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SİNPAŞ GAYRİMENKUL YATIRIM ORTAKLIĞI A.Ş.

Environmental & Social Information Sep 17, 2025

5951_rns_2025-09-17_937e40a7-fb7f-45b6-a151-b042dbc8c12c.pdf

Environmental & Social Information

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SINPAS GAYRIMENKUL YATIRIM ORTAKLIGI ANONIM SIRKETI

2025 CDP Corporate Questionnaire 2025

Word version

Important: this export excludes unanswered questions

This document is an export of your organization's CDP questionnaire response. It contains all data points for questions that are answered or in progress. There may be questions or data points that you have been requested to provide, which are missing from this document because they are currently unanswered. Please note that it is your responsibility to verify that your questionnaire response is complete prior to submission. CDP will not be liable for any failure to do so.

Read full terms of disclosure

.

09/17/2025, 11:15 am

Contents

C1. Introduction
6
(1.1) In which language are you submitting your response? 6
(1.2) Select the currency used for all financial information disclosed throughout your response.
6
(1.3) Provide an overview and introduction to your organization.
6
(1.4) State the end date of the year for which you are reporting data. For emissions data, indicate whether you will be providing emissions data for past reporting years 7
(1.4.1) What is your organization's annual revenue for the reporting period?
7
(1.5) Provide details on your reporting boundary.
7
(1.6) Does your organization have an ISIN code or another unique identifier (e.g., Ticker, CUSIP, etc.)?
7
(1.7) Select the countries/areas in which you operate.
9
(1.15) Which real estate and/or construction activities does your organization engage in?
10
(1.24) Has your organization mapped its value chain?
10
(1.24.1) Have you mapped where in your direct operations or elsewhere in your value chain plastics are produced, commercialized, used, and/or disposed of?
11
C2. Identification, assessment, and management of dependencies, impacts, risks, and opportunities
12
(2.1) How does your organization define short-, medium-, and long-term time horizons in relation to the identification, assessment, and management of your environmental
dependencies, impacts, risks, and opportunities?
12
(2.2) Does your organization have a process for identifying, assessing, and managing environmental dependencies and/or impacts? 13
(2.2.1) Does your organization have a process for identifying, assessing, and managing environmental risks and/or opportunities? 14
(2.2.2) Provide details of your organization's process for identifying, assessing, and managing environmental dependencies, impacts, risks, and/or opportunities.
14
(2.2.7) Are the interconnections between environmental dependencies, impacts, risks and/or opportunities assessed?
18
(2.3) Have you identified priority locations across your value chain?
18
(2.4) How does your organization define substantive effects on your organization? 19
C3. Disclosure of risks and opportunities
22
(3.1) Have you identified any environmental risks which have had a substantive effect on your organization in the reporting year, or are anticipated to have a substantive
effect on your organization in the future?
22
(3.1.1) Provide details of the environmental risks identified which have had a substantive effect on your organization in the
reporting year, or are anticipated to have a
substantive effect on your organization in the future
22

(3.1.2) Provide the amount and proportion of your financial metrics from the reporting year that are vulnerable to the substantive effects of environmental risks. ................ 30

(3.5) Are any of your operations or activities regulated by a carbon pricing system (i.e. ETS, Cap & Trade or Carbon Tax)? 30
(3.5.4) What is your strategy for complying with the systems you are regulated by or anticipate being regulated by?
30
(3.6) Have you identified any environmental opportunities which have had a substantive effect on your organization in the reporting year, or are anticipated to have a
substantive effect on your organization in the future?
31
(3.6.1) Provide details of the environmental opportunities identified which have had a substantive effect on your organization in the reporting year, or are anticipated to have
a substantive effect on your organization in the future
31
C4. Governance34
(4.1) Does your organization have a board of directors or an equivalent governing body?
34
(4.1.1) Is there board-level oversight of environmental issues within your organization?
35
(4.1.2) Identify the positions (do not include any names) of the individuals or committees on the board with accountability for environmental issues and provide details of the
board's oversight of environmental issues.
35
(4.2) Does your organization's board have competency on environmental issues? 37
(4.3) Is there management-level responsibility for environmental issues within your organization?
38
(4.3.1) Provide the highest senior management-level positions or committees with responsibility for environmental issues (do not include the names of individuals).
38
(4.5) Do you provide monetary incentives for the management of environmental issues, including the attainment of targets?
42
(4.6) Does your organization have an environmental policy that addresses environmental issues?
42
(4.6.1) Provide details of your environmental policies 43
(4.10) Are you a signatory or member of any environmental collaborative frameworks or initiatives? 46
(4.11) In the reporting year, did your organization engage in activities that could directly or indirectly influence policy, law, or regulation that may (positively or negatively)
impact the environment?
47
(4.12) Have you published information about your organization's response to environmental issues for this reporting year in places other than your CDP response?
48
(4.12.1) Provide details on the information published about your organization's response to environmental issues for this reporting year in places other than your CDP
response. Please attach the publication
48
C5. Business strategy
50
(5.1) Does your organization use scenario analysis to identify environmental outcomes?
50
(5.1.1) Provide details of the scenarios used in your organization's scenario analysis.
50
(5.1.2) Provide details of the outcomes of your organization's scenario analysis.
54
(5.2) Does your organization's strategy include a climate transition plan?
55
(5.3) Have environmental risks and opportunities affected your strategy and/or financial planning? 56
(5.3.1) Describe where and how environmental risks and opportunities have affected your strategy 56
(5.3.2) Describe where and how environmental risks and opportunities have affected your financial planning 57
(5.4) In your organization's financial accounting, do you identify spending/revenue that is aligned with your organization's climate transition?
58
(5.5) Does your organization invest in research and development (R&D) of low-carbon products or services related to your sector activities? 59
(5.10) Does your organization use an internal price on environmental externalities?
59
(5.11) Do you engage with your value chain on environmental issues?
60
(5.11.9) Provide details of any environmental engagement activity with other stakeholders in the value chain.
60
C6. Environmental Performance -
Consolidation Approach63
(6.1) Provide details on your chosen consolidation approach for the calculation of environmental performance data.
63
C7. Environmental performance -
Climate Change
64
(7.1) Is this your first year of reporting emissions data to CDP? 64
(7.2) Select the name of the standard, protocol, or methodology you have used to collect activity data and calculate emissions 64
(7.3) Describe your organization's approach to reporting Scope 2 emissions 64
(7.4) Are there any sources (e.g. facilities, specific GHGs, activities, geographies, etc.) of Scope 1, Scope 2 or Scope 3 emissions that are within your selected reporting
boundary which are not included in your disclosure?
65
(7.5) Provide your base year and base year emissions.
65
(7.6) What were your organization's gross global Scope 1 emissions in metric tons CO2e? 66
(7.7) What were your organization's gross global Scope 2 emissions in metric tons CO2e? 67
(7.8) Account for your organization's gross global Scope 3 emissions, disclosing and explaining any exclusions 67
(7.9) Indicate the verification/assurance status that applies to your reported emissions 72
(7.9.1) Provide further details of the verification/assurance undertaken for your Scope 1 emissions, and attach the relevant
statements
73
(7.9.2) Provide further details of the verification/assurance undertaken for your Scope 2 emissions and attach the relevant statements 74
(7.10) How do your gross global emissions (Scope 1 and 2 combined) for the reporting year compare to those of the previous reporting year?
75
(7.12) Are carbon dioxide emissions from biogenic carbon relevant to your organization?
75
(7.15) Does your organization break down its Scope 1 emissions by greenhouse gas type? 76
(7.15.1) Break down your total gross global Scope 1 emissions by greenhouse gas type and provide the source of each used global warming potential (GWP) 76
(7.16) Break down your total gross global Scope 1 and 2 emissions by country/area.
77
(7.17) Indicate which gross global Scope 1 emissions breakdowns you are able to provide.
78
(7.17.1) Break down your total gross global Scope 1 emissions by business division.
78
(7.20) Indicate which gross global Scope 2 emissions breakdowns you are able to provide.
80
(7.20.1) Break down your total gross global Scope 2 emissions by business division.
80
(7.22) Break down your gross Scope 1 and Scope 2 emissions between your consolidated accounting group and other entities included in your response 83
(7.23) Is your organization able to break down your emissions data for any of the subsidiaries included in your CDP response? 83
(7.23.1) Break down your gross Scope 1 and Scope 2 emissions by subsidiary.
83
(7.29) What percentage of your total operational spend in the reporting year was on energy?
89
(7.30) Select which energy-related activities your organization has undertaken.
89
(7.30.1) Report your organization's energy consumption totals (excluding feedstocks) in MWh.
90
(7.30.16) Provide a breakdown by country/area of your electricity/heat/steam/cooling consumption in the reporting year.
92
(7.45) Describe your gross global combined Scope 1 and 2 emissions for the reporting year in metric tons CO2e per unit currency total revenue and provide any additional
intensity metrics that are appropriate to your business operations.
93
(7.53) Did you have an emissions target that was active in the reporting year? 94
(7.53.1) Provide details of your absolute emissions targets and progress made against those targets 94
(7.54) Did you have any other climate-related targets that were active in the reporting year? 97
(7.55) Did you have emissions reduction initiatives that were active within the reporting year? Note that this can include those in the planning and/or implementation phases.
98
(7.55.1) Identify the total number of initiatives at each stage of development, and for those in the implementation stages, the estimated CO2e savings.
98
(7.55.2) Provide details on the initiatives implemented in the reporting year in the table below.
98
(7.55.3) What methods do you use to drive investment in emissions reduction activities?
99
(7.72) Does your organization assess the life cycle emissions of new construction or major renovation projects? 99
(7.74) Do you classify any of your existing goods and/or services as low-carbon products? 100
(7.77) Did your organization complete new construction or major renovations projects designed as net zero carbon in the last three years?
100
(7.78) Explain your organization's plan to manage, develop or construct net zero carbon buildings, or explain why you do not plan to do so.
100
(7.79) Has your organization retired any project-based carbon credits within the reporting year? 100
C11. Environmental performance -
Biodiversity
101
(11.2) What actions has your organization taken in the reporting year to progress your biodiversity-related commitments? 101
(11.3) Does your organization use biodiversity indicators to monitor performance across its activities?
101
(11.4) Does your organization have activities located in or near to areas important for biodiversity in the reporting year? 101
(11.4.1) Provide details of your organization's activities in the reporting year located in or near to areas important for biodiversity.
104
C13. Further information & sign off 106
(13.1) Indicate if any environmental information included in your CDP response (not already reported in 7.9.1/2/3, 8.9.1/2/3/4, and 9.3.2) is verified and/or assured by a third
party?
106
(13.1.1) Which data points within your CDP response are verified and/or assured by a third party, and which standards were used? 106
(13.2) Use this field to provide any additional information or context that you feel is relevant to your organization's response. Please note that this field is optional and is not
scored
110
(13.3) Provide the following information for the person that has signed off (approved) your CDP response.
111

C1. Introduction

(1.1) In which language are you submitting your response?

Select from:

☑ English

(1.2) Select the currency used for all financial information disclosed throughout your response.

Select from:

☑ TRY

(1.3) Provide an overview and introduction to your organization.

(1.3.2) Organization type

Select from:

☑ Publicly traded organization

(1.3.3) Description of organization

For over half a century, Sinpaş GYO A.Ş. / Sinpaş REIC has laid the foundations of modern Turkey through its distinguished projects, while assuming a leading role in the real estate sector. Embedded in every Sinpaş development are intelligence, design excellence, innovation, dynamism, originality, and dedicated efforts that add value to life. Sinpaş was the first in Turkey to highlight landscaping as an integral part of housing, recognizing that lifestyle and socialization extend beyond the walls of a home. Likewise, Sinpaş pioneered the prominent use of water features—lakes, pools, and ponds—in its projects. In housing marketing, the Company also led the sector by offering not only bank financing opportunities but also flexible in-house payment models, making home ownership more accessible to broader audiences. In summary, with its innovative vision, distinctive designs, and customer-oriented financing solutions, Sinpaş GYO A.Ş. / Sinpaş REIC has maintained a pioneering and leading position in Turkey's real estate sector for more than 50 years. All of its original projects have earned the brand numerous awards over the decades, strengthened Sinpaş's brand and financial identity, and enabled more than 80,000 people to become homeowners to date. Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş. (Sinpaş REIC) operates under the framework of the Capital Markets Law and in compliance with the regulations of the Capital Markets Board of Turkey as a real estate investment company. Within this scope, Sinpaş REIC is authorized to invest in real estate, real estate projects, real estate-based rights, and capital market instruments. The Company's primary objective is to invest in real estate and real estate-related projects with high return potential, generating rental income and capital gains from the acquisition and disposal of properties in its portfolio. Profits derived from property sales may either be distributed to shareholders as dividends at year-end or reinvested into new projects, thereby contributing to the Company's growth strategy. As the flagship company of Sinpaş Group, Sinpaş GYO A.Ş. / Sinpaş REIC shares have been traded on Borsa İstanbul (BIST) under the ticker symbol SNGYO since June 22, 2007.

[Fixed row]

(1.4) State the end date of the year for which you are reporting data. For emissions data, indicate whether you will be providing emissions data for past reporting years.

End date of reporting year Alignment of this reporting period
with your financial reporting period
Indicate if you are providing
emissions data for past reporting
years
12/30/2024 Select from:

Yes
Select from:

No

[Fixed row]

(1.4.1) What is your organization's annual revenue for the reporting period?

13366704258

(1.5) Provide details on your reporting boundary.

Is your reporting boundary for your CDP disclosure the same as that used in
your financial statements?
Select from:

Yes

[Fixed row]

(1.6) Does your organization have an ISIN code or another unique identifier (e.g., Ticker, CUSIP, etc.)?

ISIN code - bond

(1.6.1) Does your organization use this unique identifier?

Select from:

☑ No

ISIN code - equity

(1.6.1) Does your organization use this unique identifier?

Select from:

☑ No

CUSIP number

(1.6.1) Does your organization use this unique identifier?

Select from:

☑ No

Ticker symbol

(1.6.1) Does your organization use this unique identifier?

Select from:

☑ Yes

(1.6.2) Provide your unique identifier

SNGYO

SEDOL code

(1.6.1) Does your organization use this unique identifier?

Select from:

☑ No

LEI number

(1.6.1) Does your organization use this unique identifier?

Select from:

☑ Yes

(1.6.2) Provide your unique identifier

789000HBCWJQPLQ3HT14

D-U-N-S number

(1.6.1) Does your organization use this unique identifier?

