Achmea B.V.

Reference: page 71

Sustainability is embedded in Achmea's governance. The Executive Board holds ultimate responsibility for strategy including sustainability; its members are collectively accountable, while each member is individually responsible for implementation within the business units they oversee. The Supervisory Board oversees and advises the Executive Board and has discussed sustainability as part of strategy, including responsible investments and ESG in underwriting. The Executive Board has mandated the Programme board of the 'Achmea Sustainable Together' programme, chaired by an Executive Board member, to implement the sustainability strategy through workstreams. A group-level Sustainability department and ESG officers in foreign operating companies support this. Major shareholders are Vereniging Achmea, the not-for-profit association representing all customer members and the largest shareholder, and Rabobank. On board composition (page 117 disclosures), the Executive Board of Achmea B.V. is 50% male and 50% female (three each), and the Supervisory Board is 67% male and 33% female, with 67% of members considered independent.

Reference: page 75

In 2024 the Executive Board and the Supervisory Board with its committees discussed several sustainability topics, including sustainability reporting and the updated Climate Transition Plan, drafts of the sustainability statements and the ESG presentation, the updated Double Materiality Assessment and material topics, the remuneration policy element related to sustainability, sustainability commitments, sustainability risks, liability risks linked to ESG legislation, the Systematic Integrity Risk Analysis, responsible investing including fossil fuel investment policy, ESG integration in underwriting, and diversity and inclusion. Each quarter business units report financial and non-financial performance indicators to the Executive Board, followed by performance dialogues with the responsible board members. Performance dialogues on key sustainability topics take place within the Programme board of 'Achmea Sustainable Together', which then reports outcomes and key points to the Executive Board. The revised DMA outcome forms the basis for the strategic sustainability priorities set by the Executive Board for 2024.

Reference: page 73

Achmea applies a controlled and sustainable remuneration policy designed to prevent undesirable incentives, supporting management based on stakeholder value management (SVM) that creates value for customers, employees, partners, shareholders and society. Pursuing sustainability objectives and managing sustainability risks are integral parts of every role and included in the standard remuneration system. Where relevant, teams have specific sustainability objectives, and variable remuneration is partly linked to them through sustainability KPIs added to the SVM card. Variable remuneration is capped at the Dutch legal maximum of 20% of fixed annual salary, or 100% for staff working abroad, with stricter deferral rules for risk-takers and senior management. In 2024 the sustainability targets relevant for Executive Board performance covered environmental goals (reducing greenhouse gas emissions from buildings, investments and the retail motor portfolio), social Impact programmes, and governance (increasing gender diversity in top and senior management). The Supervisory Board oversees the policy, advised by its Remuneration Committee.

Reference: page 71

Achmea describes its ESG due diligence process for identifying actual and potential negative impacts on human rights and the environment when providing financial services, contracting suppliers and investing. The approach follows seven actions: integrating due diligence into policies, identifying actual or potential negative impacts, preventing and mitigating potential impacts, addressing and minimising actual impacts, establishing and maintaining a complaints procedure, monitoring effectiveness, and communicating publicly. The approach varies by role. In underwriting, due diligence focuses on preventing financial crime through customer due diligence, with an aim to implement environmental and human rights due diligence for large corporate clients in the Netherlands by 2025. In procurement, sustainability criteria are standard and EcoVadis is used in the Netherlands to assess impactful suppliers, with contract termination considered if scores remain below threshold after two years. In investments, companies are assessed against UN Global Compact principles. The content index maps the GOV-4 due diligence statement to Annex A, Approach to sustainability reporting.

Reference: page 76

Sustainability risks are integrated into Achmea's Integrated Governance, Risk Management and Compliance (IGRC) system, built on Governance, Policy, Risk Appetite, Tools and Techniques, Systems and Data, and People, culture and awareness. Governance uses the Three Lines model and risk committees with key functions such as risk management, compliance, actuarial services and internal audit. Sustainability risk is defined as the risk of a negative effect on financial results, capital or reputation arising from environmental, social or governance events, with separate E, S and G definitions provided. Sustainability risks are embedded in regular strategic risk analyses, with thresholds aligned to risk appetite. Key sustainability-related risks identified at group level are failure to achieve sustainability targets, natural disasters, and volatility on financial markets. Specific analyses include ESG risk analysis (aligned with the DMA), climate change risk analysis within the Own Risk and Solvency Assessment, and a DNB-approved partial internal model for windstorm, hail and flooding. The mandatory e-learning 'Sustainability according to Achmea' supports risk awareness. The content index maps GOV-5 internal controls over sustainability reporting to Annex A.

