ESRS E4 Biodiversity and ecosystems

BM – 3: MATERIAL RISKS AND OPPORTUNITIES AND THEIR INTERACTION WITH THE STRATEGY AND BUSINESS MODEL

To identify the material impacts, dependencies, risks and opportunities and their interaction with the strategy and business model Ferrovial has followed the Taskforce on nature-related financial disclosures (TNFD) and its LEAP approach (Locate, Evaluate, Assess and Prepare).

In accordance with the LEAP methodology the company has identified its businesses lines that negatively affect biodiversity sensitive areas (roads, waste treatment plants and landfills, water treatment and desalination plants, solar photovoltaic parks, wind farms and transmission lines) and the priority locations for the whole Company.

Priority locations

Priority locations are defined by different and recognized standards (TNFD, GRI) as those that are either located in sensitive locations or close to them (depending on the type of infrastructure, between 60 meters and 1 kilometer). Sensitive locations are:

• Areas of importance for biodiversity
• Ecosystem integrity
• Water stress areas
• Areas important for the provision of ecosystem services (indigenous communities and FAO World Agricultural Heritage Systems).

Impacts and dependencies

The main impacts regarding biodiversity and ecosystems that Ferrovial’s activities could generate are:

• GHG emissions
• Terrestrial ecosystem use or land occupation, potentially leading to:
  • Land degradation
  • Impact on the ecosystem’s condition
  • Habitat fragmentation
• Generation of large volumes of waste

These activities also depend on ecosystem services, which support its projects and operational resilience, mainly on:

• Key natural resources, such as water
• And ecosystem services related to climate regulation and soil structure (erosion)

Ferrovial currently operates in 8 countries where it interacts with nature (for further information, consult previous section, “Priority locations”, in this disclosure requirement), either because they are priority locations (as indicated in the table above) or because they interact with other natural areas, even if they are not located nearby. These non-nearby areas that may be potentially affected constitute around 154 areas.

The Company’s activities also could potentially affect threatened species. For further information, please consult the section “Disclosure Requirement E4 -5: Impact parameters related to biodiversity and ecosystem change.”

Ferrovial, aware of its responsibility to the natural environment, is committed to the protection and conservation of nature. To this end, the Company has different measures and policies (which can be consulted in the sections “Disclosure requirement E4 – 1: Transition plan and consideration of biodiversity and ecosystems in the strategy and business model”, “Disclosure requirement E4 – 2: Policies related to biodiversity and ecosystems” and “Disclosure Requirement E4 – 3: Biodiversity and ecosystem actions and resources”).

It merits mention that, in 2024, a procedure called “Go – No Go” was approved to define a series of environmental criteria (based the International Union for Conservation of Nature, known (IUCN), Green List of Protected and Conserved Areas, United Nation Universal Declaration of Human Rights and United Nations Educational, Scientific and Cultural Organization (UNESCO), World Heritage List) to be considered when making decisions on whether or not to execute a new project. In this way, we evaluate the validity of the project’s location in the context of certain protected areas:

• UNESCO World Heritage Areas: Projects located within, crosses or it adjacent to a World Heritage Site, category IX and/or X, require additional due diligence and analysis
• IUCN Protected Areas: If a project is located within, through or adjacent to one of the following IUCN protected areas, further due diligence and analysis will be required:
  • Strict nature reserve (Ia)
  • Wilderness Area (Ib)
  • National Park (II)

IRO – 1: DESCRIPTION OF PROCESSES TO IDENTIFY AND ASSESS MATERIAL BIODIVERSITY AND ECOSYSTEM-RELATED IMPACTS, RISKS AND OPPORTUNITIES

Ferrovial implemented a detailed process to identify, evaluate, and manage the impacts, dependencies, risks, and opportunities related to biodiversity and ecosystems, following international frameworks (Taskforce on Nature-related Financial Disclosures (TNFD)) and considering its operations, supply chain, and the broader ecosystem services it depends on and impacts.

The Company systematically determines and evaluates the real and potential impacts of its operations on biodiversity and ecosystems and follows the “No Net Loss” principle toward “Net positive impact.” This approach seeks to minimize and compensate for negative impacts on biodiversity through comprehensive environmental planning and commitments. Impacts are assessed based on potential habitat deterioration and specie disturbance, with preventive measures incorporated into project planning.

