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PILLAR 3: CORPORATE PERFORMANCERisk ManagementESR Group LimitedEnvironmental, Social and Governance Report 202474To ensure the effectiveness of our ethical standards and compliance-related policies, Group Internal Audit will conduct an annual review of compliance with the above policies, including ethical standards. This process helps us assess the internal controls associated with these standards and policies. We are pleased to report that no breaches of our Code of Conduct and Business Ethics were reported during FY2024. As a Group, we are committed to minimising conflicts of interest by implementing clear prohibitions and proper segregation of duties in situations where a responsible party may have a personal interest during a business transaction and must be excluded from the business discussion or receiving any related information.%u2022%u0009Whistleblowing: In alignment with our Code of Conduct and Business Ethics, Whistleblowing Policy, Group Human Resources Policy and Human Rights Policy, we have implemented grievance mechanisms to handle concerns and reports related to compliance and workplace behaviour. These channels are accessible to both internal and external stakeholders, including employees, allowing them to confidentially report any suspected infringements or violations.External third parties, including supply chain workers with commercial ties to ESR and its employees, can report whistleblowing complaints via our corporate website (https://www.esr.com/whistleblowing-policy/). All complaints submitted through this channel are handled with strict confidentiality. External whistleblowers may also visit our aforementioned corporate website to download and complete the %u2018Whistleblowing Report Form%u2019 to share their concerns. Where legally permitted, reports can be made anonymously; however, voluntarily providing contact details is encouraged to facilitate follow-up inquiries during the investigation process.Submissions are reviewed and assessed by the Group%u2019s Head of Compliance and General Counsel, who prepare regular investigative reports for internal communication and validation purposes. The Audit Committee is informed of all whistleblowing cases and determines appropriate actions to address them. ESR is dedicated to fostering an open, fair and transparent environment, ensuring that employees and external stakeholders can report misconduct or violations in good faith. Retaliation is strictly prohibited against individuals who assist in investigations, even if their reports are ultimately unsubstantiated. Notably, no workplace discrimination or ethics-related complaints were reported during FY2024.ComplianceESR remains dedicated to full compliance with the laws and regulations in every jurisdiction where we operate. As outlined in our Code of Conduct and Business Ethics and Group Human Resources Policy, employees are free to engage in political activities of their choice. However, it is crucial that these personal activities do not give the impression that employees are representing or acting on behalf of the Company unless explicitly authorised.The Company strictly forbids any form of political engagement on its behalf, including unlawful political donations or lobbying expenditures directed toward political organisations or individuals. We highlight that no contributions or expenditures were made to any political party, politician, or campaign-related activities during FY2024.Utilising our advanced technology and strong regulatory compliance framework, we established a comprehensive compliance programme. This programme is designed to uphold the highest standards of ethical conduct and regulatory adherence. %u2022%u0009ComplyESR and LRN (formerly known as Thomson Reuters) e-learning: We utilise two key tools to support our compliance efforts. ComplyESR is our new in-house compliance and risk management system, designed to streamline and simplify compliance-related tasks. ComplyESR helps us manage compliance risks and track employees%u2019 acknowledgements of ESR%u2019s Code of Conduct and Business Ethics, as well as other relevant policies such as Conflicts of Interest Policy, Anti-Bribery, Anti-Corruption and Handling of Gifts, Travel & Entertainment Policy, Anti-Money Laundering, Counter-Terrorist Financing & Sanctions Policy, Employee Dealing and The Handling of Inside Information and Whistleblowing Policy. Employees must attest that they have read, understood and will adhere to these principles annually via ComplyESR. ComplyESR is also used for attestation by all employees and ESR licensed representatives that they have read and understood the training materials and other ESG and IT corporate related policies. Additionally, we utilise LRN (formerly known as Thomson Reuters) e-learning platform, to assign compliancerelated training courses, covering various topics including anti-bribery and anticorruption, business gifts and entertainment, insider dealing and anti-competitive conduct. Each training includes a self-assessment component where employees can evaluate their understanding of the training materials. All employees must complete the mandatory training modules assigned annually and certification to the Code of Conduct and Business Ethics as well as Employee Trading.