Reference: page 55

Guided by its vision 'Sustainable Living. Together', Achmea is a financial service provider offering insurance in property (non-life), health, life and income segments, plus financing and asset management, serving private and business customers across sectors such as agriculture, real estate, construction and professional services. It also provides pension and collective healthcare services to large companies and asset management primarily for Dutch pension funds. Achmea Bank attracts savings and provides residential mortgages. Most revenue comes from financial services and insurance. Besides its Dutch home market, Achmea is active in Greece, Turkiye, Slovakia, Germany, Spain and Australia. It employs almost 16,000 internal staff, over 12,500 in the Netherlands. The business model combines diversified financial services with a multi-brand, multi-distribution strategy emphasising digitalisation and social impact, operating under brands including Zilveren Kruis, Centraal Beheer, Interpolis and FBTO, and collaborating closely with Rabobank. Sustainability activities are grouped into Own operations, Insurance and services, and Investments and financing, with a 2024 group-wide Sustainability Policy Framework.

Reference: page 60

Achmea engages with various stakeholder groups, including customers, employees, shareholders and business partners, and also with parties outside its value chain such as societal organisations, interest groups and regulators. Customers have direct contact through call centres, customer councils, panels, policyholder councils, roundtables and online surveys, and a voice through the Members' council of Vereniging Achmea, the not-for-profit association of which all Achmea customers are automatically members and which, as the largest shareholder, advocates collective customer interests and safeguards continuity. The Members' council meets three times a year with the association board and Executive Board, with thematic working groups in 2024 on claims and sustainability, the new pension system, and entitlement to care. Employees are engaged via team meetings, managers, works councils, the Central Works Council, trade unions on the collective labour agreement, and an annual engagement survey conducted in the Netherlands and in Australia, Greece, Slovakia and Turkiye. Shareholder contacts with Vereniging Achmea and Rabobank are embedded in formal governance. Business relations engage through bilateral meetings and 'De Kamer'.

Reference: page 65

Through its double materiality assessment Achmea identified fourteen material topics, mapping impact materiality (inside-out) and financial materiality (outside-in). The environmental topics are climate change mitigation and adaptation (ESRS E1), pollution of water and soil (ESRS E2), biodiversity (ESRS E4), and resource inflows and waste (ESRS E5). The social topics are responsible employer practices covering own workforce (ESRS S1), working conditions in the value chain (ESRS S2), and responsible relationships with consumers and end-users covering access to quality information, responsible advertising practices, access to products and services, and privacy of customers' personal data (ESRS S4). The governance topics are corporate culture and prevention of corruption and bribery (ESRS G1), plus the entity-specific topic Data and cybersecurity. Water (ESRS E3) and affected communities (ESRS S3) were assessed and found not material. The report describes the impacts, risks and opportunities for each topic, distinguishing actual and potential effects and noting whether risks and opportunities are material, and links each to strategy and vision.

Reference: page 62

This is the first year Achmea conducted its double materiality assessment in accordance with CSRD requirements, building on the 2023 analysis and reassessing the relevance of sustainability topics from impact materiality (inside-out) and financial materiality (outside-in) perspectives, including foreign operations. The process followed six steps: reassessing the prior DMA process note and material topics from a list of 110 potential topics; compiling a longlist of 20 potential topics through peer studies and internal stakeholder discussions; assessing the value chain and identifying internal and external stakeholders; clustering and refining to a shortlist of fourteen potential topics and their related IROs, then asking business units to specify the IROs; assessing impacts as positive or negative and actual or potential over short, medium and long term, and evaluating financial risks and opportunities; and applying thresholds aligned with risk appetite. An impact scoring at least 1.8 of 5 was deemed material, and financial materiality required at least 2.2 of 5. All fourteen assessed topics scored above the thresholds. Results were validated by the Programme board, the Executive Board, and discussed by the Supervisory Board, with external stakeholders consulted.

Reference: page 208

In line with ESRS 2 IRO-2, Annex F provides a content index showing where the relevant ESRS disclosure requirements are located in the sustainability report. The index covers ESRS 2 general disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and the minimum disclosure requirements for policies, actions, metrics and targets (MDR-P, MDR-A, MDR-M, MDR-T), pointing to the relevant topical chapters and annexes. It also maps the topical standards for the material topics (E1, E2, E4, E5, S1, S2, S4, G1 and the entity-specific Data and cybersecurity). The index identifies disclosure requirements that are being phased in under ESRS 1 Appendix C, notably the anticipated financial effects disclosures E1-9, E2-6, E4-6 and E5-6. A separate index of the ESRS 2 Appendix B data points lists each cross-cutting and thematic data point and its location, including where requirements are not material or being phased in. As 2024 is Achmea's first CSRD year, value chain information is addressed during the phase-in period.

