Affected communities

ESRS 2 SBM-3

At STRABAG, we view our social responsibility not only as an obligation towards society, but also as an opportunity to have a positive impact on local communities. This includes municipalities and local residents but also indigenous peoples.

The topic of social responsibility, and with it the assumption of responsibility towards society and affected communities, was incorporated as an integral part of our Group-wide sustainability strategy during its expansion.

The focus topic “Added value for society” includes as strategic objectives generating positive impacts for society, taking into account our potential negative societal impacts and improving the interaction with, or the inclusion of, affected communities. Implementation includes, among other things, conducting stakeholder dialogue formats, implementing guiding principles for interaction with affected communities and using additional communication tools for stakeholder engagement. The aim is also to create social value, for example through the promotion of social and cultural institutions and the expansion of infrastructure.

The double materiality assessment identified the following topics as impacts that STRABAG has on affected communities: adequate food, water and sanitation, and disputes related to land rights. These impacts can be considered systemic, as impairments of natural livelihoods and land-use conflicts may occur, particularly in countries with low environmental protection standards and insufficient legal frameworks. A resilience analysis was not carried out.

Affected communities were identified as a potentially vulnerable group. Municipalities or communities are understood as groups of people who may be directly or indirectly affected by impacts:

Local residents in the immediate vicinity of construction projects who are directly affected by the impacts of our activities.
Affected indigenous peoples and communities located either close to construction projects or further away.

No additional groups of affected communities were identified. A detailed analysis of affected communities with the determination of specific characteristics or respective risk of harm has not yet been carried out. Our construction activities may lead to negative impacts on the health and wellbeing of the population. Negative impacts on local residents, affected indigenous peoples and communities include:

Impairment of natural livelihoods, including soil, air and water pollution: construction-related changes to existing infrastructure may have potential negative impacts that could endanger food production and the availability of clean drinking water and sanitation facilities, particularly for local residents.
Land-use conflicts: particularly with regard to indigenous peoples, whose socio-cultural practices are often linked to specific land areas. Changes to or repurposing of these areas may lead to impacts on the cultural and intangible heritage of indigenous peoples.

In the case of forced evictions and land-use conflicts, particularly where indigenous peoples are affected, potential reputational risks and loss of revenue may arise. However, these risks were not assessed as material for the year 2025.

Improvements to infrastructure can create positive value for local communities. This includes the construction of transport routes and tunnels, the creation of housing, public buildings and squares, as well as barrier-free construction projects, all of which can promote social interaction and more inclusive access for residents and local communities.

Policies

ESRS S3-1

At STRABAG, we assume responsibility for our business activities and for the local communities affected by them. This commitment is described in more detail in our Policy on Employment Conditions and Human Rights, our Code of Conduct and our Supplier Code of Conduct. The Policy on Employment Conditions and Human Rights applies to all affected communities and specifically addresses the rights of minorities, indigenous peoples, communities and individuals who may be affected by wrongful land seizure and unlawful forced eviction. Our policy commits us to respecting local culture and customary rights. We respect the land tenure and property rights of affected communities and advocate for the prohibition of forced evictions and the unlawful appropriation of land, forests and waters.

Processes for engaging with affected communities and providing remedy

ESRS S3-2; ESRS S3-3

The engagement of affected communities or their representatives in our risk and opportunity management does not currently follow a structured process. Depending on the project, interaction takes place in various ways, depending on the construction phase, frequency and specific actions selected. These include analysing stakeholder groups and their needs, providing information through notices, flyers and posters or a dedicated website, as well as engaging in direct dialogue with municipalities, for example through an open construction site day or participation in public consultations. Communities are generally involved directly, although legitimate representatives may also be consulted. The engagement of indigenous peoples also takes place in different ways depending on the project. When engaging and interacting with indigenous peoples, we attach great importance to respecting their culture, way of life and customary rights and commit to free, informed and prior consent. These principles are also set out as an obligation in our Policy on Employment Conditions and Human Rights. In close consultation with the respective client, we seek to consider the engagement of indigenous peoples already during the planning phase. STRABAG attaches great importance to respecting cultural, intellectual, religious and spiritual property, as well as land-use rights, relevant legal and administrative provisions, and national laws concerning the rights of indigenous peoples. Individual Group companies, such as in Canada, have established a community management system responsible, among other things, for involving the affected communities, including indigenous peoples. All processes and actions applicable within a respective project for engaging with affected parties also apply to the engagement with indigenous peoples as an affected community.

To enable a structured process for engaging with local residents and communities, the idea of implementing a guideline as an appropriate measure was validated in 2024 and initial concepts were jointly developed. During further development in 2025, it was decided as a first step to develop guiding principles, which will be adopted in 2026. In a second step, the contents of the guideline will be communicated through various communication tools that allow for more flexible adaptation to different contexts. The guiding principles set out Group-wide recommendations for the engagement process and include principles for transparent and sincere interaction with affected communities, including early involvement of relevant stakeholders, cultural sensitivity and a stakeholder- and dialogue-oriented approach.

