The home building industry is carbon-intensive, with emissions concentrated in the upstream production of building materials and the downstream energy use of homes, which accounts for about 20% of U.S. greenhouse gas (GHG) emissions.[1] To reduce the magnitude of these emissions, the residential sector is increasingly the focus of climate-related regulations that require low-carbon energy sources and increased energy efficiency in newly built homes. Home customers, too, are demanding more energy efficient homes to reduce their energy costs, and investors continue to value companies with clear climate-related disclosures and low carbon transition plans.

NVR, a leading residential construction company operating across 16 states, has not set GHG reduction targets. It also fails to disclose its GHG emissions – information critical to determining the Company’s progress in reducing its exposure to climate-related risks and demonstrating its regulatory readiness and competitiveness with peers.

Rising State Regulations

Municipal and state governments are increasingly adopting climate-related building regulations, including restrictions on gas appliances in new homes.[2] Many states are also tightening their clean energy standards and emissions disclosure requirements. California’s first GHG disclosure requirements will go into effect in 2026.[3] In its SEC filings, NVR acknowledges that climate-related regulations are a potential material risk factor,[4] yet, it fails to provide emissions disclosure to assist investors in evaluating the Company’s climate risk and transition progress.

Competitors’ Disclosures Highlight NVR’s Disadvantage

NVR’s lack of emissions and transition planning disclosure also prevents investors from evaluating its performance against competitors. D.R. Horton reports operational emissions, while PulteGroup, Taylor Morrison Homes, and KB Home disclose both their operational and value chain emissions.[5] Additionally, while NVR states that it uses certain energy-efficient appliances and, in 2024 disclosed the average energy efficiency of its homes,[6] those homes lagged the energy efficiency scores of peers including PulteGroup, Taylor Morrison Homes, and KB Home.[7]

NVR’s lack of transparency denies investors the ability to adequately assess its climate-related risk and its ability to take advantage of market opportunities at a time when capital markets are increasingly demanding such information. By disclosing its year-on-year emissions, NVR can demonstrate its competitiveness, responsiveness to regulatory risk, and provide investors with confidence that the Company is prepared to thrive in a low-carbon economy.

[1] https://www.pnas.org/doi/10.1073/pnas.1922205117?utm_=

[2] ttps://buildingdecarb.org/zeb-ordinances

[3] https://ww2.arb.ca.gov/our-work/programs/california-corporate-greenhouse-gas-ghg-reporting-and-climate-related-financial

[4] https://nvri.gcs-web.com/static-files/92d90ad3-e063-4f95-9be7-44cd24a16bbb, p.8

[5] https://investor.drhorton.com/~/media/Files/D/D-R-Horton-IR/documents/fy23-dr-horton-inc-esg-report.pdf, p.79; https://s204.q4cdn.com/680895981/files/doc_downloads/2024/2024_Sustainability_Report_v-4.pdf, p.16; https://s27.q4cdn.com/448041563/files/doc_downloads/2025/07/9644-BMC-ESG-2024-051925-digital.pdf, p.51; https://s201.q4cdn.com/124745054/files/doc_downloads/2025/04/21/2024-Sustainability-Report_FINAL.pdf, p.53

[6] https://nvri.gcs-web.com/static-files/9d8e2a96-ce6f-440b-a245-60892ad2b323, p.9

[7] https://www.pulte.com/energy-star-builder; https://s27.q4cdn.com/448041563/files/doc_downloads/2025/07/9644-BMC-ESG-2024-051925-digital.pdf; https://investor.kbhome.com/environmental-social-and-governance-esg/environmental/default.aspx