Annual report 2024 | Sustainability statement 29 SUSTAINABILITY STATEMENT Consolidated non-financial information and sustainability information statement Annual report 2024 | Sustainability statement 30 Contents 1. Sustainability at Santander ............................................................................................................................. 31 1.1 Basis for preparation .................................................................................................................................. 31 1.2 Sustainability strategy ................................................................................................................................ 32 1.3 Stakeholder engagement ........................................................................................................................... 36 1.4 Materiality assessment ............................................................................................................................... 37 1.5 Sustainability governance ........................................................................................................................... 41 2. Environmental Information: E1 Climate Change .............................................................................................. 57 2.1 Policies related to climate change mitigation and adaptation .................................................................... 58 2.2 Developing the Group’s transition plan ...................................................................................................... 59 2.3 Supporting customers’ transition to a low carbon economy ....................................................................... 66 2.4 Environmental footprint.............................................................................................................................. 67 2.5 EU Taxonomy .............................................................................................................................................. 69 3. Social Information: S1 Own workforce .............................................................................................................. 85 3.1 Policies related to own workforce ............................................................................................................... 86 3.2 Employee-related governance .................................................................................................................... 87 3.3 Employee engagement ............................................................................................................................... 88 3.4 Working conditions ..................................................................................................................................... 89 3.5 Equal opportunities for all ........................................................................................................................... 94 3.6 Talent and skills development ..................................................................................................................... 95 3.7 Characteristics of the Group’s employees ................................................................................................... 96 4. Social Information: S4 Consumer and end-users .............................................................................................. 98 4.1 Policies related to consumers and end-users ............................................................................................. 99 4.2 Conduct with customers ........................................................................................................................... 100 4.3 Privacy, data protection and cybersecurity .............................................................................................. 103 5. Governance Information: G1 Business conduct .............................................................................................. 105 5.1 Business conduct policies and corporate culture ...................................................................................... 106 5.2 Ethical conduct .......................................................................................................................................... 108 5.3 Ethical channels ........................................................................................................................................ 110 5.4 Suppliers ................................................................................................................................................... 111 6. Independent verification report ..................................................................................................................... 112 Annual report 2024 | Sustainability statement 31 1. Sustainability at Santander 1.1 Basis for preparation i. Basis for preparation This sustainability statement is issued by Santander Consumer Bank AS. It has been prepared in accordance with the requirements of the Norwegian Accounting Act and provides consolidated non-financial information relating to the organization’s progress on Environmental, Social and Governance (ESG) matters for the financial year 2024. The report relates to the activities of Santander Consumer Bank AS (organization number: 983521592) from 1 January to 31 December 2024. The sustainability statement forms part of the consolidated directors’ report and has been approved by the Board of Directors on February 24, 2025. Santander Consumer Bank AS is a Norwegian commercial bank that holds a banking license granted and regulated by the Financial Supervisory Authority of Norway, and which also operates in Sweden and Denmark, with a wholly owned subsidiary in Finland, collectively referred to as “the Group”. The subsidiary in Finland is exempt from individual sustainability reporting as it is consolidated into the Group’s reporting. The Group is a fully owned subsidiary of Santander Consumer Finance S.A., which in turn is owned by Banco Santander S.A. The scope of this statement is the same as for the financial statements and sustainability-related data is consolidated according to the same principles as for the financial statements. The sustainability statement is prepared in accordance with the European Sustainability Reporting Standards (ESRS) issued by the European Financial Reporting Advisory Group (EFRAG) as part of the European Commission’s Corporate Sustainability Reporting Directive (CSRD) specifically under Commission Delegated Regulation (EU) 2023/2772, and Taxonomy Regulation (EU) 2020/852 and supplementing delegated acts. The disclosures and data points in the Environment, Social and Governance chapters have been assessed as material according to the Group’s Double Materiality Assessment (DMA). ii. External validation PricewaterhouseCoopers AS, an independent firm charged with auditing the financial statements of Santander Consumer Bank AS, has issued a verification report, with limited assurance, on the non-financial information required under ESRS found in this sustainability statement. The assurance conclusion can be found in the “Independent verification report” at the end of this statement. Annual report 2024 | Sustainability statement 32 1.2 Sustainability strategy The Group’s purpose is to help people and businesses prosper, and its aim is to be a leading Nordic consumer finance platform by acting responsibly and earning the lasting loyalty of employees, customers, shareholders and communities. The Group’s sustainability strategy focuses on issues that are considered as material to the Group, i.e. those areas that pose the biggest risks to or create the best opportunities for the Group; and those where the Group can have the biggest impact. It is centered around the three pillars of Environment, Social and Governance and consistent with the Group’s Double Materiality Assessment results. The strategy was approved by the Board of Directors in May 2023. An overview of the Group’s sustainability strategy To further implement the Group’s strategy, the three strategic pillars have been mapped to the Group’s value chain and the main topics outlined in the Group’s Responsible Banking Model. The Group’s sustainability strategy is integrated into its strategic and financial planning activities, which are reviewed annually and promoted through the annual three-year financial planning and budget processes. Furthermore, sustainability aspects are included the Group’s annual goals and objectives. In 2024, specific focus was placed on ensuring compliance with ESG-related regulatory requirements and continuing work to embed ESG in the organization. The Group’s ESG priorities and sustainability agenda are updated and approved by the Board of Directors annually. In 2024, key priorities included: • Progressing decarbonization of the Group’s portfolios to align with net zero (E). • Continuing to ensure human rights and good working conditions in the Group’s own workforce and conducting due diligence throughout its value chain (S). • Reinforcing reporting capabilities and ensuring readiness towards compliance with regulatory, supervisory and stakeholder expectations (G). The Group follows a risk management control model to identify, evaluate and monitor those risks that can have a significant impact on its business model profitability or solvency, ensuring the resilience of its strategy. More details are in section 1.5 Sustainability governance. 3 Strategic Pillars Ambition Strategic Actions E Support the transition to a low carbon economy Deliver on the Net zero ambition by 2050. • Set targets in our portfolios to align with pathways to net zero, while taking into consideration other environmental goals as Nature. • Support customers in their transition, engaging with them and developing a best-in-class sustainable finance and investment proposition. S Promote inclusive growth Support inclusive growth across main stakeholders: employees, customers and communities. • Diverse and inclusive workplace that fosters employees’ wellbeing. • Support financial inclusion and financial health promoting access to financial products and services and offering financial education. • Support communities, with focus on Education, Employability and Entrepreneurship. G Strong governance and culture across the organization Incorporate ESG in behaviors, policies, processes and governance throughout the Group. • Drive culture, conduct and ethical behavior. • Integrate ESG into strategic processes, Risk Management and other relevant units and continue building capabilities within the field. Annual report 2024 | Sustainability statement 33 Climate strategy The Group’s climate strategy is aligned with that of its owner, Banco Santander, and its ambition to be carbon net zero by 2050. Banco Santander is making headway by progressing in its climate strategy, helping to fulfill the commitments made as a founding member of the Net Zero Banking Alliance (NZBA, under the United Nations Environment Program Finance Initiative). As part of its climate strategy, a need to scale up activities and demand for climate transition finance across the real economy; whilst also improving the risk-return profiles of these investment opportunities, has been identified. Banco Santander’s climate strategy guides the Group’s approach to supporting its Nordic customers’ sustainability transition and the achievement of its net zero by 2050 ambition. How the Group supports and executes on Banco Santander’s climate strategy is illustrated in the figure below. Nordic implementation of Banco Santander’s climate strategy Aligning portfolios with the Paris Agreement goals Contribute to limiting temperature increases to 1.5°C in line with the NZBA and NZAMi Supporting customers in the green transition Support customers’ transition to a low carbon economy, offering guidance, advice and investments and business solutions. Reducing environmental impact Remain carbon neutral and consume electricity from renewable energy Embedding climate into risk management Manage climate and environmental risk according to regulatory & supervisory expectations. • Manage the environmental impact of financing activities. • NZBA emissions target setting initiatives in the Group’s Auto portfolio. Offer sustainable financing propositions: • Auto Financing BEVs & PHEVs. • Solar panels and other green home improvements. • Bicycles and E-bikes. • Manage the environmental impact of the Group’s own activities. • 100% renewable electricity in the Group’s offices. • Improve data on business travel and staff commuting. • Embed ESG risks into the Group’s EWRM processes. • Exposure monitoring by sector and emissions. • Integrate risks and opportunities. Customer groups, products and services During 2024, the Group served over 1.2 million customers in 4 markets: Norway, Sweden, Denmark and Finland. The Group’s customer base includes individuals, SMEs and corporates, all with varying financial needs and expectations. The Group seeks to meet those needs through simple product and service propositions in Auto, Consumer, Insurance and Deposits. The Group’s activities are organized under Grupo Santander’s global Digital Consumer Bank division. As of December 31, 2024, the Group had 1 362 employees, distributed as follows: 617 in Norway, 327 in Sweden, 251 in Denmark and 167 in Finland. The Group serves its customers and partners through its open financial services platform. Its business model and strategy are connected to impacts, risks and opportunities related to consumers and partners, which have been assessed and are described in more detail in section 1.4 Materiality assessment. The Group is supporting the green transition as a leader in electric vehicle (EV) financing — NOK 14.2 billion in EV financing in 2024, with a market share of 9.2% in the Nordics. This contributes to the decarbonization of the Group’s auto financing portfolio. The Group aims to bolster its sustainable finance propositions and maintain its EV market share over time. A description of the actions and challenges to support this aim is included in section 2.2 Developing the Group’s transition plan. The Group does not have significant exposure to concerning sectors listed under SMB-1 40 (d). Annual report 2024 | Sustainability statement 34 Time horizons In preparing this sustainability statement (including the Double Materiality Assessment) the Group has used the following time horizons: • One year for short term (this is the standard time horizon for the short term in the Group); • One to five years for the medium term (broadly corresponding to the Group’s financial planning timelines); • More than five years for the long term (aligned with the Group’s strategic plans). Value chain The Group’s defined value chain considers the consolidation scope for the Group’s annual reporting and is split into three main groups (upstream, own operations and downstream). To define the value chain, the Group considered Regulation 2022/1464 (paragraph 33); Delegated Regulation 2023/2772 (ESRS 1); and the EFRAG Value Chain Implementation Guidance. Upstream: Set of activities or processes carried out by organizations that are part of the Group’s upstream phases and that provide products or services that are used for the development and marketing of the Group’s products and services. This includes organizations with which the Group has a direct and indirect commercial relationship. • Financial institutions: Monetary institution and public entities responsible for setting monetary policy that will impact on the Group; regulating currency circulation; supervising the interbank market in which the Group operates; and providing liquidity, where required, for solvency purposes. For instance, the European Central Bank. • Investors that provide funding aligned to the Group’s self-funding strategy, and additionally the Group’s shareholder Santander Consumer Finance S.A., in turn owned by Banco Santander S.A. • Product and service vendors: Companies that provide products and services that are subsequently marketed in later phases of the Group’s value chain or used to carry out its operations. For instance, insurance companies (e.g. suppliers of products that are marketed in the Group’s downstream phase), technology providers, external audit and consulting service providers, materials suppliers and office landlords. Own operations: Activities that the Group’s functional areas and employees carry out in its markets and subsidiaries. • Assets: Assets that the Group owns. • Geographies: Places where the Group carries out its operations, specifically Norway, Sweden, Denmark and Finland. • Cross-cutting areas/functions: Departments and areas within the Group whose function is to manage and develop the Group’s operations. For instance, Compliance, Risk, Strategy, People and Culture, Sourcing. Downstream: Commercial relationships, including retail partners, as well as the financial products and services that the Group markets to meet the needs of its customers and end users for the benefit of the communities the Group operates in. The extent to which the sustainability statement covers the Group’s value chain is disclosed in E1-6 (Scope 3 GHG emissions), S4 (Consumers and end-users) and G1-2 (Management of relationship with suppliers). Annual report 2024 | Sustainability statement 35 Sources of estimation and outcome uncertainty E1-6 Scope 2 GHG emissions and Scope 3 Value Chain estimations Metric Basis of preparation Degree of accuracy Actions to improve accuracy Gross location-based Scope 2 GHG emissions (tCO2e) Consumption of purchased heating and cooling (kWh) assessment and data limited to usage in Norway. Currently limited to office locations in Lysaker and Stavanger, Norway. Discussions with the Group’s landlords to improve data scope and quality. Scope 3.1 Purchased goods and services Scope 3.2 Capital goods Scope 3.4 Upstream transportation and distribution Scope 3.9 Downstream transportation and distribution Supply chain emissions are calculated using a spend-based approach considering the payments to the Group’s suppliers in the current year. For that non primary data obtained from suppliers has been used. These are calculated using the Supply Chain Greenhouse Gas Emission Factors v1.3 from the U.S. Environmental Protection Agency. Significant estimate. Supplier taxonomies are mapped to sectors and converted into emissions through spend-based emissions factors. Then, different spending taxonomies are grouped based on the GHG scope 3 categories based on their nature. The Group is working on ways to increase granularity of information and implement any updates to methodology in alignment with Banco Santander in the future. Scope 3.6 Business travel by car Assessment based on Banco Santander proxy information for diesel and petrol car business travelling based on surveys for Santander’s largest 10 units. Significant and conservative estimate given Nordics has a higher share of Electric Vehicles compared to Banco Santander proxy data. The Group is investigating ways to capture accurate car business travel from employees in Nordics. Scope 3.7 Staff commuting Assessment conducted through survey of the Group’s employees conducted in Q4 2024. Considered accurate to a high degree with approximately 24% of employees responding to the survey. Further scoping of survey methodology to be developed in alignment with Banco Santander. Scope 3.15 Financed emissions Estimation based on data obtained from the 2023 auto passenger car portfolio, being the largest portfolio available. Obtaining emissions data from the Group’s customers is a challenge. As requirements to disclose more non- financial information increase world- wide, the quality of the Group’s reporting on financed emissions will improve. The Group is working on improving the scope and automatization of the calculation of financed emissions to enhance the way it tracks progress against targets. G1-6 Business Conduct Metric Basis of preparation Degree of accuracy Actions to improve accuracy Average time to pay an invoice Calculated by extracting all invoices paid in 2024 from the Group’s ERP system and calculating the days between invoice date and payment date for all invoices. Significant estimate with data outliers removed to calculate the average. The Group will continue to develop and strengthen its calculation methodology to report this metric more accurately in subsequent reports. Annual report 2024 | Sustainability statement 36 1.3 Stakeholder engagement The Group regularly engages with its main stakeholder groups on a range of topics through dedicated channels of communication, reports, events and industry initiatives. Listening to stakeholders is key to understanding their concerns, setting priorities, and spotting opportunities and areas for improvement. Views of internal and external stakeholder groups are incorporated into key processes such as strategy development, financial planning and evaluation of strategic initiatives. In 2024, the Group specifically engaged with employees, senior management and its Board of Directors through local sustainability surveys to inform its due diligence and Double Materiality Assessment (DMA). The results from this assessment will be an important input into future strategic discussions. The Group’s main approach for engagement during 2024 is described below for its various stakeholder groups. Customers – surveys and complaint channel: • Surveys to measure customer experience and identify improvement areas. In 2024, the Group conducted a series of representative surveys in its markets, among them a YouGov-survey on mobility, resulting in a Nordic Auto Report focusing on people's view on mobility. Insight is used to better understand the Group’s customers and the markets it operates in. • Complaints handling system to carry out root-cause analysis and apply learnings from customer complaints. Communities – direct and indirect dialogue and surveys: • The Group obtains information from individuals and Non-Governmental Organizations (NGOs) to understand the needs and challenges of the communities where the Group operates. Santander engages in two-way communication with several organizations in its markets, most notably on environmental and social affairs. In 2024, this included participation in Arendalsuka in Norway – bringing together NGOs, decision makers and companies from all industries. Investors – direct and indirect dialogue: • The Group engages with investors through direct contact on specific transactions, and through the publication of reports and statements related to ESG. Engagement is necessary to provide capital to fund the Group’s operations and growth, particularly in ESG and green finance. Regulators – dialogue and monitoring: • The Group maintains dialogue with regulators, as well as monitors for updates from public authorities relevant to its ESG work. Additionally, in 2024, the Group participated in sustainability-related industry working groups including FINFO in Norway. Employees – two main listening tools: • Your Voice (survey): Tool for collecting employee feedback. Employees can provide feedback and leave comments while remaining anonymous. Managers can access the results and identify areas of greatest risk and factors related to higher engagement. • Canal Abierto: An anonymous and confidential channel for employees to report unethical conduct and breaches of the Group’s Code of Conduct. This channel also receives reports from vendors, customers, investors and other third parties from time to time. Senior management & Board of Directors – dialogue, decision making and surveys: • Senior management and the Board of Directors define and approve the Group’s Sustainability agenda on an annual basis and take an active approach to track progress and stay informed through regular updates, discussions and decision making. Annual report 2024 | Sustainability statement 37 1.4 Materiality assessment i. Identification of material matters In 2024, The Group conducted a Double Materiality Assessment to identify the sustainability matters where the Group can have an impact on the environment and broader society, and those that pose risks to or create opportunities for the Group. The 2024 assessment identified four sustainability matters considered as material to the Group: 1) Climate change, 2) Own workforce, 3) Consumers and end users, and 4) Business conduct. The table below shows the materiality scoring of impacts (positive and negative), risks and opportunities for each ESRS topic. The Group’s double materiality assessment is aligned with Banco Santander’s group-wide methodology, adapted for local factors specifically relevant to the Nordics. The assessment is based on European Sustainability Regulatory Standards (ESRS) 1 and 2, and the Double Materiality Assessment Guide from the European Financial Reporting Advisory Group (EFRAG). External experts were not engaged in this process locally. The assessment comprised the following phases: 1. Background and stakeholder analysis General view of the Group, its operations and main lines of business, based on: • Information on the entity: Sources include strategic and financial plans, financial statements and other published reports. This analysis considers operations, products and services, geographical footprint, business relationships and the value chain. • External information: Public documents on sector trends, analyst and supervisor papers, and peers’ sustainability reports. To enhance this background analysis, the Group used the ENCORE database (environmental risk assessment) to obtain information on its environmental impacts and dependencies. This supported the assessment of actual impacts, including total GHG emissions. The Group applied stakeholder analysis to identify directly affected stakeholders (customers, employees and investors) and users of the report (supervisors and regulators, communities and NGOs). The Group analyzed information gathered during stakeholder engagement exercises and conducted surveys on sustainability matters with employees, senior management and the Board of Directors to use as part of the materiality assessment, supported by surveys conducted by Banco Santander for other key stakeholders. 2. Identification of impacts, risks and opportunities (IROs) The background analysis identified a list of IROs that were categorized and assigned to a topic, sub-topic or sub-sub-topic under ESRS 1, AR 16. For each IRO, the Group considered: • Which part of the value chain they link to, • Dependencies between impacts and risks, assessing how each impact can lead to new risks and opportunities, with special focus on the negative impacts of the human rights due diligence exercise; • Which function in the organization manages the identified IRO. 3. Assessment of impacts, risks and opportunities Impacts: The materiality of actual and potential impacts were analyzed based on the likelihood and severity (scale and scope) of occurrence and, in the case of negative impacts, also includes irreparable impacts. Risks: The Group adapted its methodology according to the maturity of quantifying environmental and social risks. The climate materiality assessment includes a climate risk assessment (transition and physical) across several time horizons. This information was used to quantify the materiality of credit, market, operational, reputational and other risks. The Group assessed other environmental risks related to Pollution, Water and marine resources, Biodiversity and ecosystems and Resource use and circular economy). For social and governance risks, the Group used the Sustainability Accounting Standards Board’s (SASB) financial materiality and internal financial information. Opportunities: The opportunities assessment was based on forecasts for the business. The Group mapped out projected ESG-related revenue against the identified opportunities and compared it to the Group’s revenue on a scale of 1 to 5. The Group set a threshold of 3.5 on a scale of 1 to 5 to classify an IRO as material (for impact and financial materiality). This considers IROs that sit between medium (3) and high (4) and above as material. Annual report 2024 | Sustainability statement 38 The Group’s DMA results ii. Impacts, risks and opportunities The Double Materiality Assessment and material impacts, risks and opportunities (IROs) was approved by the Group‘s Executive Management Committee and Board of Directors in Q4 2024. This assessment also provides input for risk management processes in the Group, such as the top and emerging risks exercise as well as other internal risk exercises. To enable prioritization and monitoring of material impacts on people and the environment, the Executive Management Committee and Board Audit Committee receive sustainability updates and progress on due diligence, action plans, metrics and targets at least two times per year. Additionally, updates to specific material impacts, risks and opportunities may be addressed on an ad-hoc basis as required. Below are details of the material IROs under each ESRS topic. In this sustainability statement, the Group outlines the current or anticipated effects and how it manages each material IRO through applicable policies, actions, and where relevant, metrics and targets. As this is the Group’s first year of developing a DMA under ESRS, it has not yet established plans for how it will respond to these effects. Nor has it introduced any specific long- term changes to its strategy or business model in relation to these IROs. No current financial effects are assessed as resulting from these IROs in the 2024 financial statements. Applicable IROs are labelled and then described in the sections and sub-sections corresponding to the relevant ESRS topic. Six sustainability matters have been considered as non-material, given none of the impacts, risks and opportunities identified reached the materiality threshold. The sustainability matters that are considered non-material are: Pollution, Water and marine resources, Biodiversity and ecosystems, Resource and circular economy, Workers in the value chain and Affected communities. A content index of applicable disclosure requirements is included in 1.5 Sustainability governance, vi. Content index of ESRS disclosure requirements. Annual report 2024 | Sustainability statement 39 Overview of the Group’s material Impacts, Risks and Opportunities E1 Climate change Current effects (narrative) Linked to impact due to own activities or business relations Sub-Topic: Climate change mitigation I- (Potential) Adverse impact on the environment (e.g. increase in GHG emissions) because of the Group’s financing and investing activity, incl. granting loans to companies operating in high polluting sectors or vehicles that are not electric/hybrid. Downstream ST & LT - Adverse environmental impact Own activities R Reputational risk derived from the perception of clients and stakeholders that banks aren't doing enough to meet low-carbon targets, act against their policies or that their public commitments can pose reputational risk. Climate-related transition risk. Own operations / Downstream ST, MT, LT - Potential reputational damage if risks materialize N/A O Support revenue growth through offering customers differentiating solutions in areas such as real estate (retrofitting) mobility (EVs and other low-carbon mobility, infrastructure) among others. Downstream ST, MT - Grow the Group’s revenue by providing sustainable solutions in several sectors and supporting customers in their transition N/A O Growth in green bonds, green loans and sustainability-linked financing instruments. Upstream ST, MT - Supporting the Group’s funding strategy N/A S1 Own workforce Sub-topic: Working conditions I- (Potential) Ensure the health, wellness and safety of employees through comprehensive controls and proactive initiatives, fostering a safe and supportive workplace environment, while encouraging employees being able to reconcile work with their personal circumstances through flexible working. Own operations ST - Contribute positively to a workplace that promotes flexible working, health and well-being Own activities O Promote employees’ overall wellbeing and adequate remuneration, ensuring compliance, meritocracy, equality and competitiveness in the Group’s markets, to help its people prosper. Own operations ST - Promote appropriate and equal remuneration Own activities R Potential risk derived from incurring in situations with employees that involve longer working hours, controversies of corruption, human rights violations or abuse. Own operations MT - Potential harm if risks materialize N/A Sub-topic: Equal treatment and opportunities for all I- (Potential) Potentially harming employees from incidents on corruption, working conditions, discrimination and harassment. Own operations ST - Potential harm if risks materialize Own activities I+ (Actual) Foster a diverse and inclusive workforce, that reflects the composition of the Group’s communities and enhances collaboration by ensuring fair and equal opportunities for all employees, regardless of gender, disabilities or other characteristics. Own operations ST - Contribute positively to an inclusive environment that offers equal opportunity for all Own activities S4 Consumers and end users Sub-topic: Information-related impacts for consumers and/or end-users I- (Potential) Channels for making complaints are not available for customers or information gathered does not drive necessary changes. Own operations ST, MT - Potential breakdown of trust and long- term relationships with customers Own activities I- (Potential) Customers are not adequately informed about the product characteristics or services in the point of sales. Downstream ST, MT - Potential breakdown of trust and long- term relationships with customers Business relations I- (Potential) The compromise of the rights and freedoms of customers, employees or shareholders as a result of the failure to implement adequate technical and organizational measures to protect their personal data in accordance with the applicable data protection regulation. Upstream, Own operations ST, MT - Potential breakdown of trust and long- term relationships with customers Business relations R Awareness and education on cyber topics to explain potential threats and provide guidance on how to avoid them. Own operations ST - Knowledge and awareness of cybersecurity matters to help reduce online threats Own activities R The potential losses that may be incurred as a consequence of sanctions or an increase in customer attrition as a result of the lack of effective detection and/or response to privacy events. Upstream, Own operations ST - Potential harm if risks materialize N/A Sub-topic: Information-related impacts for consumers and/or end-users & Social inclusion of consumers and/or end- users Annual report 2024 | Sustainability statement 40 R Risk arising by inadequate practices in the Group's relationship with customers across the product lifecycle and customers relationship. Own operations, Downstream ST - Potential harm if risks materialize N/A Sub-topic: Social inclusion of consumers and/or end-users I- (Potential) Customer difficulties or vulnerabilities are not identified, hence failing to guarantee accessibility and usability. Own operations ST, MT - Potential breakdown of trust and long- term relationships with customers Own activities G1 Business conduct Sub-topic: Corporate culture I+ (Potential) Acting responsibly and taking into account not only the interests of investors and the Group, but also the impact on employees, society, and the environment. Own operations MT - Promote decision-making that considers all stakeholders’ interests Own activities Sub-topic: Protection of whistleblowers I- (Potential) Recurrence of incidents by not implementing internal measures to effectively resolve incidents reported through the grievance channels and not implementing continuous improvements. Own operations ST, MT - Potential harm to people and/or the environment; loss of stakeholders’ trust in effectiveness of available channels Own activities I+ (Actual) Protection of whistle-blowers confidentiality through an effective communication system in which the Group reports consistent information to governing bodies through solid, standardized principles and procedures in whistleblowing channels. Own operations ST - Availability of mechanisms for stakeholders to escalate confidentially and/or anonymously (according to regulatory requirements) substandard practices by the Group and its people Own activities Sub-topic: Management of relationship with suppliers including payment practices I+ (Actual) Promote responsible practices among suppliers by engaging with them, assessing their ESG performance and providing to them recommendations and tools to improve, incl. The access to grievance mechanisms - Canal Abierto. Own operations ST - Promote responsible practice in the Group’s value chain Own activities R Risk arising from failing the implementation of operative resilience, financial soundness, reputational control and regulation compliance due to third parties. Upstream, Own