ABN AMRO

Reference: page 229

ABN AMRO operates a two-tier board structure. The Executive Board defines the overall strategy and oversees the implementation of material sustainability matters across the bank, ensuring the strategy is informed by and addresses sustainability impacts, risks and opportunities. The Supervisory Board supervises the policies set by the Executive Board and advises on sustainability matters (page 229).

The Executive Board is assisted by dedicated committees, including the Group Sustainability Committee (GSC, chaired by the CEO) for central oversight and steering on sustainability; the Group Disclosure Committee (GDC, chaired by the CFO) for accuracy of sustainability disclosures; and the Group Risk Committee (GRC, chaired by the CRO) for sustainability risk management. The Central Credit Committee factors ESG risks into credit decisions (pages 229-230).

Supervisory Board committees, in particular the Supervisory Sustainability Committee, the Risk & Capital Committee and the Audit Committee, address sustainability within their remits (page 230). All Executive and Supervisory Board members must have sufficient sustainability knowledge; new members complete an induction covering material impacts, risks and opportunities, supplemented by the Lifelong Learning Programme (page 232). Composition and diversity details are incorporated by reference into the Leadership & governance chapter (page 229).

Reference: page 233

ABN AMRO's boards are informed about sustainability matters in several ways. The Executive Board regularly discusses strategic sustainability matters and, together with the GSC (which meets monthly), receives recurring performance updates on key topics such as the climate strategy. To support CSRD implementation, the GSC granted a mandate to a dedicated steering committee operating across strategic, tactical and operational governance layers. A party submitting information to the Supervisory Board must indicate whether it has a sustainability impact and, if so, include a concise description (page 233).

In 2024 the Executive Board, the Supervisory Board and their committees discussed a broad range of sustainability matters, including: sustainability reporting and CSRD implementation; strengthened sustainability governance; the biodiversity statement and roadmap; inclusive banking progress; sustainability KPIs and commitments; the climate strategy and target-setting; the update of the double materiality assessment; the Human Rights Remedy Mechanism; diversity and inclusion; equal pay; the remuneration policy; the climate stress test; sustainability risks; and ESG legislation and societal developments (page 233).

The Audit Committee supervises sustainability reporting, including monitoring the integrity and quality of the sustainability statements (page 230).

Reference: page 204

Sustainability-related performance is integrated into ABN AMRO's incentive schemes. For the Executive Board, sustainability is taken into account via the Dow Jones Sustainability Index (DJSI) and climate strategy KPIs (page 195). The 2024 Executive Board non-financial KPIs included Sustainability (DJSI and Climate Plan), Employee Engagement, and Risk & Regulatory / Licence to Operate; the KPI for Sustainability and its targets and measures are linked to the Climate Plan and the S&P Global ESG Dow Jones Sustainability Index (pages 199, 204).

The 2024 scorecard applied an indicative weighting of around 5% to the DJSI sub-KPI and 5-10% to the Climate Plan sub-KPI within the non-financial component (page 204). For CLA+ and CLA Identified staff, sustainability is included via Sustainability Assets and climate strategy KPIs; for CLA staff, sustainability also forms part of variable remuneration (page 195). KPI weight bandwidths were amended to allow a higher weighting of sustainable long-term strategy-related KPIs (page 199).

Detailed remuneration disclosures (29(a), 29(e)) are incorporated by reference into the Leadership & governance Remuneration report (page 223).

Reference: page 237

ABN AMRO conducts sustainability due diligence in line with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. The due diligence process mirrors the bank's enterprise risk management cycle and outlines the steps applied to address actual and potential negative impacts relating to relevant OECD themes such as human rights and the environment (page 237).

Page 238 provides the required mapping of the core elements of due diligence to sections of the Integrated Annual Report:

• (a) Embedding due diligence in governance, strategy and business model -> Governance of sustainability matters; Sustainability risk management framework; Human Rights Statement.
• (b) Engaging with affected stakeholders -> How we engage with our stakeholders; the materiality process (including NGOs as proxies for affected stakeholders); the grievance mechanism.
• (c) Identifying and assessing negative impacts -> Risk identification and materiality assessment; Risk assessment and measurement.
• (d) Taking actions to address negative impacts -> Risk response.
• (e) Tracking effectiveness and communicating -> Risk reporting; Climate change (page 238).

The Sustainability Risk Management Framework applies to new and existing clients throughout their lifecycle, from acceptance through ongoing due diligence to potential client exit (page 237).

Reference: page 220

ABN AMRO has incorporated its sustainability reporting into the overall annual reporting process. Reporting risks, including those related to sustainability, are categorised under data risk as part of the non-financial risk types and managed under the bank's enterprise risk management framework. Controls include the 4-eyes principle on the drafting of disclosures, review within the Group Disclosure Committee, and dedicated sign-offs per section by management (page 220).

A risk assessment was performed as part of CSRD implementation to identify key risks in the sustainability reporting process, covering both quantitative and qualitative information. The methodology, embedded in the Non-Financial Risk Policy, assesses inherent risks and prioritises them from low to critical based on likelihood and impact on processes, operations, compliance and reputation. Main risks identified relate to change, data, HR, IT and third-party interactions; each finding is addressed by specific mitigating actions (for example, CSRD knowledge sessions to build internal capacity) (page 220).

Finance oversees the overall reporting process, and ownership of each material matter is embedded in existing functions. Findings from risk assessments and internal controls are reported semi-annually to the Executive Board and Audit Committee (page 220).

Reference: page 224

ABN AMRO Bank N.V. is a Dutch bank headquartered in Amsterdam. Sustainability is one of its three strategic pillars, focusing on the key areas of climate, nature and social impact, and has been part of the strategy since 2018 (pages 224-225).

The bank links its business model to sustainability matters via its balance sheet: of total assets, around 65% is loans and advances (of which roughly 61% residential mortgages, 33% corporate loans and 3% consumer loans), 12% financial investments and 23% other assets. The main impact arises downstream, associated with the clients the bank finances, primarily through lending portfolios such as mortgages and corporate loans (page 224).

The value chain comprises four parts: own operations, the upstream value chain (suppliers, predominantly providers of human resources or IT services), the downstream value chain of direct clients, and the downstream value chain beyond direct clients (page 219). Most of the bank's impacts are an indirect effect of activities of actors in the value chain (page 219).

Strategy and business-model elements (40(a)i-ii, 42(a),(b)) are also incorporated by reference into the Our Bank and Strategy, value creation and performance chapters (page 223).

