ABN AMRO

Reference: pages 207-209, 197

The Sustainability Statements' overview table lists ESRS 2 paragraphs 22(a)-(d) and 23(a)-(b) under "Governance of sustainability matters", and ESRS G1 paragraph 5(a)-(b) (the role and expertise of the bodies on business conduct), with paragraphs 21(a)-(e) incorporated by reference into the Leadership & governance chapter (pages 196-197).

ABN AMRO simplified its sustainability governance during 2025: the Group Sustainability Committee "was decommissioned during the year 2025", the Engagement Committee became a subcommittee of the Group Risk Committee (GRC), and from the start of 2026 a "simplified target operating model" introduces deputy CSO roles, a Group Sustainability department and the discontinuation of the Sustainability Centre of Excellence (page 207). Sandra Phlippen was appointed CSO effective 1 January 2026; the CSO reports directly to the CEO (page 207).

The Executive Board "is responsible for the continuity of ABN AMRO... as well as for sustainable long-term value creation" and for compliance with sustainability regulations (page 207). Named committees: the GRC (ESG risk management and risk profile), its Engagement Committee (client, sector and supplier engagement), and the Group Disclosure Committee (accuracy and timeliness of sustainability disclosures) (pages 207-208). On the Supervisory Board, the Supervisory Sustainability Committee "supervises sustainability aspects of the strategy and policies" (page 208).

Reference: page 209

The overview table cites ESRS 2 paragraphs 26(a), 26(b) and 26(c) under "Governance of sustainability matters" (page 196).

"Sustainability matters are discussed on a regular basis during meetings of the Executive Board and the Supervisory Board. The Executive Board generally meets on a weekly basis, and the Supervisory Board meets at least six times a year" (page 209). Both boards "receive regular updates on progress towards sustainability-related targets that have been set within ABN AMRO and on ESG risks and related developments", and "Material sustainability topics on the agenda include, among others, the DMA, ESG risks and sustainability reporting" (page 209).

On expertise: members "must have sufficient knowledge and understanding of sustainability", with emphasis on "AML/CTF, sustainability matters and diversity" (page 209). New board members complete an induction programme including "sessions on sustainability-related matters, covering material impacts, risks and opportunities", and both boards attend Lifelong Learning Programme sessions and "several deep-dive sessions" (page 209). Sessions attended in 2025 included "Sustainability: integrated transition plan" (page 166). Each board formally assesses its own performance, composition, diversity and effectiveness annually, and regulators also evaluate business conduct and climate and environmental risks as part of suitability assessments (page 209).

Reference: page 197 (incorporated by reference)

GOV-3 is not presented inside the Sustainability Statements. The incorporation-by-reference table routes ESRS 2 GOV-3 paragraphs 29(a) and 29(e) to "Leadership & governance - Remuneration report - 2025 Performance of the Executive Board", and paragraphs 29(b), 29(c) and 29(d) to "Leadership & governance - Remuneration report - KPI setting and performance" (page 197). The same table lists "ESRS E1, GOV-3 13", the climate-specific limb requiring disclosure of whether and how climate considerations are factored into board remuneration (page 197).

Within the Sustainability Statements the link is stated at a high level: "Sustainability is taken into account via KPIs as described in our Remuneration Report, which helps drive accountability" (page 207).

No percentage of variable remuneration tied to sustainability or climate targets is printed in the Sustainability Statements themselves; the quantification sits in the Remuneration report, outside the extracted chapter. A reader wanting the proportion figure has to follow the cross-reference.

Reference: pages 211-212

The overview table cites ESRS 2 paragraphs 30 and 32 under "Risk management of sustainability matters" (page 196), and the EU-legislation datapoint table records "Statement on due diligence – ESRS 2 GOV-4, paragraph 30 – Material – ESG risk management framework" (page 197).

"In a similar manner to our enterprise risk management cycle, the due diligence process, as defined in the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, outlines the steps to be applied to address actual and potential negative impacts relating to relevant OECD themes (for example, human rights and the environment)" (page 211).

Page 212 prints the required mapping table, "Core elements of due diligence as in the OECD Guidelines" against "Incorporated in Annual Report section", covering all five elements: (a) embedding due diligence in governance, strategy and business model; (b) engaging with affected stakeholders; (c) identifying and assessing negative impacts; (d) taking actions to address negative impacts; and (e) tracking effectiveness and communicating. Each row names the specific sections, for example element (c) points to "Strategy and business model - Determining impact materiality", "Risk identification and materiality assessment" and "ESG Annex - Human rights related disclosures" (page 212).

Reference: page 195

The overview table cites ESRS 2 paragraphs 36(a) to 36(e) under both "Basis of preparation" and "Risk management of sustainability matters" (page 196).

"ABN AMRO has embedded sustainability reporting within its overall governance and risk management framework, in line with the Dutch Corporate Governance Code (Verklaring Omtrent Risicobeheersing) and CSRD requirements" (page 195). Reporting risks are managed under the bank's data risk management framework: "A structured risk assessment methodology is applied, prioritising key inherent risks based on their likelihood and impact before controls are implemented" (page 195).

The identified inherent risks are named: "data quality, process inefficiencies, regulatory compliance and third-party dependencies", mitigated "through detective and preventive controls, formal sign-offs, segregation of duties and targeted actions such as staff training and process automation" (page 195). Oversight sits with "Risk Management, the Group Disclosure Committee and Finance", and "Management provides dedicated sign-offs for both qualitative and quantitative sustainability information" (page 195).

No internal audit conclusion on sustainability reporting controls and no description of how findings were reported to the Supervisory Board are given.

Reference: pages 194, 200

The index cites ESRS 2 paragraphs 40(a), 40(e), 40(f), 40(g) and 42(c) under "Strategy and business model", with 40(a)i, 40(a)ii, 42(a) and 42(b) incorporated by reference into "Our bank - Our business model" (pages 196-197).

The value chain has four parts: own operations ("direct impacts of ABN AMRO"); upstream, whose "main conventional suppliers are predominantly providers of human resources or IT services"; direct client impacts; and the "Downstream value chain of our direct clients". A diagram notes that "For a standard banking institution, most of the impact is typically observed in the downstream segments of the value chain" (page 194).

Page 200 prints "Linking our business model to sustainability matters", mapping balance-sheet items to sustainability relevance: total assets 100%, loans and advances 63% (of which residential mortgages 62%, corporate loans 33%, consumer loans 3%), financial investments 12%, other assets 25%. "The main ESG-related impact in our value chain is the downstream impact associated with the clients we finance, primarily through our lending portfolios" (page 200).