operations, Downstream ST, MT - Potential harm if risks materialize N/A Sub-topic: Corruption and bribery I- (Actual) Harm of society because of bribery and corruption practices in bank functions. Own operations ST - Potential loss of customers’ and other stakeholders’ trust Own activities R Risks derived from inadequate behavior or conduct, giving the appearance of legitimacy and legality to funds or assets with illicit origin and/or permit criminal activity to occur. Own operations ST - Potential harm if risks materialize N/A Key: I+ Positive impact I- Negative impact R Risk O Opportunity; ST, MT, LT = Short term, medium term, long term, respectively. Annual report 2024 | Sustainability statement 41 1.5 Sustainability governance i. Corporate governance of sustainability matters The composition of the Board of Directors is balanced between external and internal (employed by the shareholder Santander Consumer Finance S.A. and the Santander Consumer Bank Nordic Group) directors. The Board of Directors has 7 members, of which 2 are external (independent) members (29%), and 5 are internal members, of which 2 are employee representatives. The Board members are elected by the general assembly and the employee representatives are elected by employees of the Group. The Board of Directors consists of 3 women and 4 men. Excluding employee representatives, two out of five (40%) of the external and internal Board members are women. Among employee representatives, one out of the two members (50%) are women. The elected members of the Board serve for two years. If a Board member retires before their period of office has expired a replacement for the remaining period is elected. Each employee representative has a personal deputy also elected among and by the employees. In addition, the employees elect an observer to the Board. The election of the employee representatives is organized so that each of the countries in the Group always has a Board representative, either by the means of a fixed member, or as a deputy or observer. The Board has a skills matrix to ensure comprehensive coverage of competencies and to support succession planning. Experience covers areas such as financial services, management, governance, risk, regulatory, strategy and sustainability experience. Each year, the Board carries out a self-assessment of its competencies and work, and every other year it is carried out together with an external facilitator. Additionally, the Group’s senior management collectively hold strong experience in the Nordic consumer lending market, specifically within the financial sector and the product portfolios relevant to the Group. Annual report 2024 | Sustainability statement 42 The Group’s governance committee structure The Board of Directors is the Group’s highest decision-making body, except for matters reserved for the general meeting. The operations of the Group shall follow from and be managed in accordance with the Banking license granted by the Financial Supervisory Authority of Norway (the “NFSA”), all applicable laws and regulations and the object of the enterprise as defined in the Articles of Association. The policy Rules of Procedure for the Board of Directors of Santander Consumer Bank AS provides rules for the Board of Directors distribution of work, pursuant to section 6-23 of the Norwegian Limited Liability Companies Act (Lov-1997-06-13-44). Each Board and Committee is governed by a charter setting the objective and responsibility of each respective body. The other Board Committees on Level 1 are preparatory and advisory to the Board of Directors. The Board has delegated the day-to-day management of the Group’s activities to the Group’s CEO. Management committees, including the Executive Management Committee (ExCo), have been established to facilitate the work of the CEO and to ensure effectiveness and efficiency of business and to enhance the internal control of the Group. ExCo, also referred to as either Top Management or Senior Management throughout the report, consists of the senior managers of the Group’s main functions. The Level 2 Bank Committees are delegated from the CEO to assist the CEO. Level 3 Committees support the level 2 Committees. The Audit Executive is appointed by the Board of Directors. The Board shall verify that senior management considers internal audit report conclusions. The third line of defense conduct, on at least a yearly basis, a risk assessment for the Group. The risks are as forward looking as possible and result in an annual plan with both regular and compulsory audits according to regulation, as well as audits based on the most critical risks identified in the risk assessment. The Group has adopted a three lines of defense model to manage risk and business conduct matters. The business units and functions constitute the first line of defense and have primary responsibility for identifying, managing, and mitigating compliance risk. To oversee the compliance processes in the Group and to secure that the Executive Committee and the Board of Directors are provided with independent information regarding the compliance status in the business, the Group has an independent Compliance & Conduct function (C&C) as part of its second line of defense. The third line of defense consists of the Internal Audit function, reviewing and reporting on the first and second line of defense activities. The Group’s Chief Risk Officer and Chief Compliance Officer are members of the Group’s Level 2 committees. The C&C function reports quarterly to the Executive Committee, the Board Risk Committee, and the Board of Directors. The C&C function consists of compliance professionals across the Nordics with expertise in business conduct matters, overseen by the Chief Compliance Officer, who reports to the CEO and who also has a functional reporting line to the Chief Compliance Officer at Santander Consumer Finance S.A. To ensure the independence of the C&C function, the Chief Compliance Officer has direct access to the Board of Directors and the Board Risk Committee. Additionally, the Chief Risk Officer and Chief Compliance Officer provide expertise in Level 2 committees on risk management and business conduct. Additionally, the collective Board of Directors possesses corporate governance and risk management expertise. Level 1 Board of Directors, Board Risk Committee, Nomination Committee, Remuneration Committee and Board Audit Committee. Level 2 Executive Committee, Asset & Liability Committee, Risk Approval Committee, Risk Control Committee and Bank Investment Committee. Level 3 Capital Committee, Outsourcing & Vendor Management Committee, Models Committee, T&O Committee, Purchase Committee, HR & Culture Committee, NFR Control & Compliance Committee, Financial Risk Control Committee and Nordic Provision Committee. Annual report 2024 | Sustainability statement 43 Governance processes, controls and procedures The Board of Directors have approved the Group’s Governance and Internal Control Policy. Two of the governing principles stated are: • All areas of the organization shall take part in control activities within the Group. The governance and internal control system within the Group is based on a strong awareness of risks and a regulatory culture with an explicit ‘three-lines-of-defense’ approach. • The business shall manage its business through a risk- based approach so that risks are identified, managed and controlled through appropriate control activities. All identified risks are assessed. Relevant actions should be applied where the risk is not accepted. The Group’s organizational structure includes separation of duties between the Group’s functions, with defined responsibilities to ensure healthy and prudent management. The Group has a process for the review, approval, and implementation of internal and external regulations such as frameworks, models, policies, and procedures, which are outlined in a governing document approved by the Board. Furthermore, the Group has an internal governance unit focusing on always ensuring strong internal governance. The Group has a process of identification, monitoring, and reporting to the business, management, and Board of Directors, any regulatory developments relevant for the Group. The Group also has a process for communication and reporting to its supervisory authorities. Controls and procedures relating to management of IROs The Committee structure, governing procedures and charters ensure effectiveness and efficiency of business and enhance the internal controls of the Group in accordance with the Financial Institutions Act (FIA) section 8-11 and section 13-5. To strengthen and implement the ‘three-lines-of-defense’ approach, as well as FIA section 13-5, the Board of Directors has the Internal Audit function as its primary control function to audit and report on potential deficiencies and improvement areas in the business. The CEO is fully responsible for daily business operations as further set out in section 8-11 of the FIA as well as the CEO-instruction issued by the Board of Directors. To strengthen and exercise control, and pursuant to the FIA section 13-5, the CEO has the Compliance & Conduct function and the Risk Function as the primary control functions to control and report on potential deficiencies and improvement areas in the business in line with the three lines of defense approach. The Chief Risk Officer and the Chief Compliance Officer can also report directly to the Board of Directors and relevant Board committees in accordance with instructions set out by the Board and cannot be appointed nor dismissed without approval from the Board of Directors. The Board of Directors and Bank Committees are responsible for setting targets for their respective areas of responsibility and performing controls of results as described in the relevant charters. Each committee has their own charter and governance documentation to ensure adequate target setting and controls. Strategy, decisions on major transactions, and risk management process The objective of the Board Committees is to prepare and advise the Board of Directors in their respective areas. Board Risk Committee (BRC) focuses on the Group’s Risk Strategy and corresponding policies and procedures, as well as monitoring and controlling the effectiveness of their implementation. BRC meet regularly throughout the year, a week ahead of the Board of Director meetings. The CEO is supported by the Bank Committees to review impacts, risks and opportunities for their respective areas when developing strategies and deciding on major transactions. The Executive Management Committee (ExCo) drafts, reviews and recommends to the Board of Directors any amendments to the Group’s strategy and strategic long-term plans, including reviewing and recommending amendments to the financial plans and budget. ExCo also reviews and gives recommendations related to mergers and acquisitions. Furthermore, ExCo monitors the Group’s strategic, financial and operational performance, and makes recommendations and decisions on corrective actions. In 2024, the Board of Directors met six times to make decisions on agenda items, in addition to handling certain Board items via circulation. Sustainability-related skills and expertise in the Board A Board of Directors’ skills matrix is used to perform a qualitative assessment of the skills and expertise that the Board possesses. This matrix demonstrates that adequate skills related to sustainability are represented in the Board. Additionally, the matrix, together with the annual Board evaluation, is used to plan improvement areas for the Board of Directors. Board training is included in the Board of Directors’ annual plan to cover mandatory areas such as AML and IRB but also other relevant areas for the Board of Directors. In 2024, the Board completed training on GDPR, Code of Conduct, the Insurance Distribution Directive (IDD) and Anti-Money Laundering (AML). The training plan for 2025 also contains a separate ESG training module. Annual report 2024 | Sustainability statement 44 ii. Integration of sustainability-related performance in incentive schemes Sustainability-related performance is currently not integrated in incentive schemes employed for the Board of Directors and the Board Audit Committee. Their members’ salaries are fixed. For senior management, the corporate Remuneration policy includes necessary mechanisms to ensure that pay schemes contribute to achieving strategic and long-term sustainability objectives. Accordingly, it bases variable pay on pre-determined, specific and quantifiable financial, sustainability-based and value-creation targets that are consistent with the Group’s interests. The Group’s short-term incentive scheme applies to leaders, including the senior management team. Sustainability has been part of the qualitative element of the Group’s short-term variable pay since 2021, with a ±5% weighting. The proposed parameters to assess ESG performance aim to reward progress with main ESG metrics and to embed ESG in its management. Banco Santander’s responsible banking, sustainability and culture committee, remuneration committee, and the Board of Directors, approve the ESG incentive schemes for Grupo Santander and its subsidiaries, including the Group. iii. Human rights due diligence The Group recognizes that it holds a specific duty of care regarding human rights and working conditions across its value chain. As a requirement of the Norwegian Transparency Act (Åpenhetsloven), the Group is required to carry out and report regular and proportional due diligence assessments to identify actual and potential negative consequences on human rights and working conditions. In accordance with the Act, the Group conducts due diligence on its value chain in alignment with the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. Information about the due diligence, findings, actions and any remediation taken is communicated publicly in an annual statement. The Group has not identified any actual negative impacts relating to human rights and working conditions through its due diligence activities. The Group’s latest Transparency Act statement in available on the Group’s Investor Relations website. The Group’s commitment to upholding human rights and good working practices within its value chain, as well as the requirements of the Transparency Act and management responsibilities, are understood and acknowledged by the Group’s senior management and Board of Directors. Due diligence key findings and measures related to employees, consumers, partners and vendors are brought for senior management consideration and approval prior to external publication. Additionally, management receives regular updates on the Group’s progress, the views of affected stakeholders and other Transparency Act-related work that informs its strategy and plans. The Group CEO and Board of Directors hold ultimate responsibility for ensuring compliance with applicable legal and internal obligations. Annual report 2024 | Sustainability statement 45 Mapping of the information provided about the due diligence process Core elements of due diligence Sections in the Sustainability Statement a) Embedding due diligence in governance, strategy and business model 1.2 Sustainability strategy 1.4 Materiality assessment i. Identification of material matters 1.5 Sustainability governance i. Corporate governance of sustainability matters iv. Sustainability policies b) Engaging with affected stakeholders in all key steps of the due diligence 1.3 Stakeholder engagement 3.3 Employee engagement c) Identifying and assessing adverse impacts 1.4 Materiality assessment i. Identification of material matters ii. Impacts, risks and opportunities d) Taking actions to address those adverse impacts 2.2 Developing the Group’s transition plan v. Alignment and decarbonization lending portfolios 3.5 Equal opportunities for all i. Diversity, equity and inclusion (DE&I) 4.2 Conduct risk with customers i. Simple, personal and fair ii. Channels for monitoring customer satisfaction 4.3 Privacy, data protection and cybersecurity i. Privacy 5.2 Ethical conduct i. Conduct standards ii. Financial crime 5.3 Ethical channels i. Canal Abierto e) Tracking effectiveness of these efforts and communicating 2.4 Environmental footprint 3.4 Working conditions viii. Incidents, complaints and human rights 3.5 Equal opportunities for all i. Diversity, equity and inclusion (DE&I) 4.2 Conduct with customers ii. Channels for monitoring customer satisfaction 5.3 Ethical channels i. Canal Abierto Annual report 2024 | Sustainability statement 46 iv. Sustainability policies The following policies and steering documents are used to embed ESG standards in the Group’s strategy, business model and operations. Each policy included in the table below is applicable to all the Group’s material IROs. The policies are based on Banco Santander policies that have been adapted and approved locally. All corporate frameworks, models, policies and procedures seek to maintain a high level of governance, and the highest standards in terms of their elaboration, approval, and in the monitoring of their local transposition in the Group. Approval is the responsibility of the Board of Directors or its committees, when the regulated matter falls within their scope of responsibility according to their rules and regulations. Corporate frameworks in all cases must be approved by the Board of Directors. The Group’s approval process for setting policies, procedures, frameworks and models requires internal stakeholders in affected functions be consulted in the process of drafting steering documents, and indirectly affected functions are to be informed, as well as updated, on any changes. Through internal functional feedback and review, the approval process is used, where possible, to capture and input relevant interests of external stakeholders that are known to internal functions. Gap analysis is also conducted to support compliance with applicable regulatory standards. Post-approval, any identified gaps are monitored quarterly, and when required, implementation plans must be developed by the policy owner to support gap closure. A sign-off process requires process owners of affected internal functions to approve the document, and, where relevant, a review from the Group’s legal department is required. In addition to the below, the policies specific to the management of each material IRO are described in the applicable sections of the report (Climate change, Own workforce, Consumers and end users and Business conduct). Each policy is available to employees on the Group’s internal governance platform. The following overarching sustainability policies manage all material sustainability matters and IROs related to E1 Climate change, S1 Own workforce, S4 Consumers and end users, and G1 Business conduct. They cover all the Group’s activities across its value chain, its stakeholders and the geographies it operates in. The Group’s internal policies are not shared externally. Overview of the Group’s overarching sustainability policies Steering document Description Responsible Banking Framework The Banco Santander Responsible Banking framework serves, at a global level, to propel the organization towards a more sustainable business model that embeds Environmental, Social and Governance (ESG) criteria. The framework itself lays out common principles, roles, responsibilities, key processes, and governance arrangements, and is applicable to all the Group’s employees. The framework was initially approved by the Group’s Board of Directors in 2022. Responsible function: Responsible Banking Responsible Banking Model Develops the duties and activities on the topic of Responsible Banking by assigning roles and responsibilities of the first, second and third line of defense in ESG activities, initiatives and processes of the Group and its employees. The model outlines the Santander Responsible Banking strategy, including aligning financing activity with net-zero (NZBA), climate change mitigation and adaptation, energy efficiency and renewable energy usage in own operations. The model also covers social topics, including data protection and cybersecurity, governance requirements and stakeholder relations. Further, developing the Responsible Banking Framework, the Responsible Banking Model aims to support the embedding of ESG criteria throughout the Group. The model was approved by the Group’s Board of Directors in 2023. Responsible function: Responsible Banking Responsible Banking and Sustainability Policy Compiles overarching sustainability and responsible banking principles, including voluntary undertakings, positioned to create long-term value for the Group’s stakeholders. This policy and the Responsible Banking model are based on a number of conventions, including the Equator Principles, UN Universal Declaration of Human Rights, UN Global Compact, Principles for Responsible Banking (UNEP FI), UN Sustainable Development Goals, OECD Guidelines for Multinational Enterprises, Fundamental conventions of the ILO, 2015 Paris Climate Accords and others.IThe policy was approved by the Group’s Risk Approval Committee (RACo) in 2023. The policy is based, and adapted locally, on Banco Santander’s Responsible Banking and Sustainability policy, available to view on the Banco Santander corporate website. Responsible function: Responsible Banking Annual report 2024 | Sustainability statement 47 v. Risk management and internal controls over sustainability information Internal controls The Responsible Banking function holds the main responsibility to coordinate activities towards progressing the Group’s sustainability strategy. The function monitors and drives the Responsible Banking agenda and provides periodic updates to the Board Audit Committee on the progress of topics connected to material IROs, due diligence and the effectiveness of policies, actions, metrics and targets adopted to address them. The function also aligns with a network of colleagues in Santander Consumer Finance S.A. and Banco Santander to ensure the Group applies the methodologies and approaches outlined in this sustainability statement consistently across Santander. It is the responsibility of the functions involved in executing the strategy and preparing information on sustainability matters (for example: Risk, People and Culture, Commercial, Sourcing and others) to ensure that the information provided is true and reliable, as well as establish the necessary controls to guarantee this and correct any identified weaknesses. To consider the quality and reliability of sustainability information in this statement, the Group uses an internal control system to identify relevant risks and establish controls around the disclosure of sustainability information. The controls are executed and evaluated periodically to monitor implementation and effectiveness of the system. Aligned with Banco Santander, controls for sustainability information will be further developed over the short to medium term to cover all material sustainability reporting aspects. The Group has also started preparations for evaluating and improving the internal controls for certain key sustainability metrics in preparation for the convergence in standards of financial and sustainability standards to reasonable assurance requirements by 2028. Risk management The integration of climate and environmental factors, following the Group’s risk management model, encompasses various stages, including identification, planning, assessment, monitoring, mitigation, and reporting. The process described covers the Group’s own operations, upstream and downstream value chain: 1. Identification: To identify and manage material ESG risks, the Group periodically conducts risk identification exercises to evaluate potential events that could threaten the Group’s strategic plan, considering ESG risk factors. The following processes help the Group identify climate-related risks: a. Top Risk Identification Process: It assesses potential material risks to the Group’s strategic business plans, financial results, liquidity, or capital. This process refers to possible risk events that would pose a threat to the Group’s three-year financial plan if they were to materialize. The impact of these risk events is not considered in the existing plans, potentially resulting in deviations from targets should they occur. The exercise includes developing action plans to mitigate, transfer, or accept the potential impact of these risks. Plans are developed under senior management oversight and with the involvement of the corresponding functions. Findings from this exercise feed into the Risk Profile Assessment (RPA) and in generating stress scenarios for ICAAP, ILAAP and Recovery Plans. The three-year financial planning process also integrates the work to identify, assess and manage impacts, risks and opportunities. In connection to this, stress testing and scenario analysis are key instruments for identifying, assessing, and quantifying risk exposure, resilience to adverse environments, and risk profile sensitivity. Stress testing is a management tool used to assess the impact of certain changes—such as business structural modifications and macroeconomic or financial scenarios, on the overall solvency and/or liquidity position of an institution, including its minimum or additional requirements. This assessment involves projecting the Group’s capital and/or liquidity resources and requirements, using models or the Group’s own methodologies. This forward-looking approach highlights vulnerabilities and assesses the Group’s capacity to absorb losses and the impact on its financial position. Its scope includes all risks that could impact the risk profile and the business model, such as credit, market, liquidity, operational, and ESG risks, among others. Annual report 2024 | Sustainability statement 48 b. Risk Profile Assessment (RPA): A robust corporate methodology that covers all risk types and reveals threats to the Group’s business plan. The results of this exercise allow the Group to identify management gaps and areas for improvement. Over the past couple of years, the Group has strengthened this biannual exercise by incorporating an internal self-assessment specifically focused on evaluating climate and environmental risks. It also includes a thorough examination of the residual value risk associated with the Group’s secured (auto) lending portfolio. 2. Planning: The Group’s strategic planning includes an annual budget and a three-year financial plan. These core strategic processes enable the Group to plan for risks associated with the transition to a low-carbon economy and the physical impacts of climate change. These risks are then integrated into the short and medium-term strategy, making it easier to identify threats and changing conditions that could influence The Group’s ability to achieve its objectives. 3. Assessment: The Group continues to make progress with its climate-related risk assessment by progressively refining granularity levels with the availability of more data and updated methodologies, strictly adhering to current regulations. The Group has been conducting materiality assessments since 2022, under the framework defined by the Task Force on Climate Disclosures (TFCD), now becoming more granular and detailed with the implementation of the Corporate Sustainability Reporting Directive (CSRD) and the incorporation of the double materiality assessment framework it entails. A summary of the key risks and defined mitigants is included at the end of this section. ESG risk management is a relatively new sub-discipline, with its approaches and best practices still evolving. The Group, like others, applies ESG principles to its risk identification, product portfolio, and reporting processes, while continually learning and improving. Given the relative immaturity of impact measurement approaches, the Group's 2024 Internal Capital Adequacy Assessment Process (ICAAP) concluded that ESG risk is adequately managed and covered by Pillar 1 requirements (including operational and credit risk, as ESG is considered a cross- cutting risk). Therefore, no additional Pillar 2 capital is required for ESG risk. Furthermore, ESG risk considerations are also incorporated into the Group’ stress testing exercises. Building internal capacity through training — ensuring employees have the necessary knowledge and skills — is crucial for effectively managing climate-related and environmental risks as this area of focus grows. The Group's risk-conscious culture is a key tool for raising employee awareness. For example, the Group launched a mandatory training program for all employees in 2024 called "Practical Approach to integrating ESG Criteria.” 4. Monitoring: The Group uses risk appetite, scenario analysis, and other tools to monitor climate-related and environmental risk. The Risk Appetite sets the volume and type of risks deemed prudent for the Group's business strategy, and its reflection in thresholds on several metrics provides a sufficient control environment. The Group continues to enhance its Risk Appetite Statement by periodically introducing new metrics and limits, complementing its strategy with available methodologies and data. In 2024, several metrics related to its residual value risk exposure by type of engine, brand, and maturity were defined and implemented. In 2025, a new metric will be implemented aimed at ensuring adequate progress toward the decarbonization target for the auto portfolio by 2030. 5. Reporting: Santander is committed to transparent and regular reporting on climate and environmental factors to ensure effective management and alignment with regulatory requirements. The Group’s governance framework ensures that the Board of Directors is comprehensively informed, enabling it to mitigate potential risks and effectively communicate its sustainability strategy to stakeholders. The climate and environmental risk management reporting primarily encompasses the Annual Report, Sustainability Statement, Internal Capital Adequacy Assessment Process (ICAAP) exercise, and Banco Santander’s Pillar III disclosure report. Additionally, and complementing the risk profile assessment conducted biannually, the Enterprise Risk Management (ERM) team prepares the ESG & Climate Change Risk Monitoring report. This document provides a consolidated overview of the various elements considered when evaluating ESG risks holistically. Annual report 2024 | Sustainability statement 49 Summary of the key risks and defined mitigants Risk type \ Driver Physical Transition Reputational & Regulatory Risk ● No significant risks have been identified The Group recognizes that its climate-related activities may pose reputational and legal risks, including allegations of greenwashing. To mitigate these risks, the Group has implemented robust risk policies, regular monitoring, and transparent disclosure practices, which help us maintain a strong reputation and minimize potential harm. Strategic risk ● No significant risks have been identified The automotive industry is facing a significant transformation driven by climate-related concerns. Car sales levels may decline, and private car ownership could become less attractive, especially in urban areas. To mitigate these risks, The Group have diversified its business and closely monitor market trends, allowing us to adapt to changing circumstances and capitalize on emerging opportunities. Credit risk ● • The Group’s assets are exposed to the risk of damage from natural hazards, which could compromise the value of its collateral. To mitigate this risk, the Group has taken steps to protect its collateral through insurance coverage, providing a financial safety net in the event of damage or loss. • Rising energy prices may impact customers' ability to meet credit obligations. This risk is partially offset by existing government support programs designed to protect household purchasing power. The Group faces the risk that its customers' inability to adapt to environmental changes could lead to financial difficulties and increased defaults. Additionally, a poorly implemented sustainable lending strategy could result in misaligned pricing and negatively impact the Group’s financial performance. Residual Value risk ● Potential damages to cars. The Group’s vehicle fleet is protected against potential damage thanks to its geographic diversification, mobility options, and insurance coverage. The used car market is volatile due to regulatory, technological and consumer shifts. The Group's RV exposure is growing in line with the Group's risk policies and appetite. Managing the risk through continuous monitoring of the residual value setting, policies and sharing risks, as well as diversification of the portfolio. ● Low Risk; ● Mid-Low Risk; ● Mid-High Risk; ● High Risk Annual report 2024 | Sustainability statement 50 vi. Content index of ESRS disclosure requirements Content index of ESRS disclosure requirements ESRS 2 – General disclosures Reference Page BP-1 General basis for preparation of the sustainability statement 1.1 Basis for preparation p. 31 BP-2 Disclosures in relation to specific circumstances 1.2 Sustainability strategy p. 32-35 GOV-1 The role of the administrative, management and supervisory bodies 1.5 Sustainability governance, i. Corporate governance of sustainability matters p. 41-43 GOV-2 Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies 1.4 Materiality assessment, ii. Impacts, risks and opportunities p. 38-40 GOV-3 Integration of sustainability-related performance in incentive schemes 1.5 Sustainability governance, ii. Integration of sustainability-related performance in incentive schemes p. 44 GOV-4 Statement on due diligence 1.5 Sustainability governance, iii. Human rights due diligence p. 44 GOV-5 Risk management and internal controls over sustainability reporting 1.5 Sustainability governance, v. Risk management and internal controls over sustainability information p. 47-49 SBM-1 Strategy, business model and value chain 1.2 Sustainability strategy p. 32-35 SBM-2 Interest and views of stakeholders 1.3 Stakeholder engagement p. 36 SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model 1.4 Materiality assessment, i. Identification of material matters 1.4 Materiality assessment, ii. Impacts, risks and opportunities 1.5 Sustainability governance, v. Risk management and internal controls over sustainability information p. 37 p. 38-40 p. 47-49 IRO-1 Description of the processes to identify and assess material impacts, risks and opportunities 1.4 Materiality assessment, i. Identification of material matters 1.4 Materiality assessment, ii. Impacts, risks and opportunities p. 37 p. 38-40 IRO-2 Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement 1.4 Materiality assessment, i. Identification of material matters 1.5 Sustainability governance, vi. Content index of ESRS disclosure requirements p. 37 p. 50-51 E1 – Climate change Reference Page E1-1 Transition plan for climate change mitigation 2.2 Developing the Group’s transition plan p. 59-65 ESRS 2 SBM-3 E1 Material impacts, risks and opportunities and their interaction with strategy and business model 2.2 Developing the Group’s transition plan p. 59-65 ESRS 2 IRO-1 E1 Description of the processes to identify and assess material climate-related impacts, risks and opportunities 1.4 Materiality assessment, ii. Impacts, risks and opportunities 2.2 Developing the Group’s transition plan p. 38-40 p. 59-65 E1-2 Policies related to climate change mitigation and adaptation 2.1 Policies related to climate change mitigation and adaptation p. 58 E1-3 Actions and resources in relation to climate change policies 2.2 Developing the Group’s transition plan, v. Alignment and decarbonization lending portfolios 2.5 EU Taxonomy p. 63-65 E1-4 Targets related to climate change mitigation and adaptation 2.2 Developing the Group’s transition plan, v. Alignment and decarbonization lending portfolios p. 63-65 E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions 2.4 Environmental footprint p. 68 Annual report 2024 | Sustainability statement 51 S1 – Own workforce Reference Page ESRS 2 SBM-2 S1 Interest and views of stakeholders 3.3 Employee engagement p. 88 ESRS 2 SBM-3 S1 Material impacts, risks and opportunities and their interaction with strategy and business model 1.4 Materiality assessment, ii. Impacts, risks and opportunities 3.4 Working conditions, viii. Incidents, complaints and human rights p. 38-40 p. 93 S1-1 Policies related to own workforce 3.1 Policies related to own workforce 3.2 Employee-related governance 3.4 Working conditions, iii. Occupational health p. 86-87 p. 87 p. 90 S1-2 Processes for engaging with own workforce and workers’ representatives about impacts 3.3 Employee engagement 3.4 Working conditions, vi. Collective bargaining and social dialogue p. 88 p. 91 S1-3 Processes to remediate negative impacts and channels for own workforce to raise concerns 3.3 Employee engagement p. 88 S1-4 Taking action on material impacts on own workforce and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions 3.4 Working conditions 3.5 Equal opportunities for all, i. Diversity, equity and