy 2030, Echo-Archicom 2030 ESG Strategy, sustainability strategy, ESG strategy - refers to the sustainability strategy of both companies. In principle, the strategy is identical for both companies. This strategy is, in essence, the same.

Management Board Report - Annual Report on Echo Investment S.A. and Its Group Activities for 2025.

Echo Investment Capital Group

Contents General disclosures For the Planet For People For Stakeholders ESRS Index 4



‌1. General disclosures



‌ESRS 2

General disclosures

BP-1

General basis for the preparation of the sustainability statement

This consolidated sustainability report (sustainability statement within the meaning of ESRS) relates to the Echo Group, comprising the parent company Echo Investment S.A. and its subsidiaries (directly or indirectly controlled), including Archicom S.A. and its subsidiaries (directly or indirectly controlled). The sustainability statement has been prepared on the basis of the Accounting Act of 29 September 1994, which implements the provisions of Directives (EU) 2022/2464, 2004/109/EC, 2006/43/EC and 2013/34/EU of the European Parliament and of the Council with regard to corporate sustainability reporting (Corporate Sustainability Reporting Directive, CSRD). The Directive was transposed into the national legal framework through the Act of 6 December 2024 amending the Accounting Act, the Act on Statutory Auditors, Audit Firms and Public Oversight, and certain other acts.

The preparation of this statement has been carried out in accordance with the European Sustainability Reporting Standards (ESRS). The statement forms an integral part of the Management Board's Report on operations.

The report covers the period from 1 January 2025 to 31 December 2025, which is the same period as the Group's financial year.

In certain areas, the report applies to the Group's value chain. Specifically:

  • disclosures regarding workers in the value chain (S2) pertain to employees of construction companies who perform their work on construction sites controlled by the Group (lower tier of the value chain),

  • selected disclosures regarding the impacts of construction projects or activities undertaken within them are related to the operations of contractors on construction sites controlled by the Group (lower tier of the value chain). These are:

    1. in the scope of S3 - inconveniences to affected communities related to construction activities, social communication processes for projects implemented under the special housing act (the so-called lex developer), and the management of complaints and feedback,

    2. in the scope of E3 - water intake and wastewater discharge on construction sites and environmental safety principles,

    3. in the scope of E4 - actual impact of construction activities on the biodiversity, environmental safety principles, and the application of guidelines for tree protection,

    4. in the scope of E5 - waste management on construction sites, including compliance with requirements concerning hazardous waste.

These operations are controlled by the Group to varying degrees, however, their execution is the responsibility of the contractors.

The report is subject to limited assurance attestation by an authorized entity selected by the Audit Committee in accordance with the Group's policy. Comparative data for 2024 and earlier years (if applicable) are not subject to assurance.

In cases where the Group has chosen to include information in this report by reference, this is in accordance with ESRS 1, Section 9.1, "Inclusion by Reference," and the location of the required information has been clearly specified in each instance.

The Group has not made use of the opportunity to omit specific information relating to intellectual property, know-how, or innovation results, nor from the exemption from the obligation to disclose information regarding anticipated events or matters that are the subject of ongoing negotiations.



Reporting boundaries

Companies fully consolidated (directly or indirectly) under Echo Investment S.A.

The vast majority of companies within the Group.

Full disclosure of data.

Companies jointly controlled (directly or indirectly) by Echo Investment S.A. through equity rights.

Joint-venture companies owning the Resi4Rent, Student House, Bulwar Północny, Towarowa 22, and Galeria Młociny projects.

Outside the reporting boundaries.

Lack of operational control is based on the following premises:

  • limited ownership rights (equity participation),

  • the lack of decisive representational rights (majority in management boards),

  • the inability to direct operational activities,

  • the absence of contractual agreements granting the Group control over operational activities.

Service activities conducted by the Group for related entities.

Group companies provide services to joint-venture companies (owners of the Resi4Rent, Towarowa 22, and Galeria Młociny projects, as well as Projekt Browarna Sp. z o.o.), primarily involving project management as a substitute investor, based on separate agreements distinct from joint-venture agreements.

The Group's impact within the value chain is accounted for at a lower tier, reflecting its

responsibilities arising from these agreements (e.g., project management).

Construction sites of projects owned by the Group, jointly controlled by the Group, or projects for which the Group acts as a substitute investor.

The Group does not exercise operational control over construction sites - this is managed by

the contractors engaged by the Group under construction contracts. However, based on these contracts, the Group has influence over certain aspects, particularly in the areas of health and safety, and environmental protection.

The Group's impact within the value chain is accounted for at a lower tier, as indicated by the double materiality analysis.

This report includes information regarding the entities and operations of the entire Echo Investment Group. The scope of consolidation is consistent with that of the financial statements.

The full list of consolidated entities is available in the Standalone Financial Statements of Echo Investment

S.A. for 2025, published on the same date as this report.

The operational boundaries of this report have been defined based on the scope of control over the Group's entities and operations, following the principles listed below.

Fully controlled enitites

These are fully included in the report. However, the Group excludes construction sites of ongoing projects from its operational boundaries, as operational control over these sites lies with the construction service providers contracted to execute the development projects. The impact of controlled construction sites is accounted for at a lower level of the value chain, in accordance with the results of the double materiality analysis.

Impact boundaries and scope of data presentation in the report

Scope Description Qualification

Jointly controlled projects

The Group has conducted an analysis of its jointly controlled projects, which is presented in the financial statements using the equity method. To maintain consistency in reporting, these entities have been excluded from the operational boundaries of the report. However, the impact of jointly controlled construction sites is included at a lower level of the value chain, as indicated by the double materiality analysis.

BP-2

Disclosure of information in relation to specific circumstances

The Group has applied the definitions of short-term, medium-term, and long-term time horizons, as specified in ESRS 1, in this report. Estimates regarding future events are subject to uncertainty and may change.

The metrics presented in this report include estimated data relating to the value chain. The estimated data relate to Scope 3 greenhouse gas emissions and will be included and described in disclosure E1-6 of the report.

The Group strives to regularly expand the scope of analyzed and disclosed data to better align with the expectations of stakeholders and regulatory requirements.

The Echo Group is correcting a material error in its greenhouse gas emissions calculations for 2024. These changes stem from an error in Scope 3, Category 1 - in 2024. The Group did not take into account all available cost data and included in Category 1 emissions from ongoing investments over which we have no operational control. Due to the material error in Category 1 and other changes resulting from immaterial errors, the expansion of the scope of cost data and methodological adjustments, the Group is making changes to the 2024 report. The rationale for the changes made to the Echo Capital Group's greenhouse gas emissions calculations for 2024 is described in more detail in section ESRS E1-6.