The four EU-legislation exclusion datapoints (fossil fuel, chemical production, controversial weapons, tobacco; paragraphs 40(d)i-iv) are all marked "Not applicable – Not included" (page 197).

Reference: page 202

The index cites ESRS 2 paragraphs 45(a)i-v, 45(a), 45(b), 45(c)i-iii, 45(c) and 45(d) (page 196).

Page 202 prints a stakeholder table naming each group, its description, the input sources used and the "Main topics listed as important":

• Clients ("Consumers, small and medium-sized enterprises, large companies and non-profit organisations"), reached via call centre transcripts, meeting summaries and website search queries. Main topics: "Anti-money laundering, privacy of client data".
• Employees, via works councils in NL, Germany and France plus reuse of the 2024 DMA survey. Main topics include "Suitability of products and services, Privacy of client data, Child labour and forced labour, working conditions".
• Investors, via investor relations dialogue and investor letters (Eumedion, BlackRock). Main topics: "Climate, social inclusion, suitability of products and services".
• Society (suppliers, local communities, authorities, regulators, NGOs). Main topics: "Climate change mitigation, biodiversity, diversity & inclusion, social inclusion, affected communities".

The bank reused "the stakeholder engagement results from 2024 and analysed recent stakeholder group input, which reconfirmed the prior-year survey outcomes". Affected communities were consulted by proxy: that requirement "was addressed by including proxies (NGOs) as part of the stakeholder engagement process" (page 202).

Reference: pages 205-206

The index cites ESRS 2 paragraphs 48(a), 48(b), 48(c)i-iv and 48(d) to 48(h) (page 196).

Page 205 prints "Overview of material matters per ESRS", giving for each matter the topic, sub-topic, ABN AMRO label, definition, type of materiality and value chain position. Nine rows across five standards: E1 climate change mitigation (negative impact, downstream), climate transition risk and climate physical risk (both financial risk, "Downstream & own operations"), climate change mitigation (financial opportunity); E4 biodiversity (negative impact, downstream, "Impact: Nitrogen emissions"); S1 diversity, equity & inclusion (negative and positive impact, own operations); S4 suitability of products & services and privacy of client data (both negative impact); G1 Client Integrity, labelled "Entity-specific topic" (financial risk, downstream).

Page 206 covers current and anticipated effects. Quantified: "For material climate risks in our corporate lending portfolio (downstream), we have taken EUR 5 million provision overlays (2024: EUR 19 million)", plus economic capital held "for climate risk in our corporate lending portfolio (downstream) and for flooding, greenwashing perception and privacy-related risks in our own operations". "The effects of the announced reduction in staff in 2025... have been taken into account in the DMA assessment" (page 206).

Reference: pages 201-204

The index cites ESRS 2 paragraphs 53(a), 53(b)i-iv, 53(c)i-ii and 53(d) to 53(h), plus 53(c)iii and 53(e) under "Risk management of sustainability matters" (page 196).

Impact materiality follows five steps: "1. Understand the organisational context 2. Identify and engage with stakeholders 3. Classify actual and potential impacts 4. Assess these impacts based on scale, scope, irremediability and likelihood 5. Apply thresholds to determine material topics" (page 202). Scoring is explicit: "For adverse human rights impact, severity is weighted 3:1 against likelihood. For all other impacts, severity is weighted 1:1... topics are deemed material if they score 3.5-5, and not material if they score lower than 3.5" (page 203).

Financial materiality combined "(1) likelihood of occurrence and (2) potential magnitude of financial effects over the short, medium, and long term", followed "EBA guidelines on managing ESG risks, and covered all ESRS topics"; magnitude is "assessed against a four-point scale: Critical, High, Medium and Low" (page 203).

2025 changes: "a shift from applying a 3-step scale to a 5-step scale... and the inclusion of top-down input from the Executive Board" (page 203). Limitations are disclosed: "no specific screening of site locations was performed in our downstream value chain" (page 202). Conclusions "were reviewed and approved by the Executive Board and the Supervisory Board" (page 201).

Reference: pages 195-199

A genuine ESRS content index is printed. "The table below shows the disclosure requirements that are included in these Sustainability Statements. This table should be read in conjunction with the Incorporation by reference section" (page 195). The index cites paragraphs 54, 56, 58 and 59 for IRO-2 itself (page 196).

It is organised by chapter and paragraph number, not by DR code. Page 196 lists, for each chapter (Basis of preparation, Strategy and business model, Governance, Risk management, Climate, Biodiversity, Own workforce, Consumers and end-users, Business conduct, EU Taxonomy, ESG Annex), the standard and the exact paragraphs included, plus a "Transitional provisions applied" column. Biodiversity and Consumers and end-users show only ESRS 2 paragraph 17(b)-(e) and 17(b)-(d) against "Topic is in scope of transitional provisions".

Page 197 prints the incorporation-by-reference table (SBM-1, SBM-2, GOV-1, GOV-3, BP-2, MDR-M, MDR-T). Pages 197-199 print the ESRS 2 Appendix B table of datapoints derived from other EU legislation, with a "Materiality for ABN AMRO" column and a "Reference" column.

Footnotes qualify three entries: "ABN AMRO discloses climate-related risk metrics, which partially address E1-9 paragraph 66 and 67" (page 196), and voluntary ESG Annex disclosures of E1-5 paragraph 37 energy data and E1-7 carbon-credit information that are "Although not material" included "to ensure coherence with previous reports" and for ESG rating criteria (page 199).

Reference: pages 219-222

The index lists ESRS E1 paragraphs 14 and 16(a), 16(b), 16(h), 16(i), 16(j) under "Climate", and the EU-legislation table records "Transition plan to reach climate neutrality by 2050 – ESRS E1-1, paragraph 14 – Material – Our climate strategy" (pages 196-197).

"Our climate strategy outlines our commitment to aligning our portfolios with a 1.5°C scenario and supporting the transition to a net-zero economy by 2050" (page 219). "Our climate strategy, which contains key elements of our transition plan, is included in ABN AMRO's bank-wide business strategy and financial planning" (page 222).

Three decarbonisation levers are named: "Supporting our client's transition journey", "Aligning processes and policies" and "Engaging with industry and government", broken into six activities (page 219). Two candour points sit alongside: "the indirect influence of ABN AMRO's decarbonisation levers makes it difficult to directly measure their impact on GHG emission reductions", and "Climate scenarios were not considered in this process" (page 219).