In order to incorporate the perspectives of local residents and communities and to anchor elements particularly relevant to affected parties within the guiding principles, the principles were developed in collaboration with internal and external stakeholders. Following exchanges with subject-matter experts – including internal community managers from several countries as well as advisory support from an external NGO – a first version of the guiding principles for engagement with affected communities was prepared and will be adopted across the Group in 2026.

Given the diversity of STRABAG’s business activities, the effectiveness of a universal procedure cannot be guaranteed and must be reviewed. Responsibility for incorporating the results of risk and opportunity management into the corporate concept lies with the Corporate Responsibility Office. Responsibility for incorporation at the operational project level depends on the organisational structure of the respective client.

A key component for engaging local communities is the STRABAG whistleblower system as a way to contact STRABAG directly and report possible violations. The whistleblower system is also embedded as an action within the revised sustainability strategy. The reports received may feed into strategic considerations for the adaptation of actions to address negative impacts.

In 2025, 16 tips were received involving affected communities in the categories of “human rights and employment conditions”, “discrimination” and the “environment”.

No serious legal violations were identified based on the reports received. All reports are also examined for potential structural or systemic problems requiring appropriate action. The full review of reports received in 2025 did not indicate any structural or systemic problems.

Issues or complaints can be reported not only to the designated contact persons but also at any time via the STRABAG whistleblower platform. After receiving reports or notifications of violations, appropriate case-specific remedies are initiated. Every report is followed up in order to resolve conflicts amicably wherever possible. Compensation payments and financial redress may also be used as remedial measures on a case-by-case basis and are reviewed and adjusted depending on the incident. The concept of the remedy action plan applies here as well.

Actions and projects

ESRS S3-4

At project level, numerous actions and processes are already in place to help us engage with affected communities. These are designed to minimise negative impacts, such as noise or impairment of natural livelihoods, on local residents and other affected communities. Due to the large number of actions, many of which are integrated into daily operations, it is currently not possible to quantify the resources provided for managing material impacts.

We use several different ways to inform residents and affected communities about our construction projects. Information is communicated, among other things, in the form of flyers, letters or advertisements in local newspapers. Another widely used method is to affix information boards or banners at our construction sites. QR codes and posted notices directly at the construction site are used to provide contact details for relevant contact persons. Dedicated construction site websites are another common way of providing information. To keep residents and members of the local community informed about our construction activities, STRABAG also participates in community dialogues and informational events. An informal option frequently used is the direct exchange between employees and local residents at the construction site. This allows smaller issues to be resolved on the spot, without the need for escalation to a higher level.

In Germany, 188 of our construction projects have been certified by the German Sustainable Building Council (DGNB). The certification covers not only environmental sustainability criteria but also social aspects. Projects receiving DGNB certification are required to involve residents, property owners and local businesses through actions such as construction site visits, digital information displays, informational events, letter distribution, telephone hotlines or personal discussions.

There are no Group-wide requirements specifying which measures must be implemented from which project size onwards. The selection of actions and engagement options depends on the legal context, the location and size of the project, and the level of interaction required with local residents and affected persons. Likewise, the choice of the appropriate engagement format depends on the requirements and organisational structure of the respective client. Certain construction projects, such as the construction of an airport, are subject to legal and regulatory requirements, including the completion of an environmental impact assessment (EIA). An EIA is carried out before a building permit is granted. As part of an impact assessment, the affected population must be informed in advance about the project. The assessment, including the dissemination of information to the public, is carried out by the competent authority and is the responsibility of the client. An EIA is carried out during the planning and design phase of a project and must be completed before construction begins. The EIA does not prescribe any specific binding actions during the construction phase. The timing of the individual actions described depends on the respective project schedule.

No specific Group-wide actions were implemented in 2025, although individual actions were carried out for the duration of the respective construction projects. To strengthen the respect for the rights of affected communities, guiding principles were developed during the reporting year with the aim of promoting structured and respectful interaction with municipalities, local residents and indigenous peoples. For the development of these principles, existing actions for engagement with affected communities were collected and discussions were held with various internal stakeholders responsible for implementation, such as community managers. The aim was to identify which actions are suitable for Group-wide application and can be recommended. The principles are intended to encourage appropriate conduct towards affected communities, while allowing project-specific decisions as to which measures or processes should be implemented.

To prevent material negative impacts such as forced evictions or land-use conflicts, close coordination and cooperation with clients is necessary. In our Policy on Employment Conditions and Human Rights, we commit across the Group to respecting land-use rights and clearly oppose forced evictions. Should a violation nevertheless occur, we seek open dialogue with those affected or their representatives and involve them, where possible, in discussions with the clients.

Targets

ESRS S3-5

Dialogue with affected communities is essential to fulfilling our social responsibility and mitigating impacts. To promote the engagement with local affected communities or their representatives, we set ourselves the goal of implementing a Group-wide guideline for engaging local communities and residents at project level. In 2025, a guideline was developed with the involvement of relevant internal and external stakeholders. As a first step, we derived internal guiding principles to be adopted in 2026. In a second step, the contents of the guideline will be prepared for different communication tools and made available to employees.

The targets and concept for the guideline were communicated to the Steering Committee Sustainability and to the Management Board before final approval by the Management Board of STRABAG SE. The Group-wide Human Rights Officer reviews the effectiveness and monitors the achievement of the targets.