inclusion (DE&I) p. 89-93 p. 94-95 S1-6 Characteristics of the undertaking’s employees 3.7 Characteristics of the Group’s employees p. 96-97 S1-8 Collective bargaining coverage and social dialogue 3.4 Working conditions, vi. Collective bargaining and social dialogue p. 91 S1-9 Diversity metrics 3.5 Equal opportunities for all, i. Diversity, equity and inclusion (DE&I) 3.7 Characteristics of the Group’s employees p. 94-95 p. 96-97 S1-10 Adequate wages 3.4 Working conditions, vii. Remuneration and corporate benefits p. 91-92 S1-11 Social protection 3.4 Working conditions, v. Social protection p. 90-91 S1-14 Health and safety metrics 3.4 Working conditions, iii. Occupational health 3.7 Characteristics of the Group’s employees p. 90 p. 96-97 S1-15 Work-life balance metrics 3.4 Working conditions, i. Employee health and well-being and work-life balance p. 89 S1-16 Remuneration metrics (pay gap and total remuneration) 3.4 Working conditions, vii. Remuneration and corporate benefits 3.5 Equal opportunities for all, i. Diversity, equity and inclusion (DE&I) p. 91-92 p. 94-95 S1-17 Incidents, complaints and severe human rights impacts 3.4 Working conditions, viii. Incidents, complaints and human rights p. 93 S4 – Consumers and end-users Reference Page ESRS 2 SBM-2 S4 Interest and views of stakeholders 1.3 Stakeholder engagement p. 36 ESRS 2 SBM-3 S4 Material impacts, risks and opportunities and their interaction with strategy and business model 1.4 Materiality assessment, ii. Impacts, risks and opportunities 4.2 Conduct with customers 4.2 Conduct with customers, i. Simple, personal and fair p. 38-40 p. 100 p. 100-101 S4-1 Policies related to consumers and end-users 4.1 Policies related to consumers and end-users p. 99 S4-2 Processes for engaging with consumers and end-users about impacts 4.2 Conduct with customers, i. Simple, personal and fair p. 100-101 S4-3 Processes to remediate negative impacts and channels for consumers and end-users to raise concerns 4.2 Conduct with customers, ii. Channels for monitoring customer satisfaction p. 102 S4-4 Taking action on material impacts on consumers and end-users and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions 4.2 Conduct with customers, i. Simple personal and fair 4.2 Conduct with customers, ii. Channels for monitoring customer satisfaction 4.3 Privacy, data protection and cybersecurity p. 100-101 p. 102 p. 103-104 G1 – Business conduct Reference Page ESRS 2 GOV-1 G1 The role of administrative, management and supervisory bodies 1.5 Sustainability governance, i. Corporate governance of sustainability matters p. 41-43 ESRS 2 IRO-1 G1 Description of the processes to identify and assess material impacts, risks and opportunities 1.4 Materiality assessment, i. Identification of material matters p. 38-40 G1-1 Business conduct policies and corporate culture 5.1 Business conduct policies and corporate culture 5.2 Ethical conduct, i. Conduct standards 5.2 Ethical conduct, ii. Financial crime 5.3 Ethical channels, i. Canal Abierto p. 106-107 p. 108 p. 108-109 p. 110-111 G1-2 Management of relationships with suppliers 5.4 Suppliers, i. ESG standards in procurement p. 111 G1-3 Prevention and detection of corruption and bribery 5.2 Ethical conduct, ii. Financial crime p. 108-109 G1-4 Incidents of corruption and bribery 5.2 Ethical conduct, ii. Financial crime p. 108-109 G1-6 Payment practices 5.4 Suppliers, ii. Supplier payment practices p. 111 Annual report 2024 | Sustainability statement 52 vii. Appendix B – List of data points that derive from other EU legislation Appendix B – List of data points that derive from other EU legislation Disclosure Requirement and related datapoint SFDR reference Pillar 3 reference Benchmark Regulation and Climate Law reference Material/Not material /Not disclosed (phase-in) Page reference ESRS 2 GOV-1 Board's gender diversity paragraph 21 (d) Indicator number 13 of Table #1 of Annex 1 Commission Delegated Regulation (EU) 2020/1816, Annex II Material p. 41 ESRS 2 GOV-1 Percentage of board members who are independent paragraph 21 (e) Delegated Regulation (EU) 2020/1816, Annex II Material p. 41 ESRS 2 GOV-4 Statement on due diligence paragraph 30 Indicator number 10 Table #3 of Annex 1 Material p. 44 ESRS 2 SBM-1 Involvement in activities related to fossil fuel activities paragraph 40 (d) i Indicators number 4 Table #1 of Annex 1 Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 ( 6 ) Table 1: Qualitative information on Environmental risk and Table 2: Qualitative information on Social risk Delegated Regulation (EU) 2020/1816, Annex II Material p. 33 ESRS 2 SBM-1 Involvement in activities related to chemical production paragraph 40 (d) ii Indicator number 9 Table #2 of Annex 1 Delegated Regulation (EU) 2020/1816, Annex II Material p. 33 ESRS 2 SBM-1 Involvement in activities related to controversial weapons paragraph 40 (d) iii Indicator number 14 Table #1 of Annex 1 Delegated Regulation (EU) 2020/1818 ( 7 ), Article 12(1) Delegated Regulation (EU) 2020/1816, Annex II Material p. 33 ESRS 2 SBM-1 Involvement in activities related to cultivation and production of tobacco paragraph 40 (d) iv Delegated Regulation (EU) 2020/1818, Article 12(1) Delegated Regulation (EU) 2020/1816, Annex II Material p. 33 ESRS E1-1 Transition plan to reach climate neutrality by 2050 paragraph 14 Regulation (EU) 2021/1119, Article 2(1) Material p. 59-65 ESRS E1-1 Undertakings excluded from Paris- aligned Benchmarks paragraph 16 (g) Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book-Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity Delegated Regulation (EU) 2020/1818, Article12.1 (d) to (g), and Article 12.2 Material p. 63 ESRS E1-4 GHG emission reduction targets paragraph 34 Indicator number 4 Table #2 of Annex 1 Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 3: Banking book – Climate change transition risk: alignment metrics Delegated Regulation (EU) 2020/1818, Article 6 Material p. 63-65 Annual report 2024 | Sustainability statement 53 ESRS E1-5 Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) paragraph 38 Indicator number 5 Table #1 and Indicator n. 5 Table #2 of Annex 1 Not material ESRS E1-5 Energy consumption and mix paragraph 37 Indicator number 5 Table #1 of Annex 1 Not material ESRS E1-5 Energy intensity associated with activities in high climate impact sectors paragraphs 40 to 43 Indicator number 6 Table #1 of Annex 1 Not material ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions paragraph 44 Indicators number 1 and 2 Table #1 of Annex 1 Article 449a; Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book – Climate change transition risk: Credit quality of exposures by sector, emissions and residual maturity Delegated Regulation (EU) 2020/1818, Article 5(1), 6 and 8(1) Material p. 68 ESRS E1-6 Gross GHG emissions intensity paragraphs 53 to 55 Indicators number 3 Table #1 of Annex 1 Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 3: Banking book – Climate change transition risk: alignment metrics Delegated Regulation (EU) 2020/1818, Article 8(1 Material p. 68 ESRS E1-7 GHG removals and carbon credits paragraph 56 Regulation (EU) 2021/1119, Article 2(1) Not material ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks paragraph 66 Delegated Regulation (EU) 2020/1818, Annex II Delegated Regulation (EU) 2020/1816, Annex II Not disclosed (phase-in) ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a) ESRS E1-9 Location of significant assets at material physical risk paragraph 66 (c). Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 paragraphs 46 and 47; Template 5: Banking book - Climate change physical risk: Exposures subject to physical risk. Not disclosed (phase-in) ESRS E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes paragraph 67 (c). Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 paragraph 34; Template 2:Banking book - Climate change transition risk: Loans collateralized by immovable property - Energy efficiency of the collateral Not disclosed (phase-in) ESRS E1-9 Degree of exposure of the portfolio to climate- related opportunities paragraph 69 Delegated Regulation (EU) 2020/1818, Annex II Not disclosed (phase-in) Annual report 2024 | Sustainability statement 54 ESRS E2-4 Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil, paragraph 28 Indicator number 8 Table #1 of Annex 1 Indicator number 2 Table #2 of Annex 1 Indicator number 1 Table #2 of Annex 1 Indicator number 3 Table #2 of Annex 1 Not material ESRS E3-1 Water and marine resources paragraph 9 Indicator number 7 Table #2 of Annex 1 Not material ESRS E3-1 Dedicated policy paragraph 13 Indicator number 8 Table 2 of Annex 1 Not material ESRS E3-1 Sustainable oceans and seas paragraph 14 Indicator number 12 Table #2 of Annex 1 Not material ESRS E3-4 Total water recycled and reused paragraph 28 (c) Indicator number 6.2 Table #2 of Annex 1 Not material ESRS E3-4 Total water consumption in m3 per net revenue on own operations paragraph 29 Indicator number 6.1 Table #2 of Annex 1 Not material ESRS 2- IRO 1 - E4 paragraph 16 (a) i Indicator number 7 Table #1 of Annex 1 Not material ESRS 2- IRO 1 - E4 paragraph 16 (b) Indicator number 10 Table #2 of Annex 1 Not material ESRS 2- IRO 1 - E4 paragraph 16 (c) Indicator number 14 Table #2 of Annex 1 Not material ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) Indicator number 11 Table #2 of Annex 1 Not material ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) Indicator number 12 Table #2 of Annex 1 Not material ESRS E4-2 Policies to address deforestation paragraph 24 (d) Indicator number 15 Table #2 of Annex 1 Not material ESRS E5-5 Non-recycled waste paragraph 37 (d) Indicator number 13 Table #2 of Annex 1 Not material ESRS E5-5 Hazardous waste and radioactive waste paragraph 39 Indicator number 9 Table #1 of Annex 1 Not material ESRS 2- SBM3 - S1 Risk of incidents of forced labor paragraph 14 (f) Indicator number 13 Table #3 of Annex I Material p. 93 ESRS 2- SBM3 - S1 Risk of incidents of child labor paragraph 14 (g) Indicator number 12 Table #3 of Annex I Material p. 93 ESRS S1-1 Human rights policy commitments paragraph 20 Indicator number 9 Table #3 and Indicator number 11 Table #1 of Annex I Material p. 86-87 Annual report 2024 | Sustainability statement 55 ESRS S1-1 Due diligence policies on issues addressed by the fundamental International Labor Organization Conventions 1 to 8, paragraph 21 Delegated Regulation (EU) 2020/1816, Annex II Material p. 86-87 ESRS S1-1 processes and measures for preventing trafficking in human beings paragraph 22 Indicator number 11 Table #3 of Annex I Material p. 86-87 ESRS S1-1 workplace accident prevention policy or management system paragraph 23 Indicator number 1 Table #3 of Annex I Material p. 90 ESRS S1-3 grievance/complaints handling mechanisms paragraph 32 (c) Indicator number 5 Table #3 of Annex I Material p. 88 ESRS S1-14 Number of fatalities and number and rate of work-related accidents paragraph 88 (b) and (c) Indicator number 2 Table #3 of Annex I Delegated Regulation (EU) 2020/1816, Annex II Material p. 96-97 ESRS S1-14 Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e) Indicator number 3 Table #3 of Annex I Material p. 96-97 ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a) Indicator number 12 Table #1 of Annex I Delegated Regulation (EU) 2020/1816, Annex II Material p. 91-92 ESRS S1-16 Excessive CEO pay ratio paragraph 97 (b) Indicator number 8 Table #3 of Annex I Material p. 91.92 ESRS S1-17 Incidents of discrimination paragraph 103 (a) Indicator number 7 Table #3 of Annex I Material p. 93 ESRS S1-17 Non-respect of UNGPs on Business and Human Rights and OECD paragraph 104 (a) Indicator number 10 Table #1 and Indicator n. 14 Table #3 of Annex I Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818 Art 12 (1) Material p. 93 ESRS 2- SBM3 – S2 Significant risk of child labor or forced labor in the value chain paragraph 11 (b) Indicators number 12 and n. 13 Table #3 of Annex I Not material ESRS S2-1 Human rights policy commitments paragraph 17 Indicator number 9 Table #3 and Indicator n. 11 Table #1 of Annex 1 Not material ESRS S2-1 Policies related to value chain workers paragraph 18 Indicator number 11 and n. 4 Table #3 of Annex 1 Not material ESRS S2-1Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines paragraph 19 Indicator number 10 Table #1 of Annex 1 Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1) Not material Annual report 2024 | Sustainability statement 56 ESRS S2-1 Due diligence policies on issues addressed by the fundamental International Labor Organization Conventions 1 to 8, paragraph 19 Delegated Regulation (EU) 2020/1816, Annex II Not material ESRS S2-4 Human rights issues and incidents connected to its upstream and downstream value chain paragraph 36 Indicator number 14 Table #3 of Annex 1 Not material ESRS S3-1 Human rights policy commitments paragraph 16 Indicator number 9 Table #3 of Annex 1 and Indicator number 11 Table #1 of Annex 1 Not material ESRS S3-1 non-respect of UNGPs on Business and Human Rights, ILO principles or and OECD guidelines paragraph 17 Indicator number 10 Table #1 Annex 1 Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1) Not material ESRS S3-4 Human rights issues and incidents paragraph 36 Indicator number 14 Table #3 of Annex 1 Not material ESRS S4-1 Policies related to consumers and end- users paragraph 16 Indicator number 9 Table #3 and Indicator number 11 Table #1 of Annex 1 Material p. 99 ESRS S4-1 Non-respect of UNGPs on Business and Human Rights and OECD guidelines paragraph 17 Indicator number 10 Table #1 of Annex 1 Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1) Material p. 99 ESRS S4-4 Human rights issues and incidents paragraph 35 Indicator number 14 Table #3 of Annex 1 Not material ESRS G1-1 United Nations Convention against Corruption paragraph 10 (b) Indicator number 15 Table #3 of Annex 1 Material p. 106 ESRS G1-1 Protection of whistle-blowers paragraph 10 (d) Indicator number 6 Table #3 of Annex 1 Material p. 106 ESRS G1-4 Fines for violation of anti-corruption and anti-bribery laws paragraph 24 (a) Indicator number 17 Table #3 of Annex 1 Delegated Regulation (EU) 2020/1816, Annex II) Material p. 109 ESRS G1-4 Standards of anti- corruption and anti- bribery paragraph 24 (b) Indicator number 16 Table #3 of Annex 1 Material p. 108-109 Annual report 2024 | Sustainability statement 57 2. Environmental Information: E1 Climate Change Annual report 2024 | Sustainability statement 58 2.1 Policies related to climate change mitigation and adaptation The following policies and steering documents are used to manage material impact, risk and opportunities (IROs) related to ESRS topic E1 climate change. Locally implemented policies are available to employees on the Group’s internal governance platform. How each policy is used to manage specific material IROs is described in more detail throughout this section. Steering documents / policies to manage material IROs related to E1: Climate change Steering document Description Responsible Banking Framework Responsible Banking Model Responsible Banking and Sustainability policy As described in the section 1.5 Sustainability governance iv. Sustainability policies, including how the model outlines the Santander Responsible Banking strategy, including aligning financing activity with net-zero (NZBA), climate change mitigation and adaptation, energy efficiency and renewable energy usage in own operations. The Group’s Responsible Banking model describes the specific processes and activities that are required to be performed to manage its direct and indirect impact on the environment and climate change. For climate change mitigation and adaptation, the Group’s Responsible Banking function is required to (i) coordinate initiatives and assist business plans to ensure consistency with agreed sustainability strategy and commitments; and (ii) participate in the Net Zero Banking Alliance (NZBA) working groups and other initiatives. This is supported with collaboration from Commercial Auto and other functions that are required to develop ways to measure the financed emissions of the Group’s lending portfolio, as well as implement plans, actions and milestones to achieve its decarbonization objectives. Furthermore, the Responsible Banking model requires the Group’s Commercial functions to support customers’ sustainable transitions, to the extent possible and where applicable, in the development of sustainable finance offerings, including through the application of the Group’s Sustainable Finance and Investment Classification System (SFICS) to new and existing products, and the reporting of sufficient quality data and metrics to track and report progress the Group’s progress in sustainable lending. For energy efficiency and renewable energy deployment, the Group’s local Facilities function is responsible for measuring and monitoring the local operational carbon footprint of the Group. This includes developing measures to improve energy efficiency such as the management of office space, green building design and certification, as well as the purchasing of renewable energy used in the Group’s offices. Responsible function: Responsible Banking Environment, Social & Climate Change Risk Management policy The policy details how the Group identifies and manages risks from activities that require special attention and prohibited activities: oil and gas, energy, mining and metals and soft commodities. The policy is adopted locally from Banco Santander'. It is owned by the Group’s Chief Risk Officer and is approved by the Board of Directors. The policy references a number of external standards and best practices, including the Equator Principles, TCFD, the UN Global Compact, the Universal Declaration of Human Rights, the ILO declaration, the Rio Declaration on Environment and the UN Convention against corruption, as well as sector specific standards. Responsible function: Wholesale Risk Reputational Risk model Defines the principles for identifying, managing, preventing, and controlling reputational risk in all its processes, including those derived from ESG factors and owned by the Compliance & Conduct function. Responsible function: Compliance and Conduct Operational Risk Scenario Analysis Procedure Regulates the Group’s operational risk scenario analysis process, including defining the responsibilities of key participants throughout the cycle. The process involves annual review of applicable scenarios with a group of identified Subject Matter Experts and managers to analyze and quantify potential impacts, including for physical climate risk scenarios. Responsible function: Non-Financial Risk Banco Santander Green, Social and Sustainability Funding global framework A reference document for the issuance of green, social and sustainability labelled funding instruments for Banco Santander and its consolidated subsidiaries. The global framework considers ICMA Green Bond Principles, Social Bond Principles and Sustainability Bond Guidelines, as well as loan format contemplated within LMA, Loan Syndications and Trading Association and others. Banco Santander Sustainable Finance and Investment Classification System (SFICS) The SFICS outlines common standards to consider an asset or activity as environmental, social or sustainable in all of Grupo Santander’s units and businesses. It draws on international market guidelines, standards and principles, including the EU Taxonomy (including the additional four environmental targets from 2024), ICMA Principles, LMA Principles, UNEP FI Framework and the Climate Bonds Standard. Nordic Company Car policy Mandates that all new vehicle renewals must be EVs with zero emissions, except in cases where the country’s infrastructure does not support EV usage. The policy applies to all employees, is approved by the Group’s Risk Approval Committee (RACo) and is owned by the Chief People and Culture Officer. Responsible function: People and Culture Annual report 2024 | Sustainability statement 59 2.2 Developing the Group’s transition plan The Group has established a transition plan for climate change; however, this is not yet fully compliant with all ESRS requirements. In order to fully comply with the requirements, the Group needs to quantify the effects of its outlined actions and establish absolute emission targets for its auto lending portfolio. The Group aims to progress this work during 2025 through continued evaluation of the specific ESRS disclosure requirements and ensuring needed related processes are embedded into the organization. This chapter outlines the work conducted to date, describing the elements contributing towards the transition plan. i. Climate risk management Climate and environmental risks factors are considered transversal and likely to have an impact on existing risk types such as credit, market, liquidity, operational, reputational and strategic risks. These risk factors include elements derived from the physical effects of climate change and the transition to a low- carbon economy: • Physical risk (PR): Effects on economic activity, labor supply, communities, markets, assets, and investors. • Transition risk (TR): Risks associated with changes in regulation, technology, and market trends. The Group assesses how transition and physical risks impact on the economy, customers and business, especially in terms of impaired profitability and property values, revenues that may be affected by rising costs and lower productivity, declining demand, falling asset performance, rising cost of legal and regulatory compliance, declining household wealth and other aspects. The Group’s risk classification is fundamental for effective risk management and control. The following drivers are considered when assessing potential environmental and climate-related risks: Drivers considered to assess potential environmental and climate-related risks These climate and environmental risk factors can present both risks and opportunities for Santander and its customers. On the one hand, they can affect customers’ financial solvency over different time horizons and impact the Group’s reputation. On the other hand, the urgent transition to a low-carbon economy represents a significant business opportunity for banks. The Group actively engages with and supports customers in their transition to a low-carbon economy by offering environmentally and socially responsible products and services, leveraging sustainable business opportunities. Physical risks (PR) Transition risks (TR) Acute More intense extreme weather events, such as droughts, hurricanes or floods. Market sentiment Changes in the supply and demand of certain commodities, products and services as they consider climate risks and opportunities, which could lead to reputational and other issues. Chronic Changes in rainfall patterns, extreme weather variability, average temperature rises, severe heatwaves and rising sea levels. Policy action Implementing carbon pricing mechanisms to reduce greenhouse gas emissions; using energy sources with lower emissions; adopting energy efficient solutions; and sustainable land use practices. Technology The need to build and innovate to support the transition to an energy efficient financial system with lower CO₂ emissions. This can have a significant impact on companies as new technology displaces obsolete systems and disrupts some components of the financial industry as we know it. Annual report 2024 | Sustainability statement 60 Resilience of the Group’s strategy and business model to climate change The management of climate and environmental risk factors is of paramount importance to ensure the resilience of the Group’s strategy and business model in the face of climate change. Furthermore, it is crucial to support the transition towards a low-carbon economy, and for the Group’s ambition to be net- zero in carbon emissions by 2050. By integrating climate aspects into risk management processes and procedures, the Group can implement its sustainability strategy to contribute to the transition towards a low-carbon economy. This is carried out by integrating climate and environmental risk factors into: (i) the different phases of the risk management cycle, and (ii) the credit granting process, following a risk-based approach to consider climate and environmental factors in policies, procedures, data, tools, metrics, governance, and culture. This integration enhances the Group’s ability to adapt to climate change impacts by ensuring regulatory compliance, securing its access to finance and developing products and services offerings in the short, medium and long term. The Risk function evaluates the various risks faced by the Group within its business model and defined strategy. The primary source of risk to the Group's business model in the Nordic region, is the climate transition in the automobile sector, specifically the shift from Internal Combustion Engines (ICE) to Electric Vehicles (EVs). Other risks include those arising from the regulation and legislation of the automotive sector (as policy volatility has a direct impact on consumer behavior), as well as reputational and strategic risks. In 2024, efforts continued to further embed the integration of climate and environmental risk factors into the Group's enterprise-wide risk management processes (such as the risk appetite statement, the process of identifying top/emerging risks, and others) and key strategic exercises. Additionally, the Group has implemented its Environmental, Social and Climate Change (ESCC) risk management policy, which set out the activities that are prohibited and those that require special attention. The management of climate risk is continuously evolving, requiring a holistic and comprehensive approach to ensure effective management and control, alignment with the Group's ESG strategy, and compliance with rigorous regulatory and supervisory requirements. Given that climate risk is interconnected with all key types of risk, the Group has developed and continues to improve processes to integrate climate risk considerations into core processes and its risk management cycle. However, since the timing and severity of climate change may be unpredictable and can evolve rapidly, risk management strategies may not be effective in mitigating exposure to climate risk. Additionally, the Group may be subject to new or stricter regulatory requirements related to climate change, which could lead to increased regulatory, compliance, or other costs. Given that the risks, perspectives, and approaches of regulators, shareholders, employees, and other stakeholders regarding climate change are rapidly evolving, it can be challenging to assess the ultimate impact of climate-related risks, compliance risks, and uncertainties. Based on the information available at the time of writing, the Group has not identified any specific parts of its own operation, upstream or downstream value chain that has been excluded from the scope of its resilience analysis. Nor have any material physical or transition risks been excluded from this scope. Annual report 2024 | Sustainability statement 61 Reputational risk This section outlines how the Group manages the following IRO: R Reputational risk derived from the perception of clients and stakeholders that banks aren't doing enough to meet low-carbon targets, act against their policies or that their public commitments can pose reputational risk. Climate-related transition risk. The Group manages reputational risk in accordance with Banco Santander’s Reputational Risk Model, as described in subchapter 2.1 Policies related to climate change mitigation and adaptation. Assessment of the impact of reputational risk is carried out through processes relevant to the Group in ESG matters, such as the definition of public commitments, participation in working groups and governance bodies related to ESG issues, participation in the structuring of operations that may be sensitive from an ESG perspective, as well as in reporting processes. The number of very high-impact reputational risk events that have materialized and affected various stakeholders is used to evaluate the performance and effectiveness of the ESG reputational risk management actions. To manage reputational risk related to ESG, potential impacts of risk factors have been identified together with mitigating activities and next steps. See details below. Overview of Group approach for managing ESG risk factors Possible impacts of climate and environmental risk factors What the Group is doing to manage climate and environmental risk factors Next steps → Customers, investors, and other stakeholders could perceive that banks are not doing enough to meet low-carbon emission targets, are acting against their policies, or that their public commitments could pose a reputational risk. → Stakeholders may perceive inadequate financing/investment in climate and environmental sectors. → Customers, investors, and stakeholders may misinterpret information from statements, actions, announcements, policies, and sustainability features of products. → Hold periodic meetings to review reputational issues (including climate and environmental issues) involving the legal, responsible banking, investor relations, public policy, supervisory and regulatory relations, security and intelligence, risk, and other teams. → To implement a metric in the 2025 Risk Appetite that ensures adequate progress towards the decarbonization target of the automotive portfolio by 2030. → To continue driving cooperation between the Reputational Risk team and other teams to address reputational risk related to climate and the environment. → Continue with a conservative approach in its statements, ensuring transparent disclosures and alignment with the Group’s sustainability goals to avoid misleading stakeholders about the Group’s environmental impact. Strengthen controls over greenwashing. → To continue managing ESG-related events that involve material reputational risks. Annual report 2024 | Sustainability statement 62 ii. Climate scenario analysis Scenario analysis is an operational risk instrument used by the Group to identify relevant, potential impacts of potential high severity low frequency operational risk events (scenarios). The process assesses the Group’s resilience and aims to reduce the probability and/or severity of the scenario should it occur. Scenario analysis follows the Group’s Operational Risk Scenario Analysis Procedure and involves an annual review of applicable scenarios with a group of identified Subject Matter Experts and managers to analyze and quantify potential impacts. The process also provides input for other key Group exercises, such as the Top Risks/emerging risks identification process coordinated by the Enterprise Risk Management (ERM) function. The process contributes to defining recovery strategies as part of Business Continuity Management (BCM) and is considered when assessing the Group’s ESG risk profile within the Risk Profile Assessment (RPA). The scenario analyses conducted in 2024 are applicable for the short-, medium- and long term. The Group has not identified assets or business activities that are incompatible with, or require substantial efforts to align with, a transition to a climate- neutral economy. Physical risk scenario For the physical scenario exercise conducted in 2024, the Group assessed the location of its head office in Lysaker, Norway, identifying climate-related heavy and changing precipitation as well as flood hazards. Such an event would result in a temporary, short-term, disruption of on-site business activities at the location. However, the impact is anticipated to be limited due to the nature of the Group's operations and the capability for most employees to work remotely. Using external sources, including the Intergovernmental Panel on Climate Change's (IPCC) representative concentration pathway (RCP) climate scenarios, the Group assessed potential risks considering a specific stress exercise scenario (RCP 8.5) and scope setting supported by an initial comparison to RCP 2.6. Outcomes of the physical scenario analysis (including the estimation of direct and indirect operational risk losses) were presented to the Group’s management committee NFRC&CC (Non-Financial Risk Control and Compliance Committee) and discussed from the point of view of potential mitigating actions. The scenario is considered relevant to the Group due to the location and previous events in the approximate location. The Group — like the rest of the financial industry — is working to improve the granularity of the information available to assess physical risk and its activities and customers’ activities over the short, medium and long-term. Supporting the scenario planning, the Group also assesses the exposures prone to the impact of physical chronic and acute climate change events, based on the activity sector and region of the counterparty available for Norway, using external information provided by Munich Re. As of December 31, 2024, 126.2 MM NOK of the portfolio in Norway is exposed to chronic climate risk, and no exposure is subject to acute climate risk. Transition risk scenario For 2024, the Group conducted a transition risk scenario focused on the event of a significant error in the reporting of the Group’s Green Asset Ratio KPI in the sustainability statement due to a misclassification of ICE (internal combustion engine) vehicles as zero emission electric vehicles. This could result in an over- representation of the Group’s green performance to customers, investors and regulators, resulting in increased stakeholder concern (a reputational transition event). Mitigating actions identified include the integration of external sources to verify the vehicle type and the following of established governance practices for reporting and product approvals. The process to assess the transition risk scenario included input from key internal stakeholders on impacts to the Group’s assets and business activities. This scenario is considered particularly relevant to the financial industry and to manage and avoid reputational risks and stakeholder concerns. The 2024 transition risk scenario assessment was performed separately from the annual scenario analysis campaign. From 2025, the Group aims to incorporate the transition risk assessment into its annual scenario analysis campaign to further support the development and understanding of climate risk exposure, whilst exploring ways to integrate the findings of the climate scenario assessments into its risk and operational processes. This is expected to improve the analysis of transition risk events under different time horizons and the development of scenarios consistent with limiting climate change to 1.5oC, which are not included in the 2024 assessment. Annual report 2024 | Sustainability statement 63 iii. Funding This section outlines how the Group manages the following IRO: O Growth in green bonds, green loans and sustainability- linked financing instruments. The Group uses multiple funding channels to support its transition plan and its pursuit of a diversified funding strategy. In 2024, the Group implemented Banco Santander’s updated Green, Social and Sustainability Funding global framework (described in subchapter 2.1 Policies related to climate change mitigation and adaptation) and issued 3 Green Bonds (for 500MM and 300MM SEK and 300MM NOK) to fund the Group’s Norwegian Electric Vehicle portfolio. Banco Santander’s Green, Social and Sustainability Funding global framework is the Group’s reference for all environmental, social and sustainability-labelled funding instruments traded in sustainable capital markets. The framework enables Banco Santander entities, including the Group, to issue green, social and sustainability bonds and similar instruments in accordance with Banco Santander sustainability criteria as well as the applicable regulations at the time of launch. Consistent with best market practice and investor expectations, the framework covers use of proceeds, project assessment and selection, management of proceeds and reporting in line with the International Capital Market Association’s (ICMA) and Loan Market Association’s (LMA) guidelines. The framework is also consistent with Banco Santander’s internal guide to classifying sustainable finance and enabling activity tracking, product development and mitigating the risk of greenwashing, namely the Sustainable Finance and Investment Classification System (SFICS). SFICS is based on international industry guidelines, standards and principles including the EU Taxonomy, ICMA, LMA Principles, UNEP FI framework and Climate Bond Standards. Furthermore, in November 2024 the Group launched a Green Fixed Term Deposit product under the Sustainable Global Funding Framework to support efforts to manage emissions from its customers’ activities. This product will exclusively fund Norway’s electric vehicle portfolio, and thereby allow customers to link their savings to support lending activity that is aligned with the Group’s environmental strategy and objectives. Targets and planned actions are not disclosed under this opportunity due to the commercial sensitivity of such information. iv. EU Paris-aligned benchmarks Neither the Group