On resourcing: "we focus on operational expenditure over capital expenditure, as our climate targets largely rely on the capital investments made by our clients rather than those of ABN AMRO" (page 222). NZBA "ceased operations effective 3 October 2025" (page 219), and "In November 2025, we announced our intention to update our climate strategy" (page 219). Paragraph 16(g), undertakings excluded from Paris-aligned benchmarks, is "Not applicable – Not included" (page 197).

Reference: pages 203, 235-238 (back-filled)

Back-filled from the ESRS 2 IRO-1-related and SBM-3-related disclosures in ESRS E1, where this content is disclosed in the FY2025 report (index: ESRS E1 paragraphs 18, 20(a), 20(b), 20(c) and 21, page 196). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against (page 194).

Physical or transition classification. The material matters table types the two climate risks as "Climate transition risk" and "Climate physical risk", both "Financial risk" sited "Downstream & own operations" (page 205).

Methodology. Physical sensitivity combines "dependence on assets, labour and ecosystem services, as well as the regional and country-based exposure to hazards (such as flooding, heat stress and sea level rise)", sourced from Climate Adaptation Services "relying on 2050 projections" and Moody's ESG Solutions "relying on projections to 2040". Transition sensitivity uses sector GHG intensity from PCAF and the Global Impact Database plus Dutch Climate Agreement reduction requirements to 2030 (page 235).

Scenarios. High-emission: physical risks "assessed against a high emission scenario (Representative Concentration Pathway (RCP) 8.5 scenario)... This results in a temperature increase of 4.3°C by 2100". Transition: "assessed against our internal base case, which differs from the Paris Agreement in considering a limited overshoot scenario"; forecasts "ran until 2030" (page 203). A 1.5°C-aligned transition scenario is not used for risk identification.

Scope. "In 2025, we performed climate scenario analyses of our residential real estate, commercial real estate and road transportation portfolios", against "several long-term (to 2050) climate change scenarios" (page 238); upstream was out of scope (page 206).

Reference: pages 206, 234 (back-filled)

Back-filled from ESRS 2 SBM-3 and the E1 climate risk section, where this content is disclosed in the FY2025 report (index: ESRS E1 paragraphs 19(a), 19(b), 19(c), page 196). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against (page 194).

Scope and conduct. "We assessed the resilience of our business model to material matters in 2025, considering: Material impacts, risks and opportunities as identified by the 2025 DMA and the updated risk taxonomy; The bank's 5-year forward-looking financial plan; ... Current capital position and projections for the next 5 years; A 5-year forward-looking adverse scenario, in which carbon emission prices increase suddenly due to a large physical risk event or abrupt tightening of climate policies... Results of the ICAAP stress testing analysis, and Results of a 25-year forward-looking climate resilience scenario analysis, considering various long-term scenarios and the potential effect on portfolio size" (page 206). Horizons are tied to targets: the adverse scenario "is aligned with our interim 2030 climate strategy targets", the 25-year analysis "with our 2050 net-zero ambition".

Boundary. "The upstream value chain was not relevant for this analysis and therefore is not in scope" (page 206).

Results. "Insights from the above help us assess the bank's resilience in a transitioning economy and inform our strategy" (page 206), and "We assess the resilience of our business model to these risks, and use our climate strategy and portfolio steering to mitigate them" (page 234).

Acknowledged gap. "ESG matters have not yet been explicitly integrated in our business risk policy. We aim to address this in the next regular policy update" (page 234). No quantified output of the adverse or 25-year analysis is printed.

Reference: pages 219, 224-226, 233

The index does not cite ESRS E1 paragraphs 22-25 directly. It covers climate policies through ESRS 2 MDR-P, listing paragraphs 65(a), 65(b) and 65(c) under the "Climate" chapter (page 196) – the route ESRS E1-2 itself prescribes. The paragraph 25 breakdown (whether policies address mitigation, adaptation, energy efficiency, renewable energy deployment) is not presented as such.

Named climate policies, each with an accountable owner:

• ESG Risk Policy: "Climate risk is integrated into ABN AMRO's ESG Risk Policy... Our climate strategy supplements this policy by defining targets and initiatives" (page 219); approved by the Group Risk Committee (page 212).
• Mortgage credit policy: "integrates environmental factors into underwriting criteria, including loan-to-value and loan-to-income rules"; advisers "must discuss financing options for sustainability improvements during every mortgage consultation". Owner: "the CCO of Personal & Business Banking" (page 224).
• CRE credit policy: "a funded capex plan is required to upgrade buildings with energy label D (NL) or lower to label C or higher", and "refinancing may be declined for buildings with energy label D or lower". Owner: "the CCO of Corporate Banking" (page 225).
• ESG Risk Standard with Client Requirements: "We will only finance clients with over 5% reliance on thermal coal if they have a public 2030 phase-out plan", with named German critical-infrastructure exceptions (page 226).
• ESG Rules and Guidelines for Investment Products, setting "our WACI climate ambition and the criteria for exclusions on fossil fuel"; owned by "the Head of Global Wealth Products" (page 233).

Bank-wide: "we neither directly provide financial products or services to activities on our Exclusion List, nor engage in business with companies listed on our Controversial Weapons List" (page 212).

Reference: pages 221-233

The index lists ESRS E1 paragraphs 28 and 29(a) under "Climate", with ESRS 2 MDR-A paragraphs 68(a), 68(b), 68(c) and 68(e) (page 196). Actions are presented by decarbonisation lever, as paragraph 29(a) requires.

Supporting clients' transition. The Transition Readiness Assessment "helps determine how prepared a client is to adopt sustainable practices"; from January 2025 it was integrated into client tooling for Shipping, Power Generation, Oil & Gas Upstream and CRE and extended to trucks. "Assessments have been completed for most of the approximately 2000 clients in these sectors, except agriculture", where "TRAs were carried out for 80 clients in 2025". "In 2025, we also completed our Climate Dashboard" (page 222).

Sector actions: mortgage interest-rate discounts, where "By the end of 2025, 28% of our mortgage portfolio... benefitted from a sustainability discount" and the portfolio "comprised approximately 50,600 sustainability-linked loan elements" (page 224); "In April 2025, we introduced the free online Green Building Tool" plus the Sustainability Facility for CRE (page 225); "In 2025 we launched the Switch2ZE pilot, inviting a select group of clients to replace their fossil-fuel vehicles with zero-emission (ZE) alternatives" (page 231); and the internal "Dairy Transition Plan" (page 230). For client assets the bank works "in partnership with EOS at Federated Hermes Limited", monitoring progress "over 3-5 years" (page 233).