The main impacts regarding biodiversity and ecosystems are related to GHG emissions, terrestrial ecosystems use, and waste generation (for further information please consult section “SBM – 3: MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR INTERACTION WITH THE STRATEGY AND BUSINESS MODEL(S).”

Ferrovial recognizes its dependency on ecosystem services, which support its projects and operational resilience, mainly on natural resources, climate regulation and soil structure (for further information please consult section “SBM – 3: MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR INTERACTION WITH THE STRATEGY AND BUSINESS MODEL(S).”

The Company integrates biodiversity-related risks and opportunities into its business strategy by addressing physical risks (such as severe weather events and the condition of the ecosystem), as well as transition risks arising from regulatory changes and reputational aspects. To conduct the Company’s resilience analysis, material risks and opportunities are extracted from the priority or significant impacts and dependencies.

For further information, please consult the sections “Disclosure requirement ESRS 4 SBM – 3: Material issues, risks and opportunities and their interaction with the strategy and business model” and “Disclosure requirement E4 – 1: Transition plan and consideration of biodiversity and ecosystems in the strategy and business model”.

Ferrovial takes into consideration how impacts could potentially affect stakeholders, including affected communities, public authorities, and environmental organizations. This includes consultations with communities near sensitive areas to align conservation priorities and define avoidance or mitigation strategies. For further information consult sections ESRS 2 – IRO-1 and IRO-2 and “E4 – 2: POLICIES RELATED TO BIODIVERSITY AND ECOSYSTEMS”.

Where unavoidable impacts occur, the Company follows the Environmental Impact Assessments (EIA) for its projects (implementing different measures such as habitat restoration and other compensation measures) to maintain ecosystem functionality and value.

Scenario analysis is employed to anticipate and address biodiversity-related risks and opportunities over short, medium, and long-term horizons. This includes selecting scenarios aligned with scientific consensus and intergovernmental frameworks, such as the Convention on Biological Diversity (CBD) and IPBES, and periodically updates these scenarios to reflect evolving conditions and emerging trends. To address this resilience analysis, and in the absence of relevant standardized scenarios, the guidance provided by the TNFD was used. The scenario analysis proposed by the framework defines a series of plausible futures defined on the basis of critical uncertainties and based on compliance with the Kunming-Montreal Agreement.

Ferrovial operates in or near biodiversity-sensitive areas and evaluates the potential for its activities to affect habitats and species (further information included in the section “Disclosure requirement ESRS 4 SBM – 3: Material issues, risks and opportunities and their interaction with the strategy and business model”). For projects in such areas, the Company adheres to international and regional directives, such as the EU Birds Directive (2009/147/ EC), Habitats Directive (92/43/EEC), Environmental Impact Assessments (EIA), as per the EU Directive (2011/92/EU), and international standards. Mitigation measures—such as habitat restoration, invasive species control and adaptation of working plans—are implemented when necessary to ensure compliance with these regulations. Through its comprehensive processes and adherence to global standards, Ferrovial demonstrates its commitment to minimizing biodiversity impacts and safeguarding ecosystem services, fostering long-term sustainability and resilience across its operations.

Ferrovial does not have any activities related to the production and extraction of raw materials.

E4 – 1: TRANSITION PLAN AND CONSIDERATION OF BIODIVERSITY AND ECOSYSTEMS IN THE STRATEGY AND BUSINESS MODEL.

Ferrovial, aware of the key role played by biodiversity in the provision of services that support the economy and social welfare, understands its responsibility to nature and is committed to its protection and conservation.

In this way, the Company integrates nature issues into the Company’s strategy and decision-making, with a Biodiversity Policy integrated into the management system that governs the organizational and operational processes of all its contracts. The purpose of this policy is to define and establish the principles and criteria that govern actions with respect to biodiversity in the Company’s activities and value chain. This policy articulates the organization’s principles on:

• Conservation and protection of species and natural ecosystems
• Application of mitigation hierarchy criteria for negative impacts
• Responsible use of natural resources
• Fight against deforestation
• Application of nature-based solutions
• Integration of natural capital in risk management
• “No net loss”, working towards achieving “net positive impact”

The policy applies to all the Company’s activities and transfers its principles to its supply chain through the Supplier Code of Ethics. Based on its guidelines, natural capital and biodiversity are integrated into decision making, with a focus on identifying and analyzing dependencies, impacts, risks and opportunities.