nor Banco Santander are excluded from the EU Paris-aligned benchmarks. The Group has no exposure to undertakings excluded from the EU Paris-aligned benchmarks. v. Alignment and decarbonization lending portfolios This section outlines how the Group manages the following IRO: I- (Potential) Adverse impact on the environment (e.g. increase in GHG emissions) because of the Group’s financing and investing activity, incl. granting loans to companies operating in high polluting sectors or vehicles that are not electric/hybrid. All policies described under subchapter 2.1 Policies related to climate change mitigation and adaptation are considered relevant for this IRO. Portfolio alignment The Group is committed to assisting its customers as they transition to a low-carbon economy, aligning with Banco Santander's ambition of achieving net zero carbon emissions by 2050. The automotive sector plays an important role in this transition, as road transport is responsible for over 15% of global energy- related emissions, according to the International Energy Agency (IEA). The shift from internal combustion engines (ICE) to electric vehicles (EV), plug-in hybrid electric vehicles (PHEV) and other zero-emission drive chains is the most significant lever for decarbonization in this industry. During 2023, as part of a Santander-wide project, significant efforts were made to evaluate the emissions of the Group’s auto financing. To facilitate the evaluation process, internal methodologies that incorporate insights and recommendations from the Net Zero Banking Alliance (NZBA) guidelines, the PCAF standard, publications from the Glasgow Financial Alliance for Net Zero (GFANZ), the Science Based Targets initiative (SBTi), and other relevant standards were applied. Additionally, external data and models from reputable third-party sources, along with both financial and non-financial information, were taken into account. Annual report 2024 | Sustainability statement 64 Whilst the Group is yet to publish decarbonization targets for its auto financing portfolios that are fully compliant with ESRS standards, the output of the above referenced project has provided a significant foundation on which to establish such targets. Details of the evaluation undertaken by the Group are described below. Scenario: The “International Energy Agency - Net Zero Emissions by 2050 Scenario” (IEA-NZE) was adopted to inform the development of science-based decarbonization targets for financed sectors. This scenario offers a credible pathway to achieving net zero emissions by 2050 and limiting global temperature rise to 1.5º C, in accordance with the Paris Agreement. Target type: Physical emissions intensity metric, expressed in gCO2e/vkm by 2030 Coverage: The Group’s passenger car portfolio (including loans and leasing to customers in the Group’s downstream value chain) in Norway, Sweden, Denmark and Finland. The Group is working on obtaining information and tracking emissions for other vehicle types, however, currently only passenger cars are included. Baseline year: The baseline year for its auto lending sector assessment is 2022, chosen to be representative of the portfolio at that time. Given the complexity and data required for the assessment, financed emissions for the Auto portfolio are assessed and presented in the table below based on a 12-month lookback period. The Group’s Auto financing portfolio actuals (12-month lookback) Country Year 1, 2 Exposure (drawn amount NOK bn)3 Absolute emissions (MtCO2e)3, 4 Physical emissions intensity (gCO2e/km)3 Financial emissions intensity (MtCO2e/ NOK bn lent)3 PCAF score5 Norway 2022 22.092 0.069 85 0.003 3.7 2023 38.418 0.122 90 0.003 3.0 Sweden 2022 19.976 0.081 87 0.004 3.0 2023 33.065 0.128 87 0.004 3.0 Denmark 2022 14.658 0.058 118 0.004 3.0 2023 28.138 0.139 119 0.005 3.1 Finland 2022 13.675 0.088 138 0.006 3.0 2023 21.617 0.127 137 0.006 3.1 Financed emissions: The Group has measured the financed emissions of its auto financing portfolio in Norway, Sweden, Denmark, and Finland, following the Partnership for Carbon Accounting Financials (PCAF) methodology and utilizing the IEA NZE 2050 as a reference pathway. In alignment with the GFANZ approach, decarbonization targets are viewed as instrumental in facilitating the net zero transition of the real economy. These targets encompass: financing or enabling the development and scaling of climate solutions to replace high- emission technologies or services, including the responsible phase- out of high-emission physical assets; supporting companies that are already aligned with a 1.5ºC pathway; and financing or assisting the transition of real economy firms in accordance with transparent and robust net-zero transition plans that align with sectoral pathways compatible with a 1.5ºC target. Portfolio evolution: In addition to setting Nordic targets in alignment with ESRS, the Group is working to enhance the automation of calculations to improve its monitoring of emissions- related metrics, including total emissions, emission intensity, exposure within the auto lending portfolio, and PCAF scores. Industry dynamics: The decarbonization of this sector in Europe is primarily driven by regulatory measures, particularly laws that will prohibit the sale of internal combustion engine vehicles by 2035 at the latest. Furthermore, the pace of decarbonization is contingent on the development of electric vehicle infrastructure (such as charging stations), consumer behavior in key automotive markets, and the capacity of vehicle manufacturers to produce and market electric vehicles effectively. 1 2022 data is based on the Group’s Auto lending passenger car portfolio from July 2021 onwards. 2 2023 data is based on the Group’s full Auto lending passenger car portfolio. 3 Data is limited to consumer lending for the acquisition of passenger cars. 4 Absolute emissions are calculated with all emissions converted to WLTP, thereafter the attributed emission is multiplied with the estimated annual mileage per contract. 5 Partnership for Carbon Accounting (PCAF) scores illustrate the data quality used to calculate the financed emissions (with 1 being the highest reliability and 5 the lowest). Annual report 2024 | Sustainability statement 65 Decarbonization actions The transition from internal combustion engines (ICE) to electric vehicles (EV) and plug-in hybrid electric vehicles (PHEV) is the key decarbonization lever for this sector. As a leading auto end- user lender in the Nordics, the Group is facilitating the financing of an increasing number of EVs and PHEVs for its customers. In April 2023, senior management approved the Group’s overall Responsible Banking strategy, which was subsequently endorsed by the Board of Directors in May 2023. This strategy includes the development of the Group’s portfolios to align with its ambition to achieve net zero by 2050. To support its decarbonization efforts, the Group has identified several long-term actions, including: • Entering into new agreements and build on existing agreements with electric vehicle manufacturers. • Renewing and building on existing agreements with traditional manufacturers that have ambitious electric vehicle transition targets. • Offering additional bundles of financial products and solutions for electric vehicles (e.g. installation and financing of home chargers, solar panels). In 2024, the Group implemented several initiatives to advance its long-term decarbonization goals: • Incorporated a lower cost of ownership for electric vehicles into affordability calculations, which will enhance lending options for consumers within the Group’s legal and risk frameworks. • Continued efforts to expand e-signature options to facilitate a fully paperless application process, an initiative that will extend into 2025. • Signed multiple agreements with partners supplying electric vehicles to consumers, reinforcing the Group's commitment to these actions. Implementation of these initiatives does not currently depend on the availability or additional allocation of resources, as they are carried out on an ongoing basis as part of the business-as- usual activities. The Group has yet to estimate a specific timeline for when these actions will have their greatest impact. The success of decarbonization actions depends on electric vehicle demand and regulation as well as manufacturers’ transition plans, not to mention other external factors such as technology, infrastructure, government incentives and tariffs on electric vehicles. The Group aims to follow general market trends and help finance EVs according to the progress of the transition. Achieving the targets for decarbonization of the auto lending portfolio will depend on several external factors such as: • Regulation and policy: Effective government measures and policies are needed to reach the EV sales and decarbonization levels that the net zero scenario requires. Countries will need to meet the timelines set to end sales of new ICE vehicles. The introduction of low emission zones would support this change. The removal of subsidies on EV purchases in Nordic countries may also hinder market penetration. • Technology: A guaranteed supply of the required materials to produce EVs and PHEVs at scale is needed to match demand. Also, reducing EV and PHEV production costs is required to ensure affordability in comparison with less clean alternatives (ICE vehicles), and thus ensure a just transition. • Infrastructure: Reaching a high penetration of EVs and PHEVs will require a deep transformation of supply chains and the infrastructure that powers them (increasing the number of charging points and their performance) to shift from a model of predominantly ICE vehicles to an EV and PHEV majority. The investment needed for this infrastructure will require support from governments and other actors, which could be affected by conflicting interests such as energy security. • Original Equipment Manufacturers’ (OEMs) commitments: Manufacturers must fulfil their commitments regarding their development and the phasing out of combustion engines. Looking ahead, the Group aims to further enhance data collection and automatization of emissions calculations. Responsible Banking, Risk and other functions are monitoring action plans and emissions performance, while commercial teams are performing actions to support the Group’s decarbonization plans. Annual report 2024 | Sustainability statement 66 2.3 Supporting customers’ transition to a low carbon economy This section outlines how the Group manages the following IRO: O Support revenue growth through offering customers differentiating solutions in areas such as real estate (retrofitting) mobility (EVs and other low-carbon mobility, infrastructure) among others. The Group’s consumer financing activities are split into two main product areas: Auto finance and unsecured Consumer finance. All policies described under subchapter 2.1 Policies related to climate change mitigation and adaptation are considered relevant for this IRO. i. Auto As the Nordic region’s largest auto finance provider, the Group plays an important role in driving the transition to vehicle electrification. In 2024, 48% of all new vehicles financed (by number of contracts) were battery electric vehicles (EVs) and approximately 20% were hybrids. Notably, EV financing declined compared to the previous year due to market circumstances. The Group’s market share of new EVs registered in the Nordics was 9.2% in 2024. The Nordics has been a frontrunner in EV adoption, thanks to robust political support and favorable consumer subsidies, which in turn has attracted EV manufacturers to focus on the region. Leveraging the Group’s market leading position in auto finance has established a prominent presence in the EV financing market. The market share of EVs is growing fast in the Nordics and registrations have continued to increase, particularly in Denmark and Finland. In Norway, the new EV financing share continues to grow, mainly driven by the growth in Tesla financing, whilst financing in Sweden has decreased due to the change in government incentive, reducing the attractiveness of EV financing. Targets are not disclosed under this opportunity due to the commercial sensitivity of such information. Relevant actions are described under section v. Alignment and decarbonization lending portfolios. Development of the Group’s EV financing in 2024 versus 2023 Group TOTAL 2024 2023 Difference (%) New BEV registrations1 341 742 330 517 3.40% Financed by SCB2 31 374 36 349 -13.69% SCB market share 9.18% 11% -1.82% Norway TOTAL New BEV registrations 122 531 113 457 8% Financed by SCB 16 427 16 649 -1.33% SCB market share 13.41% 14.67% -1.27% Sweden TOTAL New BEV registrations 102 607 120 519 -14.86% Financed by SCB 8 013 14 371 -44.24% SCB market share 7.81% 11.92% -4.11% Denmark TOTAL New BEV registrations 93 510 65 634 42.47% Financed by SCB 5 111 1 877 172.3% SCB market share 5.47% 2.86% 2.61% Finland TOTAL New BEV registrations 23 094 30 907 -25.28% Financed by SCB 1 823 3 452 -47.19% SCB market share 7.89% 11.17% -3.28% 1 Market data is obtained from official sources, including Vroom (SE), Bilstatistik (DK), Value Clinic (FI) and OFV (NO). 2 Sales information is extracted from internal systems. EVs are registered by fuel type and verified by vehicle identification number. 3 No external body other than the assurance provider has verified this data. Annual report 2024 | Sustainability statement 67 ii. Consumer Within the consumer finance market, the Group’s focus has primarily been on Real Estate-related (including financing of solar panels, green heating systems and other energy efficiency and retrofit improvements) and Clean Mobility (bicycles and e-bikes) sectors. The Group serves these markets through its checkout lending product. Currently the Group does not have sufficient granular data on the type of financing activity of this portfolio to assess these activities under its SFICS and the EU Taxonomy as green and taxonomy-aligned assets. The Group plans to improve its reporting in the future to include more taxonomy-aligned activities in the Group’s Green Asset Ratio. 2.4 Environmental footprint The Group’s carbon footprint is assessed using the Greenhouse Gas Protocol’s standardized reporting criteria for GHG emissions, which include: • Scope 1: Emissions from directly owned or controlled sources. • Scope 2: Indirect emissions from purchased energy. • Scope 3: Emissions generated upstream and downstream in the value chain, covering business travel, staff commuting and others, as well as category 3.15 ‘Investments’ (i.e. the Group’s financed emissions). In addition to the scope 3 categories 3.15 Investments, 3.6 Business travel and 3.7 Employee commuting, the Group considers four supply chain-related categories as significant to its scope 3 GHG emissions: • 3.1 Purchased goods and services • 3.2 Capital goods • 3.4 Upstream transportation and distribution • 3.9 Downstream transportation and distribution The Group has calculated these categories using proxies based on operating expenditure in 2024. The emissions factors used to calculate these categories in 2024 are based on the emission intensities within the input-output (IO) database of the US Environmental Protection Agency (EPA), which are split by economic sector. The Group seeks to reduce its environmental impact through: • Efficient spaces: In 2024, the Group has implemented a Hybrid Office program to reduce its use of space and building occupancy. The new Hybrid Office format has been completed in the Group’s Stavanger, Solna and Stamholmen offices, with further work in Lysaker and Helsinki to be completed. • Agreements to purchase renewable electricity from suppliers in all its Nordic offices. • The Group’s Company Car policy which mandates that all new vehicle renewals must be EVs with zero emissions, except in cases where the country’s infrastructure does not support EV usage. The policy applies to all employees and is owned by the Nordic People & Culture director. • Awareness and involvement of the entire organization in environment-related results and reporting. In 2024, the Group’s owner Banco Santander implemented Scope 1 and 2 emission reduction targets. Starting from 2025, the Group will review how to implement these targets in its own operations, which it has not yet adopted due to the challenges around obtaining accurate and comparable data to support the setting of meaningful targets. The Group’s consumption Consumption Amount in 2024 Unit Purchased electricity1 1 880 716 kWh from renewable sources2 100% % Consumption of purchased or acquired heating and cooling 3 1 125 187 kWh Water4 19 697 m3 Purchased paper5 34 569 kg Purchased recycled paper consumption 1 847 kg Purchased certified paper consumption 29 109 kg Purchased not certified paper consumption 3 613 kg Waste Amount in 2024 Unit Total waste6, 7 9 824 kg Paper and cardboard waste 3 257 kg Electronic waste 6 567 kg Total recycled waste6, 7 6 157 kg Paper and cardboard waste 3 257 kg Electronic waste 2 900 kg 1. Purchased electricity (kWh) is based on figures provided by the landlords in each of the Group’s offices in Lysaker and Stavanger in Norway, Sweden, Denmark and Finland. 2. % from renewable sources is based on obtaining contractual instruments (contracts for renewable electricity guaranteed by the utility) used for the procurement of renewable electricity. 3. Consumption of purchased or acquired heating and cooling (kWh) are based on FY2024 figures provided by the landlord in the Group’s head office in Lysaker, and additional information from the landlord in the Group’s Stavanger office in Norway from June – December 2024. 4. Consumption of water (m3) includes information from landlords in Norway, and estimations for the Group’s other offices based on water consumption in the Lysaker head office per employee. 5. Purchased recycled, certified and not certified paper consumption (kg) are estimated from Banco Santander proxies of consumption per employee based on 2023 data from Santander’s largest business units in 10 countries. 6. Total waste and Total recycled waste for Paper and cardboard (kg) are limited to figures provided by the landlord of the Group’s head office in Lysaker, Norway. 7. Total waste and Total recycled waste for electronic waste (kg) are based on figures provided by the Group’s external provider for electronic waste management in each of the Group’s offices. Annual report 2024 | Sustainability statement 68 The Group’s GHG emissions Scope 1 GHG emissions Amount in 2024 Unit Scope 1 Direct emissions1 0 tCO2e Scope 2 GHG emissions Amount in 2024 Unit Gross Indirect emissions market-based2 0 tCO2e Gross Indirect emissions location-based3 35.4 tCO2e Significant Scope 3 GHG emissions Amount in 2024 Unit 3.1 Purchased goods and services4 12263.0 tCO2e 3.2 Capital goods4 5834.2 tCO2e 3.3 Fuel and energy-related activities (not included in Scope 1 or 2) Not material 3.4 Upstream transportation and distribution4 0 tCO2e 3.5 Waste generated in operations Not material 3.6 Business travel5 188.7 tCO2e 3.7 Staff commuting6 418.6 tCO2e 3.8 Upstream leased assets Not material 3.9 Downstream transportation and distribution4 167.5 tCO2e 3.10 Processing of sold products Not material 3.11 Use of sold products Not material 3.12 End-of-life of treatment of sold products Not material 3.13 Downstream leased assets Not material 3.14 Franchises Not material 3.15 Financed emissions7 516051.1 tCO2e Total GHG emissions Amount in 2024 Unit Total GHG emissions (market based) 534923.1 tCO2e Total GHG emissions (location based) 534958.5 tCO2e Total GHG emissions intensity Unit Total GHG emissions intensity (market-based)8 67.4 tCO2e/MM NOK Total GHG emissions intensity (location-based)8 67.4 tCO2e/MM NOK 1. Scope 1 emissions: The Group has not identified any direct energy consumption, does not have a vehicle fleet, nor any other activities that derive emissions that correspond to Scope 1, as defined by the GHG Protocol standard. 2. Scope 2 emissions: For market-based indirect emissions, the Group considers the consumption of 100% energy from renewable sources. 3. Scope 2 emissions: For location-based indirect emissions, the Group has applied International Energy Agency (IEA) emission factors (2024 edition, reference year 2022) corresponding to the electricity consumption of each country (Norway, Sweden, Denmark and Finland) regardless of its source of origin (renewable or non-renewable). Additionally, emissions from heating and cooling in Norway are estimated from available heating and cooling emission factors relevant for Lysaker/Fornebu provided by Oslofjord Varme (latest available 2023). Emission factors applied to Scope 2 emissions do not separate the percentage of biomass or biogenic CO2. 4. Scope 3.1, 3.2, 3.4, 3.9: Supply chain emissions are calculated using a spend-based approach considering the payments to suppliers in the current year. For that non primary data obtained from suppliers has been used. These are calculated using the Supply Chain Greenhouse Gas Emission Factors v1.3 from the U.S. Environmental Protection Agency. Supplier taxonomies are mapped to the sectors considered in the database and then converted into emissions through spend-based emissions factors. Then, different spending taxonomies are grouped based on the GHG scope 3 categories based on their nature (purchased goods and services, capital goods, upstream and downstream transportation). 5. Scope 3.6 Business travel: The Group calculates business travel by plane with data on the number of kilometers of air travel provided by its external travel partner and applies available conversion factors (2024) corresponding to air travel obtained from the UK’s Department for Environment, Food and Rural Affairs (DEFRA). Additional estimates for business travel by car, emissions are estimated using Banco Santander proxies of kilometers travelled per employee based on 2023 data from Santander’s largest business units in 10 countries. Available conversion factors corresponding to petrol and diesel cars are obtained from the UK’s DEFRA (2024 - used to ensure consistency with Banco Santander reporting). 6. Scope 3.7 Staff commuting: The Group conducted a survey of its employees in Q4 2024 to estimate its emissions related to staff commuting, with an overall response rate of approximately 23%. Available conversion factors corresponding to the modes of transportation identified in the survey are obtained from the UK’s DEFRA (2024 - used to ensure consistency with Banco Santander reporting). 7. Scope 3.15 Financed emissions: Estimation based on data calculated for the 2023 auto passenger car portfolio, being the largest portfolio available. 8. Total GHG emissions intensity (market-based) and (location-based): The denominator in the calculation of GHG emissions intensity is Gross Margin (7 939 MM NOK) and included in the Group’s Financial Statements (under Profit and Loss – Santander Consumer Bank Nordic Group). Annual report 2024 | Sustainability statement 69 2.5 EU Taxonomy This chapter includes the Group’s disclosures pursuant to Article 8 of the Regulation (EU) 2020/852 (Taxonomy Regulation). i. Information about Article 8 of the EU Taxonomy Regulation In 2023, the Norwegian Parliament adopted the Taxonomy Regulation (EU) 2020/852 and supplementing delegated acts set out by the European Parliament. The Taxonomy Regulation establishes the criteria for determining whether an economic activity qualifies as environmentally sustainable and incorporates an obligation that companies, including financial corporations, must disclose how operations align with the Taxonomy. The primary indicator of alignment is the Green Asset Ratio (GAR). It shows the extent to which activities in the balance sheet meet the Taxonomy’s technical standards and is the ratio of an entity’s Taxonomy aligned assets to balance sheet assets (excluding exposure to sovereigns, central banks and the trading portfolio). From 2024, financial institutions in Norway are required to publish the GAR for all six environmental objectives. Taxonomy eligible activities refer to activities included in the Taxonomy without determining if they meet the technical screening criteria that establishes under which conditions an activity can be considered as environmentally sustainable. ii. Approach to determine eligibility and alignment Eligibility The Group’s eligible activities cover lending primarily to households, as well as financial corporations, local governments and non-financial corporations subject to the Non-Financial Reporting Directive (NFRD). Alignment The Group includes a proportion of its general-purpose lending exposure to financial and non-financial corporations subject to NFRD based on the alignment ratio publicly disclosed by these counterparties (both CapEx and turnover-based alignment). Substantial Contribution Criteria The Group applies a stepwise process for the EU Taxonomy assessment: Identification of economic activities covered by the EU Taxonomy; Assessment of whether activities meet technical criteria for substantial contribution; assessment of whether activities meet the technical criteria for “Do No Significant Harm” (DNSH) to the other objectives; and check for compliance with minimum safeguards criteria. The Group identified lending activity related to zero direct (tailpipe) CO2 emissions Electric Vehicles (EVs) as a candidate for providing a substantial contribution to climate change mitigation. This activity is included as motor vehicle lending assets under 6.5 of Annex I of the Climate Delegated Act, which describes transport by motorbikes, passenger cars and light commercial vehicles and, specifically, the purchase, financing, renting or leasing of low- and zero-emission light-duty vehicles from January 1, 2022. However, due to the strict requirements to verify compliance with DNSH criteria, specifically the lack of documentation on asset level relating to the noise pollution from tires, the Group has determined at this point in time to not include lending activity related to motor vehicles as taxonomy aligned. Furthermore, due to insufficient data captured at the financed asset level, to be able to assess against the Taxonomy’s technical screening criteria, the Group has not considered lending activity relating to consumer finance (including solar panels, green heating systems, energy efficiency & retrofit and bicycles and e-bikes) as taxonomy-aligned. Annual report 2024 | Sustainability statement 70 iii. Calculation methodology Eligibility The Taxonomy eligible activities assessed by the Group include lending exposures to the following: • Financial corporations • Non-financial corporations subject to NFRD • Household loan portfolio: including building renovation loans, other purpose and vehicle loans The eligibility alignment ratios are based on mandatory reporting on information that counterparties publicly disclose (both CapEx and turnover-based eligibility) and captured by an external information provider. Derivatives, on-demand interbank loans, cash and other assets (including goodwill and commodities) are excluded from the eligibility numerator. Green asset ratio numerator The numerator includes general purpose lending exposure to financial and non-financial undertaking subject to NFRD multiplied by the undertakings' published taxonomy KPIs. Alignment is based on published data for the financial year 2023, as at the time of reporting 2024 data is not yet available. Denominator Includes the total loans and advances, debt securities, total equities and repossessed collaterals and all other covered on- balance sheet assets and excludes exposure to sovereigns, central banks and trading portfolio, in line with the regulation requirement. iv. Summary As at December 31, 2024, the Group’s GAR was 0,30% (CapEx- based) and 0,28% (turnover-based). The alignment ratio reported in 2023 was based on the Group’s best understanding of the legislative requirements at the time and was calculated at 12.37% (CapEx- and turnover-based). However, the Group has since received guidance that the DNSH criteria shall be documented at asset level, rather than portfolio level, which was the approach used for the Group’s reporting in 2023. The lack of sufficient information about rolling noise for each of the individual assets prohibits verification of compliance towards the DNSH criteria. This change explains the reduction in the Group’s reported GAR for 2024, compared against 2023. Any future relaxation of the EU taxonomy regulations and reduction in the complexity of the DNSH criteria are expected to support an increase of the Group’s proportion of taxonomy- aligned assets, as illustrated in the voluntary disclosure below. v. Voluntary estimated disclosure The consequence of the stringent requirements to verify DNSH compliance on an asset level results in the exclusion from the GAR of a significant portion of the Group’s portfolio related to climate change mitigation, i.e. lending activity related to zero direct (tailpipe) CO2 emissions EVs. As such, the Group has chosen – on the basis of a voluntary estimated disclosure – to complement the reported GAR with an additional ratio, where the numerator includes the Group’s exposures in vehicle loans for electrical vehicles (EVs) from 2022. This estimation utilizes market data from across Europe (EPREL) to evaluate compliance with external rolling noise requirements at the portfolio level. There are uncertainties associated with these estimations. The voluntary GAR has been estimated at 16.4% (CapEx-based) and 16.4% (turnover-based) as at 31 December, 2024. The Group’s exposures reported under Article 10 of the Disclosures Delegated Act Proportion of eligible economic activities Proportion of non-eligible economic activities Coverage (over total assets) Proportion of taxonomy-aligned economic activities Lending % MM NOK % MM NOK % MM NOK Green Asset Ratio Mandatory approach (CapEx-based) 58.19% 131 359.74 MMNOK 41.81% 94 397.64 MM NOK 95.58% 673,78 MM NOK 0.30% Mandatory approach (turnover-based) 58.19% 131 365.41 MM NOK 41.81% 94 391.97 MM NOK 95.58% 636,68 MM NOK 0.28% 0. Summary of KPIs to be disclosed by credit institutions under Article 8 Taxonomy Regulation Total environmentally sustainable assets (1) KPI (2) KPI (3) % coverage (over total assets) (4) % of assets excluded from the numerator of the GAR (Article 7(2) and (3) and Section 1.1.2. of Annex V) % of assets excluded from the denominator of the GAR (Article 7(1) and Section 1.2.4 of Annex V) Main KPI Green asset ratio (GAR) stock 636,68 0,28% 0,30% 95,58% 23,04% 4,42% Total environmentally sustainable activities (5) KPI KPI % coverage (over total assets) (6) % of assets excluded from the numerator of the GAR (Article 7(2) and (3) and Section 1.1.2. of Annex V) % of assets excluded from the denominator of the GAR (Article 7(1) and Section 1.2.4 of Annex V) Additional KPIs GAR (flow) 171,78 0,39% 0,40% 54,73% 21,84% 11,29% (1) Total environmentally sustainable assets used for turnover KPI. Total environmentally sustainable assets used for Capex KPI amounts to NOK 673,78 million. (2) based on the Turnover KPI of the counterparty. (3) based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used. (4) % of assets covered by the KPI over banks' total assets. (5) Total environmentally sustainable activities used for turnover KPI. Total environmentally sustainable activities used for Capex KPI amounts to NOK 177,75 million. (6) % of assets covered by the KPI over banks' flow of total assets. Result based on the Turnover KPI of the counterparty. Coverage based on the Capex KPI is 54,71 %. 71 1.1 Assets for the calculation of GAR (Capex), Page 1 Of which Use of Proceeds Of which transitional Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 171 330,14 131 174,98 673,53 - - - 184,76 0,25 - - - - - - - - - - - - - - - - - - 131 359,74 673,78 - - - 2 Financial undertakings 23 785,53 8 749,49 629,75 - - - 184,68 0,25 - - - - - - - - - - - - - - - - - - 8 934,17 630,00 - - - 3 Credit institutions 7 991,10 3 037,70 220,08 - - - 183,94 0,16 - - - - - - - - - - - - - - - - - - 3 221,65 220,24 - - - 4 Loans and advances 3 241,54 1 093,54 64,82 - - - 31,87 0,07 - - - - - - - - - - - - - - - - - - 1 125,41 64,89 - - - 5 Debt securities, including UoP 2 869,10 1 264,13 106,48 - - - 151,99 0,08 - - - - - - - - - - - - - - - - - - 1 416,11 106,56 - - - 6 Equity instruments 1 880,47 680,04 48,78 - - 0,09 0,01 - - - - - - - - - - - - - 680,13 48,79 - - 7 Other financial corporations 15794,43 5 711,79 409,68 - - - 0,74 0,09 - - - - - - - - - - - - - - - - - - 5 712,53 409,76 - - - 8 of which investment firms - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 9 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 10 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 11 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 12 of which management companies - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 13 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 14 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 15 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 16 of which insurance undertakings - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 17 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 18 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 19 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 20 Non-financial undertakings 1690,78 613,42 43,78 - - - 0,08 0,01 - - - - - - - - - - - - - - - - - - 613,50 43,78 - - - 21 Loans and advances 1690,78 613,42 43,78 - - - 0,08 0,01 - - - - - - - - - - - - - - - - - - 613,50 43,78 - - - 22 Debt securities, including UoP 0,00 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 23 Equity instruments 0,00 - - - - - - - - - - - - - - - - - - - - - - - 24 Households 145635,67 121 593,93 - - - - - - - - - - - - 121 593,93 - - - - 25 of which loans collateralised by residential immovable property 0,00 - - - - - - - - - - - - - - - - - - 26 of which building renovation loans 0,00 - - - - - - - - - - - - - - - - - - 27 of which motor vehicle loans 121593,93 121 593,93 - - - 121 593,93 - - - - 28 Local governments financing 218,15 218,15 - - - - - - - - - - - - - - - - - - - - - - - - 218,15 - - - - 29 Housing financing - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 30 Other local government financing 218,15 218,15 - - - - - - - - - - - - - - - - - - - - - - - - 218,15 - - - - 31 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 32 Assets excluded from the numerator for GAR calculation (covered in the denominator) 54 427,24 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 33 Financial and Non-financial undertakings 42 172,67 34 SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations 27 368,86 35 Loans and advances 27 368,86 36 of which loans collateralised by commercial immovable property - 37 of which building renovation loans - 38 Debt securities - 39 Equity instruments - 40 Non-EU country counterparties not subject to NFRD disclosure obligations 14 781,47 41 Loans and advances 14 772,49 42 Debt securities - 43 Equity instruments 8,98 44 Derivatives 519,63 45 On demand interbank loans 2 376,71 46 Cash and cash-related assets 0,05 47 Other categories of assets (e.g. Goodwill, commodities etc.) 9 358,18 48 Total GAR assets 225 757,38 131174,98 673,53 - - - 184,76 0,25 - - - - - - - - - - - - - - - - - - 131 359,74 673,78 - - - 49 Assets not covered for GAR calculation 10 433,85 50 Central governments and Supranational issuers 2 149,84 51 Central banks exposure 8 177,31 52 Trading book 106,70 53 Total assets 236 191,22 131 174,98 673,53 - - - 184,76 0,25 - - - - - - - - - - - - - - - - - - 131 359,74 673,78 - - - 54 Financial guarantees - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 55 Assets under management - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 56 Of which debt securities - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 57 Of which equity instruments - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Of which towards taxonomy relevant sectors (Taxonomy-eligible) TOTAL (CCM+ CA+WTR+CE+PPC+BIO) 4. For motor vehicle loans, institutions shall only include those exposures generated after the date of application of the disclosure. Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy- eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Million NOK Disclosure reference date T Total [gross] carrying amount Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations 1. This template shall include information for loans and advances, debt securities and equity instruments in the banking book, towards financial corporates, non-financial corporates (NFC), including SMEs, households (including residential real estate, house renovation loans and motor vehicle loans only) and local governments/municipalities (house financing). 2. The following accounting categories of financial assets should be considered: Financial assets at amortised cost, financial assets at fair value through other comprehensive income, investments in subsidiaries, joint ventures and associates, financial assets designated at fair value through profit or loss and non-trading financial assets mandatorily at fair value through profit or loss, and real estate collaterals obtained by credit institutions by taking possession in exchange in of cancellation of debts. 