The results of the recalculation are shown in the table below:

Material error

2024

2024

(restated data)

Difference

%

Category 1 scope 3

115,618

190,930

+65.14

Other changes resulting from immaterial errors

Category 4 scope 3

33

57

+74.81

Category 15 scope 3*

3,505

4,144

+18.24

Total changes in scope 3

634,128

710,103

+11.2

* Category 15 includes all changes with an immaterial impact on the result, including emissions reclassified from Category 1 as a result of methodological adjustments.

The Group strives to regularly expand the scope of analyzed and disclosed data to better align with the expectations of stakeholders and regulatory requirements.

This sustainability report is the Group's second report fully developed based on the methodology outlined by the ESRS.

In 2025, the Echo Group changed the methodology for calculating the tree replacement rate. Under the new approach, the analysis of the quantitative and qualitative tree replacement rate is carried out on an annual basis, by aggregating the assessment results for individual investment projects whose implementation was completed in the reporting year. The change in approach is described in more detail in ESRS E4-3 disclosure.

Information disclosed based on other regulations

In this report, the Group has included information based on other regulations or generally accepted interpretations and frameworks related to sustainability reporting. A list of these issues can be found

in Appendix 1 - Index of disclosure requirements.

Information on the use of transitional provisions

The Group, acting in accordance with the provisions of Appendix C "List of phased-in disclosure requirements" to the ESRS, has decided to make use of the available transitional provisions with regard to disclosures on anticipated financial effects. The Group has applied a deferral of disclosure in relation to the following requirements:

E1-9 - Anticipated financial effects from material physical risks and transition risks and potential climate-related opportunities,

E3-5 - Anticipated financial effects from material water- and marine resources-related risks and opportunities,

E4-6 - Anticipated financial effects from biodiversity and ecosystem-re-lated risks and opportunities,

E5-6 - Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities.

Additional disclosures (entity-specific metrics)

The Group, in order to reflect the specific nature of its operations, also reports entity-specific metrics developed based on the results of the double materiality assessment. These metrics relate to key areas associated with construction activities and cooperation with contractors and subcontractors.

They include in particular: ESRS S2 (training of workers in the value chain and standards of social facilities), ESRS S3 (placemaking and destination-type projects), ESRS E3-4 (water consumption on construction sites), ESRS E4 (metrics related to the replacement of removed trees), ESRS E5-4 (resources inflows), ESRS E5-5 (waste generated on construction sites), as well as ESRS G1 (promotion of an ethical culture through training, testing and their results) and cybersecurity.

About the Echo Group Urban areas of the Group's development activities

SBM-1

Information about the Echo Group is provided in Chapter 1 of the Management Board Report,

GDAŃSK

1.1 General information about the Company and the Group.

POZNAŃ

WARSZAWA

ŁÓDŹ

WROCŁAW

KIELCE

LEGEND

KRAKÓW

KATOWICE

Residential (Archicom) Apartments for rent (Resi4Rent) Student housing (StudentSpace) Offices (Echo)

Shopping centers (Echo)

Headquarters



Business strategy Impact of individual business strategy pillars on sustainability issues

The Echo Group's business strategy and its pillars are described in Chapter 1 of the Management Board Report, 1.2 Strategy for profitable growth in action.

The Management Board of the Group has not identified any future challenges, critical solutions, or sustainability projects to be implemented that would be pivotal for the execution of its business strategy.

Leadership position

  • As a large and powerful entity, the Group can impact industry standards, create trends, and promote sustainable development activities.

  • Ability to utilize knowledge, experience and skills of large number of specialists and internal experts, sharing knowledge among the Group's companies and projects.

  • Ambitions to become a leader not only in the scale of business conducted, but also its quality.

    Large-scale, mixed-use 'destination' projects

    Large mixed-use projects combining residential, commercial, office, and recreational functions have a positive impact on urban development and on issues such as optimal land and resource use, coherent spatial planning, designing to reduce car traffic, and the potential to create larger and more attractive green spaces.



    Property development activity

    Due to the nature of its business, the Group emphasizes ethical business conduct (the issue of dependence on administrative decisions, settlements and other decisions of public authorities) and environmental issues (in managing construction sites).

    Focus on Poland

    No significant impact identified.

    Collaboration with proven partners

    • The Group runs property development projects and has joint ventures with several entities. This makes it easier to assess the ethical performance of a given partner and is supported not only by declarations, but sometimes by long-term collaboration. This reduces the risk of cooperation with unreliable partners.

    • Since there may be potential ties (personal, capital) with certain business partners, the Group is at risk of conflict of interest in this case. Therefore, the cooperation with such business partners and significant transactions are subjected to careful analysis by the Supervisory Board of Echo Investment S.A.

The Management Board of the Group has not identified any future challenges, critical solutions, or sustainability projects to be implemented that would be pivotal for the execution of the business strategy.



Echo-Archicom 2030 Sustainability Strategy

In 2023, the Echo Investment Group announced the 2030 Echo-Archicom ESG Strategy on actions in the areas of minimizing environmental impact, social responsibility, and corporate governance. It is a phased road leading the Group to decarbonization, zero-emission of projects under construction, further increasing the role of greenery in projects, and supporting sound urban development. The Group also intends to ensure equal development opportunities for their employees, maximize the safety at construction sites and strengthen corporate governance.

The strategy is divided into three blocks corresponding to environment (E), society (S) and corporate governance (G) issues. All the stated goals are in line with the UN Sustainable Development Goals and are specific and measurable.

The Group's goals pertain to its own operations, as well as operations conducted on construction sites (at a higher level of the value chain).

The Group regularly monitors the effectiveness of its actions and progress towards the set objectives through regular reviews and reports to the Management Board, as well as working meetings of the ESG Steering Committee with the persons responsible for implementing individual objectives.

In 2025, there were no changes to the Group's strategic objectives.