Resilience assessment

Ferrovial, in order to analyze its resilience, has followed the TNFD recommendations and, for the appliaction of these, Ferrovial has developed a methodology based on the LEAP approach (Locate, Evaluate, Assess, Prepare). This methodology has a broad scope that includes both direct operations and the value chain, and focuses on the assessment of physical, systemic and transitional risks, also considering specific locations and priority areas for biodiversity and ecosystem conservation.

Firstly, Ferrovial identified its priority areas and for this purpose considered the infrastructures owned or with a long-term concession, and it evaluated their interaction with nature (with so-called sensitive areas). These infrastructures are linked to the Company’s different businesses (priority locations can be found in this report in the section “Disclosure requirement ESRS E4 SBM – 3: Material issues, risks and opportunities and their interaction with the strategy and business model”).

Impacts and dependencies are then identified and assessed using public tools such as ENCORE or WWF Risk Filter and the knowledge of the Company’s environmental experts. The impacts and dependencies were prioritized in order to identify the related risks and opportunities for all Company activities.

The analysis considered physical, transitional and systemic risks and the Company’s impact and risk management measures in the corporate strategy. The risk assessment was conducted following the Ferrovial Risk Management (FRM) process.

To address this resilience analysis, and in the absence of relevant standardized scenarios, the guidance provided by the TNFD was used. The scenario analysis proposed by the framework defines a series of plausible futures defined on the basis of critical uncertainties and based on compliance with the Kunming-Montreal Agreement. These scenarios are:

The scenarios were analyzed by taking into account three time horizons:

• Current status
• Medium term (2030)
• Long term (2050)

These horizons are used to assess nature risks, and are aligned with the horizons analyzed for climate risks. Thus, combining climate-nature interaction and enhancing the Company’s resilience.

In the risk management process, Ferrovial has several risks related to nature:

In addition to the mitigation measures mentioned above, the Company manages its risks and impacts through its FRM process, along with the specific measures detailed above. Ferrovial also has a biodiversity policy based on the conservation of species and ecosystems, the hierarchy of impact mitigation, the responsible use of natural resources and the integration of natural capital in risk management, which is guided by the principle of “no net loss,” working toward a “net positive impact”

Hypotheses formulated

The main hypotheses formulated by Ferrovial in relation to the resilience of its strategy and business model with respect to biodiversity and ecosystems are:

1. Impact on natural capital: Ferrovial’s projects and infrastructure are assumed to generate an impact on natural capital, including biodiversity and ecosystems. To minimize these impacts, the Company believes that it is possible to adopt measures that follow the mitigation hierarchy, from avoiding impacts, minimizing them, and restoring the affected ecosystems, to compensating those effects that cannot be avoided.
2. Mitigation hierarchy and “no net loss”: Ferrovial assumes that environmental management must be oriented to the principle of “no net loss” of biodiversity, working toward “net positive impact.” Under this hypothesis, it believes that negative effects on biodiversity can be neutralized through the effective compensation of impacts, which is integrated into the development of projects following de Environmental Impact Assessments (EIA), where applicable.
3. INCA methodology: The Company assumes that it is possible to effectively evaluate design and site selection alternatives through its INCA (Integrated Natural Capital Assessment) methodology. This tool is used to measure impacts on biodiversity and to assess options for minimizing them. The integrated natural capital analysis is deemed to allow for decision making that mitigates impacts on ecosystems.
4. Climate change as an additional factor: Climate change is considered to be an element that exacerbates the vulnerability of ecosystems and biodiversity. This hypothesis includes the evaluation of how future climate changes, such as extreme temperatures and changes in precipitation patterns, will affect biodiversity and, therefore, the resilience of the infrastructures that Ferrovial operates and manages.
5. Participation and consultation with local communities: Another relevant hypothesis is that the active participation of local communities and other stakeholders contribute positively to the planning and management of projects that impact biodiversity. Consultation and collaboration are considered fundamental to ensure an inclusive and sustainable approach.

These assumptions are integrated into Ferrovial’s sustainability strategy and project planning, ensuring that biodiversity-related risks are effectively managed to contribute to the long-term resilience of its operations and activities.

These results reflect Ferrovial’s commitment to sustainability and environmental protection, aligning its activities and operating processes with best practices to ensure the conservation of biodiversity and the resilience of its operations in the face of environmental risks.