Select from:

☑ No

Other unique identifier

(1.6.1) Does your organization use this unique identifier?

Select from:

☑ No

[Add row]

(1.7) Select the countries/areas in which you operate.

Select all that apply

☑ Turkey

(1.15) Which real estate and/or construction activities does your organization engage in?

Select all that apply

☑ New construction or major renovation of buildings

(1.24) Has your organization mapped its value chain?

(1.24.1) Value chain mapped

Select from:

☑ Yes, we have mapped or are currently in the process of mapping our value chain

(1.24.2) Value chain stages covered in mapping

Select all that apply

  • ☑ Upstream value chain
  • ☑ Downstream value chain

(1.24.3) Highest supplier tier mapped

Select from:

☑ Tier 1 suppliers

(1.24.4) Highest supplier tier known but not mapped

Select from:

☑ Tier 2 suppliers

(1.24.7) Description of mapping process and coverage

The Tier 2 stakeholders of Sinpaş GYO A.Ş. / Sinpaş REIC consist of actors that, although not directly engaged with, hold critical importance in terms of operational sustainability and reporting. In this context, material and equipment manufacturers, subcontractors and sub-consultants, financial and legal service providers, energy and infrastructure suppliers, facility management services, as well as service providers within the communication and marketing ecosystem fall under the Tier 2 category. However, the mapping of Tier 2 stakeholders has not yet been completed due to data and traceability limitations. [Fixed row]

(1.24.1) Have you mapped where in your direct operations or elsewhere in your value chain plastics are produced, commercialized, used, and/or disposed of?

Plastics mapping Primary reason for not mapping plastics in your value
chain
Explain why your organization has not
mapped plastics in your value chain
Select from:

No, and we do not plan to
within the next two years
Select from:

Lack of internal resources, capabilities, or
expertise (e.g., due to organization size)
Sinpaş GYO does not map plastics due to
lack of data and resources.

[Fixed row]

C2. Identification, assessment, and management of dependencies, impacts, risks, and opportunities

(2.1) How does your organization define short-, medium-, and long-term time horizons in relation to the identification, assessment, and management of your environmental dependencies, impacts, risks, and opportunities?

Short-term

(2.1.1) From (years)
0
(2.1.3) To (years)

1

(2.1.4) How this time horizon is linked to strategic and/or financial planning

The Company aligns its climate-related risk and opportunity assessments with its strategic and financial planning by embedding the defined time horizons directly into decision-making processes. Short-term risks (0–1 year) are integrated into annual budgets and operational targets, medium-term risks (1–3 years) inform investment planning and portfolio optimization, while long-term risks (3+ years) shape the Company's overall growth strategy and capital allocation framework. By classifying each risk and opportunity within these horizons, the Company ensures that strategic priorities, financial resources, and risk management practices are consistently aligned with climate-related considerations.

Medium-term

(2.1.1) From (years)

1

(2.1.3) To (years)

(2.1.4) How this time horizon is linked to strategic and/or financial planning

The Company aligns its climate-related risk and opportunity assessments with its strategic and financial planning by embedding the defined time horizons directly into decision-making processes. Short-term risks (0–1 year) are integrated into annual budgets and operational targets, medium-term risks (1–3 years) inform investment planning and portfolio optimization, while long-term risks (3+ years) shape the Company's overall growth strategy and capital allocation framework. By classifying each risk and opportunity within these horizons, the Company ensures that strategic priorities, financial resources, and risk management practices are consistently aligned with climate-related considerations.

Long-term

(2.1.1) From (years)

3

(2.1.2) Is your long-term time horizon open ended?

Select from:

☑ Yes

(2.1.4) How this time horizon is linked to strategic and/or financial planning

The Company aligns its climate-related risk and opportunity assessments with its strategic and financial planning by embedding the defined time horizons directly into decision-making processes. Short-term risks (0–1 year) are integrated into annual budgets and operational targets, medium-term risks (1–3 years) inform investment planning and portfolio optimization, while long-term risks (3+ years) shape the Company's overall growth strategy and capital allocation framework. By classifying each risk and opportunity within these horizons, the Company ensures that strategic priorities, financial resources, and risk management practices are consistently aligned with climate-related considerations.

[Fixed row]

(2.2) Does your organization have a process for identifying, assessing, and managing environmental dependencies and/or impacts?

Process in place Primary reason for not
evaluating dependencies
and/or impacts
Explain why you do not evaluate dependencies and/or impacts and describe
any plans to do so in the future
Select from:

No, but we plan to within
the next two years
Select from:

No standardized
procedure
Sinpas GYO is still building the framework and methodology of impact on the
enviromental. In next two years, it will be finalized.

[Fixed row]

(2.2.1) Does your organization have a process for identifying, assessing, and managing environmental risks and/or opportunities?

Process in place Risks and/or opportunities evaluated in this
process
Select from:

Yes
Select from:

Both risks and opportunities

[Fixed row]

(2.2.2) Provide details of your organization's process for identifying, assessing, and managing environmental dependencies, impacts, risks, and/or opportunities.

Row 1

(2.2.2.1) Environmental issue

Select all that apply

☑ Climate change

(2.2.2.2) Indicate which of dependencies, impacts, risks, and opportunities are covered by the process for this environmental issue

Select all that apply

☑ Risks

☑ Opportunities

(2.2.2.3) Value chain stages covered

Select all that apply

☑ Direct operations

☑ Upstream value chain

☑ Downstream value chain

(2.2.2.4) Coverage

Select from:

☑ Partial

(2.2.2.7) Type of assessment

Select from:

☑ Qualitative and quantitative

(2.2.2.8) Frequency of assessment

Select from:

☑ Annually

(2.2.2.9) Time horizons covered

Select all that apply

☑ Short-term

☑ Medium-term

☑ Long-term

(2.2.2.10) Integration of risk management process

Select from:

☑ Integrated into multi-disciplinary organization-wide risk management process

(2.2.2.11) Location-specificity used

Select all that apply

☑ Site-specific

☑ Local

(2.2.2.12) Tools and methods used

Commercially/publicly available tools

☑ Other commercially/publicly available tools, please specify :WRI Water Risk Atlas, Climate impact explorer, Climate Change Knowledge Portal

International methodologies and standards

☑ IPCC Climate Change Projections

Databases

☑ Regional government databases

Other

☑ External consultants

☑ Materiality assessment

☑ Partner and stakeholder consultation/analysis

☑ Scenario analysis

(2.2.2.13) Risk types and criteria considered

Acute physical

☑ Flood (coastal, fluvial, pluvial, ground water)

Chronic physical ☑ Changing temperature (air, freshwater, marine water)

Policy

☑ Carbon pricing mechanisms

Market ☑ Availability and/or increased cost of raw materials

Liability ☑ Non-compliance with regulations

(2.2.2.14) Partners and stakeholders considered

Select all that apply

☑ Customers

☑ Employees

☑ Investors

☑ Regulators

☑ Suppliers

(2.2.2.15) Has this process changed since the previous reporting year?

Select from:

☑ No

(2.2.2.16) Further details of process

Due to the recent publication of TSRS 1 and TSRS 2 in Turkey, Sinpas GYO's analysis process for environmental dependencies, impacts, risks, and/or opportunities was established in 2024. However, over the next two years, the approach to these impacts will be updated in line with Sinpas GYO's strategic plans. [Add row]

(2.2.7) Are the interconnections between environmental dependencies, impacts, risks and/or opportunities assessed?

(2.2.7.1) Interconnections between environmental dependencies, impacts, risks and/or opportunities assessed

Select from:

☑ No

(2.2.7.3) Primary reason for not assessing interconnections between environmental dependencies, impacts, risks and/or opportunities

Select from:

☑ Lack of internal resources, capabilities, or expertise (e.g., due to organization size)

(2.2.7.4) Explain why you do not assess the interconnections between environmental dependencies, impacts, risks and/or opportunities

In this reporting year, Sinpas GYO publiched its first TSRS aligned sustainability report. In this report, main objective is that how to deal with climate change in terms governance, strategy, risk management and metric and targets. However, it does not obligate to assess the enviromental dependencies and impacts. [Fixed row]

(2.3) Have you identified priority locations across your value chain?

Identification of priority locations Primary reason for not
identifying priority
locations
Explain why you do not identify priority locations
Select from: Select from: Due to limited data resource, priority locations could not be identified. In
next two years, required procedures will be established.
Identification of priority locations Primary reason for not
identifying priority
locations
Explain why you do not identify priority locations

No, and we do not plan to within
the next two years

No standardized
procedure

[Fixed row]

(2.4) How does your organization define substantive effects on your organization?

Risks

(2.4.1) Type of definition

Select all that apply

☑ Qualitative

☑ Quantitative

(2.4.2) Indicator used to define substantive effect

Select from:

☑ Other, please specify :Profit Before Tax

(2.4.3) Change to indicator

Select from:

☑ Absolute increase

(2.4.5) Absolute increase/ decrease figure

574220779.35

(2.4.6) Metrics considered in definition

Select all that apply

  • ☑ Frequency of effect occurring
  • ☑ Time horizon over which the effect occurs
  • ☑ Likelihood of effect occurring

(2.4.7) Application of definition

Sinpaş GYO applies a financial materiality approach when assessing climate-related risks and opportunities. In line with this approach, and based on the 2024 consolidated financial statements, the financial materiality threshold has been established at 5% of the Company's profit before tax (PBT). This threshold serves as a benchmark in the quantitative analysis of climate-related financial impacts and guides the Company in determining which risks and opportunities warrant prioritization and integration into strategic and financial decision-making.

Opportunities

(2.4.1) Type of definition

Select all that apply

☑ Qualitative

☑ Quantitative

(2.4.2) Indicator used to define substantive effect

Select from:

☑ Other, please specify :Profit Before Tax

(2.4.3) Change to indicator

Select from:

☑ Absolute decrease

(2.4.5) Absolute increase/ decrease figure

574220779.35

(2.4.6) Metrics considered in definition

Select all that apply

  • ☑ Frequency of effect occurring
  • ☑ Time horizon over which the effect occurs
  • ☑ Likelihood of effect occurring

(2.4.7) Application of definition

Sinpaş GYO applies a financial materiality approach when assessing climate-related risks and opportunities. In line with this approach, and based on the 2024 consolidated financial statements, the financial materiality threshold has been established at 5% of the Company's profit before tax (PBT). This threshold serves as a benchmark in the quantitative analysis of climate-related financial impacts and guides the Company in determining which risks and opportunities warrant prioritization and integration into strategic and financial decision-making. [Add row]

C3. Disclosure of risks and opportunities

(3.1) Have you identified any environmental risks which have had a substantive effect on your organization in the reporting year, or are anticipated to have a substantive effect on your organization in the future?

Climate change

(3.1.1) Environmental risks identified

Select from:

☑ Yes, both in direct operations and upstream/downstream value chain

Plastics

(3.1.1) Environmental risks identified

Select from:

☑ No

(3.1.2) Primary reason why your organization does not consider itself to have environmental risks in your direct operations and/or upstream/downstream value chain

Select from:

☑ Environmental risks exist, but none with the potential to have a substantive effect on our organization

(3.1.3) Please explain

Due to the sector coverage, plastics do not represents a material risk for Sinpas GYO. [Fixed row]

(3.1.1) Provide details of the environmental risks identified which have had a substantive effect on your organization in the reporting year, or are anticipated to have a substantive effect on your organization in the future.

Climate change

(3.1.1.1) Risk identifier

Select from:

☑ Risk1

(3.1.1.3) Risk types and primary environmental risk driver

Acute physical

☑ Flooding (coastal, fluvial, pluvial, groundwater)

(3.1.1.4) Value chain stage where the risk occurs

Select from:

☑ Downstream value chain

(3.1.1.6) Country/area where the risk occurs

Select all that apply

☑ Turkey

(3.1.1.9) Organization-specific description of risk

According to the WRI Aqueduct Water Risk Atlas, 22.86% of Sinpaş REIT's projects are in areas assessed as having a "High" River Flood Risk Stress level. The presence of Sinpaş REIT projects in regions with high river flood risk may lead to increased insurance premiums in these areas. This, in turn, could raise insurance costs for both the Company and homebuyers, thereby increasing the total property cost. In addition, potential infrastructure damage caused by flood events could increase maintenance and repair expenses, adversely affecting Sinpaş REIT's cash flow. Flood risk, under the RCP 2.6 scenario, shows an increase in 2030 (medium term) and 2035 (long term) compared to 2025. Under the RCP 8.5 scenario, it shows an increase in 2030 and a decrease in 2035 compared to 2025.

(3.1.1.11) Primary financial effect of the risk

Select from:

☑ Decreased asset value or asset useful life leading to write-offs, asset impairment or early retirement of existing assets

(3.1.1.12) Time horizon over which the risk is anticipated to have a substantive effect on the organization

Select all that apply

☑ Short-term

☑ Medium-term

☑ Long-term

(3.1.1.13) Likelihood of the risk having an effect within the anticipated time horizon

Select from:

☑ More likely than not

(3.1.1.14) Magnitude

Select from:

☑ Medium

(3.1.1.16) Anticipated effect of the risk on the financial position, financial performance and cash flows of the organization in the selected future time horizons

According to the WRI Aqueduct Water Risk Atlas, 22.86% of Sinpaş GYO's projects are in areas assessed as having a "High" River Flood Risk Stress level. The presence of Sinpaş GYO projects in regions with high river flood risk may lead to increased insurance premiums in these areas. This, in turn, could raise insurance costs for both the Company and homebuyers, thereby increasing the total property cost. In addition, potential infrastructure damage caused by flood events could increase maintenance and repair expenses, adversely affecting Sinpaş GYO's cash flow. Flood risk, under the RCP 2.6 scenario, shows an increase in 2030 (medium term) and 2035 (long term) compared to 2025. Under the RCP 8.5 scenario, it shows an increase in 2030 and a decrease in 2035 compared to 2025.

(3.1.1.17) Are you able to quantify the financial effect of the risk?

Select from:

☑ No

(3.1.1.26) Primary response to risk

Infrastructure, technology and spending 

☑ Improve maintenance of infrastructure

(3.1.1.28) Explanation of cost calculation

The cost of response to risk could not be calculated because data is not available.