Responsibility for the implementation of the ESG Strategy:

President and Vice President for Finance, who is also responsible for sustainable development issues at Echo Investment, and President of Archicom



Category: Related to product and clients / Area: E - environmental

Year of implementation

Objective description

2024

2025

By 2024

Adoption of the decarbonization strategy for Scope 1 and 2

The Group plans to adopt a decarbonization strategy in 2025

In progress

By 2025

Adoption of the decarbonization strategy for Scope 3

The Group plans to adopt a decarbonization strategy in 2026

By 2023

100% green electricity in buildings used for the Group's own needs (headquarters)

100% (excluding Archicom sales offices)

By 2025

100% of green electricity in finished buildings managed by the Group (office buildings and shopping centers)

100%

100%

By 2026

100% of green electricity in CitySpace offices

No data available

66%

By 2030

100% of green electricity at construction sites managed by the Group

Echo 32%

Archicom 0%

Echo 71%

Archicom 42%

By 2030

Ensuring zero emissions for all new Group buildings during the operational phase

In progress

In progress

2023-2024

Analysis of pilot projects (office building, rental residential building, and for-sale housing building) in terms of emission reduction and maximizing energy efficiency

Objective achieved

2023-2030

Ensuring a replacement ratio for removed trees at a minimum level of 2 (in terms of both number and ecological value)*

Quantitative: 0.80

Qualitative: 0.72

Quantitative: 2.29

Qualitative: 2.03

* Calculated for projects completed in the given reporting year

Category: Related to stakeholders relations / Area: S - social

Year of implementation

Objective description

2024

2025

By 2029

Achieving pay balance between employees of different genders in comparable positions (unadjusted gender pay gap maximum difference: 5%).

25%

24.5%

By 2027

45-55% of key management roles will be filled by women and men

47% women

53% men

47% women

53% men

2023-2030

The average number of unused holiday days at the end of the year will not exceed 10

12 days

14 days

2023-2030

Zero fatal accidents on construction sites

Zero

Zero

By 2026

Introduction of a uniform standard of welfare facilities at all Group construction sites

In 2023, the standard was introduced in the model contracts with subcontractors, in 2024 all new construction sites had the expected standard of welfare facilities

Objective achieved

2023-2030

Development and implementation of guidelines for handling neighbors' complaints, setting measurable objectives

The system was implemented in 2023 and monitored in 2024 to draw conclusions and propose improvements

In 2025, the Group focused on improving the transparency of the incident reporting completeness system

By 2023

Introduction of a system for measuring employee satisfaction on construction sites and setting related objectives

Development and implementation of a method for measuring satisfaction at construction sites

The survey is planned, with implementation scheduled for 2026

2023-2030

50% of projects implemented within large, multi-stage "destination" projects

58%

57%

2023-2030

Implementation of development projects exclusively within city boundaries - 100% throughout the entire period 2023-2030

100%

100%

2023-2030

Purchasing brownfield properties for future projects - 90% over the entire 2023-2030 period

100%

93%

Category: Related to the stakeholders relations / Area: G - governance

Year of implementation

Objective description

2024

2025

By 2023

Designation of a Management Board member responsible for ESG matters

Objective achieved

2023-2030

Inclusion of ESG topics in the agendas of the Management Boards and Supervisory Boards of Echo Investment S.A. and Archicom S.A.

At least 2 formal meetings per year dedicated to ESG issues

2

2

2023-2030

Introduction of the obligation to prepare 4 ethics-related materials for internal communication aimed at employees

4

4

2023-2030

100% of employees trained in regard to ethical principles

94%

98%

By 2026

Achieving gender parity in the governing bodies of Echo Investment S.A. and Archicom S.A.: women will constitute at least 40% of the Supervisory Boards of each of the mentioned companies, or at least 33%of the Supervisory Boards and the Management Boards of each company combined

The Management Boards regularly raise this issue in the Supervisory Board meetings, as it is their responsibility to determine the composition of the Management Boards.

In 2024, the representation of women on the Management Board of Echo Investment was 20%, on the Management Board of Archicom - 25%, while on the Supervisory Boards the share of women was 12% and 14%, respectively

In 2025, no changes made

* Due to organizational changes in the Group, the implementation of some goals will be postponed.

The goals of the Echo-Archicom Group stem from its sustainable development strategy. The Group continuously monitors the implementation of its designated objectives. In its assessment, the key strategic assumptions related to sustainability - concerning products, major markets, and customer groups - are achievable within the adopted timeframes and organizational framework. However, the achievement of certain goals may be postponed within the overall timeline set for the execution of the strategy.

Assessment of the Group's products, services, and operating markets in the context of sustainable development

The Group regularly analyzes how the goals set in its 2030 sustainable development strategy impact key products, services, market activities, and business relationships. The strategy was designed to continuously improve products, service quality, and business conduct principles in areas identified as significant by stakeholders.

Material products and services

The main objective of the strategy in this scope is to reduce the energy intensity of the buildings being developed until achieving net-zero operational emissions, using more efficient processes and materials, as well as the continuous reduction of CO2 emissions resulting from the use of renewable energy. Additionally, the Group has committed goals related to supporting biodiversity and preventing urban sprawl, which also indirectly impact its buildings, but primarily contribute to the sustainable development of cities. The assumptions of the sustainable development strategy are aligned with market trends and the expectations of clients and other stakeholders.

The Group's operations and business relationships

The Group focused on ensuring safety, stability, equal opportunities, and payments for its employees and collaborators, as well as on the use of green energy for its own needs. Additionally, it sets goals for employees on construction sites (related to safety and comfort). The assumptions of the sustainable development strategy in this scope are aligned with the policies of national governments and supranational organizations and address the needs of employees, collaborators, potential employees, as well as workers across the value chain.

Markets of Operation

The Group assesses that its activities related to construction and the development of large urban areas have a positive impact on their growth.

To ensure an accurate assessment of these issues, the Group has adopted specific and measurable goals, as well as interim targets (a so-called roadmap), in its sustainability strategy.



By implementing our sustainable development strategy, we contribute to the following UN Sustainable Development Goals

5.5 Ensure women's full and effective participation and equal opportunities for leadership at all levels of decision-making in political, economic, and public life.

11.3 By 2030, enhance inclusive and sustainable urbanization and capacity for participatory, integrated, and sustainable human settlement planning and management in all countries.

6.3 By 2030, improve water quality by reducing pollution, eliminate dumping, minimize the release of hazardous chemicals and materials, halve the proportion of untreated wastewater, and substantially increase recycling and safe reuse globally.

6.4 By 2030, substantially increase water-use efficiency across all sectors and ensure the sustainable withdrawal and supply of freshwater to address water scarcity and substantially reduce the number of people suffering from water scarcity.

11.7 By 2030, provide universal access to safe, inclusive, and accessible green and public spaces, in particular for women and children, older persons, and persons with disabilities.