Ferrovial’s Biodiversity Policy reflects the Company’s firm commitment to the conservation and protection of nature, aligning its operations with essential principles of “no net loss”. Ferrovial has adopted policies to address deforestation as part of its commitment to biodiversity and sustainability. Specifically, Ferrovial’s Biodiversity Policy includes the fight against deforestation as one of its key principles, carrying out actions to combat the deforestation associated with activities and the supply chain by committing to the restoration and reforestation of degraded areas and the acquisition of certified wood. Ferrovial will ensure that the principles set out in this policy are applied in all the subsidiaries in which it has holdings. In addition, the policy includes the conservation and protection of species and natural ecosystems, the application of the impact mitigation hierarchy and the responsible use of natural resources. Ferrovial strives to avoid, minimize and compensate for any negative impact on biodiversity, which includes activities that seek to combat deforestation and preserve ecosystems affected by its operations.

The Biodiversity Policy covers Ferrovial’s owned, leased or managed operating sites, including those located in or near biodiversity sensitive areas. The policy, approved by the Q&E Steering Committee, is integrated into the management system and governs the operational processes of all contracts.

This policy comprehensively addresses the Company’s main impacts and dependencies on the natural environment, such as:

• Impact on endangered species and protected areas.
• Land occupation and degradation resulting from construction and infrastructure activities.
• Dependence on key natural resources, such as water and ecosystem services related to climate regulation and soil structure (erosion).

The policy establishes the impact mitigation hierarchy as a central axis, which guides the Company’s actions toward the avoidance, minimization and compensation of environmental impacts, ensuring compliance with current regulations, including environmental impact statements (EIS) and other equivalent documents.

In addition, the policy integrates nature-related risks into the Company’s global risk management through the Ferrovial Risk Management model. In this way, biodiversity and natural capital management is incorporated in a structured manner into the organization’s strategy and decision- making, allowing for the proactive identification and mitigation of environmental risks.

With regard to the responsible use of natural resources, Ferrovial promotes eco-efficiency and guarantees the traceability of the products and raw materials used in its projects. As part of its commitment to the fight against deforestation, , the Company establishes the principle to acquire of certified wood, ensuring that the materials used come from sustainable and responsible sources.

The Biodiversity Policy also considers training, awareness and dissemination as key elements for the protection of biodiversity. Ferrovial promotes the education and awareness of stakeholders at all stages of its projects, ensuring that both employees and strategic partners understand and apply the principles of the policy. The Company also strengthens collaboration with different stakeholders such as governments, local communities and conservation organizations to develop global strategies and actions that promote awareness, conservation and protection of natural capital and biodiversity.

As indicated in its purpose, this policy defines and establishes the principles and criteria that govern actions with respect to biodiversity both in the Company’s activities and in the value chain. This is also reflected in the Suppliers’ Code of Ethics, which reinforces Ferrovial’s commitment to biodiversity conservation, particularly in sites considered sensitive.

In short, this policy reflects an integrated and strategic vision that combines the protection of nature, responsible resource management and continuous dialogue with stakeholders, effectively contributing to the sustainability of Ferrovial’s operations and the maintenance of the ecosystems in which it operates.

E4 – 3: ACTIONS AND RESOURCES RELATED TO BIODIVERSITY AND ECOSYSTEM

Ferrovial has adopted an active policy to address biodiversity, which includes specific measures to combat deforestation, and to protect and preserve protected areas and endangered species. As key principles to reduce the environmental impacts of its activities, Ferrovial also applies mitigation and conservation criteria in its projects to ensure the protection and recovery of affected ecosystems.

Specifically, the Company has implemented actions to address environmental challenges related to biodiversity and ecosystems. When a project has an Environmental Impact Assessments (EIA), Ferrovial carries out the measures indicated following the impact mitigation hierarchy, some of these measures being compensatory in nature. However, Ferrovial does not have any offsets related to targets. These main actions are carried out on an ongoing basis depending on the type of project.