Resources. No CapEx or OpEx amount is related to financial-statement line items or Taxonomy KPIs; the bank focuses "on operational expenditure over capital expenditure" (page 222). Several 2024 actions were discontinued, including the road-transport financial-covenant action and the power-generation Carbon Environmental Solutions action (pages 226, 231-232).

Reference: pages 220-223, 232-233, 247

The index lists ESRS E1 paragraphs 32, 33, 34(a), 34(b), 34(c), 34(e) and 34(f) with ESRS 2 MDR-T paragraphs 80(a) to 80(j); paragraph 34(a) also appears in the transitional provisions column (page 196).

Page 223 prints "Overview per sector", giving for each of eleven sector and sub-sector lines the metric, scopes covered, baseline year and value, 2025 performance, prior-year figure, 2025 financed emissions, 2030 interim target, reduction required and benchmark scenario. Figures corroborated in the per-sector narratives: residential mortgages fell "to 19.2 kgCO2/m², compared with 2024, when it was at 19.5", against a "14% reduction in carbon intensity by 2030 compared with 2025" on CRREM 1.5 NL V2 (pages 223-224); commercial real estate "increased to 60.8 kgCO2/m², compared with 2024, when it stood at 60.3", against "our current 2030 target of 35.7 kgCO2/m2 based on the CRREM 1.5°C scenario V1" (pages 223, 225); oil and gas upstream committed financing declined "from EUR 804 million in 2024 to EUR 566 million in 2025" (page 226); upstream and midstream intensity is "13.1 kgCO₂e/boe, compared with 16.0 kgCO₂e/boe in 2023" against "a 27% reduction... compared with the 2022 baseline" (page 227); and passenger cars reached "83.8 gCO₂/vkm, and for 2024 this was 96.3", targeting "63.0 gCO₂/vkm" (page 232).

Client assets: "-30% below the baseline in 2025, and to be -50% below the baseline in 2030", against a fixed 2019 benchmark and the IPCC SR 1.5°C scenario after a 2025 shift "from a moving benchmark" (pages 232-233). Financing targets: renewables and decarbonisation technologies at "EUR 5.8 billion" end-2025 against "EUR 10 billion by 2030", and early-stage capital of "EUR 408 million" deployed against "up to EUR 1 billion" (page 247).

Stated limitations: "our sector targets primarily cover scope 1 and 2 emissions of our clients" (page 220); "The climate targets have not been validated by an independent external body" (page 220); and "some 2030 targets do not fully align with the pathway chosen for the sector concerned... residential mortgages, commercial real estate, inland shipping, and road transport trucks and vans" (page 220). The sector-target threshold rose "from 0.25% to 1% of the corporate loan book", making "iron & steel, aluminium, cement and aviation" immaterial (page 221).

Reference: pages 242-246

The index lists ESRS E1 paragraphs 44(c) and 51 under "Climate" (page 196) – the gross Scope 3 limb and the requirement to break Scope 3 down by significant category. The EU-legislation table records "Gross Scope 1, 2, 3 and Total GHG emissions – ESRS E1-6, paragraph 44 – Material – GHG monitoring", footnoted: "Only scope 3 category 15 emissions have been deemed material and are therefore included in the GHG monitoring section. Other emission scopes are included in the ESG Annex" (pages 197, 199). "Gross GHG emissions intensity" (paragraphs 53 to 55) is "Not material – Not included" (page 197).

"Total GHG emissions were 36,695 ktCO2e" (page 242). "In 2025, total GHG financed emissions decreased to 29,680 ktCO2e (31 December 2024: 32,224 ktCO2e)" (page 243), split into clients' scope 1 and 2 of 14,370 ktCO2e (2024: 17,513) and clients' scope 3 of 15,310 ktCO2e (2024: 14,711) (page 242). "71% of our total assets are in scope for calculating GHG-financed emissions in line with PCAF" (page 244).

Page 243 prints a balance-sheet table of gross carrying amount in and out of scope, emissions, carbon intensity and PCAF data quality score per asset class, for both years. Page 244 adds a data-quality-score breakdown where score 5 emissions fell from 19,246 to 14,997 ktCO2e. Further tables cover corporate loans in sectors highly contributing to climate change (18,377 ktCO2e on EUR 48,678 million), carbon-related assets (EUR 1.4 billion, from EUR 1.5 billion), client assets, and facilitated emissions of 1,073 ktCO2e on EUR 13.5 billion (pages 244-246).

Own-operations Scope 1 and 2 emissions sit in the ESG Annex (page 287), outside the assured statement (pages 287, 427).

Reference: pages 206, 235-242

The index lists ESRS E1 paragraphs 66(a), 66(c), 67(a) and 67(c) under "Climate" while simultaneously placing paragraphs 66, 67, 68 and 69 in the transitional provisions column (page 196). A footnote qualifies it: "ABN AMRO discloses climate-related risk metrics, which partially address E1-9 paragraph 66 and 67. This pertains to physical risk metrics and transition risk metrics" (page 196). Paragraph 69, exposure to climate-related opportunities, is "Not material – Topic is in scope of transitional provisions" (page 198).

Physical risk amounts by acute and chronic (66(a), (c)). Page 238 gives corporate loan exposure by geography across four buckets: chronic-sensitive EUR 9,880 million, acute-sensitive EUR 10,042 million, both EUR 3,690 million, not sensitive EUR 62,904 million, of EUR 86,516 million, with 2024 comparatives and a candid footnote: "Approximately 30% of these totals concerns exposures where no physical climate data was available." Pages 239-240 add risk-class tables for commercial and residential real estate across foundation, flood, wildfire and heat stress risk, with "52% of the portfolio has a medium or high risk of experiencing the effects of heat stress by 2050" for residential real estate and damage estimates of "EUR 1,730 on average per square metre" for flooding.

Real estate by energy-efficiency class (67(c)). Page 241 breaks the EUR 13,638 million CRE portfolio across labels higher-than-A to G plus no label and unknown; "higher than A and with energy label C or higher improved to 26% and 71% respectively (2024: 22% and 69%)". The mortgage equivalent follows on page 242.

Transition risk. Page 235 rates 19 named NACE sub-sectors for physical and transition sensitivity and negative impact against gross carrying amount, identifying "cattle farming (EUR 3.1 billion) and sea and coastal freight water transport (EUR 4.8 billion)" as highest (page 236).

Monetary effects. "EUR 5 million provision overlays (2024: EUR 19 million)" plus economic capital (page 206). No prospective monetary anticipated effect is quantified, consistent with the transitional provisions claimed.