3. Banks with non-EU subsidiary should provide this information separately for exposures towards non-EU counterparties. For non-EU exposures, while there are additional challenges in terms of absence of common disclosure requirements and methodology, as the EU taxonomy and the NFRD apply only at EU level, given the relevance of these exposures for those credit institutions with non-EU subsidiaries, these institutions should disclose a separate GAR for non-EU exposures, on a best effort basis, in the form of estimates and ranges, using proxies, and explaining the assumptions, caveats and limitations. 5. Total assets excludes accumulated depreciations and loan loss reserves, transactions within the Group are not eliminated 72 1.1 Assets for the calculation of GAR (Capex), Page 2 Of which Use of Proceeds Of which transitional Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 175 065,07 132 926,69 - - - - - - - - - - - - - - - - - - - - - - - - 132 926,69 - - - - 2 Financial undertakings 22 670,08 8 215,20 - - - - - - - - - - - - - - - - - - - - - - - - 8 215,20 - - - - 3 Credit institutions 3 646,15 1 556,83 - - - - - - - - - - - - - - - - - - - - - - - - 1 556,83 - - - - 4 Loans and advances 527,80 184,73 - - - - - - - - - - - - - - - - - - - - - - - - 184,73 - - - - 5 Debt securities, including UoP 1 311,99 739,87 - - - - - - - - - - - - - - - - - - - - - - - - 739,87 - - - - 6 Equity instruments 1 806,35 632,22 - - - - - - - - - - - - - - - - - - 632,22 - - - 7 Other financial corporations 19 023,93 6 658,38 - - - - - - - - - - - - - - - - - - - - - - - - 6 658,38 - - - - 8 of which investment firms - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 9 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 10 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 11 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 12 of which management companies - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 13 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 14 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 15 Equity instruments - - - - - - - - - - - - - - - - - - - - - - 16 of which insurance undertakings - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 17 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 18 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 19 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 20 Non-financial undertakings 8,79 8,79 - - - - - - - - - - - - - - - - - - - - - - - - 8,79 - - - - 21 Loans and advances 8,79 8,79 - - - - - - - - - - - - - - - - - - - - - - - - 8,79 - - - - 22 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 23 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 24 Households 152 155,01 124 471,52 - - - - - - - - - - - - 124 471,52 - - - - 25 of which loans collateralised by residential immovable property - - - - - - - - - - - - - - - - - - - 26 of which building renovation loans - - - - - - - - - - - - - - - - - - - 27 of which motor vehicle loans 124 471,52 124 471,52 - - - - 124 471,52 - - - - 28 Local governments financing 231,18 231,18 - - - - - - - - - - - - - - - - - - - - - - - - 231,18 - - - - 29 Housing financing - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 30 Other local government financing 231,18 231,18 - - - - - - - - - - - - - - - - - - - - - - - - 231,18 - - - - 31 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 32 Assets excluded from the numerator for GAR calculation (covered in the denominator) 53 625,67 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 33 Financial and Non-financial undertakings 34 SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations 35 Loans and advances 36 of which loans collateralised by commercial immovable property 37 of which building renovation loans 38 Debt securities 39 Equity instruments 40 Non-EU country counterparties not subject to NFRD disclosure obligations 41 Loans and advances 42 Debt securities 43 Equity instruments 44 Derivatives 45 On demand interbank loans 46 Cash and cash-related assets 47 Other categories of assets (e.g. Goodwill, commodities etc.) 48 Total GAR assets 228 690,74 132 926,69 - - - - - - - - - - - - - - - - - - - - - - - - 132 926,69 - - - - 49 Assets not covered for GAR calculation 50 Central governments and Supranational issuers 51 Central banks exposure 52 Trading book 53 Total assets 238 862,30 132 926,69 - - - - - - - - - - - - - - - - - - - - - - - - 132 926,69 - - - - 54 Financial guarantees - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 55 Assets under management - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 56 Of which debt securities - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 57 Of which equity instruments - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) 5. Total assets excludes accumulated depreciations and loan loss reserves, transactions within the Group are not eliminated 3. Banks with non-EU subsidiary should provide this information separately for exposures towards non-EU counterparties. For non-EU exposures, while there are additional challenges in terms of absence of common disclosure requirements and methodology, as the EU taxonomy and the NFRD apply only at EU level, given the relevance of these exposures for those credit institutions with non-EU subsidiaries, these institutions should disclose a separate GAR for non-EU exposures, on a best effort basis, in the form of estimates and ranges, using proxies, and explaining the assumptions, caveats and limitations. Million NOK Disclosure reference date T-1 Of which environmentally sustainable (Taxonomy- aligned) Circular economy (CE) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy- eligible) Of which towards taxonomy relevant sectors (Taxonomy- eligible) Of which towards taxonomy relevant sectors (Taxonomy- eligible) Of which environmentally sustainable (Taxonomy- aligned) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM+CCA+WTR+CE+PPC+BIO) Total [gross] carrying amount Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations 1. This template shall include information for loans and advances, debt securities and equity instruments in the banking book, towards financial corporates, non-financial corporates (NFC), including SMEs, households (including residential real estate, house renovation loans and motor vehicle loans only) and local governments/municipalities (house financing). 2. The following accounting categories of financial assets should be considered: Financial assets at amortised cost, financial assets at fair value through other comprehensive income, investments in subsidiaries, joint ventures and associates, financial assets designated at fair value through profit or loss and non-trading financial assets mandatorily at fair value through profit or loss, and real estate collaterals obtained by credit institutions by taking possession in exchange in of cancellation of debts. 4. For motor vehicle loans, institutions shall only include those exposures generated after the date of application of the disclosure. 73 1.2 Assets for the calculation of GAR (Turnover), Page 1 Of which Use of Proceeds Of which transitional Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 171 330,14 131 174,71 636,40 - - - 190,70 0,27 - - - - - - - - - - - - - - - - - - 131 365,41 636,68 - - - 2 Financial undertakings 23 785,53 8 751,44 595,61 - - - 190,08 0,26 - - - - - - - - - - - - - - - - - - 8 941,52 595,87 - - - 3 Credit institutions 7 991,10 3 060,37 213,81 - - - 184,27 0,15 - - - - - - - - - - - - - - - - - - 3 244,64 213,96 - - - 4 Loans and advances 3 241,54 1 110,47 62,03 - - - 31,67 0,06 - - - - - - - - - - - - - - - - - - 1 142,14 62,10 - - - 5 Debt securities, including UoP 2 869,10 1 272,33 106,32 - - - 151,90 0,08 - - - - - - - - - - - - - - - - - - 1 424,24 106,39 - - - 6 Equity instruments 1 880,47 677,57 45,46 - - 0,69 0,01 - - - - - - - - - - - - - - - - - - 678,26 45,47 - - 7 Other financial corporations 15 794,43 5 691,07 381,80 - - - 5,81 0,11 - - - - - - - - - - - - - - - - - - 5 696,88 381,91 - - - 8 of which investment firms - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 9 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 10 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 11 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 12 of which management companies - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 13 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 14 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 15 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 16 of which insurance undertakings - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 17 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 18 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 19 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 20 Non-financial undertakings 1 690,78 611,20 40,80 - - - 0,62 0,01 - - - - - - - - - - - - - - - - - - 611,83 40,81 - - - 21 Loans and advances 1 690,78 611,20 40,80 - - - 0,62 0,01 - - - - - - - - - - - - - - - - - - 611,83 40,81 - - - 22 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 23 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 24 Households 145 635,67 121 593,93 - - - - - - - - - - - - 121 593,93 - - - - 25 of which loans collateralised by residential immovable property - - - - - - - - - - - - - - - - - - - 26 of which building renovation loans - - - - - - - - - - - - - - - - - - - 27 of which motor vehicle loans 121 593,93 121 593,93 - - - - 121 593,93 - - - - 28 Local governments financing 218,15 218,15 - - - - - - - - - - - - - - - - - - - - - - - - 218,15 - - - - 29 Housing financing - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 30 Other local government financing 218,15 218,15 - - - - - - - - - - - - - - - - - - - - - - - - 218,15 - - - - 31 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 32 Assets excluded from the numerator for GAR calculation (covered in the denominator) 54 427,24 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 33 Financial and Non-financial undertakings 42 172,67 34 SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations 27 368,86 35 Loans and advances 27 368,86 36 of which loans collateralised by commercial immovable property - 37 of which building renovation loans - 38 Debt securities - 39 Equity instruments - 40 Non-EU country counterparties not subject to NFRD disclosure obligations 14 781,47 41 Loans and advances 14 772,49 42 Debt securities - 43 Equity instruments 8,98 44 Derivatives 519,63 45 On demand interbank loans 2 376,71 46 Cash and cash-related assets 0,05 47 Other categories of assets (e.g. Goodwill, commodities etc.) 9 358,18 48 Total GAR assets 225 757,38 131 174,71 636,40 - - - 190,70 0,27 - - - - - - - - - - - - - - - - - - 131 365,41 636,68 - - - 49 Assets not covered for GAR calculation 10 433,85 50 Central governments and Supranational issuers 2 149,84 51 Central banks exposure 8 177,31 52 Trading book 106,70 53 Total assets 236 191,22 131 174,71 636,40 - - - 190,70 0,27 - - - - - - - - - - - - - - - - - - 131 365,41 636,68 - - - 54 Financial guarantees - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 55 Assets under management - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 56 Of which debt securities - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 57 Of which equity instruments - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Million NOK Disclosure reference date T Total [gross] carrying amount Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations 1. This template shall include information for loans and advances, debt securities and equity instruments in the banking book, towards financial corporates, non-financial corporates (NFC), including SMEs, households (including residential real estate, house renovation loans and motor vehicle loans only) and local governments/municipalities (house financing). 2. The following accounting categories of financial assets should be considered: Financial assets at amortised cost, financial assets at fair value through other comprehensive income, investments in subsidiaries, joint ventures and associates, financial assets designated at fair value through profit or loss and non-trading financial assets mandatorily at fair value through profit or loss, and real estate collaterals obtained by credit institutions by taking possession in exchange in of cancellation of debts. 3. Banks with non-EU subsidiary should provide this information separately for exposures towards non-EU counterparties. For non-EU exposures, while there are additional challenges in terms of absence of common disclosure requirements and methodology, as the EU taxonomy and the NFRD apply only at EU level, given the relevance of these exposures for those credit institutions with non-EU subsidiaries, these institutions should disclose a separate GAR for non-EU exposures, on a best effort basis, in the form of estimates and ranges, using proxies, and explaining the assumptions, caveats and limitations. 4. For motor vehicle loans, institutions shall only include those exposures generated after the date of application of the disclosure. 5. Total assets excludes accumulated depreciations and loan loss reserves, transactions within the Group are not eliminated Of which towards taxonomy relevant sectors (Taxonomy-eligible) TOTAL (CCM+CCA+WTR+CE+PPC+BIO) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy- aligned) Of which environmentally sustainable (Taxonomy- aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy- aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) 74 1.2 Assets for the calculation of GAR (Turnover), Page 2 Of which Use of Proceeds Of which transitional Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 175 065,07 132 926,69 - - - - - - - - - - - - - - - - - - - - - - - - 132 926,69 - - - - 2 Financial undertakings 22 670,08 8 215,20 - - - - - - - - - - - - - - - - - - - - - - - - 8 215,20 - - - - 3 Credit institutions 3 646,15 1 556,83 - - - - - - - - - - - - - - - - - - - - - - - - 1 556,83 - - - - 4 Loans and advances 527,80 184,73 - - - - - - - - - - - - - - - - - - - - - - - - 184,73 - - - - 5 Debt securities, including UoP 1 311,99 739,87 - - - - - - - - - - - - - - - - - - - - - - - - 739,87 - - - - 6 Equity instruments 1 806,35 632,22 - - - - - - - - - - - - - - - - - - - - - - - 632,22 - - - 7 Other financial corporations 19 023,93 6 658,38 - - - - - - - - - - - - - - - - - - - - - - - - 6 658,38 - - - - 8 of which investment firms - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 9 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 10 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 11 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 12 of which management companies - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 13 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 14 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 15 Equity instruments - - - - - - - - - - - - - - - - - - - - - - 16 of which insurance undertakings - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 17 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 18 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 19 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 20 Non-financial undertakings 8,79 8,79 - - - - - - - - - - - - - - - - - - - - - - - - 8,79 - - - - 21 Loans and advances 8,79 8,79 - - - - - - - - - - - - - - - - - - - - - - - - 8,79 - - - - 22 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 23 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - - 24 Households 152 155,01 124 471,52 - - - - - - - - - - - - 124 471,52 - - - - 25 of which loans collateralised by residential immovable property - - - - - - - - - - - - - - - - - - - 26 of which building renovation loans - - - - - - - - - - - - - - - - - - - 27 of which motor vehicle loans 124 471,52 124 471,52 - - - - 124 471,52 - - - - 28 Local governments financing 231,18 231,18 - - - - - - - - - - - - - - - - - - - - - - - - 231,18 - - - - 29 Housing financing - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 30 Other local government financing 231,18 231,18 - - - - - - - - - - - - - - - - - - - - - - - - 231,18 - - - - 31 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 32 Assets excluded from the numerator for GAR calculation (covered in the denominator) 53 625,67 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 33 Financial and Non-financial undertakings 34 SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations 35 Loans and advances 36 of which loans collateralised by commercial immovable property 37 of which building renovation loans 38 Debt securities 39 Equity instruments 40 Non-EU country counterparties not subject to NFRD disclosure obligations 41 Loans and advances 42 Debt securities 43 Equity instruments 44 Derivatives 45 On demand interbank loans 46 Cash and cash-related assets 47 Other categories of assets (e.g. Goodwill, commodities etc.) 48 Total GAR assets 228 690,74 132 926,69 - - - - - - - - - - - - - - - - - - - - - - - - 132 926,69 - - - - 49 Assets not covered for GAR calculation 50 Central governments and Supranational issuers 51 Central banks exposure 52 Trading book 53 Total assets 238 862,30 132 926,69 - - - - - - - - - - - - - - - - - - - - - - - - 132 926,69 - - - - 54 Financial guarantees - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 55 Assets under management - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 56 Of which debt securities - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 57 Of which equity instruments - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 1. This template shall include information for loans and advances, debt securities and equity instruments in the banking book, towards financial corporates, non-financial corporates (NFC), including SMEs, households (including residential real estate, house renovation loans and motor vehicle loans only) and local governments/municipalities (house financing). 2. The following accounting categories of financial assets should be considered: Financial assets at amortised cost, financial assets at fair value through other comprehensive income, investments in subsidiaries, joint ventures and associates, financial assets designated at fair value through profit or loss and non-trading financial assets mandatorily at fair value through profit or loss, and real estate collaterals obtained by credit institutions by taking possession in exchange in of cancellation of debts. 3. Banks with non-EU subsidiary should provide this information separately for exposures towards non-EU counterparties. For non-EU exposures, while there are additional challenges in terms of absence of common disclosure requirements and methodology, as the EU taxonomy and the NFRD apply only at EU level, given the relevance of these exposures for those credit institutions with non-EU subsidiaries, these institutions should disclose a separate GAR for non-EU exposures, on a best effort basis, in the form of estimates and ranges, using proxies, and explaining the assumptions, caveats and limitations. Pollution (PPC) Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) 4. For motor vehicle loans, institutions shall only include those exposures generated after the date of application of the disclosure. 5. Total assets excludes accumulated depreciations and loan loss reserves, transactions within the Group are not eliminated Of which environmentally sustainable (Taxonomy-aligned) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy- eligible) Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Million NOK Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Total [gross] carrying amount Circular economy (CE) Disclosure reference date T-1 Biodiversity and Ecosystems (BIO) TOTAL (CCM+CCA+WTR+CE+PPC+BIO) 75 2.1 GAR sector information (Capex) Mn NOK Of which environmentally sustainable (CCM) Mn NOK Of which environmentally sustainable (CCM) Mn NOK Of which environmentally sustainable (CCA) Mn NOK Of which environmentally sustainable (CCA) Mn NOK Of which environmentally sustainable (WTR) Mn NOK Of which environmentally sustainable (WTR) Mn NOK Of which environmentally sustainable (CE) Mn NOK Of which environmentally sustainable (CE) Mn NOK Of which environmentally sustainable (PPC) Mn NOK Of which environmentally sustainable (PPC) Mn NOK Of which environmentally sustainable (BIO) Mn NOK Of which environmentally sustainable (BIO) Mn NOK Of which environmentally sustainable (CCM+CCA+WTR+CE+PPC+B IO) Mn NOK Of which environmentally sustainable (CCM+CCA+WTR+CE+PPC+B IO) 1 C1020 - Processing and preserving of fish, crustaceans and molluscs 0,17 - - - - - - - - - - - 0,17 - 2 C2110 - Manufacture of basic pharmaceutical products 0,57 - - - - - - - - - - - 0,57 - 3 C2540 - Manufacture of weapons and ammunition 0,50 - - - - - - - - - - - 0,50 - 4 C2790 - Manufacture of other electrical equipment 0,69 - - - - - - - - - - - 0,69 - 5 G4753 - Retail sale of carpets, rugs, wall and floor coverings in specialised stores 0,01 - - - - - - - - - - - 0,01 - 6 J6110 - Wired telecommunications activities 0,15 - - - - - - - - - - - 0,15 - 7 M7010 - Activities of head offices 0,62 - - - - - - - - - - - 0,62 - 8 N8230 - Organisation of conventions and trade shows 0,40 - - - - - - - - - - - 0,40 - 9 G4511 - Sale of cars and light motor vehicles 610,32 43,78 0,08 0,01 - - - - - - - - 610,40 43,78 1. Credit institutions shall disclose in this template information on exposures in the banking book towards those sectors covered by the Taxonomy (NACE sectors 4 levels of detail), using the relevant NACE Codes on the basis of the principal activity of the counterparty. 2. The counterparty NACE sector allocation shall be based exclusively on the nature of the immediate counterparty. The classification of the exposures incurred jointly by more than one obligor shall be done on the basis of the characteristics of the obligor that was the more relevant, or determinant, for the institution to grant the exposure. The distribution of jointly incurred exposures by NACE codes shall be driven by the characteristics of the more relevant or determinant obligor. Institutions shall disclose information by NACE codes with the level of disaggregation required in the template. Water and marine resources (WTR) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD [Gross] carrying amount [Gross] carrying amount Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Breakdown by sector - NACE 4 digits level (code and label) Circular economy (CE) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount Pollution (PPC) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount TOTAL (CCM+CCA+WTR+CE+PPC+BIO) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Climate Change Mitigation (CCM) [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount Climate Change Adaptation (CCA) Biodiversity and Ecosystems (BIO) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD 76 2.2 GAR sector information (Turnover) Mn NOK Of which environmentally sustainable (CCM) Mn NOK Of which environmentally sustainable (CCM) Mn NOK Of which environmentally sustainable (CCA) Mn NOK Of which environmentally sustainable (CCA) Mn NOK Of which environmentally sustainable (WTR) Mn NOK Of which environmentally sustainable (WTR) Mn NOK Of which environmentally sustainable (CE) Mn NOK Of which environmentally sustainable (CE) Mn NOK Of which environmentally sustainable (PPC) Mn NOK Of which environmentally sustainable (PPC) Mn NOK Of which environmentally sustainable (BIO) Mn NOK Of which environmentally sustainable (BIO) Mn NOK Of which environmentally sustainable (CCM+CCA+WTR +CE+PPC+BIO) Mn NOK Of which environmentally sustainable (CCM+CCA+WTR +CE+PPC+BIO) 1 C1020 - Processing and preserving of fish, crustaceans and molluscs 0,17 - - - - - - - - - - - 0,17 - 2 C2110 - Manufacture of basic pharmaceutical products 0,57 - - - - - - - - - - - 0,57 - 3 C2540 - Manufacture of weapons and ammunition 0,50 - - - - - - - - - - - 0,50 - 4 C2790 - Manufacture of other electrical equipment 0,69 - - - - - - - - - - - 0,69 - 5 G4753 - Retail sale of carpets, rugs, wall and floor coverings in specialised stores 0,01 - - - - - - - - - - - 0,01 - 6 J6110 - Wired telecommunications activities 0,15 - - - - - - - - - - - 0,15 - 7 M7010 - Activities of head offices 0,62 - - - - - - - - - - - 0,62 - 8 N8230 - Organisation of conventions and trade shows 0,40 - - - - - - - - - - - 0,40 - 9 G4511 - Sale of cars and light motor vehicles 608,11 40,80 0,62 0,01 - - - - - - - - 608,73 40,81 TOTAL (CCM+CCA+WTR+CE+PPC+BIO) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Pollution (PPC) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD 1. Credit institutions shall disclose in this template information on exposures in the banking book towards those sectors covered by the Taxonomy (NACE sectors 4 levels of detail), using the relevant NACE Codes on the basis of the principal activity of the counterparty 2. The counterparty NACE sector allocation shall be based exclusively on the nature of the immediate counterparty. The classification of the exposures incurred jointly by more than one obligor shall be done on the basis of the characteristics of the obligor that was the more relevant, or determinant, for the institution to grant the exposure. The distribution of jointly incurred exposures by NACE codes shall be driven by the characteristics of the more relevant or determinant obligor. Institutions shall disclose information by NACE codes with the level of disaggregation required in the template. [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount Breakdown by sector - NACE 4 digits level (code and label) Circular economy (CE) [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount Biodiversity and Ecosystems (BIO) 77 3.1 GAR KPI stock (Capex), Page 1 Of which Use of Proceeds Of which transitional Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 58,10% 0,30% 0,00% 0,00% 0,00% 0,08% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 58,19% 0,30% 0,00% 0,00% 0,00% 72,54% 2 Financial undertakings 3,88% 0,28% 0,00% 0,00% 0,00% 0,08% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 3,96% 0,28% 0,00% 0,00% 0,00% 10,07% 3 Credit institutions 1,35% 0,10% 0,00% 0,00% 0,00% 0,08% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 1,43% 0,10% 0,00% 0,00% 0,00% 3,38% 4 Loans and advances 0,48% 0,03% 0,00% 0,00% 0,00% 0,01% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,50% 0,03% 0,00% 0,00% 0,00% 1,37% 5 Debt securities, including UoP 0,56% 0,05% 0,00% 0,00% 0,00% 0,07% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,63% 0,05% 0,00% 0,00% 0,00% 1,21% 6 Equity instruments 0,30% 0,02% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,30% 0,02% 0,00% 0,00% 0,80% 7 Other financial corporations 2,53% 0,18% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 2,53% 0,18% 0,00% 0,00% 0,00% 6,69% 8 of which investment firms 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 9 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 10 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 11 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 12 of which management companies 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 13 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 14 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 15 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 16 of which insurance undertakings 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 17 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 18 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 19 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 20 Non-financial undertakings 0,27% 0,02% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,27% 0,02% 0,00% 0,00% 0,00% 0,72% 21 Loans and advances 0,27% 0,02% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,27% 0,02% 0,00% 0,00% 0,00% 0,72% 22 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 23 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 24 Households 53,86% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 53,86% 0,00% 0,00% 0,00% 0,00% 61,66% 25 of which loans collateralised by residential immovable property 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 26 of which building renovation loans 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 27 of which motor vehicle loans 53,86% 0,00% 0,00% 0,00% 0,00% 28 Local governments financing 0,10% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,10% 0,00% 0,00% 0,00% 0,00% 0,09% 29 Housing financing 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 30 Other local government financing 0,10% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,10% 0,00% 0,00% 0,00% 0,00% 0,09% 31 Collateral obtained by taking possession: residential and commercial immovable properties 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 32 Total GAR assets 58,10% 0,30% 0,00% 0,00% 0,00% 0,08% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 58,19% 0,30% 0,00% 0,00% 0,00% 95,58% Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total assets covered % (compared to total covered assets in the denominator) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Disclosure reference date T Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM+CCA+WTR+CE+PPC+BIO) 78 3.1 GAR KPI stock (Capex), Page 2 Of which Use of Proceeds Of which transitional Of which enabling Of which specialised lending Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 58,13% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 58,13% 0,00% 0,00% 0,00% 0,00% 73,29% 2 Financial undertakings 3,59% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 3,59% 0,00% 0,00% 0,00% 0,00% 9,49% 3 Credit institutions 0,68% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,68% 0,00% 0,00% 0,00% 0,00% 1,53% 4 Loans and advances 0,08% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,08% 0,00% 0,00% 0,00% 0,00% 0,22% 5 Debt securities, including UoP 0,32% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,32% 0,00% 0,00% 0,00% 0,00% 0,55% 6 Equity instruments 0,28% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,28% 0,00% 0,00% 0,00% 0,76% 7 Other financial corporations 2,91% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 2,91% 0,00% 0,00% 0,00% 0,00% 7,96% 8 of which investment firms 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 9 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 10 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 11 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 12 of which management companies 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 13 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 14 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 15 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 16 of which insurance undertakings 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 17 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 18 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 19 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 20 Non-financial undertakings 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 21 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 22 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 23 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 24 Households 54,43% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 54,43% 0,00% 0,00% 0,00% 0,00% 63,70% 25 of which loans collateralised by residential immovable property 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 26 of which building renovation loans 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 27 of which motor vehicle loans 54,43% 0,00% 0,00% 0,00% 0,00% 52,11% 28 Local governments financing 0,10% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,10% 0,00% 0,00% 0,00% 0,00% 0,10% 29 Housing financing 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 30 Other local government financing 0,10% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,10% 0,00% 0,00% 0,00% 0,00% 0,10% 31 Collateral obtained by taking possession: residential and commercial immovable properties 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 32 Total GAR assets 58,13% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 58,13% 0,00% 0,00% 0,00% 0,00% 95,74% Climate Change Mitigation (CCM) % (compared to total covered assets in the denominator) Disclosure reference date T-1 TOTAL (CCM+CCA+WTR+CE+PPC+BIO) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) Proportion of total assets covered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) 79 3.2 GAR KPI stock (Turnover), Page 1 Of which Use of Proceeds Of which transitional Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 58,10% 0,28% 0,00% 0,00% 0,00% 0,08% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 58,19% 0,28% 0,00% 0,00% 0,00% 72,54% 2 Financial undertakings 3,88% 0,26% 0,00% 0,00% 0,00% 0,08% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 3,96% 0,26% 0,00% 0,00% 0,00% 10,07% 3 Credit institutions 1,36% 0,09% 0,00% 0,00% 0,00% 0,08% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 1,44% 0,09% 0,00% 0,00% 0,00% 3,38% 4 Loans and advances 0,49% 0,03% 0,00% 0,00% 0,00% 0,01% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,51% 0,03% 0,00% 0,00% 0,00% 1,37% 5 Debt securities, including UoP 0,56% 0,05% 0,00% 0,00% 0,00% 0,07% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,63% 0,05% 0,00% 0,00% 0,00% 1,21% 6 Equity instruments 0,30% 0,02% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,30% 0,02% 0,00% 0,00% 0,80% 7 Other financial corporations 2,52% 0,17% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 2,52% 0,17% 0,00% 0,00% 0,00% 6,69% 8 of which investment firms 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 9 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 10 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 11 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 12 of which management companies 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 13 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 14 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 15 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 16 of which insurance undertakings 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 17 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 18 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 19 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 20 Non-financial undertakings 0,27% 0,02% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,27% 0,02% 0,00% 0,00% 0,00% 0,72% 21 Loans and advances 0,27% 0,02% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,27% 0,02% 0,00% 0,00% 0,00% 0,72% 22 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 23 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 24 Households 53,86% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 53,86% 0,00% 0,00% 0,00% 0,00% 61,66% 25 of which loans collateralised by residential immovable property 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 26 of which building renovation loans 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 27 of which motor vehicle loans 53,86% 0,00% 0,00% 0,00% 0,00% 28 Local governments financing 0,10% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,10% 0,00% 0,00% 0,00% 0,00% 0,09% 29 Housing financing 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 30 Other local government financing 0,10% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,10% 0,00% 0,00% 0,00% 0,00% 0,09% 31 Collateral obtained by taking possession: residential and commercial immovable properties 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 32 Total GAR assets 58,10% 0,28% 0,00% 0,00% 0,00% 0,08% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 58,19% 0,28% 0,00% 0,00% 0,00% 95,58% Proportion of total assets covered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Disclosure reference date T % (compared to total covered assets in the denominator) Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM+CCA+WTR+CE+PPC+BIO) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) 80 3.2 GAR KPI stock (Turnover), Page 2 Of which Use of Proceeds Of which transitional Of which enabling Of which specialised lending Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 58,13% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 58,13% 0,00% 0,00% 0,00% 0,00% 73,29% 2 Financial undertakings 3,59% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 3,59% 0,00% 0,00% 0,00% 0,00% 9,49% 3 Credit institutions 0,68% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,68% 0,00% 0,00% 0,00% 0,00% 1,53% 4 Loans and advances 0,08% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,08% 0,00% 0,00% 0,00% 0,00% 0,22% 5 Debt securities, including UoP 0,32% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,32% 0,00% 0,00% 0,00% 0,00% 0,55% 6 Equity instruments 0,28% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,28% 0,00% 0,00% 0,00% 0,76% 7 Other financial corporations 2,91% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 2,91% 0,00% 0,00% 0,00% 0,00% 7,96% 8 of which investment firms 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 