Some of the main best practices are presented below:

Ferrovial Energy:

• Reduction of visual impact through the provision of a vegetation screen consisting of native scrub.
• Reuse of topsoil for land improvement, restoring the original shape and appearance of the land.
• Adaptation of the work plan to the possible presence of sensitive fauna: start work outside the breeding period of endangered species, no clearing during critical reproduction periods of the species, etc. Stoppage of work in the event that nests of protected species are found.
• Creation of habitats: ponds for amphibians and birds, construction of stone ponds for microfauna on the perimeter and within the grounds of an infrastructure such as a solar photovoltaic plant; placement of nesting boxes for different species of birds and bats.
• Ban the use of chemical products such as herbicides, insecticides, etc.
• Enclose the perimeter to allow the free circulation of wildlife.
• Create perimeter vegetation screens with native vegetation to interpose between observers and the infrastructure (e.g., a solar photovoltaic plant) that will also serve as a shelter and feeding grounds for different wildlife species.
• Minimize the area to be cleared to what is strictly necessary and restore and compensate for the vegetation removed when possible.
• Environmental restoration and replanting of all affected areas using native species.

Cadagua:

• Creation of wildlife and vegetation connectors.
• Replacement of vegetation cover on watercourses affected by the infrastructure.

Cintra:

• Restoration and regeneration of degraded areas: roadsides with native species.
• Creation of vegetation mosaics that promote the biodiversity of the area: promotion of both pollinator habitats and vegetation.
• Plantations that compensate for the extraction of vegetation from the infrastructure.
• Maintenance and monitoring of road perimeter fencing to prevent wildlife entry and collisions.

Ferrovial Construction:

• Shielding solutions to attenuate particularly noisy sources (specified according to the type of noise and source).
• Fences to prevent wildlife from approaching the work area.
• Adaptation of the work plan to the possible presence of sensitive fauna.
• Installation of animal shelters (e.g., for bats) and nesting boxes (encouraging breeding and reproduction of bird species).
• Use of low noise emission machinery.
• Creation of wildlife crossings in linear infrastructures that generate habitat fragmentation. At points where wildlife crossings are located at the crossroads of several road infrastructures, dissuasive elements will be installed to prevent wildlife from being directed in the funnel effect to these infrastructures and include call effect elements in the wildlife crossing.
• Design improvements on slopes susceptible to erosion (topographic, edaphic, revegetation) and use of plant debris (clearing and pruning) as soil protection cover against heavy rainfall.
• Habitat improvement plans for protected species in the area.
• Restoration and regeneration of degraded areas: roadsides, riverbanks… with native species. Creation of vegetation mosaic that promote biodiversity in the area.
• Plantations that compensate for the removal of vegetation from the infrastructure.
• Habitat enhancements for endangered species.

The following actions carried out in 2024 are of particular note:

• Vegetation preservation practices in I-35 NEX CENTRAL PROJECT (Texas, U.S.)

The I-35 NEX Central project is a design-build project in San Antonio (Texas) that consists of non-tolled elevated lanes and improvements along an existing interstate highway where workspace access is limited. Preserving green spaces along this heavily utilized interstate is a key focus.

In order to preserve as many green spaces as possible, early coordination was crucial during the design to identify viable preservation areas that would not hinder construction activities or final design plans.

Early coordination plays a pivotal role in successfully integrating vegetation preservation into a project, resulting in environmental benefits and positive impacts on the project’s financial performance. The main actions were preventive measures, such as the construction of 305 meters of orange fence and more than 100 signs to help delineate the areas in the field that were preserved and avoid any accidental removal of these preservation areas. The project successfully preserved 22,258 square meters of natural vegetation in total.

• Protection of the Greek tortoise (Testudo graeca) in the construction of the Murcia-Almeria High Speed Mediterranean Corridor Platform, Pulpí- Vera section

This is a strategic plan for the protection of this turtle (an endangered terrestrial reptile considered a protected species at national and European levels) in the project of the Murcia-Almeria High Speed Mediterranean Corridor Platform, Pulpí-Vera section of about 26 km. The ecosystem in which this infrastructure is located is mostly agricultural, although it has bushes and small shrubs, habitats of this turtle. This protection plan began in 2019 and continues to date.