(3.1.1.29) Description of response

During the project's infrastructure phase, hydraulic and flow rate calculations were conducted based on the annual rainfall data for the region. Infrastructure was built using pipes sized to meet these calculations, and approval was obtained from the relevant authority for project compliance. Rainwater drainage systems and sewer infrastructure within the project scope are regularly inspected, and their capacity is increased through cleaning. Infrastructure lines belonging to the authorities are regularly checked, and potential blockages are addressed. In areas where floodwaters are likely to enter the project site, embankments have been constructed to redirect the water to its natural course. Emergency pumping systems have been installed at the points where rainwater lines exit the project or at the lowest elevation points of the site.

Climate change

(3.1.1.1) Risk identifier

Select from:

☑ Risk2

(3.1.1.3) Risk types and primary environmental risk driver

Market

☑ Lack of availability and/or increased cost of recycled or renewable content

(3.1.1.4) Value chain stage where the risk occurs

Select from:

☑ Downstream value chain

(3.1.1.6) Country/area where the risk occurs

Select all that apply

(3.1.1.9) Organization-specific description of risk

As a leading real estate investment company, Sinpaş REIC has the possibility of being exposed to transition risks arising from the shift from fossil fuels to low-carbon energy sources, sometimes directly and sometimes indirectly. The energy transition may lead to price volatility in energy and commodity markets and disruptions in supply chains, thereby creating the possibility of cost pressures on construction and project development activities. While the increase in the costs of energy-intensive raw materials such as steel, cement, and aluminum directly affects Sinpaş REIC, sector-wide fluctuations, rising insurance and compliance costs, and delays caused by supply chains may create indirect impacts. This situation may lead to uncertainties in operational planning, pressures on long-term investment strategies, and additional risks on financial performance. For Sinpaş REIC, these risks are addressed by integrating measures such as energy efficiency, the use of sustainable materials, or the adoption of renewable energy into projects and portfolio management, thereby enhancing resilience against both direct and indirect climate-related risks.

(3.1.1.11) Primary financial effect of the risk

Select from:

☑ Increased direct costs

(3.1.1.12) Time horizon over which the risk is anticipated to have a substantive effect on the organization

Select all that apply

☑ Short-term

  • ☑ Medium-term
  • ☑ Long-term

(3.1.1.13) Likelihood of the risk having an effect within the anticipated time horizon

Select from:

☑ Very likely

(3.1.1.14) Magnitude

Select from:

☑ Medium

(3.1.1.16) Anticipated effect of the risk on the financial position, financial performance and cash flows of the organization in the selected future time horizons

The costs incurred by companies operating in the energy sector as part of the transition to a low-carboneconomy may be reflected in the prices of emission-intensive products such as electricity and fossil fuels, significantly increasing costs. The financial impact of this risk is expected to rise in the medium and long term compared to the short term.

(3.1.1.17) Are you able to quantify the financial effect of the risk?

Select from:

☑ No

(3.1.1.26) Primary response to risk

Infrastructure, technology and spending 

☑ Establish and improve end-of-life infrastructure and/or technology

(3.1.1.28) Explanation of cost calculation

The cost of response to risk could not be calculated because data is not available.

(3.1.1.29) Description of response

To address the risk of potential increases in energy costs, Sinpaş GYO has initiated the implementation of renewable energy system integrations in its future residential projects. In this context, solar panels with an installed capacity of 82 kWp are being installed in the Halkalı 33 Parcel project, and panels with an installed capacity of 172 kW are being installed in the Metrolife Premium project.

Climate change

(3.1.1.1) Risk identifier

Select from:

☑ Risk3

(3.1.1.3) Risk types and primary environmental risk driver

Liability ☑ Non-compliance with legislation

(3.1.1.4) Value chain stage where the risk occurs

Select from:

☑ Direct operations

(3.1.1.6) Country/area where the risk occurs

Select all that apply

☑ Turkey

(3.1.1.9) Organization-specific description of risk

Disclosure requirements related to climate change are becoming increasingly important in line with rising societal and regulatory awareness. Failure to meet these expectations and regulatory requirements—due to inadequate internal control mechanisms or other reasons—or the disclosure of incorrect or misleading information may result in the Company facing administrative fines or sanctions for non-compliance with legal regulations, as well as increased reputational damage. The financial impact of this risk is expected to rise in the medium and long term compared to the short term.

(3.1.1.11) Primary financial effect of the risk

Select from:

☑ Fines, penalties or enforcement orders

(3.1.1.12) Time horizon over which the risk is anticipated to have a substantive effect on the organization

Select all that apply

☑ Short-term

☑ Medium-term

☑ Long-term

(3.1.1.13) Likelihood of the risk having an effect within the anticipated time horizon

Select from:

(3.1.1.14) Magnitude

Select from:

☑ High

(3.1.1.16) Anticipated effect of the risk on the financial position, financial performance and cash flows of the organization in the selected future time horizons

Disclosure requirements related to climate change are becoming increasingly important in line with rising societal and regulatory awareness. Failure to meet these expectations and regulatory requirements—due to inadequate internal control mechanisms or other reasons—or the disclosure of incorrect or misleading information may result in the Company facing administrative fines or sanctions for noncompliance with legal regulations, as well as increased reputational damage. The financial impact of this risk is expected to rise in the medium and long term compared to the short term.

(3.1.1.17) Are you able to quantify the financial effect of the risk?

Select from:

☑ No

(3.1.1.26) Primary response to risk

Policies and plans 

☑ Improve alignment of public policy influencing activity with environmental commitments

(3.1.1.28) Explanation of cost calculation

Sinpas GYO took a consultancy services for TSRS reporting in this reporting year.

(3.1.1.29) Description of response

In line with its obligations under the Türkiye Sustainability Reporting Standards (TSRS), Sinpaş GYO / Sinpaş REIC prepared its first TSRS-compliant sustainability report in 2024 and publicly released it on August 13, 2025. [Add row]

(3.1.2) Provide the amount and proportion of your financial metrics from the reporting year that are vulnerable to the substantive effects of environmental risks.

Climate change

(3.1.2.1) Financial metric

Select from:

☑ Assets

(3.1.2.4) Amount of financial metric vulnerable to physical risks for this environmental issue (unit currency as selected in 1.2)

606101409.91

(3.1.2.5) % of total financial metric vulnerable to physical risks for this environmental issue

Select from:

☑ Less than 1%

(3.1.2.7) Explanation of financial figures

The reported financial figures represent Sinpaş GYO / Sinpaş REIC's fixed assets potentially exposed to flood risk, primarily in relation to infrastructure repair and maintenance costs. These costs are estimated to account for less than 1% of the total fixed asset value, suggesting a limited level of financial vulnerability in the short and medium term.

[Add row]

(3.5) Are any of your operations or activities regulated by a carbon pricing system (i.e. ETS, Cap & Trade or Carbon Tax)?

Select from:

☑ No, but we anticipate being regulated in the next three years

(3.5.4) What is your strategy for complying with the systems you are regulated by or anticipate being regulated by?

During this reporting year, Sinpas GYO published its sustainability report in line with the TSRS. In this report, they analyzed climate change in terms of governance, strategy, risk management, and metrics and targets. Sinpas GYO, which takes measures and makes plans related to climate change, is aware of the Turkish Climate Law. The law focuses primarily on the TR-ETS (Emissions Trading System). The reason for developing the TR-ETS is to combat the CBAM (carbon border adjustment mechanism). In the coming years, Sinpas GYO plans to take some concrete measures regarding carbon regulations.

(3.6) Have you identified any environmental opportunities which have had a substantive effect on your organization in the reporting year, or are anticipated to have a substantive effect on your organization in the future?

Environmental opportunities identified
Climate change Select from:

Yes, we have identified opportunities, and some/all are being realized

[Fixed row]

(3.6.1) Provide details of the environmental opportunities identified which have had a substantive effect on your organization in the reporting year, or are anticipated to have a substantive effect on your organization in the future.

Climate change

(3.6.1.1) Opportunity identifier

Select from:

☑ Opp1

(3.6.1.3) Opportunity type and primary environmental opportunity driver

Capital flow and financing

☑ Access to sustainability linked loans

(3.6.1.4) Value chain stage where the opportunity occurs

Select from:

☑ Direct operations

(3.6.1.5) Country/area where the opportunity occurs

Select all that apply

☑ Turkey

(3.6.1.8) Organization specific description

In a low-emission scenario, the prioritization of environmental sustainability and lowcarbon investments may lead to a significant increase in climate and sustainability financing sources. Sustainable building practices may become increasingly important for climate change adaptation and sustainable cities. In this case, sustainable financing sources could be utilized for Sinpaş GYO's current and future projects. The financial impact of this opportunity is expected to rise in the medium and long term compared to the short term.

(3.6.1.9) Primary financial effect of the opportunity

Select from:

☑ Increased access to capital

(3.6.1.10) Time horizon over which the opportunity is anticipated to have a substantive effect on the organization

Select all that apply

☑ Short-term

☑ Medium-term

☑ Long-term

(3.6.1.11) Likelihood of the opportunity having an effect within the anticipated time horizon

Select from:

☑ More likely than not (50–100%)

(3.6.1.12) Magnitude

☑ Medium-high

(3.6.1.14) Anticipated effect of the opportunity on the financial position, financial performance and cash flows of the organization in the selected future time horizons

Since 2024, Sinpaş GYO has been reporting its sustainability data through the London Stock Exchange Group (LSEG) ESG Contribution Tool platform, where companies listed on Borsa İstanbul disclose their sustainability performance. By being included in the BIST Sustainability Index, Sinpaş GYO aims to increase its access to sustainability-linked financing instruments for its future residential projects.

(3.6.1.15) Are you able to quantify the financial effects of the opportunity?

Select from:

☑ No

(3.6.1.25) Explanation of cost calculation

In this reporting year, Sinpaş REIC did not conduct a cost analysis related to the realization of this opportunity in its TSRS-aligned sustainability report.

(3.6.1.26) Strategy to realize opportunity

Sustainability-linked financing opportunities encourage the integration of environmental criteria from the design stage of new projects, making this a determining factor in project development and investment planning processes. To meet sustainability criteria that can provide financial advantages, Sinpaş GYO is developing strategies to enhance its sustainability performance.

[Add row]

C4. Governance

(4.1) Does your organization have a board of directors or an equivalent governing body?

(4.1.1) Board of directors or equivalent governing body

Select from:

☑ Yes

(4.1.2) Frequency with which the board or equivalent meets

Select from:

☑ Half-yearly

(4.1.3) Types of directors your board or equivalent is comprised of

Select all that apply

  • ☑ Executive directors or equivalent
  • ☑ Non-executive directors or equivalent
  • ☑ Independent non-executive directors or equivalent

(4.1.4) Board diversity and inclusion policy

Select from:

☑ Yes, and it is publicly available

(4.1.5) Briefly describe what the policy covers

Sinpaş REIC's Human Rights and Human Resources Policy emphasizes respect for human rights, employee health and safety, fair recruitment, and equal opportunities. The policy also highlights diversity and inclusion by fostering a culture of equality, valuing diverse backgrounds, perspectives, and experiences, and maintaining a workplace free from discrimination. In addition, Sinpaş REIC has a dedicated Sustainability Policy, through which it systematically manages its commitments across environmental, social, and governance (ESG) dimensions. Furthermore, the Company underscores its adherence to the highest standards of governance through its Ethics Policy, ensuring that transparency, accountability, and business integrity remain integral to all of its operations.

(4.1.6) Attach the policy (optional)

SiNPASGYO-iNSAN-HAKLARI-iK-POLiTiKASI (5).pdf [Fixed row]

(4.1.1) Is there board-level oversight of environmental issues within your organization?

Board-level oversight of this
environmental issue
Primary reason for no
board-level oversight of
this environmental issue
Explain why your organization does not have board-level oversight of
this environmental issue
Climate change Select from:

Yes
Select from: Rich text input [must be under 2500 characters]
Biodiversity Select from:

No, but we plan to within
the next two years
Select from:

No standardized
procedure
Sinpaş GYO is planning to establish a biodiversity policy in next two years
in order to protect natural ecosystem in their operation zone.

[Fixed row]

(4.1.2) Identify the positions (do not include any names) of the individuals or committees on the board with accountability for environmental issues and provide details of the board's oversight of environmental issues.

Climate change

(4.1.2.1) Positions of individuals or committees with accountability for this environmental issue

Select all that apply

☑ Board chair

☑ Chief Financial Officer (CFO)

☑ Board-level committee

(4.1.2.2) Positions' accountability for this environmental issue is outlined in policies applicable to the board

Select from:

☑ Yes

(4.1.2.3) Policies which outline the positions' accountability for this environmental issue

Select all that apply

☑ Board Terms of Reference

(4.1.2.4) Frequency with which this environmental issue is a scheduled agenda item

Select from:

☑ Scheduled agenda item in every board meeting (standing agenda item)

(4.1.2.5) Governance mechanisms into which this environmental issue is integrated

Select all that apply

  • ☑ Overseeing and guiding scenario analysis
  • ☑ Monitoring progress towards corporate targets
  • ☑ Approving corporate policies and/or commitments
  • ☑ Overseeing and guiding public policy engagement
  • ☑ Overseeing and guiding major capital expenditures
  • ☑ Reviewing and guiding the assessment process for dependencies, impacts, risks, and opportunities

(4.1.2.7) Please explain

In Sinpas GYO and all its subsidiaries, the highest level of responsibility for managing sustainability- and climate-related matters lies with the Board of Directors. The Board approves the core policies, targets, and roadmaps in this area to ensure that the Company's sustainability and climate-related strategies are developed and implemented in alignment with its overall business strategies. The Board is also responsible for establishing the risk management approaches and standards to be applied across the Company, defining risk policies, and updating these policies as needed in parallel with changes in operating conditions. In addition, the Board oversees the establishment and sustainable operation of an effective risk management structure, the periodic monitoring of risk levels, and the maintenance of risk limits within the set thresholds. In addition, within the framework of the established risk limits, the evaluation of emerging situations, the implementation of corrective or preventive measures when necessary, the execution of strategies aimed at mitigating risks, and the conduct of these processes within a holistic corporate risk management framework fall under the Board of Directors' overarching oversight and guidance responsibilities. The Board of Directors holds the ultimate oversight and guidance responsibility for the regular monitoring of sustainability and climate performance, the evaluation of performance indicators, and the identification of necessary improvement areas based on these indicators. In this context, while supporting senior management in implementing sustainability- and climate-related

practices, the Board ensures the maintenance of a transparent and accountable governance approach that takes stakeholder expectations into account In addition, within Sinpaş REIC, two Board-affiliated committees play a critical role in overseeing sustainability and climate-related matters: the Sustainability Committee and the Climate and Risk Committee. The Sustainability Committee coordinates the implementation of the Company's sustainability strategies, monitors performance on a regular basis, and ensures that reporting is aligned with stakeholder expectations. The Climate and Risk Committee identifies physical and transition risks associated with climate change, evaluates their financial impacts, and ensures that appropriate mitigation and adaptation strategies are implemented within the Company's corporate risk management framework. Both committees report directly to the Board of Directors, thereby ensuring transparency, accountability, and effectiveness in decision-making processes related to sustainability and climate governance. [Fixed row]

(4.2) Does your organization's board have competency on environmental issues?