12.5 By 2030, substantially reduce waste generation through prevention, reduction, recycling, and reuse.

12.6 Encourage companies, especially large and transnational companies, to adopt sustainable practices and toin-tegrate sustainability information into their reporting cycle.

7.3 By 2030, double the global rate of improvement in energy efficiency.

8.8 Protect labor rights and promote safe and secure working environments for all workers, including migrant workers, in particular women migrants, and those in precarious situations of employment.



Value chain

The value chain model of the Echo Investment Group was developed based on an analysis of material and financial flows. Its core component consists of operational processes (both business and support) within the Group, covering all activities from the acquisition of land plot, through procurement of construction services to the delivery of completed buildings to their new owners and users.

The Group's internal operations mainly include the following activities:

  • purchase of land for development purposes,

  • the preparation of architectural and construction projects, or the supervision of their development,

  • obtaining necessary permits and administrative decisions,

  • conducting tenders and contracting construction services (in exceptional cases, also purchasing goods),

  • the supervision of investment project execution, including the implementation and maintenance of health and safety standards on construction sites,

  • leasing retail and office spaces,

  • the management of completed commercial buildings,

  • the sale of residential units,

  • the sale of completed commercial buildings,

  • interior finishing and design works.

    The higher level of the value chain, known as upstream, includes all operations preceding the Group's own operations. This encompasses the sourcing of raw materials, the production of goods, as well as

    the delivery thereof to the Group's construction sites. Additionally, it includes activities such as the procurement of water and energy by entities performing operations at the upstream level of the value chain.

    The downstream level - the lower segment of the value chain - comprises everything that happens to the completed buildings constructed by the Group. This includes the use thereof by new owners and tenants, property management services, and maintenance. The final stage of the value chain is the demolition of buildings that have reached the end of their lifespan.

    This structured value chain model is utilized by the Group for business model analysis, carbon footprint calculations, and assessing the resilience of the business model in the context of climate change.

    The summary of activities and business relationships presented in the table below was developed considering:

  • significant activities, resources, and relationships within the Group's own operations, such as human resources,

  • significant activities, resources, and relationships within supply, marketing, and distribution networks, such as the procurement of materials and services, as well as the sale and delivery of products and services,

  • the financial, geographical, geopolitical, and regulatory environment in which the Group operates.

    In 2025, no significant changes occurred in the Group's value chain.

    Main characteristics of the value chain

    The Group's own operations require a sufficiently long and complex upstream value chain. When offering a product (apartment, building, rental space), the Group primarily depends on suitable land plots (sellers - Tier 1) and the availability of contractors (construction companies providing construction and related services, including securing necessary materials and products - Tier 1). At a higher level (Tier 2), key entities include manufacturers of construction materials and equipment necessary for the development of buildings. In exceptional cases, these entities may also act as direct contractors for the Group (Tier 1). At the highest level of the value chain (Tier 3), the key entities are aggregate mines, cement plants, manufacturers of construction ceramics, and steel producers.

    The entities listed above at the upstream level of the value chain have been identified due to their essential role in the Group's business operations, the scale of demand necessary to execute the Group's strategy and business model, and the limited possibility of substituting their services and products with alternatives.

    End of the building's lifecycle

Future owners and users of completed properties

Secondary (supporting) operations

Primary (business) operations

Companies providing construction, design, and other direct services

(Tier 1)

Suppliers of materials and subcontractors of services

(Tier 2)

Raw material producers (Tier 3)

Echo Group's value chain

HIGHER LEVEL (UPSTREAM)

Entities providing products or services



ECHO GROUP

Activities directly controlled by the Group -management of the Group



LOWER LEVEL (DOWNSTREAM)

Entities receiving products or services from the Group



HIGHER LEVEL (UPSTREAM) - entities providing products or services

Raw material producers (Tier 3)

Suppliers of materials and subcontractors of services (Tier 2)

Companies providing construction, design, and other direct services (Tier 1)

  • cement plants and building ceramics manufacturers

  • aggregate mines

  • steel producers

  • manufacturers of construction equipment (e.g., elevators, doors, specialized building management systems, etc.)

  • wood producers

  • energy producers (extractive industry and energy manufacturers)

  • raw material producers for construction chemicals

  • suppliers of construction materials for contractors (concrete, aggregates, building ceramics, steel structural elements, thermal insulation materials, and others)

  • suppliers of building equipment and components (windows, doors, elevators, specialized systems, prefabricated structural elements)

  • suppliers of machinery and equipment (construction machinery, formwork, scaffolding)

  • utility suppliers for contractors (including water, energy)

  • manufacturers of construction chemicals

  • land sellers (companies and individuals)

  • providers of design and planning services (architectural studios, experts)

  • capital providers (banks)

  • construction service providers (large and small general construction and specialized companies)

  • utility suppliers for the Group (including water, energy)

  • intermediaries, brokers, and providers of specialized services supporting investment projects

  • suppliers of construction materials or equipment for the Group (concrete, aggregates, building ceramics, steel structural elements, thermal insulation materials, and others)

    Logistics of construction equipment and materials to construction sites, waste removal from construction sites



    ECHO GROUP

    Activities under the Group's direct control - governance and group management

LOWER LEVEL (DOWNSTREAM)

Entities receiving products or services from the Group

Primary (business) operations Secondary (supporting) operations

Future owners and users of completed properties End of the building's lifecycle

    • land acquisition (1)

    • planning process management (2)

    • procurement and coordination of design services (3)

    • contracting construction services (4)

    • procurement of equipment and construction materials (4)

    • financing organization (5)

    • coordination and management of construction sites (6)

    • apartment sales (7)

    • leasing of commercial space (office, service and retail) (7)

    • property management (8)

    • sale of ready commercial buildings (9)

    • interior finishing and design works (10)

    • securing financing

    • accounting

    • controlling · internal audit

    • legal services

    • occupational health and safety (OHS)

    • human resources management

    • administration and management of own offices

    • communication and marketing

    • IT and cybersecurity

    • individual customers purchasing apartments

    • office tenants (large and medium-sized companies, BPO and SSC sector)

    • retail space tenants (retail chains, restaurants, specialty stores, and others)

    • CitySpace users (small businesses, often sole proprietors, as well as medium and large companies awaiting their target office space)

    • funds and other entities specializing in commercial real estate management - buyers of completed buildings (office buildings, shopping centers, rental apartments, student housing)

    • users of Resi4Rent rental apartments and StudentSpace dormitories

    • intermediaries and brokers acting on behalf of potential tenants or buyers

    • property management companies and other service providers for buildings (operating on behalf of subsequent building owners)

    • specialized companies handling demolitions, segregation of demolition waste, and its disposal



      The main entities in the lower level of the value chain are the Group's customers, such as:

  • individual customers purchasing apartments from Archicom,

  • funds purchasing completed commercial buildings from Echo Investment (mainly international real estate funds),

  • tenants of commercial space (renting out the commercial building is a prerequisite for selling the building).