The actions implemented over the course of these years were:

• Determine the potential area of distribution of the species: specific report on the situation of the species and the area of its habitat that could be affected (approximately 8 kilometers of the route and 170,985 square meters through loans that were converted into 10 protection zones).
• Temporary fencing of the species: preventing individual specimens from returning to the work area from the start of the rescue phase that will be maintained until the end of the works phase. The fence is approximately 30,000 meters in size. In 2024, this fence was maintained several times, taking into account the period of greatest activity of the species, in areas where active work and high turtle density coincided. These points were specifically the sub-areas of Fuente Flores, Jatico, Cabuzana, Desert Spring and Media Legua.
• Rescue of Testudo graeca specimens: a permit was obtained for handling protected species and the potentially affected specimens were rescued, marked and registered. If the specimen was injured or showed symptoms of illness at the time of rescue, it was transferred to a recovery center.
• Training and awareness-raising: training campaigns were given to all site personnel on how to proceed and the protocol to follow when specimens are found. In addition, informative posters have been used to disseminate the protocol for action in the event of a chance discovery and to highlight the importance of this protected species. In 2024, informative posters were installed to disseminate the action protocol in the event of a chance find and to highlight the importance of this protected species.
• Biological stoppage: establishment of a period of mandatory restrictions on certain activities on site, during the period of greatest biological activity of the fauna in the area, which involves both Testudo graeca and Bucanetes githagineus and other steppe birds.
• Periodic inspections: The site’s Environmental Technician performed periodic on-site inspections to ensure compliance with environmental requirements, including the protection of Testudo graeca. During 2023 and 2024, the inspections were intensified to a weekly frequency, given that the exploitation of the loans began, and a check list was implemented which includes the review of the condition of the fencing in these areas and any chance discoveries, if they should occur.

These actions prevented any impacts to a large number of specimens. So far, 313 specimens have been rescued and translocated between prospecting and rescue work.

These habitat restoration measures follow the TNFD guidelines and aim to promote the goals of the Kunming-Montreal Global Biodiversity Framework (GBF) agreement, the European Regulation on nature restoration, the directives associated with the Natura 2000 Network, among others.

Specific local knowledge was taken into account regarding the species to be protected and promoted, as well as the design of the areas to ensure that the local community can enjoy them. However, due to the location of the actions, no indigenous populations were located.

These actions are part of Ferrovial’s broader commitment to sustainability and the preservation of the natural environment, in line with its sustainability strategy and the fight against climate change.

Currently 235 people work in the different Quality and Environment departments of Ferrovial and its subsidiaries, which represents an approximate expenditure of 17.98 million euros.

E4 – 4: TARGETS RELATED TO BIODIVERSITY AND ECOSYSTEMS

Ferrovial has established several targets related to biodiversity and ecosystems as part of its Sustainability Strategy and Biodiversity Policy. Nature intrinsically encompasses all environmental issues that are crucial for the sustainability of the planet and, ultimately, for the conservation and protection of ecosystems. In other words, nature not only includes, but interconnects all environmental issues.

Ferrovial therefore set several targets associated with different environmental aspects that are drivers of change in the state of nature. These targets are related to GHG emissions reduction, neutralization of 100% of residual GHG emissions by 2050 with carbon sinks, water footprint objectives and objectives related to the circular economy and efficient use of resources (for further information consult sections E1-4, E3-3 and E5-3). In addition, the Company set specific nature-related targets:

1. Alignment with the Task Force on Nature-related Financial Disclosures (TNFD) for FY2025: Since Ferrovial has a commitment to fight against deforestation, and protect and conserve species and ecosystems (Biodiversity Policy principles and objectives) Ferrovial committed as an Early Adopter of the TNFD recommendations, to be able to analyze its interaction with nature (in its own operations and in its value chain), setting itself the target of complying with these requirements by financial year 2025.

As this is not a quantitative target, it does not have a baseline year, but a target of completing this exercise by FY2025, and it is reviewed annually.

2. Resilience analysis of 100% of the projects over which Ferrovial has operational control in the ADAPTARE tool, annually.

One of the Biodiversity Policy principles is the risk assessment and the resilience analysis of the Company. In order to achieve this, Ferrovial set a target to ensure that all the projects under its operational control are analyzed annually by ADAPTARE.

For further information regarding ADAPTARE methodology and scientific bases, consult section “Disclosure requirement ESRS E1 SMB – 3: Material issues, risks and opportunities and their interaction with strategy and business model.”

This target is reviewed annually and, due to the nature of the target, there are no milestones, interim targets or baseline year. In 2024, Ferrovial analyzed 100% of the projects over which the Company has operational control.

3. Application of the “Go – No go” procedure to 100% of the projects of the subsidiaries controlled by Ferrovial when they exceed a significant budget.