Reference: page 473

ABN AMRO identifies four main stakeholder groups: clients (consumers, SMEs and large companies), employees, investors (shareholders and bondholders), and society (suppliers, business partners, local communities, governments, regulators and NGOs). Stakeholder views are gathered through surveys, engagement trajectories, formal letters from investors, stakeholder roundtables and masterclasses (page 473).

For the 2024 DMA update, the bank, working with an external partner, collected insights from around 1,400 stakeholders to corroborate the impact-materiality conclusions drawn in 2023. Participation from clients and employees was robust, while investor and society response rates lagged. The requirement to consult affected communities was addressed by including NGOs as proxies (page 473).

Main topics raised by stakeholders included privacy of client data, suitability of products and services, working conditions in the supply chain, child and forced labour, anti-money laundering, climate change mitigation, circular economy, diversity and inclusion, and pollution of air (page 473).

Stakeholder engagement insights are reported to the Executive and Supervisory Boards; in 2024 they did not prompt changes to the material matters previously identified (page 232). Further stakeholder views (45(a)i-v, 45(b)) are incorporated by reference into the Strategy chapter (page 223).

Reference: page 226

ABN AMRO's 2024 double materiality assessment confirmed eight material ESRS topics: E1 Climate change, E2 Pollution, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users, and G1 Business conduct (Client Integrity). E3 Water and marine resources and S3 Affected communities are not material (page 226).

Most impacts are downstream, arising through clients the bank finances: climate change mitigation and transition/physical risk (real estate, agriculture, oil and gas, transportation); air and water pollution; biodiversity loss; and circular-economy effects. Own-operations topics include diversity and inclusion (S1), suitability of products and privacy of client data (S4) and social inclusion. Workers in the value chain (S2) covers working conditions and child/forced labour. Client Integrity (G1) is treated as a financial risk covering AML, anti-bribery and corruption, terrorism financing, tax, fraud and sanctions (page 226).

The material matters are integrated into strategy through the three focus areas of climate, nature and social impact; no new material matters were identified in 2024 and none lost relevance. A bank-wide ICAAP stress test over a five-year horizon concluded the financial effects of environmental and other risks are well within loss-absorbing capacity, confirming the business model is resilient (page 227).

Reference: page 472

ABN AMRO performed its first double materiality assessment (DMA) in 2023 and updated it for 2024, integrating the ECB Guide CER materiality assessment into the ESRS process. Four workstreams (climate, environment, social, business conduct) drew on expertise from the Sustainability Centre of Excellence, Finance, Risk, HR, Compliance and the client units (page 472).

The assessment began with the sub-topics in Appendix A of ESRS 1, tailored to ABN AMRO terminology. Because most impacts are linked to downstream financing of the real economy (residential mortgages and corporate loans), the assessment focused there, weighing IROs by sectoral and geographic classification using external sector data and internally developed environmental and social risk heatmaps (page 473).

Impact materiality followed a five-step process (understand context; engage stakeholders; classify impacts; assess by scale, scope, irremediability and likelihood; apply thresholds). A matter is material if all factors score "high" or all but one score "high"; for potential negative human-rights impacts, severity takes precedence over likelihood (pages 473-474).

Financial materiality treats ECB CER and ESRS requirements as complementary, focusing on how sustainability matters affect financial performance (page 474). The DMA outcomes are the basis for the topical disclosures (page 219).

Reference: page 221

ABN AMRO includes an Overview table of disclosure requirements listing, per chapter, the specific ESRS paragraphs covered in the Sustainability Statements. The statements cover ESRS 2 plus the topical standards E1 Climate, E2 Pollution, E4 Biodiversity, E5 Circular economy, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users, and G1 Business conduct (pages 221-222).

The table records transitional provisions applied for several standards: for example, phased-in datapoints for E1 Climate (34(a), 64, 66-69), E2 Pollution (23, 25, 40, 41), E4 Biodiversity (13, 32, 38), E5 Circular economy (24) and S1 Own workforce (55-57, 74-76, 93) (page 222).

ABN AMRO opted to include the ESRS 2 minimum disclosure requirements in the locations where they fit best: minimum disclosure requirements on policies appear in the Risk management of sustainability matters section, those on actions and targets in the topical sections, and those on metrics in the Definitions sections; they are not repeated for each topical section to avoid repetition (page 221).

The table is read together with the Incorporation by reference paragraph, which lists ESRS disclosure requirements covered in other parts of the Integrated Annual Report (for example GOV-1, GOV-3, SBM-1, SBM-2) (pages 221, 223).

Reference: pages 248-251, 276, 278-279

ABN AMRO's climate strategy (introduced December 2022) is described as containing the key elements of its transition plan, embedded in the bank-wide business strategy and financial planning. It aims to align with limiting warming to 1.5C and reaching a net-zero economy by 2050, under commitments to the Dutch Financial Sector Climate Agreement and the NZBA.

GHG targets (own + financed): Own operations target net-zero by 2030 (buildings/data centres/lease cars/business travel; 2024 in-scope emissions 9.5 ktCO2e vs 52.3 ktCO2e baseline). Financed-emission 2030 interim targets set per NZBA sector, covering 95% of exposure to NZBA carbon-intensive sectors. Examples (2024 perf vs 2030 target): residential mortgages 19.5 to 16.6 kgCO2/m2; commercial real estate 60.3 to 35.7 kgCO2/m2; power generation 3.5 to <188 kgCO2/MWh; oil & gas upstream committed financing EUR 804m to EUR 987m (already achieved); deep-sea shipping WCA -2.0% to 0%; agriculture 1.6 to 1.4 mtCO2e/EURm.

Levers/actions: Three decarbonisation levers - (1) supporting client transition (Transition Readiness Assessment, ~2,100 clients across six sectors), (2) aligning processes/policies (credit approval, thermal coal phase-out by 2030), (3) engaging industry/government.

Funding/governance: Continuous internal funding; capex quantification regarded as less relevant for a bank since targets depend on clients' capex. Progress and target-setting approved by Group Sustainability Committee and ultimately the Executive Board (ExBo); monthly/quarterly monitoring.

Alignment: NZBA, PCAF and ISS (client assets) frameworks; science-based 1.5C reference pathways (CRREM, IEA NZE, DNV) cover 93% of NZBA-sector exposure.

Assumptions/dependencies/limitations: Relies on benchmark assumptions (emerging technology, consumer-demand shifts); targets NOT validated by an independent external body; decarbonisation-lever impact cannot be directly quantified in GHG terms; climate scenarios were not used to identify levers; mortgage/CRE decarbonisation dependent on government policy and factors outside bank control. Locked-in emissions: new gas/diesel international lease-car contracts in France/Greece span five years and could yield vehicle emissions in 2030. No external stakeholders involved in target-setting.