Climate change

(4.2.1) Board-level competency on this environmental issue

Select from:

☑ No, but we plan to within the next two years

(4.2.4) Primary reason for no board-level competency on this environmental issue

Select from:

☑ Lack of internal resources, capabilities, or expertise (e.g., due to organization size)

(4.2.5) Explain why your organization does not have a board with competence on this environmental issue

Currently, the Board of Directors does not yet have formalized environmental competency; however, plans are in place to strengthen this capacity within the next two years. To support the Board in the interim, Sinpaş REIC has established a Sustainability Committee and a Climate and Risk Committee, both composed of individuals with expertise in sustainability and climate-related issues. These Committees, coordinated by the Investor Relations and Sustainability Manager, provide the Board with regular updates and recommendations on climate risks, opportunities, and regulatory developments. The Chairman of the Board, Dr. Avni Çelik, with more than 50 years of experience and expertise in civil engineering, demonstrates a strong sensitivity to environmental matters and actively guides project teams with this awareness. His leadership ensures that environmental risks are mitigated and sustainable practices are integrated into project development. By doing so, he contributes both to the management of climate-related risks and to the capture of emerging opportunities, reinforcing Sinpaş REIC's governance approach that places environmental sustainability at the core of all project and investment decisions. Within Sinpaş REIC, the Sustainability Committee and the Climate and Risk Committee ensure that sustainability- and climate-related matters are systematically addressed at the corporate level and transparently reported to the Board of Directors. These Committees play a critical role in identifying risks and opportunities, monitoring performance, and highlighting areas for improvement, thereby supporting the Board in strengthening decision-making processes and ensuring robust governance of sustainability and climate issues.

(4.3) Is there management-level responsibility for environmental issues within your organization?

Management-level responsibility for
this environmental issue
Primary reason for no
management-level responsibility
for environmental issues
Explain why your organization does not have
management-level responsibility for environmental
issues
Climate change Select from:

Yes
Select from: Rich text input [must be under 2500 characters]
Biodiversity Select from:

No, but we plan to within the
next two years
Select from:

Judged to be unimportant or
not relevant
Due to sector coverage, plastics is not a very crucial
problem for Sinpas GYO.

[Fixed row]

(4.3.1) Provide the highest senior management-level positions or committees with responsibility for environmental issues (do not include the names of individuals).

Climate change

(4.3.1.1) Position of individual or committee with responsibility

Committee

☑ Sustainability committee

(4.3.1.2) Environmental responsibilities of this position

Dependencies, impacts, risks and opportunities

  • ☑ Assessing environmental dependencies, impacts, risks, and opportunities
  • ☑ Assessing future trends in environmental dependencies, impacts, risks, and opportunities

☑ Managing environmental dependencies, impacts, risks, and opportunities

Engagement

  • ☑ Managing public policy engagement related to environmental issues
  • ☑ Managing supplier compliance with environmental requirements

Strategy and financial planning

  • ☑ Conducting environmental scenario analysis
  • ☑ Managing environmental reporting, audit, and verification processes

(4.3.1.4) Reporting line

Select from:

☑ Reports to the board directly

(4.3.1.5) Frequency of reporting to the board on environmental issues

Select from:

☑ Half-yearly

(4.3.1.6) Please explain

At Sinpaş REIC, sustainability and climate-related matters are overseen by the Sustainability Committee, which plays a central role in embedding sustainability into the Company's governance and operations. The Committee is chaired by the Vice Chairperson of the Board of Directors and coordinated by the Investor Relations and Sustainability Manager. It is composed of six members, four of whom are members of the Board of Directors, and convenes at least twice a year at predetermined intervals. Committee members are selected from individuals with expertise in sustainability to ensure informed and effective decision-making. The current members are: Ahmet Çelik, Vice Chairperson of the Board of Directors; Mahmut Sefa Çelik, Board Member of Sinpaş REIC's subsidiary Kızılbük REIC and General Manager of Kızılbük REIC A.Ş.; Seba Gacemer, Board Member and General Manager; Dursun Yaşar Çamurali, Board Member, Group CFO, and Group President Responsible for Finance; Kenan Evren Karakaya, Deputy Group President Responsible for Finance; Dr. A. Berrak Köten, Investor Relations and Sustainability Manager. The duties, roles, and responsibilities of the Committee are defined in the Sinpaş REIC Sustainability Committee Duties, Working Principles, and Procedures document. Its primary responsibilities include setting the Company's sustainability and climate policies; identifying, evaluating, and managing sustainability- and climate-related risks and opportunities; and overseeing performance monitoring and reporting. The Committee also ensures that sustainability is integrated across all business areas in line with the United Nations Sustainable Development Goals (SDGs) and Environmental, Social, and Governance (ESG) principles. In addition, the Committee is responsible for setting long-term sustainability and climate strategies and targets, coordinating implementation across departments, monitoring progress, and regularly reporting outcomes to the Board of Directors.

Climate change

(4.3.1.1) Position of individual or committee with responsibility

Committee

☑ Risk committee

(4.3.1.2) Environmental responsibilities of this position

Dependencies, impacts, risks and opportunities

☑ Assessing environmental dependencies, impacts, risks, and opportunities

☑ Assessing future trends in environmental dependencies, impacts, risks, and opportunities

☑ Managing environmental dependencies, impacts, risks, and opportunities

(4.3.1.4) Reporting line

Select from:

☑ Reports to the board directly

(4.3.1.5) Frequency of reporting to the board on environmental issues

Select from:

☑ More frequently than quarterly

(4.3.1.6) Please explain

The Early Detection of Risk Committee is responsible for the early identification of risks—including sustainability- and climate-related risks—that may endanger the Company's existence, development, or continuity; the formulation of action plans; and the management of such risks. It is also tasked with assessing the risks and opportunities identified by the risk management and internal control systems and reporting them to the Board of Directors. The Committee is chaired by Independent Board Member Mr. Bekir Uzun, and its member is Independent Board Member Dr. Osman Nuri İnceöz. The Early Detection of Risk Committee convenes at least six times a year, with meetings held at intervals of no less than two months. The purpose, structure, duties, and responsibilities of the Early Detection of Risk Committee are explicitly set out in the Sinpaş GYO Early Detection of Risk Committee's Duties, Working Principles, and Procedures. The Committee is responsible for identifying opportunities that could enhance the Company's profitability and operational efficiency, carrying out the necessary activities related to such opportunities, and timely reporting the findings to the Board of Directors. In addition, in line with the views of the Board, the Committee's duties include determining and implementing risk

policies and procedures based on risk management strategies and ensuring compliance with these principles. To effectively perform the risk monitoring function, the Committee may request information, opinions, and reports from the relevant departments when necessary. Furthermore, it regularly reviews and reports on the risks disclosed in the financial statements and annual reports prepared in accordance with the financial reporting standards adopted by the Capital Markets Board.

Climate change

(4.3.1.1) Position of individual or committee with responsibility

Committee

☑ Other committee, please specify :Climate and Risk Committee

(4.3.1.2) Environmental responsibilities of this position

Dependencies, impacts, risks and opportunities

  • ☑ Assessing environmental dependencies, impacts, risks, and opportunities
  • ☑ Assessing future trends in environmental dependencies, impacts, risks, and opportunities
  • ☑ Managing environmental dependencies, impacts, risks, and opportunities

(4.3.1.4) Reporting line

Select from:

☑ Reports to the board directly

(4.3.1.5) Frequency of reporting to the board on environmental issues

Select from:

☑ More frequently than quarterly

(4.3.1.6) Please explain

The management of climate-related risks and opportunities within Sinpaş REIC is overseen by the Climate and Risk Committee, which operates under the authority of the Board of Directors. The Committee was established to ensure the effective monitoring of environmental, social, and governance (ESG) risks, the alignment of corporate strategy with sustainability objectives, and the coordination of investor relations on these matters. Its structure is designed in accordance with Capital Markets Board regulations and international best practices (e.g., TCFD), and includes members with expertise in sustainability, risk management, and financial

analysis. The Committee's responsibilities include assessing measures and targets for climate change mitigation, monitoring and reporting on carbon emissions, energy use, water, and waste management, as well as reviewing policies on human rights, diversity, and ethical standards. Through these activities, the Committee aims to strengthen the company's long-term resilience, meet investor expectations, and ensure transparent reporting of its sustainability performance. The Committee's Operating Principles and Procedures are publicly available on the company website at the following link: https://sinpasgyo.com/Uploads/investor/surdurulebilirlik/iklim-risk-komitesi-sinpas-gyo-ir.pdf. [Add row]

(4.5) Do you provide monetary incentives for the management of environmental issues, including the attainment of targets?

Climate change

(4.5.1) Provision of monetary incentives related to this environmental issue

Select from:

☑ No, but we plan to introduce them in the next two years

(4.5.3) Please explain

Within the scope of its Compensation Policy, Sinpaş GYO pays attendance fees to the Board of Directors. The amount of these fees is determined with sensitivity to market conditions, taking into account macroeconomic developments, and is based on the Company's performance and success, subject to the approval of the General Assembly. For senior executives, a market- sensitive compensation policy is applied. Salary increases take into consideration the executive's performance, efforts for self-improvement, industry averages, and the inflation rate. Currently, Sinpaş REIC does not have a formalized monetary incentive mechanism specifically dedicated to the management of environmental issues; however, we plan to do so in future reporting periods. [Fixed row]

(4.6) Does your organization have an environmental policy that addresses environmental issues?

Does your organization have any environmental policies?
Select from:

Yes

[Fixed row]

(4.6.1) Provide details of your environmental policies.

Row 1

(4.6.1.1) Environmental issues covered

Select all that apply

☑ Climate change

(4.6.1.2) Level of coverage

Select from:

☑ Organization-wide

(4.6.1.3) Value chain stages covered

Select all that apply

  • ☑ Direct operations
  • ☑ Upstream value chain
  • ☑ Downstream value chain

(4.6.1.4) Explain the coverage

Sinpaş REIC has established its Sustainability Policy to effectively manage its environmental, social, and economic responsibilities. This policy outlines the Company's commitments in key areas such as combating climate change, promoting efficient use of natural resources, safeguarding employee rights, and contributing to society. It also reinforces accountability and transparent communication with stakeholders. Through this policy, Sinpaş REIC aims to align its operations with the United Nations Sustainable Development Goals (SDGs) and Environmental, Social, and Governance (ESG) principles, thereby ensuring long-term value creation and strengthening its resilience against sustainability and climate-related challenges.

(4.6.1.5) Environmental policy content

Environmental commitments

  • ☑ Commitment to comply with regulations and mandatory standards
  • ☑ Commitment to take environmental action beyond regulatory compliance
  • ☑ Commitment to implementation of nature-based solutions that support landscape restoration and long-term protection of natural ecosystems
  • ☑ Commitment to stakeholder engagement and capacity building on environmental issues

Social commitments

  • ☑ Commitment to respect and protect the customary rights to land, resources, and territory of Indigenous Peoples and Local Communities
  • ☑ Commitment to respect internationally recognized human rights

(4.6.1.6) Indicate whether your environmental policy is in line with global environmental treaties or policy goals

Select all that apply

☑ No, but we plan to align in the next two years

(4.6.1.7) Public availability

Select from:

☑ Publicly available

(4.6.1.8) Attach the policy

SiNPASGYO-SURDURULEBiLiRLiK-POLiTiKAMIZ.pdf

Row 2

(4.6.1.1) Environmental issues covered

Select all that apply

☑ Climate change

(4.6.1.2) Level of coverage

Select from:

☑ Organization-wide

(4.6.1.3) Value chain stages covered

Select all that apply

☑ Direct operations

☑ Upstream value chain

☑ Downstream value chain

(4.6.1.4) Explain the coverage

Sinpaş REIC has developed its Environmental and Social Policy to reduce the negative impacts of its operations on the environment and society while contributing to sustainable development. This policy encompasses the efficient use of natural resources, energy and water conservation, waste management, reduction of carbon emissions, protection of employee rights, strengthening of occupational health and safety, support for community-benefiting projects, and robust stakeholder engagement. Through this approach, Sinpaş REIC not only seeks to manage environmental and social risks but also aims to create long-term value for society, its employees, and all stakeholders. The policy further reinforces the Company's commitment to accountability by ensuring transparent reporting and regular communication, thereby enhancing stakeholder trust and aligning with global ESG and sustainability standards.

(4.6.1.5) Environmental policy content

Environmental commitments

  • ☑ Commitment to a circular economy strategy
  • ☑ Commitment to comply with regulations and mandatory standards
  • ☑ Commitment to take environmental action beyond regulatory compliance
  • ☑ Commitment to implementation of nature-based solutions that support landscape restoration and long-term protection of natural ecosystems
  • ☑ Commitment to stakeholder engagement and capacity building on environmental issues

Social commitments

  • ☑ Adoption of the UN International Labour Organization principles
  • ☑ Commitment to promote gender equality and women's empowerment
  • ☑ Commitment to respect internationally recognized human rights

Additional references/Descriptions

  • ☑ Description of dependencies on natural resources and ecosystems
  • ☑ Description of impacts on natural resources and ecosystems
  • ☑ Description of environmental requirements for procurement

(4.6.1.6) Indicate whether your environmental policy is in line with global environmental treaties or policy goals

Select all that apply

☑ No, but we plan to align in the next two years

(4.6.1.7) Public availability

Select from:

☑ Publicly available

(4.6.1.8) Attach the policy

SiNPASGYO-CEVRESEL-SOSYAL-ETKiLER-POLiTiKASI.pdf [Add row]

(4.10) Are you a signatory or member of any environmental collaborative frameworks or initiatives?