Since Ferrovial has a commitment regarding the protection and conservation of species and ecosystems (Biodiversity Policy principles and objectives) and has an impact related to the occupation of protected areas, Ferrovial set a target to define a series of environmental criteria to be considered when making decisions about whether or not to execute a new project. In this way, the validity of the location of the project in the context of certain protected areas is evaluated (for further information regarding this procedure, please, consult section “Disclosure requirement ESRS 4 SBM – 3: Material issues, risks and opportunities and their interaction with the strategy and business model”).

This target is reviewed annually and, due to the nature of the target, there are no milestones, interim targets or baseline year.

These targets are aligned with the Company’s Sustainability Strategy. In addition, they are under continuous development to establish other targets that may be relevant for Ferrovial and nature.

The Company has assessed and aligned the objectives to significant impacts, dependencies and risks such as:

• Impact on GHG emissions
• Protected areas occupation
• Impact on protected species affection
• Dependence on climate regulation
• Dependence on water
• Dependence on flood and storm protection and mass stabilization

The biodiversity and ecosystem targets are directly linked to the most significant aspects extracted from the double materiality assessment, which in turn took into account the participation of stakeholders (as described in the section “Disclosure Requirement ESRS 4 IRO – 1: Description of processes for identifying and assessing significant impacts, risks, dependencies and opportunities related to biodiversity and ecosystems”).

In order to develop its objectives, Ferrovial took into account The Kunming-Montreal Global Biodiversity Framework (GBF); however, no ecological thresholds were applied. The Company is working on aligning the TNFD to establish other targets that may be relevant, as well as the possibility of using Science-based targets for nature (SBTNs).

The Company did not use biodiversity offsets when setting targets.

Further information regarding these targets can be found in “Disclosure Requirement E1 – 4: Targets related to climate change mitigation and adaptation”, “Disclosure requirement E3 – 3: Targets related to water and marine resources” and “Disclosure requirement E5 – 3: Targets related to resource use and circular economy”.

E4 – 5: IMPACT METRICS RELATED TO BIODIVERSITY AND ECOSYSTEM CHANGES

The indicators related to the main impacts are:

• Species appearing on the IUCN Red List and national conservation lists whose habitats are in areas affected by operations.

• List of protected and/or sensitive areas and location of properties and construction sites located in protected areas and Ferrovial’s management of impacts on them (as reported in section “SBM – 3: Material issues, risks and opportunities and their interaction with the strategy and business model”).
• Restoration actions relevant to the habitat entity or the uniqueness of the restoration: Ferrovial carries out the ecological restoration of habitats affected by the construction and operation of its infrastructures in accordance with the regulations in force in each country, introducing improvements wherever possible over and above the minimum requirements.

In 2024, Ferrovial has developed more than 80 restoration actions (for further information, please, consult section “Disclosure Requirement E4 – 3: Biodiversity and ecosystem actions and resources”).

• Projects with environmental impact statements or equivalent document: In 2024, Ferrovial worked on 42 new projects (54 in 2023) subject to environmental impact statements (or equivalent document), according to the legal framework of each country.
• Scope 1, 2, and 3 GHG emissions (as reported in ESRS E1- 6).
• Energy consumption (as reported in ESRSE1- 5).
• Water footprint objectives (as reported in ESRSE3- 4).
• Waste and reused soils (as reported in ESRSE5- 5).

Priority locations

Ferrovial has identified priority areas (detailed in section “Disclosure requirement ESRS4 SBM – 3: Material issues, risks and opportunities and their interaction with the strategy and business model”) following the recommendations of the TNFD and the LEAP methodology, analyzing whether they were located within or near sensitive areas for biodiversity. Ferrovial has 23 sites within or near protected or key biodiversity areas, totaling 53.3 square kilometers.

Land-use change

Since Ferrovial’s activities have an impact on land occupation, the Company could generate land use changes; however, it depends on the type of role it has in the project. If the Company does not have a developer role, land use change would not be considered the Company’s responsibility since it does not have decision-making power in the location and design of the infrastructure. Most of the locations where the Company operates in a decision-making role do not generate significant changes in land use, as the projects are mainly located in urban areas.

For those locations outside urban areas, the Company’s main land use changes over time range from cropland to settlements and, to a lesser extent, from grassland or forest land to settlements.