Reference: pages 247-248, 254-255, 276

Climate risk is integrated into ABN AMRO's risk taxonomy, risk appetite and financial planning under sustainability risk. The sustainability risk policy framework ensures environmental risks are managed across the enterprise risk-management cycle and addresses climate change mitigation and the management of physical and transition risk for lending activities.

Own operations policies:

• Environmental and Energy Policy - reduce building energy use and increase renewable energy via procurement; overseen by the Chief Operations Officer (COO).
• Travel and Mobility Policy - electrify the lease fleet, reduce business-travel emissions, encourage alternative travel; overseen by the CHRO. These currently apply to operations in the Netherlands, with work underway to extend them to other countries. The bank is ISO 14001-certified for Environmental Management Systems.

Lending/credit policies: Standard with Client Requirements commits to phasing out thermal coal by 2030 (financing clients >5% reliant on thermal coal only with a public 2030 phase-out plan, achieved by 2038 at latest, plus a credible renewable growth strategy); credit-granting and underwriting criteria (loan-to-value, loan-to-income) incorporate environmental factors; CRE credit policy requires committed/funded capex plans for buildings with energy label D or lower. The Mortgage Advice Policy requires advisers to discuss sustainability financing at every consultation (responsibility of CCO Personal & Business Banking; CRE policy responsibility of CCO Corporate Banking).

Reference: pages 249, 252-259, 276, 278-279

Actions are organised under three decarbonisation levers and detailed per sector. Client transition support: Transition Readiness Assessment (TRA) covering ~2,100 clients across shipping, oil & gas upstream, power generation, commercial real estate, inland shipping and agriculture (to expand to road transport and oil & gas midstream); interest-rate discounts for energy-label A/B mortgages (24% of the mortgage book had a sustainability discount at end-2024; 42,000 sustainability-linked loan elements); Sustainability Facility for CRE clients (since August 2024); Carbon Environmental Solutions for EU ETS; Shipping Climate Dashboard.

Own-operations actions: upgrading Dutch offices to energy label A (95% completed) targeting <50 kWh/m2/year by 2030; transition to 100% renewable energy; electrifying the lease fleet; replacing short-haul air travel with rail and procuring sustainable aviation fuel.

Resources/funding: Continuous internal funding embedded in standard operations; the bank regards capex quantification as less relevant because climate targets depend mainly on clients' capital expenditure rather than the bank's own. Renewables/decarbonisation-technology financing reached EUR 5.4bn at end-2024 (target raised to EUR 10bn by 2030); up to EUR 1bn for early-stage capital by 2030 (EUR 333m cumulative deployed). Note: capex/opex amounts are not presented in the structured ESRS datapoint format.

Reference: pages 250-251, 276, 278-279

Targets cover own operations and financed (portfolio) emissions; financed-emission targets cover 95% of exposure to NZBA carbon-intensive sectors, with science-based 1.5C-aligned benchmarks (CRREM, IEA, DNV) covering 93%. Baselines use single-year data (NZBA-aligned). No external validation of targets.

Sector 2030 interim targets (baseline yr; 2024 performance; 2030 target):

No specific targets for iron & steel, aluminium, cement or aviation (immaterial, <1% combined). Own operations: net-zero by 2030 (-95% vs 2015 baseline, remainder offset); business travel -80% by 2030. Client-assets ambition: reduce Weighted Average Carbon Intensity of DPM equity mandates (benchmark not yet science-based).

Reference: page 279 (energy consumption and mix table; own operations, marked non-material from DMA)

Own-operations energy data for 2024 (2023 comparatives):

Natural-gas consumption fell by 2,867 MWh (heat-pump installation and other initiatives); overall energy consumption declined, cutting emissions by over 2.0 ktCO2e. Energy disclosure relates to own operations only; the bank states energy/own operations are non-material from its double materiality assessment, the material climate impact being financed emissions.

Reference: pages 271, 278

Group GHG emissions (tons CO2e), 2024 vs 2023:

Total location-based 2024: 40,621,609 tCO2e. The vast majority of emissions are indirect (Scope 3), dominated by financed emissions (PCAF methodology). Own-operations detail (page 278): Scope 1 1,459; Scope 2 market-based 810 (location-based 10,047); Scope 3 30,904 (purchased goods 7,897; business travel 8,177; employee commuting 14,830). Facilitated emissions (capital markets, primary issuances) reported for the first time per PCAF: EUR 10.6bn facilitated, 855 ktCO2e. Note: a 66 kton misstatement between Scope 1/Scope 3 for the inland shipping portfolio is disclosed for 2023.

Reference: page 278 (footnote 7), page 279

ABN AMRO uses carbon credits to compensate residual own-operations emissions. In 2024 it emitted 33,402 tons CO2 across Scope 1, Scope 2 (market-based) and Scope 3 categories (business travel, employee commuting, home workplaces, off-premise data centres and Software-as-a-Service), and purchased Verified Carbon Standard (VCS) certified carbon reduction credits to compensate. The credits come from a project financing biogas installations in North Brabant, the Netherlands, which ferment manure and other sources to produce renewable electricity fed into the national grid. The bank explicitly states that its greenhouse gas emission reduction efforts and targets are NOT influenced by its purchases of carbon credits (credits used only for residual compensation alongside the net-zero-by-2030 own-operations target, which aims to reduce 95% of emissions vs the 2015 baseline and compensate the remainder). No GHG-removal projects (e.g. direct air capture, afforestation) are reported; the disclosure concerns reduction-credit purchases only.

Reference: pages 248, 271-275

The chapter addresses portfolio/financed-emissions exposure and Paris-aligned benchmark disclosures rather than quantified monetary anticipated financial effects. Paris-aligned benchmark / carbon-related assets: In its Pillar 3 ESG disclosures, ABN AMRO reports exposures to counterparties excluded from the EU Paris-Aligned Benchmarks per Articles 12.1(d)-(g) and 12.2 of Commission Delegated Regulation (EU) 2020/1818. Carbon-related corporate loans in sectors highly contributing to climate change: EUR 1,507m gross carrying amount with 1,351,523 tCO2e (2023: EUR 1,730m), within total corporate loans of EUR 83,827m / 24,014,880 tCO2e. Carbon-related client assets: EUR 5,568m (7% of total). Client assets in sectors highly contributing to climate change: EUR 50,089m (59%).