Reference: pages 251-252

The index lists ESRS S1 paragraphs 19, 20(a), 20(b), 20(c), 21 and 24(a) to 24(d) (page 196). The EU-legislation table marks "Human rights policy commitments – ESRS S1-1, paragraph 20 – Material" and "Due diligence policies on issues addressed by the fundamental International Labour Organization Conventions 1 to 8 – ESRS S1-1, paragraph 21 – Material", while paragraph 22 (trafficking) and paragraph 23 (workplace accident prevention) are "Not material – Not included" (page 198).

"Based on the Double Materiality Assessment, we have identified the impact of Diversity, Equity and Inclusion (DE&I) as the sole material matter in relation to our own workforce" (page 251).

Three policies are described. The HR Risk Policy covers "discrimination, employee relations, health and safety, remuneration and employee suitability" and "aims to adhere to the principles of the European System of Central Banks & the Single Supervisory Mechanism Equality and Inclusion Charter" (page 251). The DE&I policy "is an integral part of our HR Risk Policy"; protected characteristics are "gender, race, nationality, ethnicity, age, religion, disability, sexual orientation, union affiliation, political affiliation and other statuses protected by applicable laws", and it includes "disciplinary actions to be taken if discrimination is detected" (page 252). The Behavioural Risk Policy "anchors the importance of 'speak-up channels'" (page 252).

Scope: the policies "apply to ABN AMRO Bank N.V. and all subsidiaries, branches and representative offices under its control globally", Executive Board accountable, day-to-day management delegated to the Group Risk Committee (page 251). Commitments are anchored in the UNGPs, the ILO Declaration and the OECD Guidelines, and an International Framework Agreement pledging respect for ILO Conventions 29, 105 and 182 (page 250).

Reference: pages 250, 252

The index lists ESRS S1 paragraphs 27(a) to 27(e), 27, 28 and 29 under "Own workforce" (page 196).

"ABN AMRO has established multiple channels to engage with its own workforce on a wide range of topics. Key engagement processes include employee councils, employee surveys and ongoing interaction with trade unions. Specific topics, such as development, performance and personal circumstances, are often addressed through direct dialogue between the employee and their line manager" (page 252).

The representative bodies are named: "the Employee Council in the Netherlands and the European Staff Council directly represent employees in ABN AMRO's governance. ABN AMRO also maintains relationships with trade unions in the Netherlands and, where applicable, in other countries where we operate" (page 250). The European Staff Council "qualifies as a European Works Council" (page 259).

Frequency and accountability: DE&I engagement runs "through initiatives such as the Diversity Table and Circles, ABN AMRO's internal networks, and forums for employee feedback such as employee advice sessions, internal surveys, and colleague discussions. These engagement activities are conducted multiple times each year", and "The Executive Board is accountable for managing the DE&I policy, with day-to-day management responsibilities delegated to the Group Risk Committee (GRC)" (page 252).

Effectiveness is assessed through surveys that "include questions about the DE&I policy and employees' perspectives on its effectiveness", plus Employee Resource Groups (page 252). The International Framework Agreement has a Monitoring Committee "comprising ABN AMRO and trade union representatives" (page 252). Non-employees have "a Supplier Conduct Feedback Channel" (page 252).

Reference: pages 253-254

The index lists ESRS S1 paragraphs 32(a) to 32(e) and 33 (page 196), and the EU-legislation table records "Grievance/complaints handling mechanisms – ESRS S1-3, paragraph 32 (c) – Material" (page 198).

Six named "speak-up channels" are set out on page 254:

• Inappropriate Behaviour Adviser, for "harassment, discrimination, bullying, aggression or violence", with "a zero-tolerance approach";
• Confidential Adviser Integrity, for those who "face challenging situations they cannot discuss with their line manager or colleagues";
• Whistleblowing channel, where "ABN AMRO's Whistleblower Policy protects employees against retaliation", and which "is also open to clients and third parties";
• Mediation Office, "an informal but structured process for voluntary and collaborative resolution of workplace conflicts";
• Employee Council Adviser, "a group of around 50 colleagues who serve as council members alongside their regular roles";
• Supplier grievance mechanisms for non-employees, since "the Supplier Code of Conduct requires a reporting mechanism for non-employees... to report incidents if necessary".

All six are open to internal and external employees. Awareness is tested: "In the Employee Engagement Survey, internal and external employees are asked if they understand how to report inappropriate behaviour", and the channels are communicated "through multiple internal platforms, including ABN AMRO's intranet, engagement surveys, e-learning modules and the collective labour agreement" (page 254).

Reference: pages 253-257

The index lists ESRS S1 paragraphs 37, 38(a) to 38(d), 39, 41 and 43, with ESRS 2 MDR-A paragraphs 68(a) to 68(e) (page 196).

Actions are organised around focus groups within ABN AMRO Netherlands (page 253):

• Women: "gender-sensitive job advertisements", interviews "conducted by both male and female interviewers", Women's Employee Resource Groups, and an annual review of "compensation practices to ensure that men and women receive equal pay for equal work".
• People with a migration background: a "Cultural Task Force, comprising directors and senior managers from minority ethnic backgrounds", the Diversity Network hosting "Diwali, Keti Koti and Ramadan Experience", and "cultural leadership training".
• People with occupational disabilities: the B-Able programme, with "social enterprises such as Onbeperkt aan de Slag and Ctalents".
• People with a refugee background: Reboot, where "Since 2017, ABN AMRO has helped 127 refugees find meaningful employment".
• Plus a Neurodiversity Network, the Pride+ Network (latest survey "conducted in 2025") and the Generational Compass.

DE&I training "is available digitally to all employees through ABN AMRO's Academy", with "modules on Unconscious Bias, Inclusive Banking, Gender, Culture, Neurodiversity and LGBTIQ+", reverse mentoring, and Start2lead required of "all new managers" (page 254).

An adverse effect is disclosed candidly: the April 2025 hiring freeze "impacted ABN AMRO's workforce composition", and "the pause of the B-Able programme between April and November resulted in 147 colleagues with occupational disabilities, compared with the long term target of 225", though "exceptions were made during the hiring freeze to allow B-Able and Reboot employees to continue entering the organisation" (page 257). No monetary resources are quantified.

Reference: page 257

The index lists ESRS S1 paragraphs 46 and 47(a), 47(b), 47(c), with ESRS 2 MDR-T paragraphs 80(a) to 80(j) (page 196).

