EPRA-Reporting: EPRA Sustainability Best Practice Recommendations

Introduction

Company Profile
LEG Immobilien SE is a housing company with 171,360 rental properties (approximately 500,000 tenants) with an average apartment size of 63 square meters and 1,600 commercial units.

LEG focuses on affordable housing. Its portfolio is geared in particular toward the growing number of smaller households that are typical for the company´s market segment. The regional focus of LEG´s portfolio is in North Rhine-Westphalia, where approximately 80 % of its residential units are located. In addition, LEG operates as a landlord in the western German states of Schleswig-Holstein, Lower Saxony, Bremen, Hesse, and Rhineland-Palatinate, among others. 

The company´s core business is the management of its own residential portfolio. LEG´s business model aims to ensure the company´s long-term viability while taking external conditions into account and addressing the interests of all key stakeholders. The strategy is based on three pillars: optimizing and digitizing the core business, expanding the value chain and strengthening the portfolio.

Headquartered in Düsseldorf, the Group had around 2,117 employees in 2025. A number of LEG companies are responsible for owning and managing the properties.

Since 2017, the company has been reporting on its social and environmental performance and has been continuously expanding the scope of indicators and properties included in its reporting.
LEG is a member of EPRA and prepares its environmental and social reports in accordance with EPRA's Best Practice Recommendations on Sustainability Reporting (sBPR) in addition to other recognized reporting standards. The report is divided into two sections:

1. General Recommendations
2. Performance Report

1. General Recommendations

System Boundaries
For the 2025 fiscal year, LEG is publishing not only the non-financial group statement in accordance with Sections 315b and 315c of the German Commercial Code (HGB) in conjunction with Sections 289c–e HGB, but also the EPRA Sustainability Best Practice Recommendations (sBPR). The framework covers the key non-financial aspects that are significant due to their substantial impact on environmental, social, and corporate culture issues. The report was prepared in accordance with the fourth version of the EPRA sBPR guidelines.

The scope of consolidation for EPRA reporting corresponds to that of the non-financial group statement pursuant to Sections 315b, 315c in conjunction with Sections 289c–289e of the German Commercial Code (HGB). Excluded are the consumption and emissions of the vehicle fleet as well as those of the biomass cogeneration plant operated by LEG. This results in discrepancies in the key figures between the two reports.

For the individual performance indicators, the following share of the property portfolio is within the system boundaries:

• Electricity: The company is responsible for the purchasing/settlement of all electricity consumed for communal areas in the property portfolio under its management.
• Fuels, district heating / -cooling: Actual data on fuel consumption and/or district heating was available for approximately 58 % (2024) of the properties managed by LEG. The remaining data gap — approximately 38 % — was filled using projections based on energy performance certificates, and approximately 4 % was filled using building age clusters.
• Water: LEG is responsible for the purchasing/settlement of all water consumed in the property portfolio it manages.
• Waste: The company is responsible for the removal and disposal of the waste generated by the rental properties for the entire property portfolio it manages.
• Employees: The report relates to all persons employed directly by LEG, including its wholly owned subsidiaries LEG Wohnen NRW (which is responsible for the operations management of LEG´s properties) and LEG Management (which monitors all corporate governance areas). Employees at joint ventures, are partially excluded as they are not subject to full operational control.
• Site health and safety and community engagement: LEG is responsible for conducting health and safety inspections, ensuring compliance with regulations and fostering community engagement across all properties under its management.
• Governance data relate to LEG’s Supervisory Board and its Management Board.

Coverage
Unless stated otherwise, the absolute performance indicators for fuel consumption, district heating, and district cooling, building certification, site health and safety, and community betterment relate to 100 % of the apartments that fall within the system boundaries defined above.

The data collected for electricity consumption relate to 100 % of the apartments within the system boundaries (2024: 97 %).

The water data collected relates to 47 % of the apartments within the system boundaries. The other 53 % are excluded because no consumption data is available for them. The waste data collected covers 23 % of the managed property portfolio. For these apartments, a separate service provider is engaged to handle waste management and collect data on the volume of waste generated, which is converted into tons using a conversion factor.

Estimation of landlord-obtained utility consumption
The data on electricity and water for 2025 are entirely estimated as the actual consumption data were not yet available by the editorial deadline. These estimates were made by calculating the absolute data and consumption indicators on the basis of the consumption data for 2024 and extrapolating this to reflect disposals and additions in 2025.