Opportunities (quantified): renewables and decarbonisation-technology financing reached EUR 5.4bn at end-2024 (target raised to EUR 10bn by 2030); up to EUR 1bn early-stage capital by 2030 (EUR 333m cumulative deployed); EUR 10bn renewable/decarbonisation-technology target by 2030 for oil & gas clients' transition.

Limitation: the bank notes climate opportunity policies are not yet formalised and does not present a quantified table of anticipated financial effects (monetary amounts at risk / net revenue from opportunities) in the structured ESRS E1-9 format; physical and transition risk are managed under sustainability risk (cross-referenced to the Risk section).

Reference: page 286

Negative pollution impacts in ABN AMRO's downstream value chain are managed through the Sustainability Risk Policy Framework, which underpins how the bank manages pollution impacts in relation to its clients. The framework applies to all environmental topics in a consistent manner, so no dedicated resources are allocated specifically for the pollution-related criteria within it.

At bank level, ABN AMRO excludes specific sectors and sub-sectors from lending products and banking services based on pollution considerations (the Exclusion List). Pollution-related exclusions in the chemical and pharmaceutical sectors relate to substances such as asbestos fibres, pharmaceuticals, pesticides, herbicides and chemicals subject to international phase-outs or bans (e.g. ozone-depleting substances). Activities non-compliant with the EU REACH regulation are also excluded. Air pollution is material from an impact perspective; water pollution is material from both an impact and a risk perspective.

Reference: page 286

Pollution impact is identified at portfolio level using the bank's pollution heatmap. Both the air and water pollution heatmaps indicate that several sub-sectors within agriculture have a high negative pollution impact, so efforts are currently oriented towards this sector; pollution- and biodiversity-related efforts in agriculture are integrated.

At client level, the Client Assessment on Sustainability (CASY) questionnaire assesses and measures pollution impact, covering water, air and soil pollution and measures taken to prevent pollution. In 2024 client assessments addressed air, water and soil pollution, including substances of concern and very high concern and incidents/emergency situations. From 2025, CASY will assess clients in chemicals, pharmaceuticals, oil and gas and mining on systems for identification, labelling and documentation of hazardous substances, plus emergency preparedness for spills, fires and natural hazards. ABN AMRO also engages clients (e.g. on pollution and health impacts in construction) and uses the Transition Readiness Assessment, including data on dairy, calves and pigs sub-sectors (fertiliser use, nitrogen practices, manure management).

Reference: page 287

While methodologies for pollution measurement based on entity-level client data are still evolving, ABN AMRO is in the exploratory phase of identifying metrics and considering targets to enhance its ability to measure and manage pollution impacts. The bank states it will begin by identifying material and feasible metrics as a starting point for setting targets.

Pollution impact targets have not yet been established. In the meantime, ABN AMRO tracks the effectiveness of its policies and actions, using data from client assessments and engagement efforts to monitor progress and guide ongoing improvements, an iterative process intended to keep the bank aligned with evolving best practices.

Reference: page 288

ABN AMRO does not report quantitative own-operations pollutant emissions; pollution is material via its financing/downstream value chain, and the bank discloses sector heatmaps of corporate-loan sensitivity instead. Air and water pollution were assessed together for E2 materiality, but due to data limitations a breakdown at sub-topic level is not provided.

The air pollution heatmap (31 December 2024) shows highest sensitivities (Moderately high/High) in agriculture, mining, manufacturing, transport and power generation. Raising of cattle (EUR 3.0 billion gross carrying amount) and sea and coastal freight water transport (EUR 5.6 billion) carry the highest sensitivities. The water pollution heatmap identifies raising of cattle (EUR 3.0 billion) and manufacture of other food products and beverages (EUR 1.7 billion) as highest. Total corporate loans assessed were EUR 83,827 million.

Reference: page 286

ABN AMRO does not quantify substances of concern (SoC) or substances of very high concern (SVHC); as a bank these arise in financed/client activities rather than its own operations. The topic is addressed qualitatively through client assessment. In 2024, CASY client assessments included elements relating to substances of concern (and very high concern), alongside mitigating negative impacts and incidents/emergency situations.

From 2025, clients operating in the chemicals, pharmaceuticals, oil and gas or mining sectors will start to be assessed on whether they have systems in place to ensure appropriate identification, labelling and documentation of hazardous substances at all stages of the production process, in line with the precautionary principle, with the scope of relevant substances varying per sector. Exclusions also apply to asbestos fibres, ozone-depleting substances and REACH-non-compliant activities.

Reference: page 289

ABN AMRO recognises pollution, particularly water pollution, as a material risk from both an impact and a risk perspective. It expects the Dutch government to take measures to improve water quality through stricter environmental-permit controls and higher taxation of polluting activities, which may negatively influence clients' creditworthiness.

In 2023 the bank conducted a cross-sector environmental risk scenario analysis (TNFD-guided, transition risk, horizon to 2030) for Dutch corporate lending clients, internalising external environmental costs of pollution and assuming permit limitations in highly sensitive natural areas. Results showed water pollution-related costs and business continuity risks were most significant for clients in manufacturing and agriculture. In relation to the Dutch government's nitrogen-reducing measures, ABN AMRO has taken management overlays (see Credit risk review). Specific monetary anticipated financial effects are not quantified.

Reference: page 281

Negative biodiversity impacts in ABN AMRO's downstream value chain are managed through the Sustainability Risk Policy Framework, which applies consistently across environmental topics; consequently no resources are allocated specifically to biodiversity criteria within it. The bank's approach is guided by its Nature Statement and the Kunming-Montreal Global Biodiversity Framework (GBF), to which it aims to contribute through targets 14, 15 and 19.

ABN AMRO supports the GBF and the EU Nature Restoration Law, and is a signatory of the Finance for Biodiversity Pledge, participating in the DNB Biodiversity Working Group, PBAF and Deltaplan Biodiversiteitsherstel. Its primary focus is the agricultural sector (highest biodiversity impact) and the built environment (largest loan-portfolio exposure). Policy principles include incorporating nature into core business, applying the mitigation hierarchy, and using sector- and location-specific information.

Reference: page 282

Biodiversity impact is identified at portfolio level via the Biodiversity risk heatmap, which indicates several agricultural sub-sectors have high negative impact, focusing efforts there. At client level, the CASY questionnaire assesses corporate clients' biodiversity impact and prevention measures. From 2025, clients will be assessed against each IPBES direct driver of biodiversity loss (land/freshwater/sea-use change; climate change; pollution; resource use and direct exploitation; invasive species, noise and light) and on dependencies on ecosystem services.