9 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 10 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 11 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 12 of which management companies 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 13 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 14 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 15 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 16 of which insurance undertakings 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 17 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 18 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 19 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 20 Non-financial undertakings 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 21 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 22 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 23 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 24 Households 54,43% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 54,43% 0,00% 0,00% 0,00% 0,00% 63,70% 25 of which loans collateralised by residential immovable property 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 26 of which building renovation loans 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 27 of which motor vehicle loans 54,43% 0,00% 0,00% 0,00% 0,00% 52,11% 28 Local governments financing 0,10% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,10% 0,00% 0,00% 0,00% 0,00% 0,10% 29 Housing financing 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 30 Other local government financing 0,10% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,10% 0,00% 0,00% 0,00% 0,00% 0,10% 31 Collateral obtained by taking possession: residential and commercial immovable properties 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 32 Total GAR assets 58,13% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 58,13% 0,00% 0,00% 0,00% 0,00% 95,74% Climate Change Mitigation (CCM) % (compared to total covered assets in the denominator) Disclosure reference date T-1 TOTAL (CCM+CCA+WTR+CE+PPC+BIO) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) Proportion of total assets covered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) 81 4.1 GAR KPI flow (Capex) Of which Use of Proceeds Of which transitional Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 99,59% 0,40% 0,00% 0,00% 0,00% 0,41% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 100,00% 0,40% 0,00% 0,00% 0,00% 54,71% 2 Financial undertakings 4,15% 0,30% 0,00% 0,00% 0,00% 0,41% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 4,57% 0,30% 0,00% 0,00% 0,00% 2,50% 3 Credit institutions 4,12% 0,30% 0,00% 0,00% 0,00% 0,41% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 4,53% 0,30% 0,00% 0,00% 0,00% 2,48% 4 Loans and advances 2,32% 0,16% 0,00% 0,00% 0,00% 0,07% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 2,39% 0,16% 0,00% 0,00% 0,00% 1,31% 5 Debt securities, including UoP 1,74% 0,14% 0,00% 0,00% 0,00% 0,34% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 2,08% 0,14% 0,00% 0,00% 0,00% 1,14% 6 Equity instruments 0,06% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,06% 0,00% 0,00% 0,00% 0,03% 7 Other financial corporations 0,04% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,04% 0,00% 0,00% 0,00% 0,00% 0,02% 8 of which investment firms 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 9 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 10 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 11 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 12 of which management companies 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 13 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 14 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 15 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 16 of which insurance undertakings 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 17 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 18 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 19 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 20 Non-financial undertakings 1,37% 0,10% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 1,37% 0,10% 0,00% 0,00% 0,00% 0,75% 21 Loans and advances 1,37% 0,10% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 1,37% 0,10% 0,00% 0,00% 0,00% 0,75% 22 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 23 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 24 Households 93,94% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 93,94% 0,00% 0,00% 0,00% 0,00% 51,40% 25 of which loans collateralised by residential immovable property 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 26 of which building renovation loans 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 27 of which motor vehicle loans 93,94% 0,00% 0,00% 0,00% 0,00% 93,94% 0,00% 0,00% 0,00% 0,00% 51,40% 28 Local governments financing 0,12% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,12% 0,00% 0,00% 0,00% 0,00% 0,07% 29 Housing financing 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 30 Other local government financing 0,12% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,12% 0,00% 0,00% 0,00% 0,00% 0,07% 31 Collateral obtained by taking possession: residential and commercial immovable properties 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 32 Total GAR assets 99,59% 0,40% 0,00% 0,00% 0,00% 0,41% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 100,00% 0,40% 0,00% 0,00% 0,00% 54,71% 1. The table shows the net flow of all new loans in 2024 which still are outstanding as of 31.12.2024 Proportion of total new assets covered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Disclosure reference date T Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) % (compared to flow of total eligible assets) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) 82 4.2 GAR KPI flow (Turnover) Of which Use of Proceeds Of which transitional Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 99,59% 0,39% 0,00% 0,00% 0,00% 0,41% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 100,00% 0,39% 0,00% 0,00% 0,00% 54,73% 2 Financial undertakings 4,19% 0,29% 0,00% 0,00% 0,00% 0,41% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 4,60% 0,29% 0,00% 0,00% 0,00% 2,52% 3 Credit institutions 4,15% 0,29% 0,00% 0,00% 0,00% 0,41% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 4,57% 0,29% 0,00% 0,00% 0,00% 2,50% 4 Loans and advances 2,36% 0,13% 0,00% 0,00% 0,00% 0,07% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 2,43% 0,13% 0,00% 0,00% 0,00% 1,33% 5 Debt securities, including UoP 1,74% 0,16% 0,00% 0,00% 0,00% 0,34% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 2,08% 0,16% 0,00% 0,00% 0,00% 1,14% 6 Equity instruments 0,06% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,06% 0,00% 0,00% 0,00% 0,03% 7 Other financial corporations 0,04% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,04% 0,00% 0,00% 0,00% 0,00% 0,02% 8 of which investment firms 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 9 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 10 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 11 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 12 of which management companies 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 13 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 14 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 15 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 16 of which insurance undertakings 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 17 Loans and advances 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 18 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 19 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 20 Non-financial undertakings 1,37% 0,09% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 1,37% 0,09% 0,00% 0,00% 0,00% 0,75% 21 Loans and advances 1,37% 0,09% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 1,37% 0,09% 0,00% 0,00% 0,00% 0,75% 22 Debt securities, including UoP 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 23 Equity instruments 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 24 Households 93,91% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 93,91% 0,00% 0,00% 0,00% 0,00% 51,40% 25 of which loans collateralised by residential immovable property 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 26 of which building renovation loans 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 27 of which motor vehicle loans 93,91% 0,00% 0,00% 0,00% 0,00% 93,91% 0,00% 0,00% 0,00% 0,00% 51,40% 28 Local governments financing 0,12% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,12% 0,00% 0,00% 0,00% 0,00% 0,07% 29 Housing financing 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 30 Other local government financing 0,12% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,12% 0,00% 0,00% 0,00% 0,00% 0,07% 31 Collateral obtained by taking possession: residential and commercial immovable properties 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 32 Total GAR assets 99,59% 0,39% 0,00% 0,00% 0,00% 0,41% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 0,00% 100,00% 0,39% 0,00% 0,00% 0,00% 54,73% 1. The table shows the net flow of all new loans in 2024 which still are outstanding as of 31.12.2024 Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) % (compared to flow of total eligible assets) Disclosure reference date T Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM+CCA+WTR+CE+PPC+BIO) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total new assets covered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) 83 Annual report 2024 | Sustainability statement 84 Annex XII Standard templates for the disclosure referred to in Article 8(6) and (7) Template 1 Nuclear and fossil gas related activities Row Nuclear energy related activities 1. The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle. NO 2. The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies. NO 3. The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades. NO Fossil gas related activities 4. The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels. NO 5. The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels. NO 6. The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels. NO Annual report 2024 | Sustainability statement 85 3. Social Information: S1 Own workforce Annual report 2024 | Sustainability statement 86 3.1 Policies related to own workforce Actual and potential impacts on the Group’s own workforce are connected to its sustainability strategy, including the social and governance aspects of its strategic pillars. Specifically, this includes promoting inclusive growth and employee wellbeing through ensuring a diverse and inclusive workplace and maintaining strong governance culture focusing on conduct and ethical behavior. The Group has not allocated resources beyond its normal operations to the management of material impacts at the current point in time because it considers the capacity adequate. This may change as the Group evolves its approach the future. The following policies and steering documents are used to manage material impacts and risks related to ESRS topic S1 own workforce. Locally implemented policies are available to employees on the Group’s internal governance platform and are applicable to all employees in each of the Group’s locations. How each policy is used to manage specific material impacts and risks is described in more detail throughout this section. Steering documents / policies to manage material IROs related to S1: Own workforce Steering document Description Responsible Banking Framework Responsible Banking Model Responsible Banking and Sustainability policy As described in the section 1.5 Sustainability governance iv. Sustainability policies, and how the model outlines the Santander Responsible Banking strategy, including social topics related to the Group’s own workforce. Furthermore, the Responsible Banking and Sustainability policy incorporates the Group’s human rights responsibilities to its employees, the relationships in its value chain and its fair treatment of customers and stakeholders in society. This includes opposition to any form of forced labor or child exploitation, as well as prevention of discrimination, health and safety, and freedom of association, among others. The policy outlines the Group’s commitment to protecting fundamental human rights, taking into consideration the UN Guiding Principles on Business and Human Rights. Responsible function: Responsible Banking Transparency Act procedure Sets out how the Group ensures respect for fundamental human rights and decent working conditions, as well as general public access and communication processes to anyone who requests in writing for general or specific information about how the Group manages actual and potential negative impacts on human rights and working conditions. The policy is owned by the Responsible Banking leader and applicable to all employees. Responsible function: Responsible Banking HR Framework The framework establishes the principles the Group must adhere to that are relevant to activities in the Group’s People and Culture function and own workforce, including equality and meritocracy, diversity, suitability and alignment to strategy and culture. The framework is locally adopted from Banco Santander, applicable to all the Group’s employees, including senior management, owned by the Chief People and Culture Officer and approved by the Group’s Board of Directors. Responsible function: People and Culture Code of Conduct (CoC) Assembles the ethical standards and rules of conduct employees must attend to and is fundamental to the compliance administration. The Group’s CoC is applicable to all employees and members of the Board and sets the ethics, principles, rules, and rules of conduct by which all activities of the Group should be governed. The Chief People and Culture Officer and Chief Compliance Officer are responsible for the policy and the Compliance function is responsible for ensuring adherence to the Group’s CoC. Responsible function: People and Culture; Compliance and Conduct Culture policy Forms the standards and principles required to embed a consistent and healthy corporate culture within the Group. The policy is applicable to all employees and is owned by the Chief People and Culture Officer. Responsible function: People and Culture General Health, Safety and Wellbeing policy A Banco Santander policy adopted locally to the Nordics and subject to strict, unreserved compliance with the law (which always prevails) in every market the Group operates in. The policy is applicable to all employees and references the Group’s HR Framework. The policy considers third party standards including the UN Sustainable Development Goals, World Health Organization WHA 72(9), ISO 45001 on occupational health and safety, council directive 89/331/CEE and Employment Act legislation specific to Danish, Finnish, Norwegian and Swedish markets. Responsible function: People and Culture Annual report 2024 | Sustainability statement 87 Flexi Working policy Sets out the new work model to support a healthy work-life balance for the Group’s employees. Responsible function: People and Culture Remuneration policy The Group’s Remuneration policy promotes risk management, good conduct and alignment with the interests of shareholders, employees, customers and society in the Group’s role as a responsible bank. The policy forbids differential treatment that is not based on a review of performance and corporate behaviors, as well as promotes gender-neutral pay management, equal opportunity and the elimination of inequality, especially in cases where men and women perform the same or similar work (“equally remunerated for equal work or work of equal value”). The policy is owned by the Chief People and Culture Officer and approved by the Group’s Board of Directors. Responsible function: People and Culture Succession Plan policy In addition to the Group’s Remuneration policy, the Succession Plan policy is established to foster diversity and equal opportunity in critical senior management positions, and for the selection, suitability assessment and succession of directors of the Group. Responsible function: People and Culture Global International Mobility policy Sets and guides the minimum standards and conditions for international moves in Santander. The policy is applicable to all employees and owned by the Chief People and Culture Officer. Responsible function: People and Culture Global Learning & Development policy Sets the standards for the programs offered to employees. The policy is applicable to all employees and is owned by the Chief People and Culture Officer. Responsible function: People and Culture 3.2 Employee-related governance Material impacts and risks identified in the Group’s own workforce are governed by the Code of Conduct (CoC) which assembles the ethical standards and rules of conduct that employees must attend to, and that is fundamental to the Group’s compliance administration. The Group’s CoC is applicable to all employees and members of the Board and sets the ethics, principles, and rules of conduct by which all activities of the Group should be governed and comprises the central component of Banco Santander’s Compliance Program. All employees are also required to complete mandatory training in the Code of Conduct to ensure proper knowledge and awareness of the ethical principles. The Code of Conduct (CoC) is shared with new employees during onboarding and is regularly reviewed and updated. The Chief People and Culture Officer and Chief Compliance Officer are responsible for the policy and the Compliance function is responsible for ensuring adherence to the Group’s CoC. Additionally, the Group has locally adopted Banco Santander’s HR Framework. The framework establishes the principles the Group must adhere to that are relevant to activities in the Group’s People and Culture function and its own workforce, including equality and meritocracy, diversity, suitability and alignment to strategy and culture. The framework is applicable to all employees, including senior management, owned by the Chief People and Culture Officer and approved by the Group’s Board of Directors. The Group promotes a positive work environment where the rights and guarantees of individuals are protected. Besides the CoC, the Group has made available other tools and resources to make it easy for employees, or related third parties, to raise awareness and communicate any irregularities. The Whistleblower Channel (Canal Abierto) provides a safe space for employees to report misconduct in the form of financial and non-financial risk. The guarantees and rights of the individuals involved in reporting are protected by the Group, which is why the Group considers this a trusted structure to raise concerns and address needs. The measures and resources placed to guarantee these rights are laid out in the Whistleblower Policy. The Chief Compliance Officer is responsible for the policy, and it is approved by the Group’s Board of Directors. As another layer of governance and protection, the Group adheres to the local work environment legislation applicable to each market. All applicable frameworks, policies, and guidelines are communicated to employees through the Group’s Internal Governance Portal. These policies are reviewed on a yearly basis to ensure they remain relevant and up to date. Annual report 2024 | Sustainability statement 88 3.3 Employee engagement The Group’s listening program, Your Voice (established in 2022) aims to gather feedback from employees to both identify and measure important elements of the working environment, including impacts on the Group’s workforce. The Group conducts the survey at least once per year. During 2024, one survey was conducted with 86% participation rate. The scale ranges from 1- 10 (with 10 being the best). The results of employee feedback prove steady progress following a positive overall trend since 2021. Overall engagement has increased from an approval rate at 7.6 in 2023 to 7,8 in 2024. Furthermore, the scores of Your Voice differ with a maximum of 0.2 between genders. The main dimension, Engagement, has an equal score. The Group’s People and Culture function and Chief People and Culture Officer have operational responsibility for employee engagement. The survey results are communicated to employees, unions and the Group’s senior management and Board of Directors. Based on the feedback received, the Group establishes both organizational and team-specific actions for improving on prioritized items. The Group compares the results against previous years to assess the effectiveness of the survey and the initiatives that have been implemented. The high participation rate supports the significance of the survey’s results and provides confidence that employees trust this structure to provide their feedback and needs. Results from “Your Voice” survey April 2024 (brackets state changes since May 2023) Your Voice highlights Monitoring, scale 1-10 (where 10 is most positive) Engagement 7,8 (+0,2) Autonomy and flexibility 8,6 (+0,1) Enable people to develop 7,9 (-) Belief in Change 7,5 (+0,5) Workload 7,5 (-) 2024 has been a progressive year within the Group’s People & Culture function. Compared to 2023, the Group has improved or remained high on scores within most dimensions measured in its employee survey. This data is supported by other KPIs within the Group’s People and Culture area. In parallel, the eNPS (employee net promoter score) has made a leap to eNPS 30 (2023: 23)], indicating that the Group has a growing and significant portion of employees promoting the Group as an employer. In addition to the “Your Voice” surveys, employees can raise concerns via the Group’s whistleblowing channel, Canal Abierto. The channel is available in the Group’s intranet and communicated in the mandatory training package. These listening tools are used to evaluate the effectiveness of actions taken relating to impacts, risks and opportunities. For more information on the Group’s whistleblowing channel please refer to sections 5.2 Ethical Conduct and 5.3 Ethical Channels. The key characteristics of the Group’s employees are described in the section 3.7. Annual report 2024 | Sustainability statement 89 3.4 Working conditions i. Employee health and well-being and work-life balance This section outlines how the Group manages the following IRO: I- (Potential) Ensure the health, wellness and safety of employees through comprehensive controls and proactive initiatives, fostering a safe and supportive workplace environment, while encouraging employees being able to reconcile work with their personal circumstances through flexible working. Details about the policies described in this subchapter can be found under 3.1 Policies related to own workforce. The Group is committed to promoting health and well-being and to building a culture of care and awareness in the organization and for society. The health and well-being strategy sets out how the Group protects the health, safety and well-being of employees, promoting a healthy lifestyle, and creating long- term value. To do that, the Group has implemented: • Strict and comprehensive safety and prevention systems; • Proactive initiatives to boost the overall well-being of employees; • A safe and supportive working environment when it comes to health; and • Flexible work alternatives and guaranteed parental leave to enhance work-life balance. At the core of this strategy is the Banco Santander Health, Safety and Wellbeing policy. The corporate policy is adopted locally to the Nordics and is subject to strict, unreserved compliance with the law (which always prevails) in every market the Group operates in. The policy is applicable to all employees and also references the Group’s HR Framework. The policy considers third party standards including the UN Sustainable Development Goals, World Health Organization WHA 72(9), ISO 45001 on occupational health and safety, council directive 89/331/CEE and Employment Act legislation specific to Danish, Finnish, Norwegian and Swedish markets. Additionally, the Group’s Culture policy, applicable to all employees and owned by the Chief People and Culture Officer, forms the standards and principles required to embed a consistent and healthy corporate culture within the Group. Employee engagement related to corporate culture is measured in the Group’s Your Voice surveys and eNPS. The Group continues to promote employees’ health and wellness, and help them get trusted, affordable solutions through a range of benefits. The Group adheres to the relevant parental leave legislation available in each market. The Group has schemes that make it easier to combine a career with family life. 10% of the employees had parental leave in 2024, where of 51% were men and 49% were women. Feedback from the Your Voice survey helps the Group track and assess the effectiveness of its actions and initiatives to support work to promote health and well-being among its workforce. The Your Voice scores for employees’ satisfaction for topics connected to health and well-being was 8.0 for 2024 (8.0 in 2023). ii. Flexi-working The Group encourages and promotes work-life balance through its Flexible Working policy. This policy governs how the Group facilitates its new work model to support a healthy work life balance for all Group employees. The policy is owned by the People and Culture function and Chief People and Culture Officer. In Q1 2024, the Group began rebuilding its offices to be suitable for hybrid working. By accepting and deciding that developing a hybrid working set-up is an incremental process the organization has allowed for valuable dialogues with internal stakeholders and continuously adjusted the Group’s approach. Actions taken to promote flexible working include: 1. New ways of working framework with local adaptations (based on local flexible working regulations). 2. Continuous monitoring of the impact of new ways of working on productivity, engagement and employer attractiveness through employee surveys. 3. Enhancement of flexible and hybrid office culture by: a. rationalizing location and space arrangements to improve access and collaboration; and b. implementing technology that enables employees to be productive and engaged in a hybrid environment. Annual report 2024 | Sustainability statement 90 iii. Occupational health Health, safety and working environment are important elements in the Group’s policies concerning people’s health and safety. Preventive working environment measures are adopted to promote employees’ safety, health, well-being, and their working capacity. There has been one personnel injury related to the workplace during the year (2023: two). The Group’s sick leave remains at a consistent rate, establishing itself in the lower end of industry benchmarks, ending at 3.5% for 2024 (2023: 3%). Collective agreements consider employee health and occupational risk prevention. The Group’s employees are covered under occupational health and safety systems and policies in compliance with risk prevention standards and best practices. The Group’s occupational risk prevention plans have been evaluated with employees' councils through: 1. Regular workplace and ergonomic assessments of health and safety risks and preventative measures to handle or eliminate them; 2. Regular psychosocial risk assessments; 3. Prevention measures when designing, procuring or acquiring offices and equipment; 4. Procedures for safe working conditions; and 5. Emergency and evacuation plans for dangerous situations in order to protect employees, visitors and suppliers. Pursuant to law, The Group has response procedures for time-dependent medical emergencies that may occur at its facilities (e.g. heart attack, choking, stroke) and offers employees first aid training annually. The Occupational Risk Prevention area draws up plans with other units, including measures to prevent or minimize the risks: 1. Employee awareness and continuous training in postural hygiene, emergencies and first aid. Risk prevention delegates are appointed, and employees sit on health and safety committees. 2. Occupational risk prevention in all operations that may impact on employees' health and safety. Accident investigation, including considering root causes of occupational accidents and manage them to prevent reoccurrence. iv. BeHealthy The Group seeks to raise awareness about health and well-being through the global Santander BeHealthy program, which celebrated its eighth year in 2024. Throughout the year, the Group ran initiatives, activities and events for employees, following the program’s four pillars: know your numbers (self-awareness), eat well (healthy nutrition), move (physical health) and be balanced (mental & emotional well-being). In April, the Group held the BeHealthy Week, bringing health and well-being to the focus of Santander, with daily, in-person and virtual events. v. Social protection All employees in the Group’s workforce are covered by social protection, through public programs or through benefits offered against loss of income due to sickness, unemployment, employment injury and acquired disability, parental leave and retirement. The Group offers employees additional protection that is complementary to public programs. These protections vary by market based on local legislation and collective agreements. The Group provides all employees insurance in the event of death and occupational accidents. The Group offers employees complementary protection in the event of absence related to sickness and parental leave. In the Norwegian and Danish markets, the Group complements public programs by covering the gap between social benefits the employee receives and their total salary. In the Swedish market, the Group also complements social benefits following Swedish local legislation. The Finnish market provides improved protection against loss of income following its collective bargaining agreement. In the Danish, Norwegian and Swedish markets, the Group offers additional health insurance to 94% of employees. In the Finnish market, permanent residents are insured against illness with health insurance. The health insurance is administered by the social security institution (Kela) and is financed with contributions by employers, employees and the state. Care and respect for employees’ rights and talent retention are key to the Group. 94% of employees have permanent contracts, and the average length of service is 8 years. The Group’s employees have appropriate pay protection in the event of an occupational accident. The Group complies with the labor and social security regulations required under sector-based laws and agreements. Annual report 2024 | Sustainability statement 91 The Group also has retirement coverage (accounting for 100% of its workforce) through public or private pension systems. The Group supplements this with defined contribution pension plans for 100% of employees. vi. Collective bargaining and social dialogue In 2024, the Group continued to guarantee freedom of association and the right to collective bargaining. Its Responsible Banking and Sustainability policy considers forming or joining unions and other representative bodies a basic right of workers, in accordance with the Group’s Code of Conduct. The Group ensures respect for freedom of association, trade unions, collective bargaining and protections for employees’ representatives under the applicable laws of each country it operates in. It remains the Group’s focus to promote and comply with the International Labor Organization’s Fundamental Conventions. 100% of employees are covered by a collective agreement. Additionally, Banco Santander employees in Europe have representation agreements with the European Trade Union Confederation. The Group has agreements with European workers' councils and confederations. The Group has a Working Environment Committee and Liaison Committee. Statutory meetings are held frequently, and the cooperation between the management and the employee representatives is solid. The Group has also remained in constant dialogue with employees’ legal representatives in bilateral and special committee meetings where all parties could discuss reporting, queries and negotiations about working conditions and employee benefits. vii. Remuneration and corporate benefits This section outlines how the Group manages the following IRO: O Promote employees’ overall wellbeing and adequate remuneration, ensuring compliance, meritocracy, equality and competitiveness in the Group’s markets, to help its people prosper. Details about the policies described in this subchapter can be found under 3.1 Policies related to own workforce. A comprehensive remuneration framework combines fixed and variable pay schemes based on targets for employees of the Group, with the aim of promoting the general well-being of employees. Variable remuneration reflects what has been accomplished and how, according to Group-wide quantitative and qualitative targets as well as individual and team targets, behavior, leadership, sustainability, commitment, growth and risk management. It includes pension plans, life insurance and other corporate benefits that employees are offered or can choose. Fixed remuneration schemes reflect local market conditions. Pay is set by strictly abiding to the practices, regulations and collective agreements in force in each jurisdiction where the Group operates in. All employees receive a wage equal to or higher than the legally established minimum and local collective agreements. The Group’s Remuneration policy (as well as the CoC and Succession Plan policy) which applies to all Group employees, forbids differential treatment that is not based on a review of performance and corporate behaviors. The policy promotes gender-neutral pay management, equal opportunity and the elimination of inequality, especially in cases where men and women perform the same or similar work (“equally remunerated for equal work or work of equal value”). The policy is owned by the Chief People and Culture Officer and approved by the Group’s Board of Directors. In addition to promoting a high-performance culture that rewards employees’ achievements and ability to make an impact, this policy promotes risk management, good conduct and alignment with the interests of shareholders, employees, customers and society in the Group’s role as a responsible bank. Annual report 2024 | Sustainability statement 92 The majority of the Group’s employees take part in a common performance management model — MyContribution, which reflects on what has been achieved and how. These reviews include quarterly or annual quantitative variables; corporate behavior assessment variables (TEAMS) based on feedback from peers and internal customers and stakeholders; and risk management variables (RiskPro), which enable the Group to analyze individual and team performance holistically. MyContribution is the Group’s common performance management model. It is updated regularly and is aligned with the Group’s culture. The Remuneration policy recognizes individual and team contributions (regardless of role), responsibility, length of service and personal traits. This policy promotes personal development and growth, and an assessment of employees’ conduct and risk management. Overall pay packages and structures should be competitive to attract and retain talented people. In the Nordics, the Group determines what this means and updates policy regularly through a formal documented procedure. The Group consults employees to gauge how appropriate and acceptable remuneration policies are. In 2024, the Your Voice score for topics connected to remuneration is 6.6% (2023: 6.5%). As part of the Group’s aim to minimize the salary gap, the organization follows the principles of transparency, good governance, increasing employee retention and engagement, and being competitive while protecting the interests of shareholders, employees, customers and broader society. As reported in the Corporate Governance section of the Board of Director’s report, top executives’ remuneration includes components based on long-term results and variable remuneration in the form of shares and other instruments. The CEO's gross annual salary amounts to 2,780,000 NOK per annum. Due to the CEO’s appointment in late 2024, the bonus eligibility starts in 2025. The average pay plus variable remuneration for employees (excluding the highest paid individual) is 875,848 NOK per annum. The annual total remuneration ratio is 8:1. The gender pay gap measures differences in remuneration between women and men in an organization, business, industry or the broader economy, irrespective of the type of work. It is calculated as the difference in the median remuneration paid to male and female employees, expressed as a percentage of the male remuneration. To comply with EU and local regulations on remuneration, the Group identified a total of 28 material risk takers in 2024, where 13 of these employees are subject to a deferred variable pay scheme because their decisions can have a material impact, supported by the Group’s Material Risk Takers Identification procedure. The Remuneration policy defers a significant amount of their variable pay (50%) for a period of 1 to 4 years, in accordance with internal and local regulation. 