In developing the value chain, the Group identified geographical areas and resource dependencies at a high level of generalization. It focused on Poland, where its operations are conducted and where its closest, key business relationships are concentrated. The Group considered dependencies on resources and ecosystem services, including raw materials for construction material production, access to water, and land availability.

Geographical scope of value chain elements Dependency on resources

Upstream level

Raw material producers (Tier 3)

The main raw materials (aggregates) come from Poland, while other components originate from international markets

Suppliers of materials, subcontractors of services (Tier 2)

The vast majority are Polish companies, which are (to varying degrees) dependent on international markets

Construction companies (Tier 1)

Poland

Natural resources: aggregates, iron ore (essential for the production of basic construction materials), water (necessary for construction processes), and land plots. Resources at the upstream level of the value chain (Tier 3).

Human resources: adequately qualified engineering staff and construction site workers. Resources at the upstream level of the value chain (Tier 1) and within the Group's own operations.

Technological resources: technology necessary for the production of materials and the construction of buildings. Resources in the upstream value chain (Tiers 2 and 1).

Capital resources: financial resources necessary for purchasing and financing the construction process. Upstream level of the value chain

  • banks (Tier 1), own operations, downstream level of the value chain

  • customers and funds purchasing completed commercial buildings.

Downstream level

Customers purchasing apartments

The vast majority are Polish citizens or residents

Buyers of completed commercial buildings

International funds from around the world

Tenants of commercial buildings

Companies of various sizes (from small to large), origins (Polish and foreign), and industries (all)

In sustainability reporting, the Group primarily considers its own operations, followed by processes and operations within the value creation chain that have the greatest impact on the Group's material topics and those over which the Group has the most significant and direct influence. Each year, the scope of analyzed and reported topics is expanded. Additional topics for analysis and reporting are selected based on the criterion of the highest estimated impact of these topics on the Group's business and the greatest ability of the Group to influence them.



Business model Key investments of the Group as indicated in the business model

The Echo Group's business model is presented in Chapter 1 of the Management Board Report, Section 1.3 Business model.

Key components of the Group's outputs and outcomes identified in the Group's business model

Financial result, as a short-term outcome of the Group's activities, is primarily a factor in assessing its performance for shareholders, since its main measure is the profit generated and the dividend distributed.

The Group's outcomes reflect its potential for long-term value creation, particularly its ability to sustain operations and achieve long-term growth. In this category, the most critical elements include financial capital (physical and financial assets that serve as a foundation for growth), intellectual capital (the knowledge, experience, and skills of employees, developed according to the Group's needs), and organizational and production capital (primarily the land bank maintained at a level ensuring operations for the next 4-5 years without the immediate need for replenishment). Social capital also plays a crucial role, encompassing the trust of customers, banks, employees, and other stakeholders.

Knowledge, skills, and experience of employees

The Group considers these as its key assets, enabling it to conduct business operations with a high level of professionalism. The Group invests in employee development, including training programs, aligned with current business priorities. A detailed description of the approach to employees and other individuals working for the Group is provided in the S1 disclosures.

Financial capital

The Group maintains a high level of financial liquidity, allowing it to meet all its obligations, acquire land for new projects (including responding to market opportunities), explore and enter new business segments, and pay dividends. The Management Boards and Supervisory Boards of Echo Investment and Archicom regularly monitor liquidity through scenario analyses. Both companies maintain strong relationships with the capital market, ensuring access to financing for ongoing projects and, if necessary, for daily operations.

Assets - primarily land designated for development

The Group continuously maintains a land bank, ensuring the ability to conduct development activities for the next 4-5 years. It also collaborates with other entities, allowing it to maximize its expertise while mitigating risks.

Social capital

The Group upholds its reputation by adhering to all legal, social, and ethical standards, and providing professional communication channels for its stakeholders.



Value creation model

Input

Business model

Output

Impact

Gain

  • increase in the Group's value on the Stock Exchange

Financial capital

  • PLN 1.7 billion of equity and liabilities

  • acquired external financing (loans and bonds)

Financial results

  • PLN (11.5) million - net profit (loss)

  • PLN 377 million - cash

  • PLN 6.6 billion - Group's asset value

Development fee

Human and intellectual capital

  • own employees

  • individuals providing services to the Group

  • work of external experts

  • internal management, control, IT systems, and others

Human and intellectual capital

  • increase in employees' qualifications and knowledge

  • improvement in employee loyalty and satisfaction

  • enhancement of the efficiency and quality of internal management systems

Operating results

  • 2,847 sold apartments

  • 2,138 apartments handed over to clients

  • 2,087 residential units for rent handed over to Resi4Rent

  • EUR 160.5 million - total value of the Office House building, in which the Echo Group sold its 30% stake to AFI

  • 35,754 m2 total of office space managed by CitySpace

  • EUR 61.4 million - value of refinancing obtained for Galeria Libero

  • 1,221 - number of places offered by the first three StudentSpace dormitories in Kraków

Construction Marketing

Organizational and production capital

  • PLN 6.6 billion of assets

  • purchased services (design, construction)

  • acquired investment land

  • processes and procedures

Permits, architectural design

Leasing, active property management

Social capital

  • customer and contractor trust

  • cooperation with shareholders and banks

  • employee loyalty

  • compliance with legal requirements

Organizational and production capital

  • acquisition of land for the development

    of 166,810 m2 of residential usable floor area

  • acquired contractors

  • increase in the Group's potential to create value in the future

Land aquisition

Sale

Cash

Social capital

  • acquired clients

  • increase in trust and understanding from customers and contractors

  • no significant financial penalties

Input refers to the resources the Group has utilized tocreate value (including the state of assets

and liabilities as of the end of 2025).

Dividend

Output represents the direct results of the Group's activities in 2025.

General disclosures

Impact is the long-term value or change resulting fromthe Group's actions and business model.