Clients in agriculture, forestry, mining and animal protein will be assessed on commitment to zero deforestation/degradation of HCV and HCS forests, and agriculture/forestry clients on zero peatland degradation. At bank level, exclusions address conversion/degradation of protected areas, deforestation, non-RSPO palm oil, illegal logging, and Arctic oil and gas. Actions prioritise higher levels of the mitigation hierarchy, avoiding reliance on biodiversity offsets.

Reference: page 283

ABN AMRO has set an overarching aim to halt and reverse biodiversity loss by 2030, guided by GBF targets 14, 15 and 19. However, while methodologies for aggregated biodiversity measurement based on entity-level client data are still evolving, the bank is in the exploratory phase of identifying metrics and considering targets, and states that aggregated biodiversity impact targets have not yet been established.

It notes that steering on previously reported drivers of biodiversity loss is not possible because the data used is based on countries' sector averages. The bank will begin by identifying material and feasible metrics as a starting point for setting targets, while tracking the effectiveness of its policies and actions using client assessment and engagement data. The related Circular Loan volume target is referenced as contributing to halting and reversing biodiversity loss.

Reference: page 285

ABN AMRO does not report ESRS-defined own-operations land-use/biodiversity metrics; no sites in its own operations are located near biodiversity-sensitive areas. Instead it discloses a Biodiversity and ecosystems heatmap for corporate loans (31 December 2024) rating sub-sectors by sensitivity to physical risk, transition risk and negative impact, with gross carrying amounts.

Highest sensitivities are in agriculture, mining, manufacturing, power generation and transport. Notable exposures include raising of cattle (EUR 3,049 million), sea and coastal freight water transport (EUR 5,612 million), indoor growing of crops (EUR 1,471 million) and support activities for petroleum and natural gas extraction (EUR 1,094 million), against total corporate loans of EUR 83,827 million. Heatmap drivers derive from the Global Impact Database and ENCORE, adjusted for country biodiversity levels.

Reference: page 290

Circular economy is material for ABN AMRO due to the resource use impact of the sectors it finances. Negative resource use impacts in the downstream value chain are managed through the Sustainability Risk Policy Framework, applied consistently across environmental topics, so no resources are allocated specifically to circular economy criteria within it.

ABN AMRO has prioritised the circular transition since 2017. It contributed to the circular economy finance guidelines now part of the EU Categorisation System, signed a joint statement (March 2024) supporting circular economy development with the Dutch government and leading banks (building on the Circular Finance Roadmap 2030), and published an open-source Circular Risk Scorecard (February 2024). The EU and the Netherlands target a circular economy by 2050.

Reference: page 291

Resource use impact is assessed at client level via CASY, covering clients' impact on resource use and measures to promote a circular economy; 2024 assessments included the waste hierarchy and resource use in own operations and the value chain. From 2025, clients will be assessed on reducing virgin material use (design, recycling, life-time extension) and circularity in line with the 9R principles.

Exclusions apply (e.g. Hong Kong Ship Recycling Convention breaches; Basel Convention violations in chemicals/pharma). Concrete actions include the Sustainable Impact Fund (EUR 500 million commitment; 2024 stake in concrete-recycler Urban Mine), a dedicated Product-as-a-Service (PaaS) desk, a thematic engagement on ship recycling, and Tikkie, which facilitated nearly 3 million can/bottle recycling transactions in 2024 (tenfold increase versus 2023).

Reference: page 292

While methodologies for aggregated resource use measurement are still evolving, ABN AMRO is in the exploratory phase of identifying metrics and considering targets, and states resource use impact targets have not yet been established. It will begin by identifying material and feasible metrics as a starting point.

The bank has a circular loan volume target measuring the cumulative financing volume of circular loans. However, it notes this does not directly measure resource use and is not outcome-based, so it does not consider the circular loan volume target suitable as an impact target for this material matter. In the meantime, ABN AMRO tracks the effectiveness of its policies and actions using client assessment and engagement data.

Reference: page 297-298

ABN AMRO's Diversity & Inclusion (D&I) policy is an integral part of its HR Risk Policy, reaffirming commitment to a diverse, inclusive and equitable workplace, equal opportunity, and prevention of harassment and discrimination. Protected characteristics include gender, race, nationality, ethnicity, age, religion, disability, sexual orientation, union and political affiliation. For non-employees via third-party suppliers these principles are reinforced through the Supplier Code of Conduct.

Additional policies:

• Behavioural Risk Policy safeguarding an enabling working environment and providing speak-up channels, aligned to the Code of Conduct and core values (care, courage, collaboration).
• Human Rights Statement aligned with the UN Guiding Principles, OECD Guidelines and ILO Declaration; the bank is a signatory of an International Framework Agreement (IFA) with FNV and UNI Global Union, pledging to respect ILO Conventions No. 29, 105 and 182.
• The HR Risk Policy references D&I best practices per the Dutch Corporate Governance Code. The Executive Board (ExBo) is accountable for the D&I policy, with day-to-day management delegated to the Group Risk Committee.

Reference: page 297-298, 300

ABN AMRO engages its workforce through multiple channels: employee councils, employee surveys and pulse surveys, and ongoing interactions with trade unions. The Employee Council and European Staff Council directly represent employees in the bank's governance, and the bank maintains relationships with trade unions where it operates.

Engagement on D&I occurs through the Diversity Table and Circles, internal networks, employee advice sessions, internal surveys, D&I roundtables, pulse checks, and colleague discussions, conducted multiple times per year. Regular surveys include questions on the D&I policy and its perceived effectiveness, and the workforce is encouraged to provide additional feedback.

As a signatory of the IFA with FNV and UNI Global Union, the bank operates an IFA Monitoring Committee (ABN AMRO and trade union representatives) which offers unions an opportunity to share workforce-related insights. For non-employees via third-party suppliers, the bank is striving to open its grievance mechanism so they too have a channel to express their perspectives.

Reference: page 299

ABN AMRO operates multiple processes to remediate potential negative impacts, including gender equality and equal pay, D&I training, the Behavioural Risk Policy, and measures against workplace violence and harassment (zero-tolerance policy).