50% of variable pay is delivered in instruments and is subject to potential reduction ('malus') or recovery ('clawback'). Key actions taken in 2024 relating to remuneration and corporate benefits: • In 2024, corporate bonus metrics included new strategic priorities, maintaining the focus on customers (with active customers as the main metric), as well as RoTE (which continues to be part of the scheme). The third pillar included as a metric is capital, to outline the importance of capital generation throughout the organization. • The Group introduced a relative performance multiplier that may increase or reduce the result of the metrics mentioned above, based on results versus top peers in each market in terms of metrics that are considered more relevant to each subsidiary or business (and for the Group, the weighted average of subsidiaries’ results), such as net interest margin, cost/income ratio, and non-performing loans. Gender Pay Gap (Mean) 16,75% 2024 Annual report 2024 | Sustainability statement 93 viii. Incidents, complaints and human rights This section outlines how the Group manages the following IRO: R Potential risk derived from incurring in situations with employees that involve longer working hours, controversies of corruption, human rights violations or abuse. Human rights are promoted both in the Group’s Responsible Banking and Sustainability Policy and Code of Conduct, described under subchapter 3.1 Policies related to own workforce. Assessments of human rights and working conditions in the Group’s own operations are conducted as part of the due diligence required under the Norwegian Transparency Act (Åpenhetsloven). The Group has implemented its Transparency Act procedure, owned by Responsible Banking and is applicable to all employees, to document how the Group performs annual due diligence on human rights and working conditions in its value chain (including own operations, customers, partners and vendors) required under the Transparency Act. The Group applies the UN Guiding Principles on Business and Human Rights to assess potential risks and adverse impacts on human rights and working practices within its internal organizational practices. The Responsible Banking and Sustainability policy incorporates the Group’s human rights responsibilities and commitments to its employees and includes opposition to any form of forced labor or child exploitation, as well as prevention of discrimination, health and safety and freedom of association, among others, taking into consideration the UN Guiding Principles on Business and Human Rights. In 2024, no incidents in the Group’s own operations related to human rights or working conditions and employment processes were identified as part of this due diligence. Nor did the Group identify any of its operations at significant risk of incidents of forced, compulsory or child labor. The group received reports on one incident of sexual harassment and one regarding discrimination in 2024. Both have been followed up by the Irregularity Committee and People & Conduct function. There is no record of any lawsuit filed by an employee or their representatives against the Group in relation to incidents of discrimination or violation of fundamental rights. The Group has a zero-tolerance approach to harassment or discrimination of any kind and thus operates with a target of zero occurrences. Annual report 2024 | Sustainability statement 94 3.5 Equal opportunities for all i. Diversity, equity and inclusion (DE&I) This section outlines how the Group manages the following IROs: I- (Potential) Potentially harming employees from incidents on corruption, working conditions, discrimination and harassment. I+ (Actual) Foster a diverse and inclusive workforce, that reflects the composition of the Group’s communities and enhances collaboration by ensuring fair and equal opportunities for all employees, regardless of gender, disabilities or other characteristics. Details about the policies described in this subchapter can be found under 3.1 Policies related to own workforce. At Santander, diversity, equity and inclusion (DE&I) are part of the common enablers of the Group’s culture policy. The Group is committed to following local regulations including the Equality and Anti-Discrimination Act. Achieving inclusive and sustainable growth involves managing the Group’s business responsibly. The only way to help people and businesses prosper is by doing things in a Simple, Personal and Fair way. The Group’s corporate culture is based on the notion that “how” business is conducted is just as important as “what” is done. These common factors and facilitators are the cornerstone of the Group’s culture and apply to the entire organization: a) Leadership: The Group’s leaders must act with integrity and be open, contributive, transformational and inclusive to inspire the teams to develop and work with the highest level of motivation, purpose and virtue; and b) Diversity, equity and inclusion: DE&I are material aspects linked to the Group’s strategic vision that affect all stakeholders and must be present throughout the value chain in order to be managed holistically. On top of complying with domestic and international laws on diversity, equity and inclusion, the Group takes action in these areas in a responsible, tangible and transparent manner based on three principles: 1. Diversity: Support all forms of diversity (gender, ethnicity, religion, age, sexual orientation, disability, socio-economic origin, among others) to empathize more with customers’ needs and offer innovative solutions. 2. Equity: Promote equal opportunity throughout the employee life cycle to avoid bias that may cause discrimination, without undermining meritocracy. Foster accessible environments and products for customers and promote investment to reduce social inequality. 3. Inclusion: Create a respectful environment in which people feel valued and can harness their potential and feel a sense of belonging. To mitigate the potential negative impact and harm to its employees, the Group maintains rigorous standards for hiring, promotions, succession planning and talent pipelines to strengthen diversity. Additionally, implicit bias training, as well as mentoring, networking and other actions are aimed at creating a more inclusive environment. The Group’s activities in the Nordics are reinforced by strong regulation and protection of employees from corruption, discrimination and harassment in the workforce. As part of the commitment to continue reinforcing this plan in the long term, the Group has embedded diversity in every People and Culture initiative, such as the new role of managers, employee value propositions (EVP), and women's mentoring and sponsorship programs. In the short- to medium term, the Group is also working to reduce unconscious biases in recruitment, strengthening governance of all initiatives to promote diversity, as well as supporting the career progression and promotion of women. In 2024, the Group actively promoted #beYourself, a campaigning expression entailing that the working environment promotes inclusiveness of any individual expression independent of gender, race, age, disabilities and nonvisible diversity like religion, sexual orientation, and life experience. Part of the campaign involved the Group launching both unbiased training as well as diversity and inclusiveness training for all leaders to bring awareness to the impact of unconscious biases in People and Culture activities, such as recruitment. The Group has implemented the following Banco Santander policies and procedures to foster diversity and equal opportunity in management positions: the Succession Plan policy for critical senior management positions; procedures for appointing key positions and assessing suitability; and procedures for the selection, suitability assessment and succession of the Group’s directors. Annual report 2024 | Sustainability statement 95 Gender equity: The Group is committed to increasing gender representation in leadership positions. The total workforce consists of 45% women; women in senior management positions (also referred to as top management and defined as members of the Group’s Executive Committee) are 25% (2 out of 8); and 40% of mid manager positions are women. The Group is working to have a more balanced presence between women and men across the organization. To achieve this, the Group applies remuneration policies that remove bias in promotions and pay, and to ensure suitable compensation based on merit and responsibility. The Group has also reviewed succession plans to both mitigate operational risks as well as to ensure gender balance is incorporated into succession planning to further strengthen gender diversity in its senior management. 3.6 Talent and skills development i. Talent management and mobility The Group’s talent attraction strategy focuses on positioning itself as an employer of choice, providing a great candidate experience when hiring and onboarding, and moving fast to respond to the ever-changing needs of its business. To support this, the Group has locally adopted Banco Santander’s Global International Mobility policy, applicable to all employees and owned by the Chief People and Culture Officer, which guides and sets minimum standards and conditions for international moves. International mobility is both an asset for employees to grow and a vital element of building relations and cultural understanding of Santander`s international market and operations. In 2024, the focus has been identifying business needs and anticipating future talent needs. The Group has created talent programs that help individuals meet their individual growth aspirations, while considering business demands. The Group understands that its people appreciate the opportunities an international working environment provides. ii. Learning and development The Global Learning and Development policy sets the standards for training programs offered to employees. The policy is applicable to all employees and is owned by the Chief People and Culture Officer. In 2024, the Group continued to reinforce a culture where employees are encouraged to lead their own development and ensure their skills and knowledge stay relevant. The Group enables employees to advance their development by taking advantage of the Grow@Santander program. Grow@Santander is a Nordic program aiming to develop leaders and employees according to the Group’s future competence needs. In 2021, the Group transferred its strategic competence plan into a Global learning platform (Dojo). The innovative Dojo learning platform enables recommendations of courses and training programs that align with employees’ current and future positions, expectations and other skills necessary for a successful future career. Dojo also offers courses based on employee interests and future required skills. Mandatory training is frequently conducted for employees, connected to regulatory requirements, including AML, Compliance, and Cyber Security. The People and Culture function reports monthly to the Group’s Compliance function on fulfilment of mandatory training in a compliance training completion report. In 2024, the Group introduced new mandatory content for all employees specifically on ESG. The Group has worked strategically with competence development for several years and is committed to long-term personal development for all employees, with individual development plans that are reviewed on an annual basis. The Group supports this commitment through initiatives gathered under Grow@Santander, containing initiatives like PROLeaders, PROLearners, Young Leader, Mundo and Swap, as well as a leader program specifically designed for Operations. The Group experiences that our people appreciate the opportunities an international working environment provides. For all employees, the Group has reopened talent programs such as its Young Leader Program, Mundo and Swap. The programs allow for short-term or long-term international working experience. Annual report 2024 | Sustainability statement 96 3.7 Characteristics of the Group’s employees General information about this chapter Employee data included in this report is extracted from the relevant source depending on the specific data type. These sources are: • Workforce related information (headcount, terminations, demographic, and contract type) is extracted from the Group’s People and Culture system. • Attendance data linked to the Group’s payroll provider. Information extracted from the relevant time and attendance system in each of the Group’s local markets. • Reported workplace injury information is extracted from relevant sources in the Group’s local markets. • Gender is based on information as reported by employees themselves. Other information about the data: • The headcount data is effective as of December 31, 2024. It reflects the total number of active employees in the company. Includes regular and fixed term employees categorized by gender and market. • Where data is presented for a specific year, the effective date of the report is as of the last day of that year. For example, where data is presented for 2024, the effective date is as of December 31, 2024. • Where the metric discloses a measure of central tendency, such as averages or the median for a specific period, a snapshot of the data is extracted as of the last day of each month within the specified period (from last day of last period + 1, to the last day of the specified period). If the measure is for 2024, the data is extracted as of the last day of each month from January 1, 2024, to December 31, 2024. Employees by region and gender (headcount, 2024) Workforce by contract type, broken down by gender (headcount, 2024) Men Women Other Not Disclosed Total No. of employees 746 616 0 0 1362 No. of permanent employees 694 586 0 0 1280 No. of temporary employees 52 30 0 0 82 No. of non- guaranteed hours employees 0 0 0 0 0 Workforce by contract type, broken down by region (headcount, 2024) Norway Sweden Denmark Finland Total Number of employees 617 327 251 167 1362 Number of permanent employees 591 310 230 149 1280 Number of temporary employees 26 17 21 18 82 Number of non- guaranteed hours employees 0 0 0 0 0 Workforce by age bracket (2024) Aged < 30 Age 30 - 50 Age over 50 Number (headcount) % of total Number (headcount) % of total Number (headcount) % of total Norway 130 21.1% 335 54.3% 152 24.6% Sweden 62 19.0% 197 60.2% 68 20.8% Denmark 44 17.5% 135 53.8% 72 28.7% Finland 40 24.0% 104 62.3% 23 13.8% Total 276 20.3% 771 56.6% 315 23.1% Region No of employees1 Men Women Other Not reported Norway 617 330 287 0 0 Sweden 327 166 161 0 0 Denmark 251 162 89 0 0 Finland 167 88 79 0 0 Total 1362 746 616 0 0 1Total headcount corresponds to information provided in Note 30 in the Financial Statements. Annual report 2024 | Sustainability statement 97 Headcount covered by collective agreement (2024) Country % Number of employees1 Norway 99.7 615 Sweden 100.0 327 Denmark 100.0 251 Finland 99.4 166 TOTAL 99.8 1359 Collective bargaining coverage and social dialogue (2024) Collective Bargaining Coverage Social Dialogue Coverage Rate2 Employees - EEA Workplace representation (EEA only) 0-19% 20-39% 40-59% 60-79% 80-100% Danish, Finnish, Norwegian and Swedish Markets Danish, Finnish, Norwegian and Swedish Markets External turnover rate (2024) Total Terminations3 Average Headcount Turnover ratio4 Norway 92 617 14.9 Sweden 52 334 15.6 Denmark 30 253 11.9 Finland 23 169 13.6 Total 197 1372 14.4 Top management composition (2024)5 Men Women Total Senior management 6 2 8 Occupational health and safety (2024)6,7 Men Women Total Severity rate8 0.00 0.00 0.00 No. of fatal occupational accidents9 0 0 0 Work-related illness10 0 0 0 Total number of days of absence due to accidents and occupational diseases11 1 0 1 Accident rate12 0.00 0.00 0.00 Work-related accident rate (CSRD criterion) 0.00 0.00 0.00 1 The headcount data is effective as of December 31, 2024. It reflects the total number of active employees in the company covered by collective bargaining agreement. Includes regular and fixed term employees categorized by market. 2 Percentage of employees covered by collective bargaining agreements and workplace representation. 3 An employee is considered terminated when inactive due to a termination process (voluntary or involuntary). 4 Total number of terminated employees during the period, divided by the average headcount of the same period and categorized by market. 5 Composition of the members of the Executive Management Committee (ExCo) by gender. Members of the Executive Management Committee are considered Top Management. 6 The table includes occupational disease/injuries/deaths that have been reported to the corresponding entity in the local market. 7 Hours worked are theoretical and do not include commute time or commute-related accidents. 8 Days not worked due to work related accident for every 1000 hours worked. 9 Number of employees who passed away due to a work accident or occupational illness. 10 Number of unique work-related illnesses reported during the year. 11 Total number of days of absence due to work-related accidents / diseases reported in during the year. 12 Number of occupational accidents with leave for every 1,000,000 hours worked. Annual report 2024 | Sustainability statement 98 4. Social Information: S4 Consumer and end-users Annual report 2024 | Sustainability statement 99 4.1 Policies related to consumers and end-users The following policies and steering documents are used to manage material impacts and risks related to ESRS topic S4 consumers and end users. Locally implemented policies are available to employees on the Group’s internal governance platform. How each policy is used to manage specific material impacts and risks is described in more detail throughout this section. Policies related to consumers and end-users Steering document Description Responsible Banking Framework Responsible Banking Model Responsible Banking and Sustainability policy As described in the section 1.5 Sustainability governance iv. Sustainability policies. The Responsible Banking model outlines the Santander Responsible Banking strategy, including social topics related to the Group’s consumers and end users. The model also covers social topics, including ensuring customer privacy through data protection and cybersecurity. The Responsible Banking and Sustainability policy incorporates human rights responsibilities across the Group’s value chain, as well as its fair treatment of customers and stakeholders in society. This includes opposition to any form of forced labor or child exploitation, as well as prevention of discrimination, health and safety and freedom of association, among others, aligned with the International Bill of Human Rights. The policy outlines the Group’s commitment to protecting fundamental human rights, taking into consideration the UN Guiding Principles on Business and Human Rights. Responsible function: Responsible Banking Transparency Act Procedure The Procedure establishes roles and responsibilities required to perform due diligence under the OECD guidelines for Multinational Enterprises, supporting the Group’s efforts to assess and ensure human rights and fundamental working conditions. Responsible function: Responsible Banking Approval of Products and Services policy Governs the new product approval process and is supported by the Approval of Products and Services procedure, which describes the activities to be performed before a new or changed product or service can be introduced, marketed or provided to customers. Product owners in the Group are responsible for ensuring compliance with the policy and procedure and all new or changed products require approval from the Group’s Risk Approval committee. The policy is owned by the Chief Compliance Officer and approved by the Group’s Board of Directors. Responsible function: Compliance and Conduct Conduct Risk with Customers Management model The model takes due account of the vulnerability, special circumstances and/or economic stress of customers, as well as to avoid over-indebtedness of customers. Under the model, the Compliance & Conduct function aims to ensure that employees possess the knowledge and skills needed to identify and manage conduct risks associated with the design, sale and after-sales of the products and services offered. The model is owned by the Chief Compliance Officer and is approved by the Board of Directors. Responsible function: Compliance and Conduct Customer Service, Dissatisfactions Handling and Root Cause Analysis policy Defines the criteria for dealing with customer service activities and outlines how incoming customer complaints are monitored, assessed and reported to relevant governance committees. The policy is owned by the Chief Compliance Officer and approved by the Group’s Risk Approval Committee (RACo). Responsible function: Compliance and Conduct Data Protection & Privacy policy Applicable to all personal data and its processing, the policy defines data protection criteria and the control of information and confidentiality. The corporate standards remain consistent with data protection and privacy laws at all times, ensuring the ethical and transparent management of personal data to enable individuals to exercise greater control over their data. The policy is owned by the Data Privacy Office and approved by the Group’s Board of Directors Responsible function: Privacy Office Annual report 2024 | Sustainability statement 100 4.2 Conduct with customers The Group’s product offering constitutes deposits and loans to customers within the Auto Finance and unsecured Consumer lending segments, in addition to Insurance products. The Group’s customer base primarily consists of consumers of such financial services offerings. This includes private individuals (adults from different social backgrounds) as well as business customers. The Group does not discriminate against consumers and only uses objective selection criteria such as affordability measures when dealing with its customers. Securing customer confidence and satisfaction is key to the Group – by applying strict rights to privacy and data protection principles for all customers. The simple, personal and fair treatment of the Group’s customers, with special attention to individuals in vulnerable situations, is of strategic priority. The Group does not offer harmful products or services that may increase risks for chronic diseases. The Group is focusing on improving customer experience through the optimization of mobile responsive onboarding solutions, net banks, apps, chat bots and a range of product offerings, whilst operating as a responsible lender within the regulatory environment. The key aim is to deliver accessible channels for all customers, including individuals with disabilities throughout the whole customer lifecycle. The Group is applying multiple methodologies to assess customer characteristics within the customer lifecycle, with its purpose to understand and identify relevant risk exposures and measures to apply within the domains of credit- and operational risk. The Group’s goal is to prevent negative impacts on customers such as over-indebtedness and through fraud prevention. Methodologies are applied on various customer segments, ensuring targeted measures are adopted in correlation with the identified risk. The potential negative impacts identified under this standard are considered to be systemic to the consumer financial industry. i. Simple, personal and fair This section outlines how the Group manages the following IROs. The risk identified arises from the potential negative impacts identified and relates to all the Group’s customers: I- (Potential) Customers are not adequately informed about the product characteristics or services in the point of sales. I- (Potential) Customer difficulties or vulnerabilities are not identified, hence failing to guarantee accessibility and usability. R Risk arising by inadequate practices in the Group's relationship with customers across the product lifecycle and customers relationship. All policies described under subchapter 4.1 Policies related to consumers and end-users are considered relevant for this IRO. As a responsible lender, the Group offers simple, personal, and fair products and services, prioritizing customer satisfaction and ethical consumer protection. Embracing responsible banking principles, customers’ needs and wider societal interests are taken into consideration to mitigate over-indebtedness and product misrepresentation. The Group practices prudent and responsible credit provision, providing fair banking solutions in accordance with the UN Principles of Responsible Banking. The Group focuses on ensuring adequate communication is provided to customers throughout the customer lifecycle and engages with customers on relevant topics throughout the customer relationship. Customer engagement occurs within pre-onboarding, onboarding and active customer relationship phases. Relevant risk considerations are managed within the product development cycle prior to launch of products in local markets. The commercialization of products requires information about products and their characteristics to be communicated, including terms and conditions as well as the Group’s practices on data privacy and consumer rights. The Group ensures adherence to local marketing regulations and does not target vulnerable consumers in marketing and sales strategies. As per the nature of the Group’s products, consumers are not dependent on product labels or manuals to avoid a potentially damaging use of products or services. The customer onboarding phase ensures prudent affordability assessments are performed by utilization of relevant data to Annual report 2024 | Sustainability statement 101 mitigate potential negative impacts on customers, the Group and society. Throughout the active customer relationship, the Group has enabled engagement points through various channels for customers to raise any relevant concerns, via online platforms or directly to its customer service teams. The Group actively encourages customers in vulnerable situations to proactively contact the Group, to ensure customer insights and perspectives are obtained and to mitigate potential negative impacts and risks. The Group encourages customers to use their rights to freedom of expression, and has not identified any negative customer impact as a result. The Group monitors incoming customer complaints and handles dissatisfaction by applying a governance model of customer service, dissatisfaction handling and root cause analysis. Assessments are monitored and reported to relevant governance committees, ensuring risks are managed effectively. The Group mitigates the potential negative impact of not informing customers about products and services characteristics and not identifying customer difficulties and vulnerabilities through its New Product Approval process. New products are assessed against the Group’s mission to contribute to the progress of people and businesses, and that the product offered is simple, personal and fair. The process includes risk assessments of the suitability, transparency, communication, execution, sales channels of the product and the requirements for monitoring customers with financial difficulties. The Group’s Approval of Products and Services policy, owned by the Chief Compliance Officer, governs the New Product Approval process. It is supported by the Approval of Products and Services procedure, which describes the activities to be performed before a new or changed product or service can be introduced, marketed or provided to customers. Product owners in the Group are responsible for ensuring compliance with the procedure and all new or changed products require approval from the Group’s Risk Approval committee. The Group seeks to mitigate the potential impact of failing to identify or consider customers’ difficulties and vulnerabilities through its Conduct Risk with Customers Management model. The model is owned by the Chief Compliance officer and approved by the Board of Directors. The model takes due account of the vulnerability, special circumstances and/or economic stress of customers so that the Group proceeds with their best interests and offers them viable solutions wherever possible. This includes seeking to avoid customer over- indebtedness, by ensuring that their level of debt does not negatively impact their ability to meet financial commitments. Under the model, the Compliance & Conduct function aims to ensure that employees possess the knowledge and skills needed to identify and manage conduct risks associated with the design, sale and after-sales of the products and services offered. The Group identifies a vulnerable customer as someone who, due to their personal circumstances, is more likely than others to be adversely affected, or sustain a financial and/or personal loss. Signs that a customer may be vulnerable include, without limitation: disability/incapacity; serious illness; mental health problems; age-related difficulties; low level of literacy or education; divorce or separation; victims of domestic violence; job loss, economic stress or victims of natural disasters. Additionally, over-indebtedness is considered as where a customer is unable to honor their contractual financial obligations in due course over a sustained period of time due to their financial commitments related to debt. In 2024, the Group continued to make headway with embedding Banco Santander regulations on vulnerable customers and the prevention of over- indebtedness in its Nordic markets. The aim is to provide a common approach and standards to avoid disparate management between markets. The Group adheres to local regulations around customer protection and has developed indicators that it continues to work on to identify and monitor customers in special circumstances, as well as developing methodologies that will identify signs of vulnerability in order to adapt services to the specific needs of its customers. Annual report 2024 | Sustainability statement 102 ii. Channels for monitoring customer satisfaction This section outlines how the Group manages the following IRO: I- (Potential) Channels for making complaints are not available for customers or information gathered does not drive necessary changes. The Customer Service, Dissatisfactions Handling and Root Cause Analysis policy described under subchapter 4.1 Policies related to consumers and end-users are considered relevant for this IRO. Customer complaints are closely monitored based on the number of complaints per 10 000 customers and is adjusted by the Uphold Ratio (% of complaints resolved in the customer’s favor). In 2024, the average number of complaints per 10 000 customers - adjusted for the Uphold Ratio - was 1.83 (2023: 2.31), which is below the internal Alert threshold of 2.75, indicating effective levels of customer service. There are several channels available for customers to file a complaint, all cases are mitigated, and actions are taken to optimize processes where required. The Nordic complaint handling set-up has a solid and strong governance process. Policies and routines are in place, as well as a control environment to monitor performance. According to the Group’s Customer Service, Dissatisfactions Handling and Root Cause Analysis policy, customers (and non- customers) who contact the Group for any enquiry, request or express their dissatisfaction, or any kind of problem, shall be treated fairly, accurately and in accordance with their needs and expectations. All dissatisfactions must be logged by frontline staff into tools which allow the information to be stored in an accessible form, identifying the reasons that have generated the dissatisfaction. Information on how to express dissatisfaction can be found on the Group’s websites within each country it operates in. When contacting customer service, staff make it clear to customers how they may express their dissatisfaction and provide the appropriate channel. The Group is continuously monitoring, investigating activities, and applying mitigation actions and controls that are in place to ensure a proper process for handling dissatisfactions received from customers. Its internal procedures state that customers shall be treated fairly, consistently and promptly and any remedial action shall be appropriate. As well as complaint channels, the Group also monitors customer Net Promoter Scores (NPS) and customer feedback. NPS is used to identify the likelihood of customers recommending the Group. NPS scores are measured with a single question survey and reported with a number from –100 to +100. Customers score from 0-10. Detractors are defined as customers scoring 0-6 and are deducted from the promoters, those scoring 9-10 (7-8 are neutral) to reach the NPS score. The Group invites all new customers to provide their feedback, and again every 12 months. In 2024, the Group continued to improve NPS tracking, with over 55 994 customer responses and more than 43 182 comments received. The overall NPS score decreased to 28.9 (2023: 30.9), and market-specific scores were as follows; Norway: 23.8 (2023: 24.7), Sweden: -5.4 (2023: 4.4), Denmark: 44.9 (2023: 44.8), and Finland: 40.3 (2023: 52.9) Additionally, the Group monitors Partner NPS engagement as a key stakeholder in its downstream value chain. In 2024, the overall Partner NPS score is 60.6 (2023: 60.1); Norway: 65.0 (66.4), Sweden: 44.1 (2023: 55.6), Denmark: 76.9 (2023: 61.1) and Finland: 62.1 (2023: 54.7). Annual report 2024 | Sustainability statement 103 4.3 Privacy, data protection and cybersecurity i. Privacy This section outlines how the Group manages the following IROs. The risks identified below arises from the potential negative impact identified and relates to all the Group’s customers. I- (Potential) The compromise of the rights and freedoms of customers, employees or shareholders as a result of the failure to implement adequate technical and organizational measures to protect their personal data in accordance with the applicable data protection regulation. R Awareness and education on cyber topics to explain potential threats and provide guidance on how to avoid them. R The potential losses that may be incurred as a consequence of sanctions or an increase in customer attrition as a result of the lack of effective detection and/or response to privacy events. The Data Protection & Privacy policy described under subchapter 4.1 Policies related to consumers and end-users are considered relevant for this IROs. The use of new technologies and progress with the digitalization of businesses has led to a rapid increase in the processing of personal data. The Group’s commitment to complying with regulation on the protection of personal data throughout its life cycle is key in this regard. The Group’s corporate standards remain consistent with data protection and privacy laws at all times, ensuring the ethical and transparent management of personal data to enable individuals to exercise greater control over their data. The Group uses reasonable measures that are designed to obtain and use only the data that is strictly necessary to process personal data for legitimate purposes. Additionally, technical and organizational measures aim to preserve the confidentiality, integrity, availability and resilience of the systems and services used to process data; to ensure the correct protection of data subjects’ rights and freedoms; and to boost individuals’ and broader society’s trust. The Group’s actions to manage privacy and data protection include: • Responsibility to abide by the General Data Protection Regulation (GDPR) and local regulation on data protection. • Solid governance model with: o Group data protection policies, establishing a Group privacy program; and o A common Data Protection Officer (DPO) appointed to the four units. The Group formally discloses appointees to local authorities. • A common, regular monitoring and reporting model, including meetings documented in minutes on compliance status, security incidents, key risks and focal points, and other key data protection matters. • Procedures to manage security-related incidents and the risks that stem from the potentially unauthorized use of personal data. • Cooperation with third-party service providers that must comply with data protection regulation. All vendors are subject to a suitability test that the Group monitors through management indicators and reviews regularly. • Review and testing on compliance with data protection laws, which the Group’s Compliance & Conduct function and Internal Audit function perform as part of their annual programs. • Corporate tools to manage data protection-related tasks by bringing together and monitoring control information through indicators and an annual review program. For instance, regular updates to the Group’s data processing