Are you a signatory or member of any environmental collaborative
frameworks or initiatives?
Select from:

No, but we plan to within the next two years

[Fixed row]

(4.11) In the reporting year, did your organization engage in activities that could directly or indirectly influence policy, law, or regulation that may (positively or negatively) impact the environment?

(4.11.1) External engagement activities that could directly or indirectly influence policy, law, or regulation that may impact the environment

Select all that apply ☑ Not assessed

(4.11.2) Indicate whether your organization has a public commitment or position statement to conduct your engagement activities in line with global environmental treaties or policy goals

Select from:

☑ No, but we plan to have one in the next two years

(4.11.5) Indicate whether your organization is registered on a transparency register

Select from:

☑ Unknown

(4.11.8) Describe the process your organization has in place to ensure that your external engagement activities are consistent with your environmental commitments and/or transition plan

In this reporting year, Sinpas GYO published TSRS aligned sustainability report. In this report, Sinpaş GYO announced climate ransitions plans and actions. Despite of a few gaps exist in terms of metrics and targets, they started to establish enviromental commitmets and transition plans. [Fixed row]

(4.12) Have you published information about your organization's response to environmental issues for this reporting year in places other than your CDP response?

Select from:

☑ Yes

(4.12.1) Provide details on the information published about your organization's response to environmental issues for this reporting year in places other than your CDP response. Please attach the publication.

Row 1

(4.12.1.1) Publication

Select from:

☑ In mainstream reports, in line with environmental disclosure standards or frameworks

(4.12.1.2) Standard or framework the report is in line with

Select all that apply

☑ IFRS

☑ Other, please specify :TSRS

(4.12.1.3) Environmental issues covered in publication

Select all that apply

☑ Climate change

(4.12.1.4) Status of the publication

Select from:

(4.12.1.5) Content elements

- Select all that apply

  • ☑ Governance ☑ Content of environmental policies
  • ☑ Emission targets
  • ☑ Emissions figures
  • ☑ Risks & Opportunities

(4.12.1.6) Page/section reference

☑ Strategy ☑ Value chain engagement

In 2024 TSRS ALIGNED SUSTAINABILITY REPORT of Sinpas GYO, the distribution of section starts is mentioned below. - Governance, page 16 - Strategy, page 24 - Risk Management, page 40 - Metrics and Targets,page 42.

(4.12.1.7) Attach the relevant publication

2024 TSRS ALIGNED SUSTAINABILITY REPORT OF SINPAS GYO.pdf

(4.12.1.8) Comment

Türkiye Sustainability Reporting Standards (TSRS) were announced in December 2023. As Sinpaş GYO, we have prepared and publicly released our first TSRSaligned sustainability report, which is available on our corporate website. [Add row]

C5. Business strategy

(5.1) Does your organization use scenario analysis to identify environmental outcomes?

Climate change

(5.1.1) Use of scenario analysis

Select from:

☑ Yes

(5.1.2) Frequency of analysis

Select from:

☑ Annually

[Fixed row]

(5.1.1) Provide details of the scenarios used in your organization's scenario analysis.

Climate change

(5.1.1.1) Scenario used

Physical climate scenarios ☑ RCP 2.6

(5.1.1.2) Scenario used  SSPs used in conjunction with scenario

Select from:

☑ SSP1

(5.1.1.3) Approach to scenario

Select from:

☑ Qualitative and quantitative

(5.1.1.4) Scenario coverage

Select from:

☑ Organization-wide  

(5.1.1.5) Risk types considered in scenario

Select all that apply

☑ Acute physical

(5.1.1.6) Temperature alignment of scenario

Select from:

☑ 1.5°C or lower  

(5.1.1.7) Reference year

2024

(5.1.1.8) Timeframes covered

Select all that apply

☑ 2025

☑ 2030

☑ 2040

☑ 2050

(5.1.1.9) Driving forces in scenario

Finance and insurance ☑ Cost of capital

Direct interaction with climate

☑ On asset values, on the corporate 

(5.1.1.10) Assumptions, uncertainties and constraints in scenario

Sinpaş GYO has identified and financialized climate-related risks and opportunities using scenario analyses. In this context: Floods In analyzing flood risk, Sinpaş GYO assessed the level of exposure of the projects in its portfolio, as well as those of its subsidiary Kızılbük GYO, using the WRI Aqueduct Water Risk Atlas. For projects with "Low," "Low–Medium," and "Medium" levels of risk, the size of the project areas was taken as the basis, and potential financial impacts were calculated using repair costs per square meter as stated in the academic literature. These financial impacts were then evaluated under short-, medium-, and long-term projections in accordance with the RCP 2.6 and RCP 8.5 scenarios.

(5.1.1.11) Rationale for choice of scenario

The RCP 2.6 scenario assumes rapid global emission reductions, accelerated renewable energy transition, and strong implementation of climate policies. For Sinpaş GYO, this scenario is highly relevant to testing the resilience of the company's long-term business strategy, as it aligns with Türkiye's 2053 net-zero target and anticipates increased adoption of low-carbon construction materials, energy efficiency measures, and renewable energy integration in the real estate sector.

Climate change

(5.1.1.1) Scenario used

Physical climate scenarios ☑ RCP 8.5

(5.1.1.2) Scenario used  SSPs used in conjunction with scenario

Select from:

☑ SSP5

(5.1.1.3) Approach to scenario

Select from:

☑ Qualitative and quantitative

(5.1.1.4) Scenario coverage

Select from:

☑ Organization-wide  

(5.1.1.5) Risk types considered in scenario

Select all that apply

☑ Acute physical

(5.1.1.6) Temperature alignment of scenario

Select from:

☑ 4.0ºC and above  

(5.1.1.7) Reference year

2024

(5.1.1.8) Timeframes covered

Select all that apply

☑ 2025

☑ 2030

☑ 2040

☑ 2050

(5.1.1.9) Driving forces in scenario

Finance and insurance

☑ Cost of capital

(5.1.1.10) Assumptions, uncertainties and constraints in scenario

Sinpaş GYO has identified and financialized climate-related risks and opportunities using scenario analyses. In this context: Floods In analyzing flood risk, Sinpaş GYO assessed the level of exposure of the projects in its portfolio, as well as those of its subsidiary Kızılbük GYO, using the WRI Aqueduct Water Risk Atlas. For projects with "Low," "Low–Medium," and "Medium" levels of risk, the size of the project areas was taken as the basis, and potential financial impacts were calculated using repair costs per square meter as stated in the academic literature. These financial impacts were then evaluated under short-, medium-, and long-term projections in accordance with the RCP 2.6 and RCP 8.5 scenarios.

(5.1.1.11) Rationale for choice of scenario

The RCP 8.5 scenario assumes limited global emission reduction, higher volatility in energy prices, accelerated temperature increases, and intensifying physical risks such as heatwaves, water stress, and flooding. For Sinpaş GYO, applying this scenario is critical to assessing the resilience of its business model against climaterelated physical risks.

[Add row]

(5.1.2) Provide details of the outcomes of your organization's scenario analysis.

Climate change

(5.1.2.1) Business processes influenced by your analysis of the reported scenarios

Select all that apply

  • ☑ Risk and opportunities identification, assessment and management
  • ☑ Strategy and financial planning
  • ☑ Resilience of business model and strategy
  • ☑ Capacity building
  • ☑ Target setting and transition planning

(5.1.2.2) Coverage of analysis

Select from:

(5.1.2.3) Summarize the outcomes of the scenario analysis and any implications for other environmental issues

Sinpaş GYO has identified and financialized climate-related risks and opportunities using scenario analyses. In this context: Floods In analyzing flood risk, Sinpaş GYO assessed the level of exposure of the projects in its portfolio, as well as those of its subsidiary Kızılbük GYO, using the WRI Aqueduct Water Risk Atlas. For projects with "Low," "Low–Medium," and "Medium" levels of risk, the size of the project areas was taken as the basis, and potential financial impacts were calculated using repair costs per square meter as stated in the academic literature. These financial impacts were then evaluated under short-, medium-, and long-term projections in accordance with the RCP 2.6 and RCP 8.5 scenarios. Compliance with Legal Regulations Sinpaş GYO has addressed the financial impact of compliance with legal regulations under two headings: reputational loss and administrative sanctions. In calculating the quantitative impact of reputational risk, the 2024 gross sales revenue was taken as the basis. A forward-looking projection was made by considering a 10-year compound growth with an annual growth assumption of 10%. Optimistic, moderate, and pessimistic scenarios were defined for the short, medium, and long term, and the quantitative impacts were estimated based on the projected sales revenue losses in these scenarios. For the quantitative impact of administrative sanction risk, the 2024 gross sales revenue was likewise taken as the basis. Specific rates were applied to this amount, if the quantitative impacts would increase by 2% annually in the medium term and by 5% annually in the long term. Changing Energy Dynamics Under the changing energy dynamics risk, unit energy costs were calculated by considering the amounts of electricity and natural gas consumed in the projects within Sinpaş GYO's portfolio. Based on these data, the analysis assumed a 10% annual increase in energy costs in future projections, and the potential quantitative impact of the risk was evaluated accordingly. With respect to its climate-related risks and opportunities, Sinpaş GYO will not disclose quantitative information, as the expected impacts on the Company fall below the financial materiality threshold. [Fixed row]

(5.2) Does your organization's strategy include a climate transition plan?

(5.2.1) Transition plan

Select from:

☑ No and we do not plan to develop a climate transition plan within the next two years

(5.2.15) Primary reason for not having a climate transition plan that aligns with a 1.5°C world

Select from:

☑ Lack of internal resources, capabilities, or expertise (e.g., due to organization size) 

(5.2.16) Explain why your organization does not have a climate transition plan that aligns with a 1.5°C world

Our organization currently does not have a climate transition plan that fully aligns with a 1.5°C pathway primarily due to limited internal resources, technical capabilities, and expertise. However, we are actively monitoring regulatory developments, capacity-building opportunities, and best practices in the sector to progressively enhance our climate-related strategy and aim to align more closely with a 1.5°C pathway in the future [Fixed row]

(5.3) Have environmental risks and opportunities affected your strategy and/or financial planning?

(5.3.1) Environmental risks and/or opportunities have affected your strategy and/or financial planning

Select from:

☑ Yes, both strategy and financial planning

(5.3.2) Business areas where environmental risks and/or opportunities have affected your strategy

Select all that apply

☑ Investment in R&D

☑ Operations

[Fixed row]

(5.3.1) Describe where and how environmental risks and opportunities have affected your strategy.

Investment in R&D

(5.3.1.1) Effect type

Select all that apply

☑ Risks

(5.3.1.2) Environmental issues relevant to the risks and/or opportunities that have affected your strategy in this area

Select all that apply

☑ Climate change

(5.3.1.3) Describe how environmental risks and/or opportunities have affected your strategy in this area

Project-based flood risk assessments are considered one of the key decision criteria in the project development process. For new investments in high-risk areas, insurance strategies, technical measures, and potential revenue impacts are evaluated in an integrated manner through risk–cost analyses. This approach shapes both project feasibility studies and long-term portfolio management strategies. Cost risks arising from potential fluctuations in energy prices are also among the key parameters considered during project development. Accordingly, feasibility studies for new projects include analyses of energy efficiency, the applicability of renewable energy systems, and long-term operating costs. Investment decisions are shaped based on these assessments. Sinpaş REIC, under the coordination of the Investor Relations and Sustainability Manager, closely monitors climate change-related legal regulations. These developments are regularly reported to the Sustainability Committee, the Climate and Risk Committee, and ultimately to the Board of Directors, ensuring that climate and environmental issues are diligently monitored, assessed, and addressed. Based on the feedback provided by these governance bodies, the Company's strategies and action plans are shaped and systematically integrated into the overall corporate governance framework.

Operations

(5.3.1.1) Effect type

Select all that apply

☑ Risks

☑ Opportunities

(5.3.1.2) Environmental issues relevant to the risks and/or opportunities that have affected your strategy in this area

Select all that apply

☑ Climate change

(5.3.1.3) Describe how environmental risks and/or opportunities have affected your strategy in this area

Sustainability-linked financing opportunities encourage the integration of environmental criteria from the design stage of new projects, making this a determining factor in project development and investment planning processes. To meet sustainability criteria that can provide financial advantages, Sinpaş GYO is developing strategies to enhance its sustainability performance. [Add row]

(5.3.2) Describe where and how environmental risks and opportunities have affected your financial planning.

(5.3.2.1) Financial planning elements that have been affected

Select all that apply

☑ Capital expenditures

(5.3.2.2) Effect type

Select all that apply

☑ Risks

(5.3.2.3) Environmental issues relevant to the risks and/or opportunities that have affected these financial planning elements

Select all that apply

☑ Climate change

(5.3.2.4) Describe how environmental risks and/or opportunities have affected these financial planning elements

Environmental risks and opportunities directly shape our capital planning. In projects located in flood-prone areas, we strengthen infrastructure by integrating stormwater management and drainage systems. To reduce our exposure to energy price volatility, we are installing renewable energy systems such as solar panels in our housing projects, which help lower long-term costs. We also align our reporting with TSRS to remain compliant with new regulations, avoiding potential costs and safeguarding access to capital markets. In addition, sustainability-linked financing is a key opportunity for us; by integrating environmental criteria from the design stage, we are able to access more favorable financing conditions and strengthen our overall sustainability performance. [Add row]

(5.4) In your organization's financial accounting, do you identify spending/revenue that is aligned with your organization's climate transition?

Identification of spending/revenue that is aligned with your organization's
climate transition
Select from:

No, and we do not plan to in the next two years

[Fixed row]

(5.5) Does your organization invest in research and development (R&D) of low-carbon products or services related to your sector activities?

(5.5.1) Investment in low-carbon R&D

Select from:

☑ No

(5.5.2) Comment

As a REIC, we do not have a dedicated R&D department, and therefore we cannot directly refer to investments in the R&D of low-carbon products or services. However, Sinpaş REIC continues to advance the development of projects in line with internationally recognized green building standards such as LEED and BREEAM. Through this approach, the Company strengthens the environmental sensitivity of its portfolio and ensures alignment with broader climate change mitigation and sustainability objectives.

[Fixed row]

(5.10) Does your organization use an internal price on environmental externalities?