Reference: page 80

Achmea is committed to the Paris Agreement and aims to align its activities with a 1.5C pathway. As required by the Climate Commitment of the Dutch financial sector, it published its first Climate Transition Plan in 2022, with updates in 2023 and 2024, approved by the Executive Board. The plan focuses on reducing the CO2e emissions of investments and financing, promoting sustainable projects, and investing in green technologies. Achmea targets net zero emissions in its own operations by 2030 (with a 48% gross reduction for Dutch operations by end 2024 versus 2019), a net zero insurance portfolio by 2050, net zero for corporate investments (own risk and policyholder) by 2040, and net zero for government bonds, mortgages, banking loans and investment property by 2050. It is a member of the Forum for Insurance Transition to Net Zero (FIT) and provided feedback on the draft SBTi standard for financial institutions.

Reference: page 86

Achmea integrates climate into multiple policies. For insurance it is a signatory of the Principles for Sustainable Insurance (PSI) and applies an ESG underwriting policy for Dutch commercial clients (established 2024) excluding certain activities, plus a Product Approval and Review Process (PARP) policy. In healthcare it follows the Dutch Green Deal Sustainable Healthcare 3.0. For investments its Socially Responsible Investment (SRI) policy covers thematic policy, exclusion policy, due diligence policy and engagement guidelines, based on the UN Global Compact, UNGPs, ILO conventions and OECD guidelines. The strict exclusion policy bars companies deriving more than 1% of revenue from coal, tar sands, shale or Arctic oil and gas, and more than 5% from thermal coal electricity. Voting is exercised through ISS, supporting climate resolutions. Mortgage and investment property activities are governed by the SRI policy, mortgage acceptance policy and Achmea Real Estate ESG strategy.

Reference: page 86

Achmea pursues a five-pillar climate mitigation action plan for corporate investments: engaging companies toward net zero, exercising voting rights, excluding companies with inadequate climate policies, excluding the most polluting fossil fuel companies, and investing in the energy transition including green bonds. In 2023 it launched an engagement program with ten high-emission companies and engages ten oil and gas companies through the Dutch Climate Coalition. In 2024 it tightened the fossil fuel exclusion policy, adding 199 companies. Green corporate bonds reached 13% of the corporate bond portfolio. For insurance it engages customers (target 25% of commercial portfolio by 2025, 50% by 2030), offers EV insurance and flood cover, and joined PCAF methodology work. Mortgage and real estate actions include green loans, insulation, solar panels, heat pumps, energy label improvements, and around 19 million euro budgeted for sustainable renovations in 2024-2029.

Reference: page 100

Achmea's reduction targets are aligned with the Paris Agreement and a 1.5C pathway. For corporate investments (own risk and policyholder) it targets a 32% reduction in financed emissions by 2025 and 68% by 2030 versus the 2020 market benchmark, reaching net zero by 2040; emissions were already 57% below the 2020 benchmark in 2024. Achmea Investment Management funds target a 50% reduction by 2030 and net zero by 2050. Mortgages and banking loans aim for a 33% CO2 reduction by 2030 versus 2022 (interim 18.0 kg CO2/m2), net zero by 2050. Investment property targets at least 55% reduction by 2030 versus 1990 (achieving 63% in 2024) and net zero by 2050. The Dutch retail motor insurance portfolio targets a 15-20% reduction in emissions per kilometer by 2030 versus 2021. Government bonds target net zero by 2050.

Reference: page 163

Achmea reports its consolidated GHG footprint in Annex C, Table 1. For 2024 gross Scope 1 emissions were 8,923 tCO2e and gross Scope 2 emissions were 10,627 tCO2e location-based and 1,789 tCO2e market-based, against a 2019 base year. Total gross indirect Scope 3 emissions were 6,858,794 tCO2e, dominated by financed and insurance-associated emissions: financed emissions (own risk and policyholder) of 2,773,890 tCO2e, financed emissions from Assets under Management of 1,416,000 tCO2e, insured emissions from non-life insurance of 254,995 tCO2e, and insured emissions from health (NSLT) insurance of 2,397,165 tCO2e, plus operational Scope 3 categories such as employee commuting (9,347) and business travel (3,279). Total GHG emissions were 6,878,344 tCO2e location-based and 6,869,506 tCO2e market-based, up 182% versus 2023 mainly due to newly included health insurance and Assets under Management emissions.