Five measurable targets are set for ABN AMRO Netherlands (page 257): "Ensure at least 48% of the Extended Leadership Team are women"; "Target 35% of senior and middle management positions to be held by women"; "Set gender diversity targets for senior leadership positions within subsidiaries"; "Achieve 8% of senior management, and 9% of middle management with a migration background"; and "Support the participation of at least 225 people with an occupational disability" plus "Continue the annual hiring of 20 people with a refugee background".

Progress is reported against each, including where missed. "Women currently represent 34% of the Extended Leadership Team against a 48% ambition, with senior and middle management representation also below the 35% target. Cultural diversity targets were met at the middle-management level, while senior management offers opportunities for further improvement" (page 257). "the pause of the B-Able programme between April and November resulted in 147 colleagues with occupational disabilities, compared with the long term target of 225. In addition, we did not meet our annual target of hiring 20 people with a refugee background; the total remains 127, unchanged from 2024" (page 257).

Governance: targets "are approved by the management teams of the client units/functions before receiving final approval from the Executive Board and the Supervisory Board. Progress towards these targets is monitored annually" (page 257).

Forward position: "For the period 2026 to 2029... ABN AMRO aims to set new targets for gender representation and cultural diversity within Hay grades 12 to 15. Our previous gender targets were in place until the end of 2025" (page 257). Baseline values and base years are not printed alongside the targets.

Reference: pages 258-259

The index lists ESRS S1 paragraphs 50(a), 50(b)i-iii, 50(b), 50(c), 50(d)i-ii, 50(d), 50(e) and 50(f) (page 196).

Total headcount is 24,632 at 31 December 2025, by country "20,300 The Netherlands, 3,791 Rest of Europe, 245 USA, 168 Asia, 128 Rest of the world" (page 258). The basis is stated: "This figure reflects the actual number of employees as at 31 December 2025, without the use of assumptions or averages... it does not take into account contractual working hours but the actual number of employees" (page 258).

The infographic on page 258 presents gender diversity in headcount overall, for the Netherlands and for top management, a breakdown by contract type (permanent versus temporary and full-time versus part-time, each split by gender), and an age breakdown in six brackets, each with a 2024 comparative. Three gender categories are used: male, female, and "Other & unknown". [Individual values from that infographic are not reproduced here: the sub-charts are interleaved in the extracted text and cannot be attributed to a specific series with confidence, so the figures would not be safe to restate. They should be read from the printed page.]

Turnover is given in prose: outflow of 2,629 (2024: 2,213) at a rate of 11% (2024: 10%), where turnover "includes the total number of employees who left voluntarily, were dismissed, retired or passed away during service. To calculate the turnover rate, ABN AMRO used the headcount as at 31 December 2025" (pages 258-259).

Country disaggregation follows the 10% rule and applies only to the Netherlands: "ABN AMRO is required to report separately on the headcount and the breakdown in gender for countries representing at least 10% of the total number of employees (Netherlands)" (page 259). Contract-type methodology is stated: "the active number of employees is split by type of contract and then further split by gender" (page 259).

Comparability is qualified: "the figures presented in this section reflect a change driven by the acquisition of HAL, whose inclusion in our consolidated reporting has resulted in updated workforce totals and related breakdowns" (page 258). No employees-at-period-end headcount in full-time equivalents is given in the statements; "The total number of employees in FTEs is disclosed in our Financial performance section" (page 258).

Reference: page 259

The index lists ESRS S1 paragraphs 60(a), 60(b), 63(a) and 63(b), and places paragraph 60(c) in the transitional provisions column (page 196). The chapter confirms the partial claim: the quick-fix applies "regarding collective bargaining coverage in non-EEA countries" (page 251).

The consolidated figure is given: "ABN AMRO is required to report, at the consolidated level, the percentage of employees covered by a collective labour agreement (CLA)... The outcome of this metric is 93.17%. This percentage reflects that the Netherlands, Brazil, France, Germany and Belgium each have a CLA in place, and that the vast majority of our employees in these countries are covered by it" (page 259).

The country disaggregation follows: "For 2025, this applied only to the Netherlands... 97.58% of ABN AMRO's Dutch workforce are covered by a collective labour agreement and 99.76% of employees in the Netherlands are covered by workers' representatives. The percentages are similar to 2024, when the corresponding figures were 97.72% and 99.77%, respectively" (page 259).

Social dialogue structures are described: "In the Netherlands, we have various different works councils and an overarching Employee Council. Besides these works councils, we have established the European Staff Council (ESC). The ESC qualifies as a European Works Council and it represents ABN AMRO's Corporate Banking and Wealth Management staff in the Netherlands and in the other European countries where ABN AMRO has corporate banking and wealth management activities" (page 259).

What the phase-in removes is the non-EEA regional breakdown of coverage. The consolidated and Dutch figures are complete.

Reference: pages 257, 259

The index lists ESRS S1 paragraphs 66(a) and 66(b) under "Own workforce" (page 196).

Top management gender distribution is stated in prose, with the definition of the population: "For the gender diversity at the top management level (as defined in the ESRS), we split the employees in the Extended Leadership Team by gender (34% female and 66% male)" (page 259).

Progress against the gender target is reported as a shortfall rather than glossed: "Women currently represent 34% of the Extended Leadership Team against a 48% ambition, with senior and middle management representation also below the 35% target. Cultural diversity targets were met at the middle-management level, while senior management offers opportunities for further improvement" (page 257).

For age, the requirement is answered by the infographic on page 258, which presents an "Age breakdown of employees (in %)" across six brackets, "<24", "24-29", "30-39", "40-49", "50-59" and ">59", with a 2024 comparative. The methodology is stated: "For the age breakdown, active employees are split over six age brackets as in the infographic above" (page 259). [The individual bracket percentages are not reproduced here: in the extracted text the 2025 and 2024 series are interleaved and cannot be mapped to specific brackets with confidence. They should be read from the printed page.]

Two points a reader should note. The ESRS prescribes three age brackets, under 30, 30 to 50 and over 50; ABN AMRO's six-bracket presentation is more granular but is not expressed in the prescribed form, so the prescribed figures have to be derived by aggregation. And the age data is presented as percentages rather than headcounts.

Reference: page 260

The index lists ESRS S1 paragraphs 74(a) to 74(e) under "Own workforce" (page 196).

The disclosure is a complete nil-exception return: "At ABN AMRO, all employees are fully covered by social protection – either through national legislation or benefits provided by ABN AMRO. This coverage safeguards employees against loss of income due to major life events, including sickness, unemployment (from the start of employment), employment injury and acquired disability, parental leave and retirement" (page 260).