(5.10.1) Use of internal pricing of environmental externalities

Select from:

☑ No, and we do not plan to in the next two years

(5.10.3) Primary reason for not pricing environmental externalities

Select from:

☑ Lack of internal resources, capabilities, or expertise (e.g., due to organization size)

(5.10.4) Explain why your organization does not price environmental externalities

We do not currently apply an internal price on environmental externalities due to limited resources and expertise, but we are monitoring regulatory developments such as the upcoming Turkish ETS and plan to evaluate internal carbon pricing in the medium term. [Fixed row]

(5.11) Do you engage with your value chain on environmental issues?

Engaging with this stakeholder on environmental
issues
Environmental issues covered
Customers Select from: Select all that apply

Yes

Climate change
Investors and shareholders Select from:

Yes
Select all that apply

Climate change

[Fixed row]

(5.11.9) Provide details of any environmental engagement activity with other stakeholders in the value chain.

Climate change

(5.11.9.1) Type of stakeholder

Select from:

☑ Investors and shareholders

(5.11.9.2) Type and details of engagement

Education/Information sharing

☑ Share information on environmental initiatives, progress and achievements

(5.11.9.3) % of stakeholder type engaged

Select from:

☑ 76-99%

(5.11.9.4) % stakeholder-associated scope 3 emissions

Select from:

☑ Unknown

(5.11.9.5) Rationale for engaging these stakeholders and scope of engagement

n the Real Estate Investment Trust (REIC) sector, the financing of projects and the sustainable growth of the portfolio are of critical importance for our investors and shareholders, directly influencing their investment decisions. Since REICs are subject to capital markets regulations, transparent and consistent information sharing not only builds trust but also ensures compliance with mandatory reporting obligations. Sinpaş REIC communicates its sustainability performance to investors through regular sustainability reporting, annual activity reports, Public Disclosure Platform (KAP) announcements, and investor meetings. This approach increases awareness of climate-related risks and opportunities, while also safeguarding long-term access to capital and strengthening investor confidence in the Company's sustainability strategy.

(5.11.9.6) Effect of engagement and measures of success

Through annual disclosure reports, we provide stakeholders with up-to-date information on our environmental initiatives, risk management, and achievements. This engagement supports informed decision-making by investors and enhances our company's credibility in capital markets.

Climate change

(5.11.9.1) Type of stakeholder

Select from:

☑ Customers

(5.11.9.2) Type and details of engagement

Education/Information sharing

☑ Share information on environmental initiatives, progress and achievements

(5.11.9.3) % of stakeholder type engaged

Select from:

☑ 76-99%

(5.11.9.4) % stakeholder-associated scope 3 emissions

Select from:

☑ Unknown

(5.11.9.5) Rationale for engaging these stakeholders and scope of engagement

Customers are increasingly interested in the environmental performance of the buildings they invest in or occupy. By sharing information on our environmental initiatives, we strengthen customer trust and meet their expectations for sustainable real estate projects.

(5.11.9.6) Effect of engagement and measures of success

Through regular communication channels, project presentations, and sustainability disclosures, customers are informed about our progress and certifications. This engagement enhances customer satisfaction and supports sales of sustainable housing projects. [Add row]

C6. Environmental Performance - Consolidation Approach

(6.1) Provide details on your chosen consolidation approach for the calculation of environmental performance data.

Climate change

(6.1.1) Consolidation approach used

Select from:

☑ Equity share

(6.1.2) Provide the rationale for the choice of consolidation approach

Sinpaş GYO has adopted the equity share approach in defining its organizational boundaries for environmental data reporting. According to this approach, the greenhouse gas emissions of subsidiaries and affiliates are included in the Company's emissions inventory in proportion to its equity share. [Fixed row]

C7. Environmental performance - Climate Change

(7.1) Is this your first year of reporting emissions data to CDP?

Select from:

☑ Yes

(7.2) Select the name of the standard, protocol, or methodology you have used to collect activity data and calculate emissions.

Select all that apply

☑ 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories

☑ The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (Revised Edition)

☑ Other, please specify :TEİAŞ National Electricity Generation Emission Factor (2023 & 2024) and TÜBİTAK

(7.3) Describe your organization's approach to reporting Scope 2 emissions.

(7.3.1) Scope 2, location-based

Select from:

☑ We are reporting a Scope 2, location-based figure

(7.3.2) Scope 2, market-based

Select from:

☑ We have no operations where we are able to access electricity supplier emission factors or residual emissions factors and are unable to report a Scope 2, market-based figure

(7.3.3) Comment

We report Scope 2 emissions using the location-based method. Since we currently do not have operations where contractual instruments (such as renewable energy certificates or power purchase agreements) are in place, we do not apply the market-based method. Should such instruments become available in the future, we will also disclose Scope 2 emissions on a market-based basis [Fixed row]

(7.4) Are there any sources (e.g. facilities, specific GHGs, activities, geographies, etc.) of Scope 1, Scope 2 or Scope 3 emissions that are within your selected reporting boundary which are not included in your disclosure?

Select from:

☑ No

(7.5) Provide your base year and base year emissions.

Scope 1

(7.5.1) Base year end

12/30/2024

(7.5.2) Base year emissions (metric tons CO2e)

1475.28

(7.5.3) Methodological details

The base year emissions were calculated in line with internationally recognized methodologies and national regulations. Scope 1 emissions cover stationary combustion from natural gas use for space heating in buildings and diesel consumption in backup generators activated during power outages. Activity data was collected from utility invoices and generator meters, and converted from volume (liters/sm³) to energy units (TJ). Emission factors were sourced from the 2006 IPCC Guidelines (Vol. 2, Ch. 2, Tables 2.2 & 2.4), supported by TÜİK's national greenhouse gas inventory and TÜBİTAK references. Scope 1 also includes mobile combustion from company-owned and service vehicles using diesel and gasoline. Data was obtained from supplier invoices, on-site logs, and ERP records, and calculations followed IPCC 2006 Guidelines (Vol. 2, Ch. 3, Tables 3.2.1–3.2.4), applying AR6 Global Warming Potentials. In addition, fugitive emissions from split air conditioning units, FM200 fire extinguishing systems, and transformer equipment were assessed using equipment capacity labels, maintenance logs, and site observations. Calculations applied the IPCC 2019 Refinement (Vol. 3, Ch. 7, Table 7.9) methodology, multiplying equipment charge × default leakage rates × AR6 GWPs to obtain COe.

Scope 2 (location-based)

12/30/2024

(7.5.2) Base year emissions (metric tons CO2e)

2402.99

(7.5.3) Methodological details

Scope 2 emissions (location-based) were calculated from purchased electricity for facilities, lighting, and office operations. Data was collected from electricity supplier invoices, meter readings, and facility consumption reports. Emissions were calculated using the location-based approach, multiplying annual consumption (kWh) by the national grid emission factor. Emission factors were sourced from TEİAŞ national electricity generation data (2023–2024) and TÜBİTAK, with AR6 GWPs applied. [Fixed row]

(7.6) What were your organization's gross global Scope 1 emissions in metric tons CO2e?

Reporting year

(7.6.1) Gross global Scope 1 emissions (metric tons CO2e)

1475.28

(7.6.3) Methodological details

The reporting year emissions were calculated in accordance with internationally recognized standards and Türkiye's Greenhouse Gas Monitoring and Reporting Regulation. Scope 1 emissions include stationary combustion from natural gas consumption for space heating in buildings and diesel consumption in backup generators during power outages. Activity data was collected from utility invoices and generator meters. Values in liters/sm³ were converted into energy units (TJ), and emission factors were applied from the 2006 IPCC Guidelines (Vol. 2, Ch. 2, Tables 2.2 & 2.4), TÜİK's national greenhouse gas inventory, and TÜBİTAK references. For mobile combustion, emissions from gasoline and diesel use in company-owned and service vehicles were included. Data was gathered from supplier invoices, site logs, and ERP records, and calculations followed IPCC 2006 Guidelines (Vol. 2, Ch. 3, Tables 3.2.1–3.2.4), applying AR6 Global Warming Potentials (GWPs). Fugitive emissions were also considered, covering leakage from split air conditioning systems, FM200 fire suppression systems, and transformer equipment. Equipment labels, maintenance logs, and site inspections were used as data sources, and emissions were estimated using the IPCC 2019 Refinement (Vol. 3, Ch. 7, Table 7.9) methodology (equipment charge × default leakage rate × AR6 GWP). [Fixed row]

(7.7) What were your organization's gross global Scope 2 emissions in metric tons CO2e?

Reporting year

(7.7.1) Gross global Scope 2, location-based emissions (metric tons CO2e)

2402.99

(7.7.4) Methodological details

Scope 2 emissions (location-based) were calculated from purchased electricity for facilities, lighting, and office operations. Data was collected from electricity supplier invoices, meter readings, and facility consumption reports. Emissions were calculated using the location-based approach, multiplying annual consumption (kWh) by the national grid emission factor. Emission factors were sourced from TEİAŞ national electricity generation data (2023–2024) and TÜBİTAK, with AR6 GWPs applied. [Fixed row]

(7.8) Account for your organization's gross global Scope 3 emissions, disclosing and explaining any exclusions.

Purchased goods and services

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Capital goods

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Fuel-and-energy-related activities (not included in Scope 1 or 2)

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Upstream transportation and distribution

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Waste generated in operations

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Business travel

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Employee commuting

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Upstream leased assets

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Downstream transportation and distribution

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Processing of sold products

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Use of sold products

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

End of life treatment of sold products

(7.8.1) Evaluation status

Select from:

☑ Not evaluated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Downstream leased assets

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Franchises

(7.8.1) Evaluation status

Select from:

☑ Not evaluated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Investments

(7.8.1) Evaluation status

Select from:

☑ Relevant, not yet calculated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Other (upstream)

(7.8.1) Evaluation status

Select from:

☑ Not evaluated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year.

Other (downstream)

(7.8.1) Evaluation status

Select from:

☑ Not evaluated

(7.8.5) Please explain

Scope 3 emissions have not been calculated in the relevant reporting year. [Fixed row]

(7.9) Indicate the verification/assurance status that applies to your reported emissions.

Verification/assurance status
Scope 1 Select from:

Third-party verification or assurance process in place
Scope 2 (location-based or market-based) Select from:

Third-party verification or assurance process in place
Scope 3 Select from:

No emissions data provided

[Fixed row]

(7.9.1) Provide further details of the verification/assurance undertaken for your Scope 1 emissions, and attach the relevant statements.

Row 1

(7.9.1.1) Verification or assurance cycle in place

Select from:

☑ Annual process

(7.9.1.2) Status in the current reporting year

Select from:

☑ Complete

(7.9.1.3) Type of verification or assurance

Select from:

☑ Limited assurance

(7.9.1.4) Attach the statement

sinpas-gyo-tsrs-surdurulebilirlik-raporu-2024.pdf

(7.9.1.5) Page/section reference

48

(7.9.1.6) Relevant standard

Select from:

☑ ISO14064-1

(7.9.1.7) Proportion of reported emissions verified (%)

100 [Add row]

(7.9.2) Provide further details of the verification/assurance undertaken for your Scope 2 emissions and attach the relevant statements.

Row 1

(7.9.2.1) Scope 2 approach

Select from:

☑ Scope 2 location-based

(7.9.2.2) Verification or assurance cycle in place

Select from:

☑ Annual process

(7.9.2.3) Status in the current reporting year

Select from:

☑ Complete

(7.9.2.4) Type of verification or assurance

Select from:

☑ Limited assurance

(7.9.2.5) Attach the statement

sinpas-gyo-tsrs-surdurulebilirlik-raporu-2024.pdf

(7.9.2.6) Page/ section reference

48

(7.9.2.7) Relevant standard

Select from:

☑ ISO14064-1

(7.9.2.8) Proportion of reported emissions verified (%)

100 [Add row]

(7.10) How do your gross global emissions (Scope 1 and 2 combined) for the reporting year compare to those of the previous reporting year?

Select from:

☑ This is our first year of reporting, so we cannot compare to last year

(7.12) Are carbon dioxide emissions from biogenic carbon relevant to your organization?

Select from:

(7.15) Does your organization break down its Scope 1 emissions by greenhouse gas type?

Select from:

☑ Yes

(7.15.1) Break down your total gross global Scope 1 emissions by greenhouse gas type and provide the source of each used global warming potential (GWP).

Row 1

(7.15.1.1) Greenhouse gas

Select from:

☑ CO2

(7.15.1.2) Scope 1 emissions (metric tons of CO2e)

1440.326

(7.15.1.3) GWP Reference

Select from:

☑ IPCC Sixth Assessment Report (AR6 - 100 year)

Row 2

(7.15.1.1) Greenhouse gas

Select from:

☑ CH4

(7.15.1.2) Scope 1 emissions (metric tons of CO2e)

(7.15.1.3) GWP Reference

Select from:

☑ IPCC Sixth Assessment Report (AR6 - 100 year)

Row 3

(7.15.1.1) Greenhouse gas

Select from:

☑ N2O

(7.15.1.2) Scope 1 emissions (metric tons of CO2e)

0.045

(7.15.1.3) GWP Reference

Select from:

☑ IPCC Sixth Assessment Report (AR6 - 100 year) [Add row]

(7.16) Break down your total gross global Scope 1 and 2 emissions by country/area.

Scope 1 emissions (metric tons CO2e) Scope 2, location-based (metric tons CO2e)
Turkey 1475.28 2402.99

[Fixed row]

(7.17) Indicate which gross global Scope 1 emissions breakdowns you are able to provide.

Select all that apply

☑ By business division

(7.17.1) Break down your total gross global Scope 1 emissions by business division.

Row 1

(7.17.1.1) Business division

Sinpaş CO. Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Sinpaş CO.

(7.17.1.2) Scope 1 emissions (metric ton CO2e)

0

Row 2

(7.17.1.1) Business division

Güney Marmaris Otel Yönetimleri ve Hizmetleri A.Ş. Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Güney Marmaris Otel Yönetimleri ve Hizmetleri A.Ş.

(7.17.1.2) Scope 1 emissions (metric ton CO2e)

0

Row 3

(7.17.1.1) Business division

Kızılbük Gayrimenkul Yatırım Ortaklığı A.Ş. Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. In this context, the emissions from the activities of Kızılbük Gayrimenkul Yatırım Ortaklığı A.Ş. have been incorporated into the inventory.

(7.17.1.2) Scope 1 emissions (metric ton CO2e)

292.93

Row 4

(7.17.1.1) Business division

S.S. Modern Bursa Konut Yapı Kooperatifi Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from S.S. Modern Bursa Konut Yapı Kooperatifi.