Speak-up channels for own workforce (employees and external employees) include:

• Inappropriate Behaviour Adviser for harassment, discrimination, bullying, aggression or violence
• Integrity Adviser for compromised interests or difficult situations
• Whistleblowing channel to confidentially report suspected irregularities
• Mediation Office for informal, structured resolution of workplace conflicts
• Employee Council Adviser (around 50 colleagues) addressing reorganisation tensions, workload and working-environment concerns

Channels are communicated via the intranet, engagement surveys, e-learning modules and the CLA package. The engagement survey asks whether employees understand the steps to take and feel confident using reporting channels. The Supplier Code of Conduct provides a reporting mechanism for non-employees via third-party suppliers.

Reference: page 300-301

The sole material matter for own workforce identified through ABN AMRO's DMA is diversity and inclusion. Actions to mitigate negative impacts include a Change Risk Policy (CRP) governing initiatives affecting the bank's values, strategic priorities or risk profile, safeguarding against significant material negative impacts on the workforce.

D&I is a strategic programme influencing HR, Product Development, Communications and Social Impact. The bank focuses on creating equal opportunities for specific focus groups: women, the LGBTIQ+ community, individuals with occupational disabilities, people from migrant and refugee backgrounds, and neurodiversity. Impact is assessed via employee surveys, quarterly reports and other metrics.

A detailed table of 2024 and planned 2025 programmes and activities is provided per focus area (General, Gender, Cultural, B-Able, Reboot, LGBTIQ+, Neurodiversity), including the D&I Learning Academy, mentoring and boardroom coaching programmes, the Gender Equality Manifest, Equal Pay reports, the B-Able programme for occupational disabilities, the Reboot programme for refugees, and the Defiantly Different LGBTIQ+ leadership programme.

Reference: page 302

ABN AMRO NL D&I targets for 2025 (specific to employees):

Gender representation

• At least 48% of the Extended Leadership Team to be women
• 35% of senior and middle management positions held by women
• Gender diversity targets set for senior leadership at subsidiaries

Cultural diversity

• 8% of senior management and 9% of middle management with a migration background

Inclusion of vulnerable and underrepresented groups

• Support participation of at least 225 people with a work-related disability
• Continue annual hiring of 20 people with a refugee background

Diversity targets are set by the D&I department with the Diversity Circles, approved by client unit/function management teams and finally by the ExBo and Supervisory Board. Progress is monitored annually and published in the D&I section of the Strategy, value creation & performance chapter.

Reference: page 303-304

Total employee headcount was 23,299 as at 31 December 2024 (actual headcount basis, not FTE). Geographic split: Netherlands 20,117; Rest of Europe 2,663; USA 249; Asia 159; Rest of world 111.

A total of 42 employees are in the "Other & unknown" gender category (37 permanent / 5 temporary; 37 full-time / 5 part-time). Turnover counts employees who left voluntarily, were dismissed, retired or died in service.

Other metrics:

• Turnover rate: 10.00%
• Absenteeism: 4.20% (4.19% in 2023)
• 50% of open positions filled by internal candidates
• Inflow 2,647; outflow split natural / reorganisation / other

Reference: page 304

ABN AMRO's European Staff Council (ESC) qualifies as a European Works Council, representing staff in the Netherlands, Belgium, Germany, France and the UK, and serving as a forum for information, consultation and dialogue on economic, financial and social matters across the bank and its subsidiaries.

Collective bargaining coverage (Netherlands):

• 97.72% of ABN AMRO's workforce are covered by the Dutch collective labour agreement (CLA)
• 99.77% of employees are covered by workers' representatives in the Netherlands

The CLA coverage percentage is calculated by dividing the total number of active employees in the Netherlands falling under a CLA by the total number of active employees in the Netherlands, multiplied by 100.

Reference: page 303-304

Gender diversity at top management level (ESRS definition = Extended Leadership Team): 39% female and 61% male.

Gender diversity by Hay level:

Additional metrics:

• Share of women in management positions: 34%
• Share of women in management positions in revenue-generating functions: 34%
• Share of women in STEM-related positions: 36%

Age breakdown is reported across six brackets (<24, 24-29, 30-39, 40-49, 50-59, >59), split by gender.

Reference: page 303-304

ABN AMRO reports that 1% of employees have a work-related disability, a figure that includes only ABN AMRO Netherlands. It is calculated by dividing the number of disabled employees by the total number of active internal employees (within ABN AMRO NL) multiplied by 100. The bank plans to include data from entities outside the Netherlands in coming years, subject to legal restrictions on data collection.

Through its B-Able programme, the bank identifies suitable job opportunities for individuals with occupational disabilities, working with business units and social enterprises such as Onbeperkt aan de Slag and Ctalents, and participates in a lobbying group advocating for individuals with disabilities (engaging social partners such as the UWV). A D&I target supports participation of at least 225 people with a work-related disability.

Reference: page 303-304

ABN AMRO's performance management methodology, 'Together & Better', applies to most internal employees worldwide. 92.7% of employees register their objectives in Talent2Grow (92.4% male, 93.1% female, 97.6% other & unknown).

Training metrics:

The bank also runs a continuous learning programme, SHARP; in 2024 the average SHARP time was 2.8 hours per employee (not yet included in average training hours as it cannot be split by gender).

Reference: page 303, 305

Gender pay gap: 16%. It is calculated as the difference between the average gross hourly pay of male and female employees, divided by the average gross hourly pay of male employees, multiplied by 100%. To address it, ABN AMRO focuses on increasing gender diversity at higher job levels.

Remuneration ratio: 12. Calculated as the annual total remuneration of the highest paid individual divided by the median employee annual total remuneration (excluding the highest paid individual). It does not include benefits in kind, which the bank aims to include in the medium term.

The gender pay gap and remuneration ratio shown in the "Our employees at a glance" section differ from the figures in the Remuneration report (which includes the CEO Pay ratio) due to a difference in methodology: the Sustainability statements are aligned with the ESRS. The bank reviews compensation annually to ensure equal pay for equal work and conducts annual pay surveys on pay gaps between women and men and across cultural backgrounds.

Reference: page 305

In 2024, ABN AMRO recorded 7 incidents related to discrimination and harassment, handled by HR Labour Affairs. The bank is formalising a governance process to unify assessment and registration of incidents across channels; until fully implemented, reported incidents for 2023 and 2024 only include those registered with HR Labour Affairs, and the total number of incidents reported through the 'speak-up' channels for 2024 will not be disclosed.

The bank received no complaints through the National Contact Points for OECD Multinational Enterprises in 2024, and there were no significant fines, penalties or compensation for damages from violations related to social and human rights issues. In 2024, ABN AMRO did not register any severe human rights violations, including non-compliance with the UN Guiding Principles, the ILO Declaration or the OECD Guidelines, and no related fines, penalties or compensation were recorded for 2024.