Reference: page 103

As the largest health insurer in the Netherlands, Achmea manages pollution of water and soil mainly through its health insurance value chain, where pharmaceutical residues from medication use reach groundwater and surface water. Its strategy is anchored in the Green Deal Sustainable Healthcare 3.0, linked to the Approach to Medication Residues in Water. Working with other Dutch health insurers, Achmea developed an Implementation Plan for Dutch Health Insurers covering procurement policy, raising awareness among insured individuals, and sustainability criteria for procuring preferred medicines. In 2024 it developed a national uniform procurement policy for 2025, aligned with the Green Deal and aimed at pharmacists, hospitals and mental healthcare. Zilveren Kruis's procurement policy refers to this national policy, published on its website on 1 April 2024. No specific policies exist yet for international operations.

Reference: page 104

In 2024 Achmea developed a national uniform procurement policy for 2025 in collaboration with other Dutch health insurers, intended to reduce medication use and waste. Important elements include minimising waste through appropriate prescribing, informing patients about the disposal of unused medicines, advising on timely medication reduction, prescribing environmentally friendlier options such as powdered inhalers, and advocating non-pharmacological interventions with general practitioners. Hospitals are expected to implement plans to reduce medicine waste and overuse. Methods for measuring the reduction of medication use and waste within the sector still need to be established. By the end of 2026 Achmea aims to understand the environmental impacts of medicines within the sector. Senior management in the Dutch Healthcare division oversees implementation. Financial resources are currently part of regular business operations; future resources are yet to be determined.

Reference: page 104

The Green Deal Sustainable Healthcare 3.0 formulates fundamental goals for sustainable healthcare, but many goals are not sufficiently measurable or lack baseline measurements. The Ministry of Health, Welfare and Sport is currently setting up the monitoring framework for the Green Deal, and KPIs and objectives will be established in conjunction with this. Within the Implementation Plan for Dutch Health Insurers, mental healthcare insurers aim for a reduction in medication use and waste, with a target of 20% for medicine waste by 2026 compared to 2023. By the end of 2026 Achmea aims to have developed an understanding of the environmental impacts of medicines within the sector, working with the Dutch health insurers. The methods for measuring the reduction of medication use and waste within the sector still need to be established.

Reference: page 106

As a financial service provider Achmea has limited direct impact on biodiversity; its main impact arises downstream through insurance and investment activities, where insured companies and investees may depend on or harm ecosystems. Achmea recognises the urgent need to address biodiversity loss and wants to contribute to conservation and restoration through its insurance and investment portfolios. Assessing the impacts, risks and opportunities of these portfolios in more detail is described as an important initial step in developing a transition plan and biodiversity policies, including potential biodiversity offsets. Because it is currently in this first phase, Achmea has not formulated a transition plan or policies yet. In 2025 it aims to develop a groupwide biodiversity policy framework for an overarching approach, to be incorporated into the Achmea sustainability policy framework and used as the basis for further development of biodiversity policies.

Reference: page 107

Achmea has included biodiversity in its existing investment policy. In its Socially Responsible Investment (SRI) policy, Nature & Environment is one of the themes, focusing on the preservation and improvement of biodiversity, preventing degradation in highly vulnerable ecosystems, preventing serious soil pollution, and avoiding irresponsible management of agricultural land. Asset managers integrate ESG factors such as toxic emissions and waste, water stress, and biodiversity and land use into investment analyses and decisions. The SRI policy also contains an exclusion policy for companies and countries, considering the impact of behaviour on society and the environment, severity, scale, irreversibility and likelihood. For insurance, Achmea is a member of two Principles for Sustainable Insurance working groups on Nature-Positive Insurance and committed to the Finance for Biodiversity Pledge in 2021. A groupwide biodiversity policy framework is planned for 2025.

Reference: page 108

Achmea states it is in the initial stages of this topic and does not have a list of key actions taken in 2024, but has established initiation and monitoring activities for 2025. Through Achmea Investment Management it engages with companies via normative and thematic programmes, exercises voting on shareholder proposals related to biodiversity, pollution and land use, and participates in collective initiatives including Nature Action 100, PRI Spring and the FAIRR Protein Diversification Engagement. It contributes to the Hagelunie Innovation Fund supporting agriculture and horticulture, including biodiversity strips at greenhouse companies, and supports installation of green roofs. Planned 2025 actions include preliminary assessments of insurance and own-risk investment portfolios using TNFD LEAP, the ENCORE database, Iceberg Data Lab data, and reporting biodiversity footprints in the SRI report. Employees in the sustainability transition will receive biodiversity training by the end of 2025.