(7.17.1.2) Scope 1 emissions (metric ton CO2e)

0

Row 5

(7.17.1.1) Business division

Boğaziçi Eğitim Hizmetleri ve Ticaret A.Ş. Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Boğaziçi Eğitim Hizmetleri ve Ticaret A.Ş.

(7.17.1.2) Scope 1 emissions (metric ton CO2e)

0

Row 6

(7.17.1.1) Business division

Etkinsürekli İhracat Lojistik ve Ticaret A.Ş. Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Etkinsürekli İhracat Lojistik ve Ticaret A.Ş.

(7.17.1.2) Scope 1 emissions (metric ton CO2e)

0

Row 7

(7.17.1.1) Business division

Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş.

(7.17.1.2) Scope 1 emissions (metric ton CO2e)

1182.35 [Add row]

(7.20) Indicate which gross global Scope 2 emissions breakdowns you are able to provide.

Select all that apply

☑ By business division

(7.20.1) Break down your total gross global Scope 2 emissions by business division.

Row 1

(7.20.1.1) Business division

Sinpaş CO.

(7.20.1.2) Scope 2, location-based (metric tons CO2e)

(7.20.1.1) Business division

Güney Marmaris Otel Yönetimleri ve Hizmetleri A.Ş. Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Güney Marmaris Otel Yönetimleri ve Hizmetleri A.Ş.

(7.20.1.2) Scope 2, location-based (metric tons CO2e)

0

Row 3

(7.20.1.1) Business division

Kızılbük Gayrimenkul Yatırım Ortaklığı A.Ş. Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. In this context, the emissions from the activities of Kızılbük Gayrimenkul Yatırım Ortaklığı A.Ş. have been incorporated into the inventory.

(7.20.1.2) Scope 2, location-based (metric tons CO2e)

1298.24

Row 4

(7.20.1.1) Business division

S.S. Modern Bursa Konut Yapı Kooperatifi Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from S.S. Modern Bursa Konut Yapı Kooperatifi.

(7.20.1.2) Scope 2, location-based (metric tons CO2e)

(7.20.1.1) Business division

Boğaziçi Eğitim Hizmetleri ve Ticaret A.Ş. Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Boğaziçi Eğitim Hizmetleri ve Ticaret A.Ş.

(7.20.1.2) Scope 2, location-based (metric tons CO2e)

0

Row 6

(7.20.1.1) Business division

Etkinsürekli İhracat Lojistik ve Ticaret A.Ş. Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Etkinsürekli İhracat Lojistik ve Ticaret A.Ş.

(7.20.1.2) Scope 2, location-based (metric tons CO2e)

0

Row 7

(7.20.1.1) Business division

Sinpaş GYO

(7.20.1.2) Scope 2, location-based (metric tons CO2e)

1104.75 [Add row] (7.22) Break down your gross Scope 1 and Scope 2 emissions between your consolidated accounting group and other entities included in your response.

Consolidated accounting group

(7.22.1) Scope 1 emissions (metric tons CO2e)

1475.28

(7.22.2) Scope 2, location-based emissions (metric tons CO2e)

2402.99

(7.22.4) Please explain

Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. Within this scope, the consolidated accounting group emissions reported (Scope 1: 1,475.28 tCOe, Scope 2: 2,402.99 tCOe) cover all subsidiaries. [Fixed row]

(7.23) Is your organization able to break down your emissions data for any of the subsidiaries included in your CDP response?

Select from:

☑ Yes

(7.23.1) Break down your gross Scope 1 and Scope 2 emissions by subsidiary.

Row 1

(7.23.1.1) Subsidiary name

Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş.

(7.23.1.2) Primary activity

Select from:

☑ REIT

(7.23.1.3) Select the unique identifier you are able to provide for this subsidiary

Select all that apply

☑ Ticker symbol

(7.23.1.7) Ticker symbol

SNGYO

(7.23.1.12) Scope 1 emissions (metric tons CO2e)

1182.35

(7.23.1.13) Scope 2, location-based emissions (metric tons CO2e)

1104.75

(7.23.1.15) Comment

Sinpaş GYO calculates Scope 1 and Scope 2 location-based emissions for its own operational activities.

Row 2

(7.23.1.1) Subsidiary name

Sinpaş CO.

(7.23.1.2) Primary activity

Select from:

☑ Construction & building materials dealing & distribution

(7.23.1.3) Select the unique identifier you are able to provide for this subsidiary

Select all that apply

☑ No unique identifier

(7.23.1.12) Scope 1 emissions (metric tons CO2e)

0

(7.23.1.13) Scope 2, location-based emissions (metric tons CO2e)

0

(7.23.1.15) Comment

Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Sinpaş CO.

Row 3

(7.23.1.1) Subsidiary name

Güney Marmaris Otel Yönetimleri ve Hizmetleri A.Ş.

(7.23.1.2) Primary activity

Select from:

☑ Hotels & lodging

(7.23.1.3) Select the unique identifier you are able to provide for this subsidiary

Select all that apply

☑ No unique identifier

(7.23.1.12) Scope 1 emissions (metric tons CO2e)

0

(7.23.1.15) Comment

Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Güney Marmaris Otel Yönetimleri ve Hizmetleri A.Ş.

Row 4

(7.23.1.1) Subsidiary name

Kızılbük Gayrimenkul Yatırım Ortaklığı A.Ş.

(7.23.1.2) Primary activity

Select from:

☑ REIT

(7.23.1.3) Select the unique identifier you are able to provide for this subsidiary

Select all that apply

☑ Ticker symbol

(7.23.1.7) Ticker symbol

KZBGY

(7.23.1.12) Scope 1 emissions (metric tons CO2e)

292.93

(7.23.1.13) Scope 2, location-based emissions (metric tons CO2e)

(7.23.1.15) Comment

Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. In this context, the emissions from the activities of Kızılbük Gayrimenkul Yatırım Ortaklığı A.Ş. have been incorporated into the inventory.

Row 5

(7.23.1.1) Subsidiary name

S.S. Modern Bursa Konut Yapı Kooperatifi

(7.23.1.2) Primary activity

Select from:

☑ Residential building construction

(7.23.1.3) Select the unique identifier you are able to provide for this subsidiary

Select all that apply

☑ No unique identifier

(7.23.1.12) Scope 1 emissions (metric tons CO2e)

0

(7.23.1.13) Scope 2, location-based emissions (metric tons CO2e)

0

(7.23.1.15) Comment

Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from S.S. Modern Bursa Konut Yapı Kooperatifi.

(7.23.1.1) Subsidiary name

Boğaziçi Eğitim Hizmetleri ve Ticaret A.Ş.

(7.23.1.2) Primary activity

Select from:

☑ Education services

(7.23.1.3) Select the unique identifier you are able to provide for this subsidiary

Select all that apply

☑ No unique identifier

(7.23.1.12) Scope 1 emissions (metric tons CO2e)

0

(7.23.1.13) Scope 2, location-based emissions (metric tons CO2e)

0

(7.23.1.15) Comment

Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Boğaziçi Eğitim Hizmetleri ve Ticaret A.Ş.

Row 7

(7.23.1.1) Subsidiary name

Etkinsürekli İhracat Lojistik ve Ticaret A.Ş

(7.23.1.2) Primary activity

Select from:

☑ Logistics - 3rd party

(7.23.1.3) Select the unique identifier you are able to provide for this subsidiary

Select all that apply

☑ No unique identifier

(7.23.1.12) Scope 1 emissions (metric tons CO2e)

0

(7.23.1.13) Scope 2, location-based emissions (metric tons CO2e)

0

(7.23.1.15) Comment

Sinpaş GYO has adopted the financial control approach in calculating its greenhouse gas emissions and has included its subsidiaries in the calculations. However, apart from Kızılbük GYO, the other subsidiaries and affiliates do not operate any physical office buildings or processes that would result in energy consumption. Therefore, no Scope 1 or Scope 2 greenhouse gas emissions arise from Etkinsürekli İhracat Lojistik ve Ticaret A.Ş. [Add row]

(7.29) What percentage of your total operational spend in the reporting year was on energy?

Select from:

☑ More than 0% but less than or equal to 5%

(7.30) Select which energy-related activities your organization has undertaken.

Indicate whether your organization undertook this energy-related activity in
the reporting year
Consumption of fuel (excluding feedstocks) Select from:

No
Consumption of purchased or acquired electricity Select from:

Yes
Consumption of purchased or acquired heat Select from:

Yes
Consumption of purchased or acquired steam Select from:

No
Consumption of purchased or acquired cooling Select from:

No
Generation of electricity, heat, steam, or cooling Select from:

No

[Fixed row]

(7.30.1) Report your organization's energy consumption totals (excluding feedstocks) in MWh.

Consumption of purchased or acquired electricity

(7.30.1.1) Heating value

Select from:

☑ Unable to confirm heating value

(7.30.1.2) MWh from renewable sources

(7.30.1.3) MWh from non-renewable sources

5436625.36

(7.30.1.4) Total (renewable + non-renewable) MWh

5436625.36

Consumption of purchased or acquired heat

(7.30.1.1) Heating value

Select from:

☑ Unable to confirm heating value

(7.30.1.2) MWh from renewable sources

0

(7.30.1.3) MWh from non-renewable sources

3878124.61

(7.30.1.4) Total (renewable + non-renewable) MWh

3878124.61

Total energy consumption

(7.30.1.1) Heating value

Select from:

☑ Unable to confirm heating value

(7.30.1.2) MWh from renewable sources

(7.30.1.3) MWh from non-renewable sources

9314749.97

(7.30.1.4) Total (renewable + non-renewable) MWh

9314749.97 [Fixed row]

(7.30.16) Provide a breakdown by country/area of your electricity/heat/steam/cooling consumption in the reporting year.

Turkey

(7.30.16.1) Consumption of purchased electricity (MWh)

5436625.36

(7.30.16.2) Consumption of self-generated electricity (MWh)

0

(7.30.16.4) Consumption of purchased heat, steam, and cooling (MWh)

3878124.61

(7.30.16.5) Consumption of self-generated heat, steam, and cooling (MWh)

0

(7.30.16.6) Total electricity/heat/steam/cooling energy consumption (MWh)

9314749.97 [Fixed row]

(7.45) Describe your gross global combined Scope 1 and 2 emissions for the reporting year in metric tons CO2e per unit currency total revenue and provide any additional intensity metrics that are appropriate to your business operations.

Row 1

(7.45.1) Intensity figure

5e-7

(7.45.2) Metric numerator (Gross global combined Scope 1 and 2 emissions, metric tons CO2e)

3878.27

(7.45.3) Metric denominator

Select from:

☑ unit total revenue

(7.45.4) Metric denominator: Unit total

7760895169

(7.45.5) Scope 2 figure used

Select from:

☑ Location-based

(7.45.9) Please explain

Sinpaş GYO's gross Scope 1 and 2 emissions amount to 3,878.27 tCOe, with a unit total revenue of 7,760,895,169 resulting in an intensity figure of 0.0000005 tCOe per unit revenue. As this figure has been calculated for the first time, no year-on-year comparison can be made. [Add row]

(7.53) Did you have an emissions target that was active in the reporting year?

Select all that apply

☑ Absolute target

(7.53.1) Provide details of your absolute emissions targets and progress made against those targets.

Row 1

(7.53.1.1) Target reference number

Select from:

☑ Abs 1

(7.53.1.2) Is this a science-based target?

Select from:

☑ No, but we anticipate setting one in the next two years

(7.53.1.5) Date target was set

09/26/2021

(7.53.1.6) Target coverage

Select from:

☑ Country/area/region

(7.53.1.7) Greenhouse gases covered by target

Select all that apply

☑ Carbon dioxide (CO2)

(7.53.1.8) Scopes

Select all that apply

☑ Scope 1

☑ Scope 2

(7.53.1.9) Scope 2 accounting method

Select from:

☑ Location-based

(7.53.1.11) End date of base year

12/30/2024

(7.53.1.12) Base year Scope 1 emissions covered by target (metric tons CO2e)

1475.28

(7.53.1.13) Base year Scope 2 emissions covered by target (metric tons CO2e)

2402.99

(7.53.1.31) Base year total Scope 3 emissions covered by target (metric tons CO2e)

0.000

(7.53.1.32) Total base year emissions covered by target in all selected Scopes (metric tons CO2e)

3878.270

(7.53.1.33) Base year Scope 1 emissions covered by target as % of total base year emissions in Scope 1

100

(7.53.1.34) Base year Scope 2 emissions covered by target as % of total base year emissions in Scope 2

100

(7.53.1.53) Base year emissions covered by target in all selected Scopes as % of total base year emissions in all selected Scopes

100

(7.53.1.54) End date of target

12/31/2052

(7.53.1.55) Targeted reduction from base year (%)

100

(7.53.1.56) Total emissions at end date of target covered by target in all selected Scopes (metric tons CO2e)

0.000

(7.53.1.57) Scope 1 emissions in reporting year covered by target (metric tons CO2e)

1475.28

(7.53.1.58) Scope 2 emissions in reporting year covered by target (metric tons CO2e)

2402.99

(7.53.1.77) Total emissions in reporting year covered by target in all selected scopes (metric tons CO2e)

3878.270

(7.53.1.78) Land-related emissions covered by target

Select from:

☑ No, it does not cover any land-related emissions (e.g. non-FLAG SBT)

(7.53.1.79) % of target achieved relative to base year

(7.53.1.80) Target status in reporting year

Select from:

☑ Underway

(7.53.1.82) Explain target coverage and identify any exclusions

Türkiye's 2053 net zero emissions target covers all greenhouse gases (CO, CH, NO, and F-gases) and all sectors, including energy, industry, transport, buildings, waste, and agriculture. The target is nationwide and does not exclude any sector or activity. It is aligned with international climate policies such as the Paris Agreement, the EU Green Deal, and Türkiye's Climate Law.

(7.53.1.83) Target objective

Achieving net zero greenhouse gas emissions by 2053. This will be accomplished through emission reduction measures, energy transition, renewable energy investments, energy efficiency improvements, expansion of carbon sinks, and the adoption of climate-friendly technologies. Remaining emissions will be balanced through enhanced natural sinks and carbon capture technologies.

(7.53.1.84) Plan for achieving target, and progress made to the end of the reporting year

To achieve the 2053 net zero target, Sinpaş GYO plans to progressively implement energy efficiency measures, expand the use of renewable energy systems (e.g., rooftop solar installations in residential projects), and adopt low-carbon construction materials. Feasibility studies for life cycle assessments and pilot applications for net zero carbon buildings are also being developed. In the reporting year, preparatory steps were taken by integrating renewable energy plans into new projects (Halkalı 33 Parsel and Metrolife Premium) and aligning corporate sustainability strategy with national climate commitments.