The 2025 data for heating and fuels are based on estimates, as the actual consumption data were not available at the time of publication. The estimates were made using the following methodology: The results of the 2024 climate balance is used and adjusted for portfolio changes and for the reporting year using the climate factor from the German Weather Service (DWD). This adjustment is necessary to reflect the weather conditions for the 2025 reporting year. In addition, greenhouse gas savings from decarbonization measures already implemented are considered in the projection for the 2025 fiscal year.

The estimates for electricity, water, heating, and fuels for 2024 used in the previous year were replaced by the actual consumption data for 2024. For administrative buildings, water consumption for 2024 and 2025 will be projected based on the most recent consumption data available.

The waste data is reported by a service provider that operates as the waste manager for around 23 % of the property portfolio. The combined volumes of the waste containers provided for these properties by LEG were analyzed. These volumes are not always the same as the waste containers’ actual fill volumes. Also, these figures do not add up to the actual volume of waste at these properties, as some of the waste is disposed of in public containers which are emptied directly by the local council.

The volumes collected in the waste containers provided by LEG are converted into tons using general conversion factors for the several types of waste. These conversion factors were marked up by 10 % as the waste containers hold an above-average volume of waste (except organic waste) thanks to the service provider’s active waste management. Conversion factors: residual waste: 0.11 t/m³; recyclable materials: 0.033 t/m³; paper, card, cardboard packaging: 0.22 t/m³; organic waste: 0.25 t/m³.

Third Party Assurance
The relevant key figures were taken from the non-financial group statement and were therefore subject to review by an independent auditor. To the extent that the key figures contained in this report are derived from non-financial reporting, they are audited accordingly. The calculation of LFL, however, was not reviewed by an independent third party, but is based on the underlying audited data.

Boundaries – Reporting on landlord and tenant utility consumption
The data for electricity and water relate only to the consumption (based on meter readings and bills) that LEG purchases as the lessor for communal areas/central services or private apartments (and which is subsequently billed to the tenants). Data that are billed to tenants directly (i.e., bills that tenants receive directly from their provider) have not been taken into account.

Analysis – Normalization
The consumption indicators were calculated on the basis of floor area (square meters) for entire buildings, including rental apartments. LEG is aware that the methodology used to calculate consumption indicators results in a discrepancy between the numerator and denominator, as electricity bills are only available for common areas, whereas bills for fuel, district heating, district cooling, and water consumption for common areas/central services and rental units (it is not possible to separate these consumption data).

Performance Indicators for Health and Safety

These are calculated using the following formulas:

• Injury rate = number of reported injuries / total number of hours worked
• Work loss rate = number of workdays lost (from three and upwards) due to workplace injury / total number of workdays
• Absence rate = number of days missed due to illness / total number of workdays

Analysis – Segment Analysis (by Property Type, Geographical Location)
The segment analysis is based on the property classification used in the financial report (see 2025 annual report). LEG´s portfolio comprises around 171,360 apartments and 1,600 commercial units. The segment analysis does not distinguish between residential and commercial units as they are located in the same buildings and therefore the consumption billed to the lessor cannot be separated. A further segment analysis by geographical location is not relevant as about 80 % of the apartments are in North Rhine-Westphalia and the remaining part in other German states and are therefore in the same climate zone.

Disclosure on own offices
Since the 2023 calendar year, all administrative buildings have been included in the report. The administrative areas include LEG´s headquarters, its branch offices, and numerous smaller administrative spaces operated by LEG. 100 % of the space is recorded, and all available consumption data is reported. To determine waste volumes, the combined volumes of the waste containers were analyzed. These do not always correspond to the actual fill levels of the waste containers. The conversion of volumes to tons is based on general conversion factors for each type of waste.

Reporting Period
Absolute performance indicators and consumption indicators relate to the last reporting year (2025). The like-for-like analysis of performance metrics for electricity and heating energy covers the past two years, with extrapolated figures used for 2025. The Like-for-like analysis of the performance indicators for water relates to the last two years for which the company was able to collect actual consumption data (2024 and 2023). For further information, see “Estimates of Utility Services Billed to the Lessor.”

However, the like-for-like analysis for waste relates to the years 2025 and 2024, as the corresponding waste volumes are available for these years.

Materiality
LEG is mindful of its corporate responsibility toward the environment and society. To this end, the company engages in an ongoing and structured examination of social and environmental changes. As part of this process, the impacts on the business model and value creation are analyzed. The effects of business activities on the environment and society are taken into account in decision-making processes.