Reference: page 108

Achmea states that, as it is still in the initial stages of this topic, it is in the process of developing metrics and targets. By signing the Finance for Biodiversity Pledge, Achmea Investment Management committed to establishing objectives by 2024 and reporting on them in 2025. As a portfolio activity for 2025, Achmea will formulate targets by the end of 2025 at the latest to reduce the biodiversity footprint of its equity and corporate bond funds. Initial assessments of the insurance and own-risk investment portfolios are planned to serve as the basis for establishing further actions and targets. Within the SRI investment theme Nature & Environment, current objectives are aimed at preventing degradation of biodiversity in highly vulnerable ecosystems, preventing serious soil pollution, and avoiding irresponsible management of agricultural land.

Reference: page 108

Achmea states that currently no metrics are used to monitor the effectiveness of actions to manage this material topic, and metrics are not validated by an external party, as it is still in the initial stages. It has, however, defined monitoring activities for 2025. It will report on the biodiversity footprint, measured in square kilometres of average species richness, of the Achmea Investment Management investment funds covering listed equities and corporate bonds in the SRI report. The impact of the corporate investment portfolio will be evaluated using data from Iceberg Data Lab, and Achmea will report annually on the biodiversity footprint, in square kilometres of average species abundance, of its own-risk investments in the annual report and SRI report. It will also monitor high-risk sectors for involvement in deforestation, following TNFD recommendations.

Reference: page 111

Resource inflows and waste is material for Achmea's health insurance activities, where high consumption of pharmaceuticals, medical equipment and personal protective equipment places pressure on the environment; the impact for non-life insurance was assessed as non-material. Achmea's strategy is anchored in the Green Deal Sustainable Healthcare 3.0, aimed at green and climate-neutral healthcare and efficient circular use of resources, moving from a throwaway culture toward reuse. In its procurement policy Achmea expects healthcare providers to commit to the actions established by their industry organisation under the Green Deal. Zilveren Kruis's procurement policy refers to the national uniform procurement policy for all types of healthcare, published on its website on 1 April 2024. Senior management of the Dutch Healthcare division oversees achievement of these goals. No specific policies exist yet for international operations.

Reference: page 112

In 2024 Achmea investigated how health insurers and care administration offices can jointly establish sustainability criteria for procurement contracts with suppliers of medical devices. Through its procurement policy it focused on reducing waste and promoting reuse by healthcare providers, particularly regarding medical devices, food and medicines. Where regulations could hinder these initiatives, Achmea advocated for adjustments to the regulations. It also contributed to a sector initiative encouraging healthcare providers to reduce resource use when acquiring medical devices. In 2025 and beyond, Achmea will work with other Dutch health insurers on the further development of actions arising from the Implementation Plan for Dutch Health Insurers. Currently the financial resources allocated for these actions are part of regular business operations, and future resources linked to these actions still need to be determined.

Reference: page 111

In line with national objectives under the Green Deal Sustainable Healthcare 3.0, Dutch health insurers aim to reduce primary resource consumption and promote circular healthcare. By 2030 they aim to reduce primary resource consumption by 50% compared to 2016, and to limit unsorted residual waste in healthcare to a maximum of 25% by 2030, with the ultimate goal of maximum circular healthcare by 2050. These objectives are reflected in the Implementation Plan for Dutch Health Insurers, with targets for 2026: 25% less unsorted residual waste compared to 2018, a 20% reuse rate for medical devices, 5% fewer purchased incontinence medical devices compared to 2022, and a 20% reduction in primary resource consumption of procured healthcare compared to 2016. The Ministry of Health is establishing the monitoring framework, with KPIs to be determined accordingly.

Reference: page 111

Resource inflows in the healthcare insurance value chain are significant due to high consumption of materials such as pharmaceuticals, medical equipment and personal protective equipment. Scarce resources, such as minerals needed for chips in medical devices, require careful management to minimise their inflow. In the Netherlands, the healthcare sector accounts for 13% of the national consumption footprint for abiotic (non-living) resources. Achmea has established, based on research under the Green Deal Sustainable Healthcare 3.0 and expert judgment, that resource inflow is material for its health insurance activities; it has not conducted its own screening and will reassess as more value chain data becomes available. Because the impact lies within its value chain and information is still limited, Achmea has not obtained all information on upstream and downstream activities, so its management approach is still under development.