Reference: page 308

ABN AMRO has no standalone social risk policy. Social risk is embedded in the Sustainability Risk Management Framework and Sustainability Risk Policy, which address all sustainability risks. Negative impacts on value chain workers in the downstream value chain are managed through this Framework.

Supporting documents include the Human Rights Statement (first developed 2012, last updated 2020, currently being reassessed), the Modern Slavery Statement (updated annually, latest in Q2 2024, next update planned 2025) and the Code of Conduct. These commitments cover all human rights concerns including forced labour and child labour.

The bank is guided by key international standards: the UN Guiding Principles on Business and Human Rights (UNGPs), the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises.

For procurement, the Supplier Code of Conduct (overseen by the Chief Procurement Officer) sets ethical and labour-rights expectations for suppliers; it was reviewed in 2024 to explicitly address worker safety, precarious work, human trafficking, forced labour and child labour.

Reference: page 309

ABN AMRO strives to engage with potentially affected value chain workers, their legitimate representatives or credible proxies. As a financial institution its impact is indirect, so direct contact is difficult; the bank consults credible proxies such as NGOs and trade unions.

Engagement differs by role:

• As a lender: mainly through clients via the CASY tool (includes human-rights questions); high-risk sectors trigger additional KYC documentation. Oversight by the Engagement Committee (EC). Project/export finance applies the Equator Principles (e.g. a Maldives infrastructure project monitored by an Independent Environmental Social Consultant).
• As an investment services provider: engages on stakeholder practices, mainly via EOS at Federated Hermes and subsidiary ABN AMRO Investment Solutions; member of the Platform Living Wage Financials (PLWF).
• As a procurer: an International Framework Agreement (IFA) signed with the FNV trade union federation and UNI Global Union, with a joint monitoring committee.

In late 2024 the bank ran consultation rounds with expert NGOs focused on vulnerable groups such as mining workers.

Reference: page 312

ABN AMRO believes individuals whose human rights are harmed should have access to remedy. It expects corporate clients to provide effective grievance mechanisms under the UNGPs, an expectation embedded in the Sustainability Risk Management Framework.

The bank developed a Human Rights Remedy Mechanism (HRRM), currently in pilot phase, enabling individuals negatively affected by corporate clients and their value chains to access remedies. ABN AMRO states it is the first European commercial bank to implement such a mechanism, inspired by development finance institutions.

The HRRM is managed by the Social Impact and Human Rights team within the Sustainability Centre of Excellence (secretariat and primary contact point). The process covers receipt and review of cases, engagement with relevant parties, and ongoing monitoring, with oversight by an independent external facilitator appointed by the bank.

Since the pilot launched in 2024, no eligible cases of severe human-rights issues or incidents have been reported. Full process details are published on the bank's HRRM website page.

Reference: page 312

ABN AMRO aims to prevent and mitigate negative material impacts on value chain workers by engaging with clients and using its leverage within the bank's broader ESG framework. Depending on the severity of impact, actions may include thematic engagement, active ownership, collaborative engagement or engagement through ABN AMRO Investment Solutions' delegated portfolio managers.

Where specific cases arise (via external reports or own risk assessments), the bank may engage directly with company management, requiring deliverables such as policy reviews, specific KPIs and confirmation of implementation within a defined timeframe. Teams in the Sustainability Centre of Excellence tailor requirements to each case.

Salient issues are tracked through the environmental and social risk heatmap (using Shift red-flag indicators, Impact Institute GID data and OECD indices). In 2024 the highest sensitivities for value chain workers were in mining, transport, accommodation/food service and financial/insurance sectors.

A notable action: decent working conditions for migrant workers in the Netherlands. Labour-agency clients must now be certified by the Labour Standards Foundation (SNA) and, if providing housing, the Housing Standards Foundation (SNF). As a pilot, the bank engaged 200 non-SNA-certified clients to encourage certification.

Reference: page 314

ABN AMRO is in the exploratory phase of establishing measurable, outcome-oriented targets and recognises the importance of defining meaningful metrics to drive its strategy, enhance positive impacts and mitigate negative impacts on value chain workers.

No formal targets have yet been established. In the interim, the bank tracks the effectiveness of its policies and actions by assessing how well it exercises leverage with corporate clients and businesses in its investment sphere of influence.

The development of metrics and targets is at an early stage and will be guided by a gap analysis and a roadmap informed by the CSRD exercise. The bank states it anticipates being able to share more detailed information in its next report.

A related operational metric: in 2024 ABN AMRO onboarded 345 suppliers to the Hellios FSQS screening system as part of supply-chain due diligence.

Reference: pages 316-319

The DMA identified three material consumer matters: privacy, suitability of products & services, and social inclusion (scope largely limited to consumers, not corporate clients).

• Personal Data Policy: minimum standards for processing personal data across the full data lifecycle, grounded in GDPR principles adapted into ABN AMRO sub-principles, and implementing the Binding Corporate Rules (BCRs) for transfers outside the EU; supported by the Risk Management Framework and Third Party & Outsourcing Risk policy.
• Supplier Code of Conduct / Procurement Standard: requires suppliers to safeguard personal data; overseen by the Chief Procurement Officer (CPO).
• Product Approval and Review (PAR) Policy: ensures products serve clients' best interests and a defined target market; aligns with Client Centricity Principles and ESG objectives; ExBo holds ultimate accountability.
• Duty of Care and Client Centricity (DoC & CC) Policy (introduced June 2024): umbrella policy prioritising clients' interests.
• Client Categorisation, Suitability and Appropriateness Policy and Complaints Management Policy complete the framework. Human rights guided by the UN Guiding Principles, ILO Declaration and OECD Guidelines.

Reference: pages 319-320

ABN AMRO engages clients through both proactive and reactive channels, with privacy engagement focused on reactive channels (data breaches, privacy complaints, GDPR rights requests).

• General engagement uses roundtables, surveys, client panels and pilot programmes (e.g. a 2024 pilot testing a new payment feature). The Customer Digital Engagement department gathers insights, including via third-party researchers and inputs from the Dutch consumers' association Consumentenbond.
• The most senior executive accountable for privacy is the ExBo member for the COO Organisation.
• Engagement with specific vulnerable groups: women, culturally diverse clients, elderly clients, those facing financial stress, individuals with disabilities, the digitally less familiar, and young people. In 2024 the bank consulted clients with physical disabilities (focus groups, surveys, one-on-one interviews), which informed the selection of new online banking login processes. Special protocols protect vulnerable groups such as minors.