Since the 2024 fiscal year, LEG has based this on the double materiality analysis in accordance with the European Sustainability Reporting Standards (ESRS), which are applied in full. The materiality analysis process and the current underlying materiality assessment are described in detail in the 2025 Annual Report in the chapter “DR IRO-1: Description of the procedures for identifying and assessing material impacts, risks, and opportunities” (p. 123 ff.). The specific circumstances of the real estate industry were taken into account throughout the materiality analysis process and are addressed in particular in topic standards E1 and S4.

The assessment of material impacts, risks, and opportunities was conducted through close consultation with the risk management team. In addition, these are validated annually.
 

Performance Report

Environment Action Area

Energy Consumption and Emissions
Based on the 2024 reporting year, energy consumption and emissions were extrapolated for the 2025 reporting year by adjusting for the 2025 portfolio changes. The 2025 projection is based on the actual consumption figures for 2024. For the projection, it is assumed that tenants’ heating behavior remains consistent with the previous year. These consumption figures were adjusted to reflect the weather conditions in 2025. As 2025 was significantly colder than 2024, this results in higher consumption values and correspondingly increased emissions. Once the actual consumption figures for 2025 are available, the reported values may change accordingly.

Energy Consumption
In the 2025 reporting year, electricity consumption decreased by a total of 0.12%. In contrast, fuel consumption rose by 5.33% and district heating consumption by 10.81%.

The energy intensity of the real estate portfolio thus increased by 3.09%. This development is attributable to higher fuel and district heating demand due to weather conditions, as well as to the acquisition of the BCP portfolio. On a like-for-like basis, electricity consumption decreased by 1.46%.

Fuel consumption rose by 0.77% and district heating consumption by 4.87%. The increase is primarily attributable to weather-related higher energy consumption. In addition, the expansion of several district heating connections was implemented in 2025, which also led to higher consumption values.

Emissions
Scope 1 emissions rose accordingly by 5.16 %. Scope 2 emissions increased by a total of 7.60 % in the location-based analysis and by 6.54 % in the market-based analysis during the reporting year. In the market-based analysis, emissions from electricity decreased by 2.85 % compared to 2024, while emissions from district heating increased by 9.73 %. In the location-based analysis, emissions decreased by 2.62 %, while emissions from district heating increased by 10.81 %.

The increase in emissions from 2024 to 2025 relates exclusively to actual absolute emissions and is attributable to the acquisition of the BCP portfolio as well as higher energy consumption due to weather conditions.

In terms of greenhouse gas emission intensity, Scope 1 and Scope 2 emissions rose from 24.98 in 2024 to 25.61 in 2025 (location-based) and from 22.57 in 2024 to 23.04 in 2025 (market-based) in kg CO2e/m²/year. In the climate-adjusted analysis, however, the consumption metric decreased compared to the previous year. The climate-adjusted values are reported in the nonfinancial report as well as in the climate pathway.

On a like-for-like basis, Scope 1 emissions decreased by a total of 2.86%. Scope 2 emissions, on the other hand, increased by 2.42% (market-based) and by 3.27% (location-based). Market-based emissions from electricity decreased by 3.06% from 2024 to 2025. Location-based emissions from electricity decreased by 2.82%. This reduction is primarily attributable to the increased share of renewable energy.

Emissions from district heating increased by 4.26% (market-based) and 4.87% (location-based) in the like-for-like analysis. The increase is mainly attributable to weather-related higher energy consumption.

Scope 3 emissions (“3.03 Upstream Heat” and “3.13 Household Electricity”) totaled 176,839 t CO2e. This represents a 9.62% reduction compared to the previous year. Further information on the measures to reduce energy consumption and GHG emissions in LEG´s portfolio can be found from page 136, ESRS E1: Climate Change, in the annual report.

Water
Absolute water withdrawal rose by 3.97 % in 2025 compared to 2024. The water withdrawal parameter remained stable. In the like-for-like analysis, consumption increased by 1.07 % between 2024 and 2023. Accordingly, the water withdrawal parameter indicator remained unchanged in the like-for-like analysis. All water comes from the municipal water supply.

Further information on water management activities in LEG´s property portfolio can be found in LEG´s Water Policy at: www.leg-wohnen.de/en/corporation/sustainability/codes-and-guidelines/policies/water-guideline

Waste Disposal
The total weight of waste collected in the 23 % of apartments for which data was collected decreased slightly by 0.01 % between 2024 and 2025. 59 % of this is residual waste, of which only a small proportion is sent to landfill, while the majority is used for energy recovery in waste incineration plants. In the like-for-like analysis, the total weight of waste collected in apartments for which LEG was able to gather corresponding data decreased slightly by 0.2 % between 2025 and 2024.