Reference: page 117

Achmea is developing a People strategy built on its 'Sustainable Living. Together' vision, aimed at recruiting, developing, deploying and retaining talent in a safe and healthy workplace. Several policies cover the own workforce: the Achmea General code of conduct, the 1-Achmea policy for an inclusive environment with equal opportunities, a separate ID&E policy for the Executive Board and Supervisory Board, learning and development policies, work-life balance policies, the Whistleblower policy, the policy on undesirable behaviour, the confidential advisor policy and the Risk Inventory and Evaluation (RI&E) and Psychosocial Workload (PSA) policies. Achmea commits to human and labour rights aligned with the UDHR, ICCPR, ICESCR, ILO core conventions, the OECD Guidelines and the UN Guiding Principles, and joined the UN Global Compact in 2024. A specific gender equality and equal pay policy is scheduled for 2025.

Reference: page 118

Achmea involves employees in developing, implementing and evaluating its policies. Employees provide feedback through the annual Employee Engagement Survey (Medewerker Betrokkenheidsonderzoek, MBO), whose results are discussed in teams to jointly determine improvement actions, with employees informed how their feedback shaped decisions. Social dialogue takes place individually in regular manager and employee meetings and collectively with employee representation bodies such as the Works Council (OR) and labour unions. In the Netherlands meetings with labour unions cover working conditions and the social plan, and both union members and non-members help set the agenda for the Collective Labour Agreement negotiations. Communication channels include the intranet and Microsoft Viva Engage. Achmea notes it does not consult employees specifically on setting or monitoring the targets in this chapter, but remains open to feedback. Employee perspectives also feed in through diversity networks.

Reference: page 117

Achmea offers multiple channels for raising concerns and remediating negative impacts. Anyone working for Achmea can report suspected wrongdoing through the Whistleblower policy, with reports made to an internal or external confidential advisor, handled confidentially and protecting the reporter. Employees can also use the Achmea General code of conduct procedures, the policy on undesirable behaviour, the confidential advisor policy, customer-aggression procedures and a general individual complaint procedure under the social plan. Employees who file complaints suffer no adverse consequences. Concerns can be raised via line managers, HR, diversity networks, confidential advisors and the 'Speak Up' page. The Executive Board annually receives a report on the number of complaints and issues raised. Complaints about unwanted behaviour go to the Committee on Unwanted Behaviour, which investigates, advises and holds hearings, retaining records for five years. Foreign operating companies maintain their own reporting mechanisms.

Reference: page 120

Achmea took actions across its four material HR topics in 2024. For ID&E it converted the 1-Achmea policy into actionable plans, developed a gender dashboard for managers, improved multicultural data, ran an organisation-wide working climate survey, integrated diversity criteria into senior management, Executive Board and Supervisory Board appointments, and pursued inclusive hiring and accessible facilities. For training it expanded the All You Can Learn portfolio and the 'My Learning' platform. For work-life balance it introduced meeting-free days, shortened meetings and well-being initiatives accessible through 'Healthy working plazas'. Against violence and harassment it ran roadshows, leadership programmes, training and awareness campaigns, introduced confidential advisors and the 'Speak Up' page, and at Zilveren Kruis launched an action plan on undesirable behaviour. Foreign operating companies at Union, Interamerican and Eureko Sigorta implemented their own ID&E, training and well-being measures. Financial resources are part of regular operations.

Reference: page 123

Achmea has set measurable targets across its material HR topics. For gender diversity it aims to fill 35% of management positions with women by 2025 and 40% by 2030, aligned with the Charter Talent to the Top target of 35% women in top management by 2025. It targets having 1.16% of FTEs from the PSO target group (Performance Ladder Social Entrepreneurship Basic Step 1). It aims for a minimum MBO inclusion score of 8.0 by 2025, extending beyond 2030; the 2024 result was 7.8. For training, the target of 50% participation in All You Can Learn was exceeded at 68%, and the satisfaction-score target of 7.5 was exceeded at 8.6. For work-life balance, the 2024 vitality target was 7.2 (result 7.4) and absenteeism target was below 4% (result 4.08%). Achmea notes employees were not consulted on setting these targets.

Reference: page 160

At 31 December 2024 Achmea employed 15,762 people (15,318 FTE), up from 15,508 (15,009 FTE) in 2023. By gender the workforce was 7,769 male and 7,993 female, so women made up roughly 50.7%. Of the total, 12,831 worked in the Netherlands (including 1,126 at third-party companies) and 2,931 at international subsidiaries in Australia, Greece (Interamerican, 1,420), Türkiye (Eureko Sigorta, 666) and Slovakia (Union, 714). By contract type 14,695 held permanent and 1,067 temporary contracts; 12,001 worked full-time and 3,761 part-time, with part-time work far more common among women (2,962 versus 799 men). In 2024, 1,648 employees left Achmea, a turnover rate of 10.6%. There are no registrations of employees identifying with a gender other than male or female. All figures are headcount at year-end.