Echo Investment Capital Group

Contents For the Planet For People For Stakeholders ESRS Index 24



Group's business segments

Main business segments and characteristics of their customers

The Echo Group is a property development group with extensive experience in the main sectors of the real estate market: residential, office, and retail/service. The Group has unique skills and ability to develop large, mixed-use and city-forming "destinations" projects - places that are good for living, working and leisure. We create projects that fit into and complement urban fabric.

Apartments for sale

CUSTOMERS

Individual investors purchasing apartments for personal use or investment purposes.

Echo Group's achievements in the residential property segment in 2025 are described in chapter 1 of the Management Board Report,

1.11 Residential segment for individual clients - market outlook and the Group's business activities.



Office buildings

CUSTOMERS

This offer is for two types of customers:

  1. Companies looking for a place for their usual offices, usually large and medium-sized companies, both Polish and with foreign capitals. A large part of them are companies from the BPO/SSC sector.

  2. Large investment funds that buy finished and leased office buildings in order to earn from their lease and increase in value.

Echo Investment's achievements in the office segment in 2025 are described in chapter 1 of the Management Board Report, 1.13 Office segment - market outlook and Group business activities.

Flex, serviced offices

CUSTOMERS

Serviced offices are used by the following types of clients:

  1. Medium and large companies view a serviced office as a solution for short-term projects or temporary - for example, until they are provided with a target, traditional office space.

  2. Small companies, often sole proprietors, experts and specialists.

CitySpace's achievements in the flexible office segment in 2025 are described in chapter 1

of the Management Board Report, 1.13 Office segment - market outlook and Group business activities.



Shopping centers, retail spaces

CUSTOMERS

  1. Retail and service chains that lease areas to their establishments.

  2. Large investment funds that buy finished and leased shopping centers in order to profit from their lease and increase in value - a profile similar to buyers of office buildings.

    Echo Investment's achievements in the commercial real estate segment in 2025 are described in chapter 1 of the Management Board Report, 1.14 Retail segment - market outlook and Group business activities.

    Services

    The Group provides its clients with services such as investor substitution, construction management, consulting, accounting, marketing, etc.

    CUSTOMERS

    Primarily related parties (Galeria Młociny, Towarowa 22, Resi4Rent, StudentSpace), and in rare cases also third-party entities.

    The Group does not sell products or services that are banned in certain markets, subject to concerns from stakeholders or public debate.

    In 2025, there were no significant changes in the Group's products, services, or customer categories.



    Selected financial data of the Echo Group is described in chapter 1 of the Management Board Report, 1.4 Selected financial data of the Group and 1.5 Main figures disclosed in the annual financial statements of the Company and its Group.

    The Group's sales revenue broken down by segments

    The Group's sales revenue broken down by significant sectors ESRS [PLN thous.]

    Revenue from sales and costs of the Group by business segments [PLN thous.] 2023 2024 2025

    2023

    2024

    2025

    Segment

    Revenue

    Cost*

    Revenue

    Cost*

    Revenue

    Cost*

    Revenue amount - 68.10.Z PKD (M.68.11 according to NACE) -buying and selling of own real estate (sale of apartments)

    1,293,212

    746,820

    1,642,915

    Residential

    1,293,422

    1,033,220

    747,006

    489,732

    1,642,923

    1,082,620

    Revenue amount - 41.10.Z PKD (M.68.12 according to NACE) -activities related to the implementation of construction projects (project management services, finishing of offices, commercial,

    85,343

    125,980

    155,706

    Resi4Rent

    35,409

    33,307

    39,069

    16,908

    64,088

    45,212

    and service spaces)

    StudentSpace

    -

    -

    39,094

    26,414

    69,694

    58,414

    Revenue amount - 68.20.Z PKD (M.68.20 according to NACE) -

    176,233

    197,360

    200,930

    rental and management of own or leased real estate (rental of residential, office, commercial, and other space

    Commercial properties

    244,462

    326,071

    258,236

    185,113

    236,015

    162,727

    Amount of other (unclassified) income

    18,505

    13,244

    13,169

    Total

    1,573,293

    1,392,598

    1,083,405

    718,167

    2,012,720

    1,348,973

    Total amount of revenue

    1,573,293,

    1,083,405

    2,012,720

    In the Group's business analysis and financial reporting, the Group does not use classifications based on PKD (NACE) codes but rather follows the division into business segments.

    *Cost of sales, profit (loss) from investment properties, administrative costs related to project execution, sales costs, general and administrative costs, other net operating costs.

    The Group does not conduct any activities related to the fossil fuel sector, chemicals production, weapons, cultivation, and production of tobacco.

    Management of the Group and sustainability issues

    GOV-1, including GOV-1 in G1 (5a, 5b)

    The role of the administrative, management, and supervisory bodies

    Echo Investment S.A. is the parent company, consolidating the entire Group. The main shareholder of the Company is Lisala Sp. z o.o., an entity controlled by the Hungarian company Wing IHC Zrt. The ultimate beneficial owner of the Company is Tibor Veres.

    Shareholders of Echo Investment S.A. as at 31 December 2025 are described in CHAPTER 1 of the Management Board Report, 1.7 Echo Investment S.A. shareholding structure and specification of shares.

    General Meeting of Shareholders

    The highest governing body of the parent company Echo Investment

    S.A. is the General Meeting of Shareholders. It enables all shareholders to exercise their rights to direct its activities.

    The General Meeting of Shareholders holds key powers, particularly including:

    • the approval of annual reports,

    • granting of discharge to Management Board and Supervisory Board members for the performance of their duties,

    • taking decisions on dividend,

    • other rights granted directly by the Commercial Companies Code or the Company's Articles of Association.

      Shareholders and the Company may propose resolutions for adoption by the General Meeting of Shareholders during its proceedings. Shareholders may also request the Company to provide information on a specific topic, even outside the General Meeting. Such a request may include topics related to corporate governance processes, control, and procedures used to monitor impacts, risks, and opportunities, as well as their management and oversight.

      In 2025, one Ordinary General Meeting of Shareholders was held. It did not make any decisions or review any matters related to the Group's sustainability issues.



      Supervisory Board

      The Supervisory Board acts as a supervisory body.

      Supervisory Board's Powers

      • establishment of the Supervisory Board's rules of procedure and the approval of the Management Board's rules of procedure,

      • assessment as to whether individual members of the Supervisory Board meet the independence criteria,

      • preparation of reports on remuneration received by members of the Management Board and members of the Supervisory Board,

      • examine the Company's financial statements for the last financial year,

      • assessment of the Company's Management Report and suggestions of the Management Board regarding the distribution of profit and the coverage of loss,

      • review opinions on motions submitted by the Management Board directed to the General Meeting, and express opinion and pass resolutions on other issues submitted by the Company's Management Board,

      • appointment, dismissal, and suspension of the Management Board or its individual members,

      • selection or change of an audit firm,

      • request from the Management Board information specified in the Commercial Companies Code.