Due to the relatively low coverage rate of waste data and the applied calculation methodology, it is difficult to draw conclusions about overall performance. Nevertheless, various measures are being implemented, such as raising tenants ´awareness, to reduce the amount of waste.

Building Certification
Building certification refers to energy performance certificates, which are currently available for approximately 96.4 % of the company´s property portfolio (based on floor area). 55.6 % of individual apartments (2024: 46.5 %) have an energy efficiency certificate in efficiency classes A+ through D. This is due to the relatively high advanced age of the buildings. Energy efficiency ratings for buildings have steadily improved in recent years thanks to numerous decarbonization measures.

Society Action Area

Diversity
LEG is committed to ensuring a balanced workforce composition and gender equality. Around 35.6 % of direct employees and 25 % of managers are women. The ratio of the basic salary and remuneration of women to that of men is 100.71 % for all employees and 125.77 % at the management level. Differences are solely due to length of service and seniority. Since 2024, employees of TechnikServicePlus GmbH (TSP) have also been included in the key figures. The largest share of employees (50.87 %) is between the ages of 30 and 50. 31.55 % are over 50, and 17.57 % are under 30.

Training and Continuing Professional Development
LEG actively promotes initial and further training and supports its employees’ career growth. In 2025, female employees completed an average of 15.64 training hours and male employees 18.33 training hours on various compliance, professional topics, and career development opportunities. Additionally, 77.7 % of employees participated in an annual professional development interview. These conversations serve as a dialogue between employees and managers, offering insights into employees' skills and competencies. Employees also have the opportunity to discuss the support they need, their job satisfaction, and how they would like to continue developing within the company.

Further information on the approach to employee training and professional development can be found in the Training and Continuing Professional Development Policy at: www.leg-wohnen.de/en/corporation/sustainability/codes-and-guidelines/policies/training-and-further-education-policy

Turnover
In 2025, 305 new employees were hired, corresponding to a new hire rate of approximately 14.4 %. At the same time, 225 employees left the company, resulting in a turnover rate of 10.6 %. Further information on initiatives related to the employees, including employee engagement, satisfaction, and retention, can be found in the Training and Continuing Professional Development Policy mentioned above: www.leg-wohnen.de/en/corporation/sustainability/codes-and-guidelines/policies/training-and-further-education-policy

Health and Safety
Given the nature of the work, LEG generally assesses the risk in the area of employee health and safety as low. This is confirmed by an injury rate of 2.06 % in 2025 and a work loss rate of 0.11 %. The most frequent reason for absences is illness, with an absence rate of 14.04 days per employee in 2025.

LEG systematically and comprehensively ensures site safety through both its own employees and service providers, who inspect and check buildings and facilities. 100 % of the property portfolio underwent such a health and safety review in 2025. If any defects or accident risks were reported, tradesmen were immediately commissioned. After the work was completed, the rectification of defects was checked and documented.

Further information on this approach on employee and tenant health and safety can be found on page 149 (ESRS S1: Own workforce) and starting on page 159 (ESRS S4: Consumers and end-users) of LEG´s annual report.

Community Engagement
Community engagement activities are organized across 100 percent of the managed real estate portfolio. These activities include a variety of measures aimed at increasing tenant satisfaction, promoting social cohesion, encouraging people to be good neighbors, boosting local communities and responding to social challenges. Further information on this approach and examples of some of the many initiatives implemented in LEG’s real estate portfolio in 2025 can be found starting on page 159 of the Annual Report, under ESRS S4: Consumers and End Users. 

Governance
Detailed background information on governance performance indicators, as well as a profile of the Supervisory Board and a description of the nomination process and the handling of potential conflicts of interest, can be found on page 14 and following, page 24 et seq. and p. 92 et seq. of the current Annual Report, as well as at:www.leg-wohnen.de/en/corporation/leg-group/members-of-the-management-and-supervisory-board and www.leg-wohnen.de/en/corporation/sustainability/codes-and-guidelines.

Mr. Michael Zimmer, as the Chairman of LEG’s Supervisory Board, has extensive social commitments and has initiated or personally founded various foundations. Mr. Zimmer serves as the Chairman of the Board of Trustees for the following foundations: Your Home Helps – Foundation of the LEG Immobilien Group: www.dein-zuhause-hilft.de, CORNELIUS – Foundation for the Children of Addicted Parents: www.cornelius-stiftung.de, Der bewohnte Garten – Foundation for the Promotion of Contemporary Art: www.derbewohntegarten.de. He is therefore an expert in the areas of environment and society. All three members of the Management Board are experts in the areas of the environment and society.