(7.53.1.85) Target derived using a sectoral decarbonization approach

Select from:

☑ Yes

[Add row]

(7.54) Did you have any other climate-related targets that were active in the reporting year?

Select all that apply

☑ No other climate-related targets

(7.55) Did you have emissions reduction initiatives that were active within the reporting year? Note that this can include those in the planning and/or implementation phases.

Select from:

☑ Yes

(7.55.1) Identify the total number of initiatives at each stage of development, and for those in the implementation stages, the estimated CO2e savings.

Number of initiatives
To be implemented 2

[Fixed row]

(7.55.2) Provide details on the initiatives implemented in the reporting year in the table below.

Row 1

(7.55.2.1) Initiative category & Initiative type

Low-carbon energy consumption

☑ Solar PV

(7.55.2.3) Scope(s) or Scope 3 category(ies) where emissions savings occur

Select all that apply

☑ Scope 2 (location-based)

(7.55.2.4) Voluntary/Mandatory

☑ Voluntary

(7.55.2.9) Comment

As part of our environmental initiatives, we are installing solar energy panels in our residential projects. In the Halkalı 33 Parsel project, a rooftop solar power system with a capacity of 82 kWp is planned, with completion expected by 2027. In the Metrolife Premium project, rooftop solar panels with a combined capacity of 172 kWp (84 kW in parcel 6372 and 88 kW in parcel 6373) will be installed, with completion planned for 2026. These solar energy investments are expected to improve energy efficiency and reduce greenhouse gas emissions. However, the potential emission reduction has not yet been calculated, and the investment amount has not been disclosed. [Add row]

(7.55.3) What methods do you use to drive investment in emissions reduction activities?

Row 1

(7.55.3.1) Method

Select from:

☑ Dedicated budget for energy efficiency

(7.55.3.2) Comment

We allocate dedicated budgets to energy efficiency and renewable energy integration within our projects, such as the installation of rooftop solar panels in Halkalı 33 Parsel and Metrolife Premium. These investments are planned and financed as part of our capital expenditure strategy. [Add row]

(7.72) Does your organization assess the life cycle emissions of new construction or major renovation projects?

(7.72.1) Assessment of life cycle emissions

Select from:

☑ No, but we plan to for upcoming projects

<-- PDF CHUNK SEPARATOR -->

(7.72.2) Comment

We have not yet conducted life cycle emission assessments for new construction or major renovation projects; however, we plan to carry out such assessments in future projects.

[Fixed row]

(7.74) Do you classify any of your existing goods and/or services as low-carbon products?

Select from:

☑ No

(7.77) Did your organization complete new construction or major renovations projects designed as net zero carbon in the last three years?

Select from: ☑ No, but we plan to in the future

(7.78) Explain your organization's plan to manage, develop or construct net zero carbon buildings, or explain why you do not plan to do so.

We have not yet completed new construction or major renovation projects designed as net zero carbon, but we plan to do so in the future. Our approach is to progressively integrate energy efficiency measures, renewable energy systems, and low-carbon materials into our upcoming projects. In line with national climate targets and global best practices, we are preparing feasibility studies and pilot applications to set the foundation for net zero carbon buildings.

(7.79) Has your organization retired any project-based carbon credits within the reporting year?

Select from:

☑ No

C11. Environmental performance - Biodiversity

(11.2) What actions has your organization taken in the reporting year to progress your biodiversity-related commitments?

Actions taken in the reporting period to progress your biodiversity-related
commitments
Select from:

No, we are not taking any actions to progress our biodiversity-related
commitments

[Fixed row]

(11.3) Does your organization use biodiversity indicators to monitor performance across its activities?

Does your organization use indicators to monitor biodiversity performance?
Select from:

No

[Fixed row]

(11.4) Does your organization have activities located in or near to areas important for biodiversity in the reporting year?

Legally protected areas

(11.4.1) Indicate whether any of your organization's activities are located in or near to this type of area important for biodiversity

Select from:

☑ Yes

(11.4.2) Comment

Marmaris National Park is designated as a legally protected area under Turkish legislation (National Parks Law No. 2873 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2873.pdf). The Kızılbük Thermal Resort Hotel is located in close proximity to this National Park.

UNESCO World Heritage sites

(11.4.1) Indicate whether any of your organization's activities are located in or near to this type of area important for biodiversity

Select from:

☑ No

(11.4.2) Comment

There are no UNESCO World Heritage sites in or near the locations of Sinpaş GYO's operations.

UNESCO Man and the Biosphere Reserves

(11.4.1) Indicate whether any of your organization's activities are located in or near to this type of area important for biodiversity

Select from:

☑ No

(11.4.2) Comment

None of Sinpaş GYO's projects are located in or near UNESCO Biosphere Reserves.

Ramsar sites

(11.4.1) Indicate whether any of your organization's activities are located in or near to this type of area important for biodiversity

Select from:

☑ No

(11.4.2) Comment

Sinpaş GYO's operations are not situated in or near any Ramsar-designated wetlands.

Key Biodiversity Areas

(11.4.1) Indicate whether any of your organization's activities are located in or near to this type of area important for biodiversity

Select from:

☑ No

(11.4.2) Comment

No activities were carried out in or near areas classified as Key Biodiversity Areas (KBA).

Other areas important for biodiversity

(11.4.1) Indicate whether any of your organization's activities are located in or near to this type of area important for biodiversity

Select from:

☑ No

(11.4.2) Comment

Sinpaş GYO has no activities in or near other areas considered important for biodiversity outside legally protected areas.

[Fixed row]

(11.4.1) Provide details of your organization's activities in the reporting year located in or near to areas important for biodiversity.

Row 1

(11.4.1.2) Types of area important for biodiversity

Select all that apply

☑ Legally protected areas

(11.4.1.3) Protected area category (IUCN classification)

Select from:

☑ Category Ia-III

(11.4.1.4) Country/area

Select from:

☑ Turkey

(11.4.1.5) Name of the area important for biodiversity

Marmaris National Park

(11.4.1.6) Proximity

Select from:

☑ Adjacent

(11.4.1.8) Briefly describe your organization's activities in the reporting year located in or near to the selected area

During the reporting year, Kızılbük REIC, a subsidiary of Sinpaş REIC, continued construction and tourism-related activities at the Sinpaş Kızılbük Thermal Wellness Resort project, which is located in close proximity to Marmaris National Park, a legally protected area recognized for its biodiversity and ecological value. Potential impacts such as habitat disturbance, increased human activity, and tourism-related resource use are not present in Sinpaş REIC's direct projects. These issues apply only to the activities of its subsidiary, Kızılbük REIC, where processes are closely monitored. Such risks have been assessed through environmental impact assessments (EIAs) and project design reviews. Mitigation measures include: careful site planning to prevent overlap with the National Park, adoption of environmentally sensitive construction practices, implementation of operational controls to minimize pollution and disturbance, and ensuring continuous compliance with national environmental regulations.

(11.4.1.9) Indicate whether any of your organization's activities located in or near to the selected area could negatively affect biodiversity

Select from:

☑ Yes, but mitigation measures have been implemented

(11.4.1.10) Mitigation measures implemented within the selected area

Select all that apply

  • ☑ Site selection
  • ☑ Project design
  • ☑ Operational controls

(11.4.1.11) Explain how your organization's activities located in or near to the selected area could negatively affect biodiversity, how this was assessed, and describe any mitigation measures implemented

Potential impacts such as habitat disturbance, increased human activity, and tourism-related resource use are not present in Sinpaş REIC's direct projects. These issues apply only to the activities of its subsidiary, Kızılbük REIC, where processes are closely monitored. Such risks have been assessed through environmental impact assessments (EIAs) and project design reviews. Mitigation measures include: careful site planning to prevent overlap with the National Park, adoption of environmentally sensitive construction practices, implementation of operational controls to minimize pollution and disturbance, and ensuring continuous compliance with national environmental regulations. [Add row]

C13. Further information & sign off

(13.1) Indicate if any environmental information included in your CDP response (not already reported in 7.9.1/2/3, 8.9.1/2/3/4, and 9.3.2) is verified and/or assured by a third party?

Other environmental information included in your CDP response is verified
and/or assured by a third party
Select from:

Yes

[Fixed row]

(13.1.1) Which data points within your CDP response are verified and/or assured by a third party, and which standards were used?

Row 1

(13.1.1.1) Environmental issue for which data has been verified and/or assured

Select all that apply

☑ Climate change

(13.1.1.2) Disclosure module and data verified and/or assured

Identification, assessment, and management of dependencies, impacts, risks, and opportunities

☑ All data points in module 2

(13.1.1.3) Verification/assurance standard

☑ ISAE 3000

☑ ISAE 3410, Assurance Engagements on Greenhouse Gas Statements

(13.1.1.4) Further details of the third-party verification/assurance process

The 2024 TSRS-aligned sustainability report of Sinpaş GYO has been subject to limited assurance by PKF Aday Bağımsız Denetim A.Ş. in accordance with ISAE 3000 and ISAE 3410 standards, covering climate-related disclosures.

(13.1.1.5) Attach verification/assurance evidence/report (optional)

2024-tsrs-aligned-sustainability-report-sinpas-gyo.pdf

Row 2

(13.1.1.1) Environmental issue for which data has been verified and/or assured

Select all that apply

☑ Climate change

(13.1.1.2) Disclosure module and data verified and/or assured

Disclosure of risks and opportunities

☑ All data points in module 3

(13.1.1.3) Verification/assurance standard

General standards

☑ ISAE 3000

☑ ISAE 3410, Assurance Engagements on Greenhouse Gas Statements

(13.1.1.4) Further details of the third-party verification/assurance process

The 2024 TSRS-aligned sustainability report of Sinpaş GYO has been subject to limited assurance by PKF Aday Bağımsız Denetim A.Ş. in accordance with ISAE 3000 and ISAE 3410 standards, covering climate-related disclosures.

(13.1.1.5) Attach verification/assurance evidence/report (optional)

2024-tsrs-aligned-sustainability-report-sinpas-gyo.pdf

Row 3

(13.1.1.1) Environmental issue for which data has been verified and/or assured

Select all that apply

☑ Climate change

(13.1.1.2) Disclosure module and data verified and/or assured

Governance

☑ All data points in module 4

(13.1.1.3) Verification/assurance standard

General standards

☑ ISAE 3000

☑ ISAE 3410, Assurance Engagements on Greenhouse Gas Statements

(13.1.1.4) Further details of the third-party verification/assurance process

The 2024 TSRS-aligned sustainability report of Sinpaş GYO has been subject to limited assurance by PKF Aday Bağımsız Denetim A.Ş. in accordance with ISAE 3000 and ISAE 3410 standards, covering climate-related disclosures.

(13.1.1.5) Attach verification/assurance evidence/report (optional)

2024-tsrs-aligned-sustainability-report-sinpas-gyo.pdf

(13.1.1.1) Environmental issue for which data has been verified and/or assured

Select all that apply

☑ Climate change

(13.1.1.2) Disclosure module and data verified and/or assured

Business strategy

  • ☑ Internal pricing of environmental externalities
  • ☑ Scenario analysis

(13.1.1.3) Verification/assurance standard

General standards

☑ ISAE 3000

☑ ISAE 3410, Assurance Engagements on Greenhouse Gas Statements

(13.1.1.4) Further details of the third-party verification/assurance process

The 2024 TSRS-aligned sustainability report of Sinpaş GYO has been subject to limited assurance by PKF Aday Bağımsız Denetim A.Ş. in accordance with ISAE 3000 and ISAE 3410 standards, covering climate-related disclosures.

(13.1.1.5) Attach verification/assurance evidence/report (optional)

2024-tsrs-aligned-sustainability-report-sinpas-gyo.pdf

Row 5

(13.1.1.1) Environmental issue for which data has been verified and/or assured

Select all that apply

☑ Climate change

(13.1.1.2) Disclosure module and data verified and/or assured

Environmental performance – Climate change

☑ All data points in module 7

(13.1.1.3) Verification/assurance standard

General standards

☑ ISAE 3000

☑ ISAE 3410, Assurance Engagements on Greenhouse Gas Statements

(13.1.1.4) Further details of the third-party verification/assurance process

The 2024 TSRS-aligned sustainability report of Sinpaş GYO has been subject to limited assurance by PKF Aday Bağımsız Denetim A.Ş. in accordance with ISAE 3000 and ISAE 3410 standards, covering climate-related disclosures.

(13.1.1.5) Attach verification/assurance evidence/report (optional)

2024-tsrs-aligned-sustainability-report-sinpas-gyo.pdf [Add row]

(13.2) Use this field to provide any additional information or context that you feel is relevant to your organization's response. Please note that this field is optional and is not scored.

(13.2.1) Additional information

In addition to the disclosures provided in this CDP response, Sinpaş GYO publishes an annual sustainability report prepared in alignment with the Türkiye Sustainability Reporting Standards (TSRS) and the GRI Standards. The report covers a wide range of environmental, social, and governance (ESG) topics, including climate-related risks and opportunities, scenario analyses, GHG emissions accounting (Scope 1 and Scope 2, location-based), stakeholder engagement processes, and our progress towards national and international sustainability targets. Our 2024 Sustainability Report has been subject to limited assurance by an independent auditor in accordance with ISAE 3000 and ISAE 3410 standards, ensuring the reliability and credibility of the disclosed information. Furthermore, Sinpaş GYO

continues to integrate sustainability considerations into its long-term strategy and project development processes, with a particular focus on energy efficiency, renewable energy integration, and compliance with the evolving regulatory landscape. Through transparent reporting and ongoing stakeholder engagement, we aim to strengthen investor confidence, support sustainable urban development, and demonstrate our commitment to contributing to Türkiye's climate targets and the global transition to a low-carbon economy.

(13.2.2) Attachment (optional)

2024-tsrs-aligned-sustainability-report-sinpas-gyo.pdf [Fixed row]

(13.3) Provide the following information for the person that has signed off (approved) your CDP response.

(13.3.1) Job title

Ahmet Çelik - Vice Chairman of the Board of Directors, Sinpaş GYO Dr. A. Berrak Köten - Investor Relations and Sustainability Manager, Sinpaş GYO

(13.3.2) Corresponding job category

Select from:

☑ Board chair

[Fixed row]

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