inventory and assessments. • Employee training and awareness campaigns on data protection, which form part of the Group’s mandatory annual curriculum that the Group monitors through management indicators. The Group performs role- based training related to certain processes. • Special focus on regulatory developments to update and consolidate criteria, methodologies and documents. Annual report 2024 | Sustainability statement 104 Cybersecurity Cybersecurity provides vital support to the Group’s purpose of helping people and businesses prosper and its aim to provide customers with first-rate digital services. The Banco Santander cybersecurity framework sets out the governance, functions, roles and responsibilities to manage cybersecurity throughout the Group, including the role of the Chief Information Security Officer (CISO). The Group’s cybersecurity policies, which develop the cybersecurity framework, are based on international standards and subject to ongoing review to maintain and enhance safety levels. In 2024, The Group updated its Cybersecurity requirements policy for technical and business areas, which includes security provisions for the different domains. Protecting customer information is the responsibility of every Santander employee. This is outlined in the Group’s Cybersecurity rules to protect Santander policy, owned by the CISO, which sets out the principles that must be followed. Actions taken in 2024 include: To spread awareness and provide education on cyber topics and guidance on how to avoid them, the Group ran the following awareness initiatives during 2024: Regular ethical phishing exercises to strengthen employees’ and partners’ resilience to cyber threats. Promoting a culture of reporting suspicious incidents or messages through all available channels. • Updates to mandatory cybersecurity training for employees, including security recommendations against malicious attacks by email, text message or phone call, deepfake, phishing, social engineering, and other threats. • Specialized training for high-risk groups such as payment agents, IT professionals and developers, digital asset owners, Board members, and executives and their support teams. • Specialized fraud training for contact center agents and branch employees. • Internal awareness campaigns for all Group employees to keep them up to date with the latest cybersecurity and fraud trends. The Group also runs campaigns through its digital channels. Furthermore, users can report suspicious messages by writing to reportphishing@gruposantander.com. These initiatives are considered to provide a positive benefit to all the Group’s customers by strengthening customer awareness of cyber topics and threats as well as supporting customers’ protection when using digital channels. Annual report 2024 | Sustainability statement 105 5. Governance Information: G1 Business conduct Annual report 2024 | Sustainability statement 106 5.1 Business conduct policies and corporate culture The following policies and steering documents are used to manage material impacts and risks related to ESRS topic G1 business conduct. Locally implemented policies are applicable to all the Group’s locations and are available to employees on the Group’s internal governance platform. How each policy is used to manage specific material impacts and risks is described in more detail throughout this section. Policies related to business conduct Steering document Description Responsible Banking Framework Responsible Banking Model Responsible Banking and Sustainability policy As described in the section 1.5 Sustainability governance iv. Sustainability policies, including how the model outlines the Santander Responsible Banking strategy and social topics related to the Group’s business conduct. This also includes establishing governance criteria and practices, including promoting ethical behavior to stakeholders, the establishment of the Responsible Banking Agenda and promoting diversity and ESG experience in Board and senior management as described in the Responsible Banking framework. Responsible function: Responsible Banking Whistleblower policy Outlines how to access and raise concerns about breaches via the whistleblower channel in a prudent and effective way. The measures and resources placed to guarantee the rights and protections of the individuals involved are laid out in the Whistleblower policy. The Chief Compliance Officer is responsible for the policy and it is approved by the Group’s Board of Directors. Responsible function: Compliance and Conduct Financial Crime Compliance Corporate framework Based on the Banco Santander framework, which sets out the principles for minimizing financial crime, which underpin these programs: the anti-money laundering and terrorism financing prevention program (AML/CTF); the sanctions program; and, since 2023, the anti-bribery and anti- corruption program (ABC). The Anti-Bribery and Corruption policy (ABC policy) Outlines the key requirements, principles and minimum standards for Anti-Bribery and Corruption and to ensure effective compliance with all applicable legislation and regulations in the Nordics. The policy is owned by the Chief Compliance Officer and approved by the Group’s Board of Directors. Responsible function: Compliance and Conduct AML and CTF Manual Sets the criteria, roles and responsibilities, key processes and governance to be applied by the Group to prevent money laundering and terrorist financing and to comply with applicable regulations. The policy is based on Banco Santander’s AML/CTF corporate policy and reference document which sets the minimum required standards for local units in regard to anti-money laundering and counter terrorist financing. Responsible function: Financial Crime Prevention Outsourcing policy Sets the criteria and steps required for execution and good governance of outsourcing agreements. The policy is derived from the Group's Outsourcing and Third-Party Agreements Framework and ensures suppliers meet certain minimum requirements for operational resilience, solvency, reputation, and regulatory compliance. The policy is owned by the head of organization and cost and approved by the Board of Directors. Responsible function: Organization and Cost Certification policy The policy defines responsible practices in the Group’s supply chain and how it identifies suppliers that pose the greatest risk in terms of sustainability. This methodology also helps in determining which controls to adopt according to the risk in question. The policy is owned by the Head of Organization and Cost and approved by the Board of Directors. Responsible function: Organization and Cost Annual report 2024 | Sustainability statement 107 Code of Conduct (CoC) Assembles the ethical standards and rules of conduct employees must attend to and is fundamental to the compliance administration. The Group’s CoC is applicable to all employees and members of the Board and sets the ethics, principles, rules, and rules of conduct by which all activities of the Group should be governed. The Chief People and Culture Officer and Chief Compliance Officer are responsible for the policy and the Compliance function is responsible for ensuring adherence to the Group’s CoC. Responsible function: People and Culture; Compliance and Conduct Culture policy Forms the standards and principles required to embed a consistent and healthy corporate culture within the Group. The policy is applicable to all employees and is owned by the Chief People and Culture Officer. Responsible function: People and Culture i. Santander Way This section outlines how the Group manages the following IRO: I+ (Potential) Acting responsibly and taking into account not only the interests of investors and the Group, but also the impact on employees, society, and the environment. The Code of Conduct (CoC) and Culture policy described under subchapter 5.1 Business conduct policies and corporate culture are considered relevant for this IRO. “The Santander Way”, is the bedrock of the Group’s corporate culture, including Santander’s values (Simple, Personal and Fair), corporate behaviors (T.E.A.M.S), leadership principles and robust risk culture (Risk Pro) which guide employees and senior management on a daily basis. New corporate behaviors (T.E.A.M.S) were launched in 2022 and in 2024 the Group progressed implementation of the following activities: • Updated and improved the Group’s relevant internal webpages to make culture and health focus more visible to all employees. • Continued its assessment of how to improve the Group’s efforts through its employee listening program. As a result, the Group rolled-out the change model “ADKAR” to all Level 2 and Level 3 leaders as an action for transformation and change. • Set up a community of cultural ambassadors and provided funding to organize networks and promote social activities to continue to build a great culture together with its employees. • Continued to promote its culture through its performance review, “MyContribution”, where 50% is based on 'what', 40% on 'how' and 10% on risk management. Annual report 2024 | Sustainability statement 108 5.2 Ethical conduct This section outlines how the Group manages the following IRO: I- (Actual) Harm of society because of bribery and corruption practices in bank functions. R Risks derived from inadequate behavior or conduct, giving the appearance of legitimacy and legality to funds or assets with illicit origin and/or permit criminal activity to occur. The Financial Crime Compliance Corporate framework, The Anti- Bribery and Corruption policy (ABC policy), AML and CTF Manual and Code of Conduct described under subchapter 5.1 Business conduct policies and corporate culture are considered relevant for this IROs. i. Conduct standards The Group’s Code of Conduct (CoC) sets out the behaviors and values that all Santander employees must abide by when engaging with colleagues, customers, vendors and broader society. It helps promote a solid risk management and compliance culture and provides a means to prevent the risks the Group is exposed to. It promotes equal opportunity, diversity and non-discrimination, zero tolerance for sexual or work- related harassment, respect for others, work-life balance, human rights, and environmental protection. The Group’s Board of Directors approves the CoC, which applies to all employees including its general workforce and senior management, who must be aware of and comply with the CoC. The Internal Audit function regularly reviews compliance with the CoC, with autonomy to check that it is appropriate and effective. The Banco Santander General Code of Conduct (GCC), on which the CoC is based, is available on the Banco Santander corporate website for all stakeholders to read and is in force in every Group subsidiary. It includes a message from the Executive Chair on the importance of having a solid and common corporate culture that all Santander employees are on board with. The Group’s CoC also has a message from their local CEO. The core implementation mechanisms are: 1. Mandatory training for employees on the CoC in the form of an annual course that instils the guidelines they must follow in their day-to-day activities; why every employee's conduct matters; how to handle conflicts of interest according to the Group’s policy, and what to do if they receive gifts and invitations from people outside Grupo Santander. The training is supplemented with a statement that reinforces employees’ pledge to comply. Banco Santander also gives training on the GCC guidelines to the Group’s Board members, who are key to avoiding and mitigating risk, setting a global corporate culture based on ethical principles, and complying with internal and external rules. 2. #YourConductMatters: Campaigns via email, Intranet and other media to boost employees’ awareness of the CoC, as well as of Canal Abierto and the latest whistleblower protection laws. 3. The Conduct & Compliance function, which deals with employees’ queries on the enforcement of the CoC. 4. Canal Abierto, The Group’s whistleblowing channel where employees and stakeholders can report violations of the CoC and of Santander corporate behaviors. 5. Analysis and penalization of violations according to the law. The Group’s risk appetite metrics include monitoring of employees’ completion of mandatory training on the CoC. The 2024 completion rate was 98.9%. Moreover, mandatory training forms part of the Group’s employee annual performance review, which acts as an incentive to complete it in due time. The Group also monitors how many incidents reported to the Group’s ethical channels are linked to violations of the CoC. ii. Financial crime Financial crime prevention for anti-bribery and corruption, and training The Group’s Financial Crime Compliance corporate framework sets out the principles for minimizing financial crime, which underpin: the anti-money laundering and terrorism financing prevention program (AML/CTF); the sanctions program; and, since 2023, the anti-bribery and anti-corruption program (ABC). In 2024, the Group continued to prioritize implementing its ABC program, with a solid commitment from such high-risk areas as Marketing, Sourcing and People and Culture. The Group designs its policies to manage the impacts and risks related to financial crime, to minimize these risks and to protect the Group’s integrity. These policies are transposed to ensure they are aligned with Nordic legal requirements. They are available to employees through the Group’s internal governance platform, internal newsletters, and training sessions to ensure that all stakeholders understand their responsibilities. Annual report 2024 | Sustainability statement 109 Identifying high risk functions The Group conducts a risk and control self-assessment (RCSA) to identify high risk functions within the organization. It involves assessing the inherent risks of business activities and functions, based on exposure to bribery, corruption and other financial crimes. The Marketing, Commercial, Sourcing and People and Culture functions are identified as high risk due to their frequent engagement with external parties and the elevated potential for conflicts of interest, improper influence and corrupt practices. The RCSA includes qualitative and quantitative measures to review historical incidents, industry-specific risk factors, the complexity of the transactions that these functions manage, and regulatory changes. Once high-risk functions are identified, the Group implements enhanced controls, due diligence procedures and additional monitoring mechanisms to mitigate risks. Preventing, detecting and managing financial crime incidents The Group’s system to prevent and detect bribery and corruption includes confidential reporting channels and an independent committee that ensures investigations remain impartial. The findings of these investigations are reported to the audit committee and other management and oversight bodies. The Group’s whistleblowing channel, which is managed according to the CoC and the Whistleblower policy, ensures confidentiality, anonymity and protection for whistleblowers against reprisals. Employees can use Canal Abierto to report violations of laws, and internal or external compliance requirements related to the fight against financial crime. The Group has a robust system to prevent, detect, investigate and respond to incidents of bribery and corruption. It includes internal controls, due diligence procedures and independent committees that operate outside the chain of command to ensure impartial incident management. The findings of these investigations are reported regularly to the Group’s management and oversight bodies. Key actions under anti- bribery and corruption measures include reviewing contracts with vendors, implementing additional controls in high-risk areas, and updating due diligence procedures. Anti-Money Laundering The Group has established anti-money laundering (AML) policies and procedures to comply with global standards, including know your customer (KYC) and customer due diligence (CDD) processes, as well as transaction monitoring and reporting of suspicious activity. These policies are designed to minimize the risks of money laundering, terrorist financing and other illicit activities. The Groups three lines of defense model monitors that the AML framework is effective and aligned with ever-changing regulatory requirements. The Group is enhancing its AML policies and procedures in response to the new EU AML Directive (AMLD 6), which introduces stricter requirements for financial institutions in a bid to harmonize AML regulations across the EU and boost cooperation between financial intelligence units (FIUs). The Group is also strengthening its due diligence and risk assessments for customers and transactions in high-risk third countries in line with the AMLD 6. This includes increased monitoring and scrutiny of transactions involving these jurisdictions. These efforts are enabling the Group to continue bolstering its commitment to detecting and preventing financial crime, bribery and corruption, in line with international best practice and the EU regulatory framework. The 2nd line Financial Crime Compliance team monitors the Group’s work to mitigate the negative impacts and risks related to financial crime. Training programs In 2024, the Group continued to enhance its financial crime training, based on the programs included under its corporate framework (the anti-money laundering and terrorism financing prevention program; the sanctions program; and the anti-bribery and anti-corruption program). The Group combines basic courses with customized training for teams in key risk areas and specialized training for Board members. The Nordic Code of Conduct (CoC) training is mandatory for all employees including senior management and the Board of Directors (BoD). The CoC training includes bribery and corruption risks, ethical principles, the whistleblowing channel, conflicts of interest and standards for gifts and invitations. This approach ensures that the Group is well prepared to prevent, detect and manage financial crime risks effectively according to international ethics and transparency standards. Mandatory financial crime training programs cover all staff, including senior management and the BoD. In addition, the following specific training was given to the BoD in 2024: • Code of Conduct in Securities Markets • IRB & IVT (Internal ratings-based system & Internal validation team) • Operational Risk • AML (Anti–money laundering) • IDD (Insurance Distribution Directive) In 2024, the Group had 0 convictions or fines relating to violation of anti-corruption and anti-bribery law. Annual report 2024 | Sustainability statement 110 5.3 Ethical channels i. Canal Abierto This section outlines how the Group manages the following IRO: I- (Potential) Recurrence of incidents by not implementing internal measures to effectively resolve incidents reported through the grievance channels and not implementing continuous improvements. I+ (Actual) Protection of whistle-blowers confidentiality through an effective communication system in which the Group reports consistent information to governing bodies through solid, standardized principles and procedures in whistleblowing channels. The Whistleblower policy and Code of Conduct described under subchapter 5.1 Business conduct policies and corporate culture are considered relevant for this IROs. Canal Abierto is an anonymous and confidential Grupo Santander channel to report unethical conduct. It protects whistleblowers by expressly prohibiting reprisals or any negative consequence against them. Based on Grupo Santander’s channel, the Group administers its own ethical channel according to its Whistleblower policy. The policy is owned by the Chief Compliance Officer and approved by the Board of Directors. Minimum standards include CEO endorsement; communication to employees of the importance of using the channel; information on how incidents have been handled and lessons learned; easy access to the channel and anonymity (if desired); external platforms to receive reports according to best practice; mechanisms to manage conflicts of interest in internal investigations of reports; and regular internal audits. The Board of Directors approved the Whistleblower policy and the related usage and operation procedure and it is administered under the Chief Compliance Officer's direct remit. These policies and procedures are available to employees on the Group’s Internal Governance portal. Canal Abierto is available to employees on the Group’s intranet and to stakeholders through the Banco Santander corporate website and the Canal Abierto platform. Canal Abierto is mainly set up to receive reports from employees; however, the channel is open to vendors, partners, customers and other stakeholders, who can report violations of the Group’s CoC. Business incidents or complaints outside of Canal Abierto’s scope are not accepted on these channels. On Canal Abierto, whistleblowers can report their suspicions about professional conduct related to: • Unlawful acts in the workplace; • Irregularities or breaches of the Code of Conduct and its implementing regulation that may be subject to disciplinary action; • Improper accounting or auditing practices, internal control or influence on external auditors (SOX); • Violations of anti-money laundering and terrorism financing laws or of internal regulations to comply with those laws, as well as acts of corruption and bribery; • Violations of securities market laws; • Conduct that may involve an act that infringes the law or any other regulation and, in particular, a serious or very serious criminal or administrative offence, or infringement of European Union law; and • Acts or conduct that go against the Group’s corporate behaviors. The Group pledges to handle reports received through Canal Abierto in a diligent, independent and objective manner for the benefit of the parties involved. This is a protective measure for the people who communicate in good faith through the channel, as well as for anyone else who forms part of the related internal investigations. These criteria, which are set out in the Group’s Whistleblower policy, reflect that pledge: • Appropriate handling of the reports received, notwithstanding their possible rejection should they fall under any of the cases provided for in internal regulations or if it is considered that there are no grounds for a case. 60-day processing time, which could be extended by up to 30 days for cases that are considered especially complex. Conflict of interest management during the investigation of cases, in which anyone who may have a conflict of interest with the persons involved in the matter will refrain from taking part. The usage and operation procedure details the teams tasked with investigating each case in relation to the type of report. The prohibition of reprisals against employees or other stakeholders who report, in good faith, breaches of internal or external regulations or conduct that does not align with corporate behaviors, or for having merely accessed an ethical channel. Every year, employees undertake a mandatory training course on the CoC that includes a module on the importance of using Canal Abierto. Moreover, the Group raises awareness of Canal Abierto and its assurances among its employees through email and in other channels that detail statistics on the handling of the reports received, the channel’s features, when to use it, and other relevant information. Each year, the Compliance area reports to the Group’s risk and audit committees on the Group’s channels, including key statistics and other related matters. Annual report 2024 | Sustainability statement 111 In 2024, the Group received 19 reports through its channels. The Group received 0 reports in 2024 regarding corruption, which led to 0 dismissals. The Compliance area aims to enhance how it manages and analyses the Group’s ethical channels in order to keep governing bodies abreast of the risks that may be identified, the key concerns of employees and stakeholders, and the action plans put in place to reinforce the Group’s ethical and compliance culture. The Group collects data on its ethical channels every quarter in relation to the reports received, the report type and the measures taken. 5.4 Suppliers i. ESG standards in procurement This section outlines how the Group manages the following IRO: I+ (Actual) Promote responsible practices among suppliers by engaging with them, assessing their ESG performance and providing to them recommendations and tools to improve, incl. The access to grievance mechanisms - canal Abierto. R Risk arising from failing the implementation of operative resilience, financial soundness, reputational control and regulation compliance due to third parties. The Outsourcing policy and the Certification policy described under subchapter 5.1 Business conduct policies and corporate culture are considered relevant for this IROs. In 2024, the Group initiated a supplier ESG certification methodology to promote responsible practices in its supply chain, supplemented by its Third-party Certification policy. The methodology aims to identify the suppliers that pose the greatest risk in terms of sustainability, and to help determine which controls to adopt according to the risk identified. The Group implemented its ESG methodology in 2024, which includes a review of its supply chain to identify the level of risk of suppliers in ESG matters, based on the sector and country in which they operate, their number of employees and the environmental impact of their activity; as well as an assessment, where required. This assessment includes ESG aspects such as goals set for GHG emissions reductions, inclusion in terms of gender and people with disabilities, flexi-working, minimum wage and good governance practices, codes of conduct and anti-corruption policies, human and labor rights recognition, and other elements set out in international standards such as the United Nations Global Compact. Based on findings, and where deemed necessary, the Group supplements supplier assessments with remediation plans. This helps the Group’s suppliers in their transformation and compliance with domestic, European and international ESG regulatory frameworks. There is ongoing work to begin reporting on the progress of the ESG certification of vendors in the short to medium term. ii. Supplier payment practices The Group complies with the maximum payment terms prescribed by law. The Group’s cost model oversees payments to third parties and complements specific controls used for SMEs. Late payments are prevented by the Group’s internal payment procedures and rules. Invoices are scanned and processed through the Group’s ERP system. There is a minimum requirement of “four eyes” for invoice approvals, meaning that at least two people must approve an invoice before it is paid. The Group’s standard payment terms for all categories of suppliers is 30 days. In 2024, the average time to pay an invoice from the date when the contractual or statutory term of payment starts was 32.1 days. This was calculated by extracting all invoices paid in 2024 from the Group’s ERP system and calculating the days between invoice date and payment date for all invoices. Data outliers were removed to calculate the average. The percentage of payments aligned with the standard payment term was 55.6% in 2024. There were no legal proceedings in a court of law for late payments in 2024. Annual report 2024 The Board of Directors of Santander Consumer Bank Lysaker February 24, 2025 Natalia Cazorla Gil Board Member Anne Kvam Board Member Tone Bergsaker Strømsnes Employee Representantive Morten Johansson Helland Chief Executive Officer Rolf Larsen Employee Representative Joaquin Caracuel Barbecho Deputy Chair Jørn Borchgrevink Chair To the General Meeting of Santander Consumer Bank AS Independent Sustainability Auditor’s Limited Assurance Report Limited Assurance Conclusion We have conducted a limited assurance engagement on the consolidated sustainability statement of Santander Consumer Bank AS (the «Company»), included in the section Sustainability Statement 2024 of the Board of Directors' report (the «Sustainability Statement»), as at 31 December 2024 and for the year then ended. Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention that causes us to believe that the Sustainability Statement is not prepared, in all material respects, in accordance with the Norwegian Accounting Act section 2-3, including: • compliance with the European Sustainability Reporting Standards (ESRS), including that the process carried out by the Company to identify the information reported in the Sustainability Statement (the «Process») is in accordance with the description set out in chapter 1.4 Materiality assessment; and • compliance of the disclosures in chapter 2.5 EU Taxonomy of the Sustainability Statement with Article 8 of EU Regulation 2020/852 (the «Taxonomy Regulation»). Basis for Conclusion We conducted our limited assurance engagement in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised), Assurance engagements other than audits or reviews of historical financial information («ISAE 3000 (Revised)»), issued by the International Auditing and Assurance Standards Board. We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion. Our responsibilities under this standard are further described in the Sustainability Auditor’s Responsibilities section of our report. Our Independence and Quality Management We have complied with the independence and other ethical requirements as required by relevant laws and regulations in Norway and the International Code of Ethics for Professional Accountants (including International Independence Standards) issued by the International Ethics Standards Board for Accountants (IESBA Code), which is founded on fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and professional behaviour. The firm applies International Standard on Quality Management 1, which requires the firm to design, implement and operate a system of quality management including policies or procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements. Other Matter The comparative information included in the Sustainability Statement was not subject to an assurance engagement. Our conclusion is not modified in respect of this matter. Responsibilities for the Sustainability Statement The Board of Directors and the Managing Director (Management) are responsible for designing and implementing a process to identify the information reported in the Sustainability Statement in accordance with the ESRS and for disclosing this Process in chapter 1.4 Materiality assessment of the Sustainability Statement. This responsibility includes: PricewaterhouseCoopers AS, Dronning Eufemias gate 71, Postboks 748 Sentrum, NO-0106 Oslo T: 02316, org. no.: 987 009 713 MVA, www.pwc.no Statsautoriserte revisorer, medlemmer av Den norske Revisorforening og autorisert regnskapsførerselskap 2 / 4 • understanding the context in which the Group's activities and business relationships take place and developing an understanding of its affected stakeholders; • the identification of the actual and potential impacts (both negative and positive) related to sustainability matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the Group's financial position, financial performance, cash flows, access to finance or cost of capital over the short-, medium-, or long-term; • the assessment of the materiality of the identified impacts, risks and opportunities related to sustainability matters by selecting and applying appropriate thresholds; and • making assumptions that are reasonable in the circumstances. Management is further responsible for the preparation of the Sustainability Statement, in accordance with the Norwegian Accounting Act section 2-3, including: • compliance with the ESRS; • preparing the disclosures in chapter 2.5 EU Taxonomy of the Sustainability Statement, in compliance with the Taxonomy Regulation; • designing, implementing and maintaining such internal control that Management determines is necessary to enable the preparation of the Sustainability Statement that is free from material misstatement, whether due to fraud or error; and • the selection and application of appropriate sustainability reporting methods and making assumptions and estimates that are reasonable in the circumstances. Inherent limitations in preparing the Sustainability Statement In reporting forward-looking information in accordance with ESRS, Management is required to prepare the forward-looking information on the basis of disclosed assumptions about events that may occur in the future and possible future actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as expected. Sustainability Auditor’s Responsibilities Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability Statement as a whole. As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement and maintain professional scepticism throughout the engagement. Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include: • Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on the effectiveness of the Process, including the outcome of the Process; • Considering whether the information identified addresses the applicable disclosure requirements of the ESRS; and • Designing and performing procedures to evaluate whether the Process is consistent with the Company’s description of its Process set out in chapter 1.4 Materiality assessment. 3 / 4 Our other responsibilities in respect of the Sustainability Statement include: • Identifying where material misstatements are likely to arise, whether due to fraud or error; and • Designing and performing procedures responsive to where material misstatements are likely to arise in the Sustainability Statement. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Summary of the Work Performed A limited assurance engagement involves performing procedures to obtain evidence about the Sustainability Statement. The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed. The nature, timing and extent of procedures selected depend on professional judgement, including the identification of disclosures where material misstatements are likely to arise in the Sustainability Statement, whether due to fraud or error. In conducting our limited assurance engagement, with respect to the Process, we: • Obtained an understanding of the Process by: o performing inquiries to understand the sources of the information used by management (e.g., stakeholder engagement, business plans and strategy documents); and o reviewing the Company’s internal documentation of its Process; and • Evaluated whether the evidence obtained from our procedures with respect to the Process implemented by the Company was consistent with the description of the Process set out in chapter 1.4 Materiality assessment. In conducting our limited assurance engagement, with respect to the Sustainability Statement, we: • Obtained an understanding of the Group’s reporting processes relevant to the preparation of its Sustainability Statement by: o Obtaining an understanding of the Group's control environment, processes and information system relevant to the preparation of the Sustainability Statement, but not for the purpose of providing a conclusion on the effectiveness of the Group’s internal control; • Evaluated whether the information identified by the Process is included in the Sustainability Statement; • Evaluated whether the structure and the presentation of the Sustainability Statement is in accordance with the ESRS; • Performed inquiries of relevant personnel on selected information in the Sustainability Statement; • Performed substantive assurance procedures on selected information in the Sustainability Statement; 4 / 4 • Where applicable, compared disclosures in the Sustainability Statement with the corresponding disclosures in the financial statements and other sections of the Board of Directors' report; • Evaluated the methods, assumptions and data for developing estimates and forward-looking information; • Obtained an understanding of the Company’s process to identify taxonomy-eligible and taxonomy- aligned economic activities and the corresponding disclosures in the Sustainability Statement; • Evaluated whether information about the identified taxonomy-eligible and taxonomy-aligned economic activities is included in the Sustainability Statement; and • Performed inquiries of relevant personnel and substantive procedures on selected taxonomy disclosures included in the Sustainability Statement. Oslo, 24 February 2025 PricewaterhouseCoopers AS Erik Andersen State Authorised Public Accountant – Sustainability Auditor (This document is signed electronically) SCB CSRD report 2024 Signers: Name Method Date This document package contains: - Closing page (this page) -The original document(s) -The electronic signatures. These are not visible in the document, but are electronically integrated. This file is sealed with a digital signature. The seal is a guarantee for the authenticity of the document. Andersen, Erik BANKID 2025-02-24 11:28