Reference: page 162

Achmea reports on non-employees in its own workforce, defined as individual contractors who work for it (self-employed persons) and persons from companies mainly engaged in job placement, such as temporary employment agencies. At 31 December 2024 there were 2,327 non-employees, comprising 1,214 male and 1,113 female, down from 2,480 in 2023 (1,285 male and 1,195 female). The information on self-employed workers is compiled using the same methods and procedures as for employees, covering both the Dutch entities and the foreign operating companies. Employees of outsourced services, employees of suppliers and consultants are not counted as part of Achmea's own workforce.

Reference: page 118

Achmea values social dialogue at both individual and collective levels. Collective dialogue occurs between the employer and employee representation bodies such as the Works Council (OR), the Central Works Council (COR) and labour unions. In the Netherlands, regular meetings with labour unions address working conditions, work-related aspects and the social plan, and both union members and non-members are involved in setting the agenda for the Collective Labour Agreement (CLA) and in decisions on negotiation outcomes. Within foreign operating companies, meetings with labour unions take place within local law and regulations; at Union the commitment to equal treatment is included in the CLA. Most Dutch employees fall under the Achmea CLA, with a 34-hour working week applying to CLA personnel. The report does not disclose a single overall collective bargaining coverage percentage.

Reference: page 161

Achmea reports diversity metrics by age and gender. By age (headcount, consolidated): under 30 years 756 male and 1,068 female; 30 to 50 years 3,806 male and 4,347 female; over 50 years 3,207 male and 2,578 female. Gender diversity by job level shows that at consolidated top management women held 34.9% (131 of 375). In the Netherlands excluding third-party companies, 34.5% of top management were women (101 of 293), while across Achmea as a whole 34.9% of top management were women. For boards across all group companies, the Supervisory Board of Achmea B.V. was 33% female (3 of 8) and the Executive Board of Achmea B.V. was 50% female (3 of 6). Members of administrative, management and supervisory bodies across all group companies were 31% female (73 of 234).

Reference: page 126

Achmea reports training and skills development metrics. The average number of training hours per employee in 2024 was 22.0 for men and 25.0 for women in the Netherlands excluding third-party companies, 8.4 for men and 9.2 for women in other locations, and 19.1 for men and 20.2 for women in total. Participation in the All You Can Learn programme reached 68% in 2024, exceeding the 50% target, with a course satisfaction score of 8.6 against a target of 7.5. On performance and career development reviews, Achmea cannot report figures for the Netherlands (marked N/A) because since 2019 it replaced traditional appraisals with the TOP framework, whose discussions are not recorded; for other locations 94.9% of men and 95.1% of women participated in such reviews.

Reference: page 128

Achmea tracks work-life balance through two main KPIs, vitality and absenteeism, both drawn from the annual MBO and HR systems. In 2024 the vitality score was 7.4 against a target of 7.2 (2023 result 7.2), and the absenteeism rate was 4.08% against a target below 4% (2023 result 4.12%). The percentage of employees who took family leave (including maternity, paternity, parental and caregiving leave) was 12% in 2024, up from 9% in 2023, comprising 8% of men and 17% of women. 99% of Achmea employees are entitled to family-related leave, with the missing 1% being employees above the collective labour agreement in countries where family leave is not regulated by law. Achmea introduced a 34-hour workweek in 2021 in the Netherlands and offers 16 weeks of paid maternity leave.

Reference: page 122

Achmea reports the uncorrected gender pay gap as the difference between the average gross hourly wage of male and female employees, expressed as a percentage of the male average. For 2024 the ratio was 16.6% for the Netherlands excluding third-party companies (2023: 17.9%) and 21.4% for total Achmea. By salary scale the gap was smaller, for example 1.3% at top management and 7.4% for CLA employees J and K within total Achmea. The gap is attributed to more men in higher salary scales, women's lower average years of service and lower average age. On pay ratio, the CEO to median employee ratio was 27.8 based on all employees and 24.5 for Dutch operations excluding third-party companies. Based on average salary (Dutch Corporate Governance Code), the ratio was 18.8 in 2024 (2023: 19.8).