        In addition to the issues reserved by the Commercial Companies Code, the prior consent of the Supervisory Board is required for:

      • giving its consent to incurring liabilities and disposing of rights as regards issues included in the Company's current operations, if their value exceeds 20% of the Company's equity,

      • approve the contracting of liabilities and disposing of the rights to the extent within the current business of the Company, if their value exceeds 10% of the Company's equity,

      • payment to shareholders of an advance on the expect ed dividends proposed in the resolution of the Management Board,

      • adoption of the annual budget and business plan for the Company and its subsidiaries prepared by the Management Board.



        The composition of the Supervisory Board, professional biographies of its members,

        along with their expertise, experience, and skills in managing sustainability issues (as at 31 December 2025).

        Noah M. Steinberg

        Chairman of the Supervisory Board

        Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance,

    • corporate impact management,

    • risk management,

    • human resource management (including diversity and inclusion),

    • supply chain management (value chain creation),

    • environmental protection.

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as a business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.

      Tibor Veres

      Vice-Chairman

      of the Supervisory Board

      Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance,

    • corporate impact management,

    • risk management,

    • supply chain management (value chain creation),

    • environmental protection.

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as a business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.



      Margaret Dezse

      Independent Member

      of the Supervisory Board

      Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance: involved in assessing competence and filling key directorships and partner candidates; establishing remuneration policies, promoting and supporting corporate values, codes of conduct, as well as processes for anti-corruption, independence assessment, and conflict of interest assessment,

    • risk management: risk assessment and mitigation, support in preparing and implementing policies, and promoting corporate culture. She has also been engaged in this area as a member of the management boards of various companies,

    • human resource management: participated in personnel decisions, and built organizational structures, taking into account, among other things, aspects of diversity, equal working conditions, and remuneration structures. She is a certified coach at EY, as well as a mentor for the CPA Career Development Mentorship program in Alberta, Canada,

    • supply chain management: in 2024, she participated in a presentation for members of CPA Canada called Connecting ESG Reporting Standards with the Reality of Supply Chains".

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.



      Maciej Dyjas

      Member of the Supervisory Board

      Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance: comprehensive knowledge of corporate governance principles, which are also necessary in the context of ESG management. Expertise related to the roles and responsibilities of management boards, committees, and top management,

    • risk management: experience in transactions, he has detailed knowledge of risk management, with a particular focus on identifying and advising on risks,

    • human resource management: he has played a key role in hiring and building teams.

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.

      Sławomir Jędrzejczyk Independent Member of the Supervisory

      Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance: the preparation and implementation of data reporting processes to the Supervisory Board and financial and accounting processes, creation and implementation of the Code of Ethics, creation and monitoring of CSR policies, and budgets,

    • human resource management: staffing of key positions in companies, assessment of competencies, promotions, and employee remuneration policies,

    • corporate impact management: managing finances, as well as analyst and shareholder relations, organizing project standards and quality, and improving the efficiency of business operations,

    • supply chain management.

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.



      Bence Sass

      Member of the Supervisory Board

      Knowledge, experience, and skills related to managing sustainable development issues:

    • risk management,

    • human resource management (including diversity and inclusion).

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as a business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction

      Nebil Șenman

      Member of the Supervisory Board

      Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance: having an in-depth understanding of regulations and industry best practices helps him to make strategic decisions to create long-term value,

    • sustainable finance: his experience allows him to play a key role in ensuring that the operations of companies are in line with the highest ethical standards and sustainable development,

    • corporate impact management: he has specialized in building strong relationships with various stakeholders, from shareholders to regulators, promoting the transparency and accountability of companies,

    • human resource management: as a member of various supervisory boards, he evaluates key managers and directors. He has played a key

      role in hiring a significant number of highly qualified professionals.

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.



      Balazs Gal

      Member of the Supervisory Board

      Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance,

    • risk management,

    • environment protection.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.

      The professional backgrounds of the members of the Echo Group Supervisory Board are described in detail in CHAPTER 1 of the Management Board Report, 1.1. General information about the Company and the Group.

      Audit Committee

      There are no committees nor designated individuals within the Supervisory Board responsible for overseeing impacts, risks, and opportunities related to sustainability. Selected tasks from the scope described above, however, are carried out by the Audit Committee, which consists of the following members:

    • Margaret Dezse - Chair,

    • Sławomir Jędrzejczyk,

    • Nebil Șenman.

      The responsibilities of the Audit Committee include, among others, evaluating the risk management system, the effectiveness of the internal control system, and compliance management. The Audit Committee fulfills its duties with the support and cooperation of the Company - primarily working with the Management Board, Director of Internal Audit, Finance Director, business controlling, other employees, and Group experts.

      Oversight of the Audit Committee's activities in the area of sustainability is exercised by the Supervisory Board (through the ability to make changes to the composition of the Audit Committee) and by the General Meeting of Shareholders (through the ability to appoint or dismiss members of the Supervisory Board and to grant or withhold discharge for the performance of their duties).

      Audit Committee meetings are typically convened four times a year but may also be called on an ad hoc basis to address specific matters.

      Echo Investment S.A. Supervisory Board diversity by dependency - as at 31 December 2025 [%]

      2024

      2025

      number

      share

      number

      share

      Dependent

      6

      75%

      6

      75%

      Independent*

      2

      25%

      2

      25%

      Other (e.g., employee representative)

      -

      -

      -

      -

      Total

      8

      100%

      8

      100%

      *Independence from the Group and the Group's related parties was established in accordance with Article 129(3) of the Act on Statutory Auditors and the adopted independence criteria set out in the Audit Committee Regulations.

      Echo Investment S.A. Supervisory Board gender diversity as at 31 December 2025 [%]

      2024

      2025

      number

      share

      number

      share

      Women

      1

      12.5%

      1

      12.5%

      Men

      7

      87.5%

      7

      87.5%

      Total

      8

      100%

      8

      100%

      The Group did not reveal any cases of gender non-reporting or people identifying with a gender other than male or female.