Reference: pages 321-322

The official complaints procedure lets clients (and non-clients) submit complaints via the website, online chat, phone or app, covering accessibility, suitability, discrimination and product use.

• An initial response is provided within five days, naming the expert handling the complaint and giving an expected response date.
• Complaints may be escalated to the second-line Security and Integrity Management (SIM) team.
• If no response within eight weeks, clients can contact Kifid (Dutch Institute for Financial Complaints) or Meldpunt Discriminatie.
• Privacy complaints escalate to the Data Protection Officer (DPO) within the Privacy Office, or directly to the regulator.
• Effectiveness is measured via a satisfaction survey generating a journey Net Promoter Score (jNPS); the Complaints Management team reports quarterly to the ExBo on complaint trends.
• The Whistleblower Policy protects clients and third parties against retaliation; this channel is separate from the complaints channel.

Reference: pages 322-325

Privacy: A bank-wide privacy programme was set up; in 2024 the bank established a first line of defence (1LoD) Privacy Centre of Excellence and appointed Privacy Stewards. Tools include the Privacy Dashboard and an in-development Complaints Management Dashboard. A May 2024 ransomware attack on a supplier caused unauthorised access to data of a limited group of clients; impacted clients were promptly informed, the supplier secured deletion of stolen data, and the incident was reported to the Dutch Data Protection Authority.

Social inclusion: Delivered via the Inclusive Banking team, Social Impact team, Financial Accessibility team and Financial Health department. The Financial Inclusion Statement (June 2024) targets women, culturally diverse clients, the elderly and young people (Bank information desks, Help with Banking, Help with Money Matters Advisers). Other actions: anti-discrimination taskforces; NVB sector standards for NPOs and sex workers; the Elfin partnership and Code-V for women; accessibility work aligned with the European Accessibility Act. Derisking is non-material but addressed via DFC-KYC training and information portals.

Reference: page 325

ABN AMRO has set few formal outcome-oriented, time-bound targets for consumers and end-users.

• Privacy: No privacy-specific targets were tracked in 2024. Monitoring takes place only as defined in the Risk Appetite Statement: the percentage of data breaches reported beyond the required timeframe, and the number of client complaints related to data protection.
• Social inclusion: The bank is in the exploratory phase of establishing outcome-oriented targets to enhance financial inclusion. No formal targets have been set; it will explore in 2025 whether setting such targets is feasible and meaningful. Progress is monitored using qualitative and quantitative indicators including client feedback, usage rates of new products and demographic studies.
• Suitability of products & services: No additional outcome-oriented, time-bound targets set. Effectiveness is tracked via the Compliance Risk Appetite Statement (RAS) and KRIs at group level, product reviews, monitoring/control/testing (MC&T), thematic reviews and audits.

Reference: pages 326-329

Good corporate governance and a culture based on core values underpin ABN AMRO's business conduct. The material topic from the DMA is Client Integrity (financial materiality), covering six risk types: Anti-Money Laundering, Anti-Bribery and Corruption, Combating the Financing of Terrorism, Tax, Fraud and Sanctions.

Key policies:

• Client Acceptance and Anti-Money Laundering (CAAML) Policy – prevents/detects money laundering and terrorist financing.
• Anti-Bribery and Corruption (ABC) Policy, Tax Policy, Fraud Risk Policy, Sanctions Policy, plus Gifts, Conflicts of Interest and Inducements policies.
• Code of Conduct – all employees must sign and follow it. Pre-employment screening applies to all staff.

Anchored in the Dutch Financial Supervision Act, the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act, and the Dutch Sanctions Act 1977. An AML, CTF and Sanctions Statement and the ABC Policy are publicly available. Client Integrity awareness training (Dec 2024 coverage): "Always be aware of tax" 98%, "Introduction to our gatekeeper role" 97%, yearly "Risk refresher" 97%.

Reference: pages 328-329

Bribery and corruption is marked non-material from the DMA, but the bank reports its prevention and detection framework.

• Bribery and corruption risks are monitored annually through the Systematic Integrity Risk Analysis (SIRA), governed by the Anti-Bribery and Corruption (ABC) Policy (CRO accountable Executive Board member). Risk governance follows the three lines of defence model.
• Pre-employment screening investigates the integrity of all staff. Employees receive continuous learning via Sharp! and specific ABC courses (compulsory for at-risk functions); they are trained to recognise warning signs and report incidents, and to register gifts given and received.
• Anti-Bribery and Corruption training: All Staff, 97% coverage, every 3 years, 60-minute e-learning (coverage reflects staff trained since June 2021; 2021 cohort reassigned via the bank-wide risk refresher from end-2024).
• Staff and external parties are encouraged to speak up; internal ABC violations are investigated by the independent Security & Integrity Management department.

Reference: page 329

No internal breaches of the ABC Policy were identified during the reporting period.

Violations of the ABC Policy by staff or third parties, and any suspicions of bribery and corruption related to clients, are reported internally and to the relevant regulatory bodies. An unacceptable risk of corruption may lead to a prospective third party or client being rejected, or, for existing relationships, to termination. Internal violations are investigated by the independent Security & Integrity Management department.

(Separately, a 2021 settlement with the Netherlands Public Prosecution Service related to AML process shortcomings is disclosed under Client Integrity; DNB has identified shortcomings in event-driven review processes that may lead to enforcement measures, with no provision recorded as the financial impact cannot be reliably estimated.)

Reference: pages 330-331

Marked non-material from the DMA but reported in full. Political dialogue is coordinated by the Public Affairs team, comprising two in-house lobbyists (one covering The Hague, one Brussels); ABN AMRO Clearing has its own lobbyists for clearing in Brussels. Apart from 3.3 FTE in-house lobbyists, ABN AMRO employs no external lobbyists; in-house lobbyists are registered in the EU Transparency Register and comply with the Dutch Banker's Oath and the European Code of Conduct for Interest Representatives.

Key 2024 EU topics: Basel III implementation, the Payment Services Regulation and combating online fraud; Dutch topics included the ACM savings-market consultation and risk-based AML.

Total contributions (€ thousands, 2024 vs 2023):

• Spending on lobbyists: 714 (2023: 690)
• Large membership expenditures: 5,729 (5,751), of which NVB 5,316, VNO-NCW 175, IIF 152, ISDA 86
• Political contributions: nil (stated policy not to fund politicians, parties or campaigns)
• Total: 6,443 (2023: 6,441)