That names all five events the standard asks about – sickness, unemployment from the start of employment, employment injury and acquired disability, parental leave, and retirement – and reports full coverage against each, so no breakdown by country of employees not covered is required. The source of coverage is identified for each case as either national legislation or benefits the bank itself provides, which is the distinction the requirement turns on.

The statement is made group-wide rather than country by country. Given a workforce of 24,632 spread across the Netherlands (20,300), the rest of Europe (3,791), the USA (245), Asia (168) and the rest of the world (128) (page 258), a reader cannot see which jurisdictions rely on statutory schemes and which on bank-provided benefits, but the reported outcome leaves no uncovered population to disaggregate.

Reference: pages 258-259

The index lists ESRS S1 paragraph 79 under "Own workforce" (page 196).

The metric is reported with its comparative: "Employees with occupational disability 1%" for both years in the metrics panel, footnoted precisely as "Employees with occupational disability for 2025 decreased to 0.72% compared with 0.79% in 2024" (page 258).

Scope and calculation basis are disclosed: "The percentage of employees with occupational disabilities includes only those within ABN AMRO Netherlands. We plan to include data from entities outside the Netherlands, subject to legal restrictions on data collection in those countries in the short term. To calculate the percentage of employees with a disability, the number of disabled employees are divided by the total number of active internal employees (within ABN AMRO Netherlands) and multiplied by 100" (page 259).

The underlying headcount appears elsewhere in the chapter: the B-Able pause between April and November 2025 "resulted in 147 colleagues with occupational disabilities, compared with the long term target of 225" (page 257), against a standing target to "Support the participation of at least 225 people with an occupational disability" (page 257).

So the figure covers roughly 82% of the workforce by headcount (20,300 of 24,632, page 258) rather than the full group, and the bank gives its reason: legal restrictions on collecting disability data outside the Netherlands.

Reference: pages 259-260

The index lists ESRS S1 paragraph 83(a) and places paragraph 83(b) in the transitional provisions column (page 196). The chapter is explicit: "For these metrics we have applied the quick-fix, meaning we only provide a partial disclosure relating to training below on a voluntary basis" (page 259); page 251 confirms it applies to "average number of training hours by gender".

Performance review coverage is reported with a gender split: "Currently, 95.6% of our employees (95.3% male, 95.9% female and 100% undefined [other & unknown]) have registered their objectives in Talent2Grow... The figures for 2025 have improved slightly compared with the previous year: in 2024 92.7% of our employees had registered their objectives (male: 92.4%, female: 93.1% and undefined [other & unknown]: 97.6%)" (page 260).

Average training hours are split by course type: "For 2025, the average number of hours spent on training was 8.05 hours per employee. This figure can be split to 5.15 study hours per employee spent on mandatory courses and 2.9 hours spent on SHARP" (page 259). The metrics panel shows 8 hours for 2025 against 7 for 2024 (page 258). Basis: "We calculate the average number of study hours for all active internal employees based on all completed courses and information regarding the study hours per course" (page 259).

The system is named: "'Together & Better' applies to most internal employees worldwide, though some subsidiaries follow their own performance management processes" (page 259).

What the quick-fix removes is the gender split of training hours; the review-coverage metric is itself split by gender, so the omission is confined to that one limb.

Reference: page 260

The index lists ESRS S1 paragraphs 93(a) and 94, and places paragraph 93(b) in the transitional provisions column (page 196).

The chapter states the position plainly: "Work-life balance refers to the percentage of employees within ABN AMRO who are entitled to take family-related leave. This is 100% as it is included in national legislation and/or included in the benefits provided by ABN AMRO to its employees. For this metric, we applied the phase-in in 2024, and the quick-fix in 2025. This means that we have included a partial disclosure on a voluntary basis" (page 260). Page 251 confirms the quick-fix covers "percentage of employees that took an entitlement to family-related leave".

So the entitlement limb is answered in full and without exception, and the source of the entitlement is identified as national legislation or bank-provided benefits. The accompanying social protection disclosure reinforces it, listing parental leave among the events against which "all employees are fully covered" (page 260).

What the quick-fix removes is the second limb: the percentage of entitled employees who actually took family-related leave, and its breakdown by gender. Neither is reported, and the bank flags this as why its disclosure is partial. The omission is declared rather than silent, and it is the take-up rate that is missing, not the entitlement.

Reference: page 260

The index lists ESRS S1 paragraphs 97(a), 97(b) and 97(c) (page 196). The EU-legislation table marks "Unadjusted gender pay gap – ESRS S1-16, paragraph 97 (a)" and "Excessive CEO pay ratio – ESRS S1-16, paragraph 97 (b)" both "Material" (page 198).

Both metrics are reported with comparatives: "In 2024, ABN AMRO reported a remuneration ratio of 12; for the current reporting year, this has increased to 13. The gender pay gap has also increased, rising from 16% last year to 18% in the current reporting year" (page 260).

Both definitions are given, including that the gender pay gap "is calculated by dividing the difference between the average gross hourly pay level of male employees and the average gross hourly pay level of female employees by the average gross hourly pay level of male employees and multiplied by 100%" (page 260).

The deterioration is explained rather than left bare: "This development can be explained by two changes. First, improvements were made to the calculation by adding several components – including pension contributions for the Netherlands – which were not part of last year's calculation. The second change relates to the inclusion of HAL employees, who became part of ABN AMRO on 1 July 2025" (page 260). Footnoted caveats add that the new CEO "was appointed in March; therefore, her included remuneration does not cover a full year" (page 260).

The reconciliation is flagged: these figures "differ from the figures presented in our Remuneration report... due to the difference in methodology used in the Sustainability Statements (which are aligned with the ESRS)" (page 260). Remedial intent: "To address the pay gap, ABN AMRO is focusing on increasing gender diversity at higher job levels" (page 260).

Reference: pages 260-261

The index lists ESRS S1 paragraphs 103(a) to 103(d) and 104(a), 104(b) (page 196). The EU-legislation table marks "Incidents of discrimination – ESRS S1-17, paragraph 103 (a)" and "Non-respect of UNGPs on Business and Human Rights and OECD – ESRS S1-17, paragraph 104 (a)" both "Material" (page 198).

Incident counts are given with a comparative: "In 2025, ABN AMRO recorded a total of 15 incidents related to discrimination and harassment, which were handled by HR Labour Affairs. This is higher compared with 2024, when 7 incidents were recorded and handled. In addition, HAL identified 2 incidents in 2025; HAL dealt with them internally, as it had not yet been integrated into ABN AMRO's HR Labour Affairs channels during the reporting year" (page 260).