      Echo Investment S.A. Supervisory Board diversity of nationality as 31 December 2025 [%]

      2024

      2025

      number

      share

      number

      share

      Hungarian

      3

      37.5%

      3

      37.5%

      Polish

      2

      25.0%

      2

      25.0%

      American

      1

      12.5%

      1

      12.5%

      Canadian

      1

      12.5%

      1

      12.5%

      German

      1

      12.5%

      1

      12.5%

      Total

      8

      100%

      8

      100%



      Echo Group's Management Board

      The Group is managed by the Management Board of the parent company, Echo Investment S.A., which consolidates the entire Group in its financial reporting. Nevertheless, since the capital groups of the two main companies, Echo Investment S.A. and Archicom S.A., carry out development activities in different sectors of the real estate market, have distinct clients, and a different way of developing projects and financing them, the Management Boards of Echo Investment S.A. and Archicom S.A., in most cases, act as the management boards for sister companies, or the equivalent thereof, and cooperate with each other in specific business situations.

      The business functions of the two groups (land purchasing, contracting and optimization, managing architectural departments, managing business, conducting sales and leasing, and providing building management and after-sales services), operate independently in each group and the results of their work or activities are not considered consolidated in any analysis of the business of the groups.

      The operational consistency of the entire Group is ensured by the fact that three members of the Management Board of Echo Investment S.A. and two representatives of the Supervisory Board of Echo Investment

      S.A. sit on the seven-member Supervisory Board of Archicom S.A. (this is not a rule, but the result of a decision of the GMS). Nicklas Lindberg, the President of Echo Investment S.A. and the Chairman of the Supervisory Board of Archicom S.A., plays the largest part when it comes to coordinating the work of both Management Boards.

      To properly understand the functioning of the Group and to faithfully present the responsibilities in connection with key issues and data, this report presents information of the two main companies in the Group and, where relevant, presents information separately for the two groups.

      The Management Boards of both main Companies serve as the executive bodies. They oversee all affairs of their Company, subject to the limitations set forth by the provisions of the Commercial Companies Code and the Company's Articles of Association. This encompasses responsibility for managing impacts, risks, and opportunities. These powers and duties are executed through the implementation of relevant policies applicable within the Group, the management of subordinate employee resources, the clearly defined responsibilities of each Management Board member, and the objectives established for both Management Boards and its individual members by the Supervisory Boards.



      The composition of the Echo Investment S.A. Management Board, professional biographies of its members, talong with their expertise, experience, and skills in managing sustainability issues (as at 31 December 2025).

      Nicklas Lindberg

      President of the Management Board, CEO

      Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance,

    • construction site safety,

    • corporate impact management

    • diversity and inclusion management: social matters that improve the surroundings of ongoing projects and support community groups in need.

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.

      Maciej Drozd

      Vice-President of the Management Board, CFO

      Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance,

    • risk management,

    • human resource management,

    • construction site safety,

    • human rights.

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.



      Artur Langner

      Vice-President of the Management Board

      Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance,

    • supply chain management,

    • environmental protection,

    • construction site safety,

    • human resource management.

      * On 19 February 2026, Management Board member Artur Langner submitted his resignation from the position of Vice-President of the Management Board of the Company and from his membership on the Management Board, with immediate effect. On 26 February 2026, the Supervisory Board of the Company appointed Rafał Mazurczak, previously a member of the Management Board, as Vice-President of the Management Board.

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.

      Rafał Mazurczak

      Member of the Management Board, COO

      Knowledge, experience, and skills related to managing sustainable development issues:

    • supply chain management,

    • construction site safety,

    • environmental protection,

    • risk management,

    • human resource management,

    • CSR.

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.



      Małgorzata Turek

      Member of the Management Board

      Knowledge, experience, and skills related to managing sustainable development issues:

    • corporate governance,

    • enterprise impact management,

    • construction site safety,

    • human resource management.

      (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

    • the role of ESG as business standard,

    • the business benefits of ESG,

    • the impact of the financial sector on ESG management,

    • the overview of ESG strategies in the construction sector,

    • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

      (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

    • the strategic importance of decarbonization for the Echo Group,

    • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

    • climate policy directions in Poland, the EU, and globally,

    • decarbonization pathways in the Echo Group's own operations,

    • the role of the Management Board in achieving climate goals and setting strategic direction.

      The professional backgrounds of the members of the Echo Group Supervisory Board are described in detail in CHAPTER 1 of the Management Board Report, 1.1. General information about the Company and the Group.

      There are no employee representatives or independent members in the Management Board of Echo Investment S.A.

      The Management Boards and Supervisory Boards of both main companies are included in all ESG training courses organized by the Echo Group to develop their knowledge, experience, and skills related to sustainable development management at the same level.

      As Waldemar Olbryk, President of Archicom S.A., is responsible for supervising sustainability-related matters within the Echo Group, we also present below his knowledge, experience, and skills in managing sustainability issues.

Waldemar Olbryk

President of Archicom, responsible for sustainable development issues within the Echo Group

Knowledge, experience, and skills related to managing sustainable development issues:

  • corporate governance,

  • safety on the construction site,

  • corporate impact management,

  • diversity and inclusion management: social matters that improve the surroundings of ongoing projects and support community groups in need.

    (2024) Scope of training to obtain a certificate of "ESG training for Supervisory Boards and Teams":

  • the role of ESG as business standard,

  • the business benefits of ESG,

  • the impact of the financial sector on ESG management,

  • the overview of ESG strategies in the construction sector,

  • the role of Management Boards and Supervisory Boards in managing the ESG transformation.

    (2025) Training course: "Decarbonization of the Echo Group in Practice - Strategy, Responsibilities, and Benefits", covering:

  • the strategic importance of decarbonization for the Echo Group,

  • climate ambitions and commitments resulting from the Echo Group's ESG Strategy,

  • climate policy directions in Poland, the EU, and globally,

  • decarbonization pathways in the Echo Group's own operations,

  • the role of the Management Board in achieving climate goals and setting strategic direction.



Echo Investment S.A. Management Board gender diversity as at 31 December 2025 [%]

2024

2025

number

share

number

share

Women

1

20%

1

20%

Men

4

80%

4

80%

Total

5

100%

5

100%

The Echo Group did not reveal any cases of gender non-reporting or people identifying with a gender other than male or female.

Echo Investment S.A. Management Board diversity of nationality as at 31 December 2025 [%]

2024

2025

number

share

number

share

Polish

4

80%

4

80%

Swedish

1

20%

1

20%

Total

5

100%

5

100%



Group

Earlier from Echo Investment

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