SB 261 Disclosure

Fenwick & West conducts forward-looking climate risk modeling across its office portfolio using standardized scenarios aligned with the Intergovernmental Panel on Climate Change (IPCC) Representative Concentration Pathways (RCPs). The analysis evaluates both:

• RCP 4.5 (Moderate Emissions Scenario): Assumes moderate greenhouse gas mitigation efforts and climate stabilization by mid-century.
• RCP 8.5 (Business as Usual Scenario): Assumes continued high emissions without significant policy intervention.

Risks are assessed across three planning horizons to capture both near-term operational and long-term strategic implications:

• Near-term (2025): Baseline current conditions and immediate adaptation needs.
• Mid-term (2030): Risks materializing within strategic planning cycles and typical lease renewal periods.
• Long-term (2050): Risks affecting long-term real estate strategy, owned asset values, and market viability.

Each office location is evaluated for exposure to seven key climate hazards: extreme heat, drought, hurricanes and tropical storms, sea level rise and coastal flooding, inland flooding, wildfire proximity, and water stress. Locations receive a risk rating (Low, Medium, High, Very High) for each hazard across the scenario-time horizon combinations, creating a matrix of potential future conditions.

The Risk Identification assessment process involves multiple steps:

• Asset-Level Screening: Locations are geocoded and evaluated against climate hazard datasets that project future conditions under RCP 4.5 and 8.5 scenarios. This includes factors such as projected maximum temperatures, precipitation extremes, storm surge modeling, and groundwater depletion rates.
• Exposure Quantification: This risk assessment was performed using headcount by office as the best available proxy to risk but does not necessarily reflect the firm's understanding of its material risks.
• Scenario Comparison: By comparing risk ratings across RCP 4.5 and RCP 8.5 scenarios, risks that are potentially mitigable through global emissions reductions versus those that are "locked in" regardless of climate policy outcomes are identified.
• Time Horizon Analysis: The firm tracks how risks evolve from baseline (2025) through mid-term (2030) to long-term (2050), identifying locations where currently low risks escalate to medium or high ratings. These "emerging risks" require proactive adaptation planning before they materialize.
• Severity and Likelihood Integration: Each risk rating incorporates both the physical severity of potential climate impacts and the likelihood of occurrence within each time horizon.

Beyond physical hazards, the Firm evaluates transitional risks stemming from policy, regulatory, market, technology, and reputational factors associated with the transition to a low-carbon economy. This includes assessing exposure to energy volatility, carbon pricing, evolving building codes, client and employee sustainability and disclosure expectations. In 2025, Fenwick & West developed a climate risk management framework, including annual climate risk assessments conducted with cross-functional workshops by Greenplaces. Identified risks are being incorporated into a firm-wide Enterprise Risk Management system, which includes third-party vendor assessments and an Emergency Action Plan. The firm also reviews climate-related risks and opportunities in office operations and construction and integrates initiatives during annual budgeting to reduce resource dependency and environmental impacts. In addition, the Firm's voluntary participation in programs such as CDP, pro bono work, and ongoing investments in and protection of office spaces further mitigate potential climate-related exposures.

Below are the risks and opportunities identified over the short-, medium-, and long-term under RCP 4.5 and RCP 8.5 scenarios.

Risks

• Certain offices are exposed to High physical risks in all time horizons and scenarios
• Increased compliance costs and possible penalties for non-compliance with government sustainability initiatives
• Increased market demands for climate-related action from clients and competitive pressure from other Firms
• Increased costs for enhancements to IT infrastructure and cloud migration

Opportunities

• Regularly review and revise the firm's Emergency Action plan and insurance coverage while reinforcing the firm's commitment to occupying LEED-certified, high-performance office buildings.
• Proactively address both regulatory and client climate-related requirements through the Firm's sustainability program
• Build resilience by working with suppliers on climate adaptation measures, exploring sustainable sourcing options, and scaling partnerships that reduce exposure to climate-related disruptions.
• Continue to grow advisory capabilities in ESG and Climate Tech

In particular, the Firm anticipates that risks associated with extreme heat and coastal flooding may rise relative to current baseline conditions. With respect to transition risks, the Firm will continue to closely monitor emerging and forthcoming climate-related legislation, regulatory requirements, and industry standards to ensure ongoing compliance. Fenwick & West will also evaluate any future developments that may necessitate updates to its existing policies, procedures, or operational practices. By contrast, the Firm does not expect the relative risk profile for hurricanes at its office locations to change based on currently available data and modeling inputs.

Fenwick & West is assessing how climate-related risks, particularly rising energy and insurance costs in markets such as Silicon Valley, New York, Santa Monica, and Washington, DC, may impact its financial position and business continuity. Increasing exposure to extreme heat, hurricanes, and wildfires in these locations may influence real-estate strategy, operational resilience measures, and quality-of-life considerations for talent. Clients are placing growing emphasis on climate preparedness, making strong climate resilience an emerging competitive differentiator. At the same time, climate change is creating opportunities for practice growth in areas such as real estate transactions, insurance coverage disputes, and infrastructure-related regulatory and financing work.

The firm's resilience strategy is rooted in its established business continuity framework, which is being reviewed and tested to ensure stable operations under both RCP 4.5 and RCP 8.5 scenarios. As a technology-focused professional services firm with limited direct exposure to physical climate impacts, the Firm is well positioned to maintain core service delivery during periods of acute or chronic climate stress. The Firm's growing Climate Tech and ESG advisory capabilities, along with its advanced internal sustainability practices, further strengthen preparedness by embedding climate considerations into strategic planning, facilities management, procurement, and client service. Together, these measures enhance Fenwick's ability to continue operations, protect personnel and assets, and support customers during climate-related outages.

Fenwick & West systematically monitors its office locations for exposure to climate risks and integrates this analysis with personnel metrics at each site. By linking climate vulnerability with personnel data, the reporting Firm is able to identify which offices may face the greatest potential financial impact from climate-related hazards. This approach enables the firm to prioritize resilience planning, allocate resources more effectively, and proactively manage risks to both operations and long-term financial stability.

Fenwick & West measures its Scope 1, Scope 2, and Scope 3 emissions annually and reports through CDP. Risks associated with emissions include potential regulatory costs, reputational pressures, and changes in client or supplier expectations as carbon reporting becomes increasingly standardized. This FY2024 emissions footprint has not undergone 3rd party assurance, but was prepared with the assistance of a specialized GHG software & services provider.

Fenwick & West does not currently have any climate-related targets, but may consider setting them in the next two years.