The boundary of the count is disclosed rather than glossed: "Until this process is fully implemented, the reported incidents for 2025 only include those registered with HR Labour Affairs. Consequently, the total number of incidents reported through the 'speak-up channels' in 2025 is not disclosed here. ABN AMRO is formalising the governance process for its speak-up channels, with the aim of full implementation in the coming years" (pages 260-261). So the 15 is a subset of all reported concerns, and the bank says so twice.

The remaining limbs are nil returns: "Similar to 2024, ABN AMRO did not receive any complaints through the National Contact Points for OECD Multinational Enterprises in 2025. Furthermore, there were no significant fines, penalties or compensations for damages resulting from violations related to social and human rights issues. In 2025, ABN AMRO did not register any severe human rights violations, including non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration... or the OECD Guidelines" (page 261).

Reference: pages 267-268

The index lists ESRS G1 paragraph 18 – procedures to prevent, detect and address allegations or incidents of corruption and bribery, including separation of investigators and reporting outcomes to the bodies – under "Business conduct" (page 196).

The risk is scoped to six types: "Money Laundering, Financing of Terrorism, Bribery & Corruption, Tax Evasion, Fraud and Sanction Circumvention" (page 267). Five policies implement it: the CAAML Policy, the Anti-Bribery and Corruption (ABC) Policy ("aims to protect ABN AMRO from any direct or indirect involvement in bribery or corruption and sets the framework for managing bank-wide bribery and corruption risks", describing "several bribery and corruption risk indicators (e.g. adverse media)"), the Tax Policy, the Fraud Risk Policy and the Sanctions Policy (pages 267-268). "All policies apply globally to all ABN AMRO entities", and the ABC Policy is "available on our website" (page 268).

Separation of duties and reporting lines: "risk governance follows the three lines of defence principle"; "the Chief Risk Officer (CRO) [is accountable] for the ABC and Fraud Risk Policies"; and "The Risk & Capital Committee (R&CC) receives quarterly updates on the activities of Detecting Financial Crime (DFC)" (page 268).

The detection system: DFC, established 2019, runs a client lifecycle of onboarding, ongoing due diligence and exit, reviewing clients "every 1 to 5 years, depending on the client's risk score"; flagged risks trigger "an event-driven review (EDR)", unacceptable risks "may lead ABN AMRO to exit the client relationship", all "supported by a yearly Systematic Integrity Risk Analysis (SIRA)" (page 268).

Training is tabulated: four mandatory all-staff e-learnings – tax awareness (25 min), gatekeeper role (60 min), risk refresher (90 min, yearly) and Anti-Bribery and Corruption (60 min, every 3 years) – each at 99% coverage at December 2025, with HAL excluded (page 268). The percentage of functions at risk covered, and training given to the boards, are not separately reported.

Reference: pages 196, 268 (renumbered, part of MDR-T/GDR-T disclosures)

The statement was prepared under the 2023 ESRS (page 194), in which business conduct targets fell under ESRS 2 MDR-T rather than a numbered G1 targets DR. The index routes them that way, and distinctively: the "Business conduct" row lists ESRS 2 paragraphs 81(b)i, 81(b)ii and 81(b) – MDR-T's provision for an undertaking that has not set measurable outcome-oriented targets and must instead disclose whether it nevertheless tracks effectiveness, through what processes, and against what level of ambition and indicators. Every other material chapter (Climate, Own workforce) is given paragraphs 80(a) to 80(j), the full target disclosure. Only Business conduct is given the no-target limb (page 196).

So ABN AMRO sets no business conduct target, and the effectiveness-tracking limb is what it reports instead.

Processes. "The Risk & Capital Committee (R&CC) maintains a focus on compliance-related matters and oversees the integration of ESG risks (e.g. CI) into the bank's risk control framework. The R&CC receives quarterly updates on the activities of Detecting Financial Crime (DFC)" (page 268). The client lifecycle supplies the operational cycle: periodic review "every 1 to 5 years, depending on the client's risk score", transaction and client monitoring and filtering, event-driven reviews, and client exit, "supported by a yearly Systematic Integrity Risk Analysis (SIRA)" (page 268).

Indicators. Training coverage is the one quantified indicator, at 99% for each of the four mandatory Client Integrity e-learnings at December 2025, caveated because "Percentages may fluctuate throughout the year" and HAL employees are excluded (page 268).

Level of ambition. Qualitative only: "ABN AMRO's focus is on the effectiveness of our monitoring processes and the quality of client due diligence" (page 268). No base period from which progress is measured is given, which is the part of paragraph 81(b)ii left unanswered.

Supervisory pressure is disclosed alongside: "DNB has indicated that these shortcomings may lead to enforcement measures. A potential financial impact cannot be reliably estimated, and no provision has been recorded" (page 268).

Reference: pages 196, 268

The index lists ESRS G1 paragraphs 24, 25(a), 25(b) and 25(c) under "Business conduct" (page 196) – the mandatory convictions and fines limb plus three voluntary limbs on confirmed incidents, dismissals and terminated business-partner contracts.

What the chapter contains. The Business conduct chapter runs to two pages (267-268) and prints no number of convictions, no amount of fines for violation of anti-corruption or anti-bribery laws, and no count of confirmed incidents. A full-text search of the Sustainability Statements and the ESG Annex returns no such figure; the words "convictions" and "confirmed incidents" do not appear in the report.

The EU-legislation datapoint table is consistent with that absence, marking both derived datapoints "Not material – Not included": "Fines for violation of anti-corruption and anti-bribery laws – ESRS G1-4, paragraph 24 (a)" and "Standards of anti-corruption and anti-bribery – ESRS G1-4, paragraph 24 (b)" (page 199). Those two entries cut against the chapter table's listing of paragraph 24, and the two tables are hard to reconcile.

What is disclosed instead. Actions to address breaches, the paragraph 24(b) limb, are qualitative: event-driven reviews where risks are flagged, and client exit, since "Unacceptable CI risks (e.g. fraud, money laundering) may lead ABN AMRO to exit the client relationship. This is done only after thorough investigation and in accordance with legal requirements" (page 268).

The one concrete matter is supervisory rather than a conviction: "DNB continues to monitor progress and provides observations, such as previously identified shortcomings in ABN AMRO's EDR process. DNB has indicated that these shortcomings may lead to enforcement measures. A potential financial impact cannot be reliably estimated, and no provision has been recorded" (page 268).

Marked reported on the strength of the index's own datapoint list, but the quantitative core of G1-4 is not in the document.