Reference: page 131

In 2024 Achmea had 19 confidential advisors (18 internal, 1 external) who handled 140 cases (2023: 118 cases). The Committee on Unwanted Behaviour ruled on 2 complaints filed in 2023, both dismissed. There were 5 new complaints in 2024 (2023: 4), of which 2 were declared inadmissible, 1 was resolved through conflict mediation, 1 was postponed due to the complainant's absence and 1 remained under review. The new complaints related to bullying (4) and (sexual) harassment (1). There were 3 reports under the Whistleblower policy (2023: 1 report). Achmea received no indications of reports regarding serious human rights incidents involving employees, and no fines, penalties or compensation were awarded. The 2023 and 2024 data relate to incidents involving employees; Achmea plans to expand this in 2025 to include incidents from external customers directed at employees.

Reference: page 134

Achmea addresses working conditions for value chain workers across two areas. For insurance and services (health insurance), it relies on its Human rights and labour rights statement and the complaints mechanism, and is committed in the Netherlands to the Integral Care Agreement (Integraal Zorgakkoord, IZA) and the Future-proof Labour Market Care and Welfare Programme (TAZ), aimed at healthcare providers and their employees. For investments and financing, it applies its Socially Responsible Investment (SRI) policy, built on the ILO Declaration of Fundamental Principles and Rights at Work, the UN Global Compact, OECD guidelines and the UN Guiding Principles. Achmea will not tolerate modern slavery, child labour, forced labour or human trafficking, and expects business partners and suppliers to respect human and labour rights and pay a living wage. Senior management oversees implementation.

Reference: page 134

The viewpoint of healthcare value chain workers is represented through professional and industry associations such as V&VN and trade unions. In relation to the IZA and TAZ, consultations with professional associations and trade unions are conducted under the guidance of the Ministry of Health, Welfare and Sport. Achmea does not engage directly with healthcare workers itself. For investments and financing, engagement plays an important role in preventing or mitigating negative impacts. Achmea conducts normative engagement with companies that violate or risk violating international standards, and thematic engagement with companies in sectors, chains or regions of high labour standards risk, in collaboration with ISS ESG. It exercises influence through voting at shareholder meetings and by co-filing shareholder resolutions, and reports activities in its semi-annual SRI reports. It does not engage directly with investee company employees.

Reference: page 136

Through its complaints mechanism (or grievance mechanism), workers in the value chain, alongside customers and consumers, can directly express their concerns and needs. The mechanism addresses complaints related to communication, environmental issues and human rights matters. Reporters can contact Achmea via the general website, its brands, e-mail or telephone, with the same procedures for every stakeholder. Each reporter receives an initial substantive response within five working days. If a reporter is dissatisfied, they can request a second review, with referral to dispute resolution bodies or the court where no resolution is reached. Reports are analysed to improve services and KPIs monitor performance. Employees can also report incidents through the whistleblower policy. In 2024, Achmea received no indications of reports regarding serious human rights issues or incidents involving value chain workers at healthcare providers in the Netherlands.

Reference: page 135

Achmea states its actions are part of an ongoing process stemming from its policies, guidelines and codes, and that implementation does not require a separate detailed action plan, so it has no distinct list of key actions for 2024. For healthcare, measures related to the IZA are implemented through the procurement policy of entities such as Zilveren Kruis, and progress is monitored within the IZA. For investments, Achmea uses normative and thematic engagement and shareholder voting to prevent or mitigate impacts, and where necessary expects companies to take recovery measures or provide compensation. In line with its SRI policy, it applies exclusion criteria and a country exclusion policy based on the ITUC Global Rights Index, with companies assessed quarterly by ISS-ESG. Financial resources are considered part of regular operations.

Reference: page 134

Achmea has not yet established its own targets or metrics for working conditions in the value chain. For healthcare, the effectiveness of IZA agreements is monitored and reported quarterly under the responsibility of the Ministry of Health, Welfare and Sport, and Achmea has not set goals or criteria itself, noting that the many factors influencing worker health and safety make it impossible to evaluate the effectiveness of actions. For investments, objectives for 2030 are set in the Achmea SRI theme policy and progress is reported in the SRI annual report. However, for reporting year 2024 no specific objectives have been established, and Achmea does not foresee setting specific objectives for the coming years.

Reference: page 139

Achmea identified four material consumer topics: access to quality information, responsible advertising, access to products and services, and privacy of personal data. Its Human rights and labour rights statement covers its role as a financial service provider, and it strives to make products available, sufficient, affordable and accessible to everyone. Specific policies include the Trusted communication standard (writing at CEFR B1 level for private customers, updated to version 2.0 in 2024), website accessibility to WCAG AA, the Product Approval and Review Process (PARP), the Achmea Guiding Principles on duty of care and the Customer centric insurances policy, the Ethical framework for data-driven applications and Ethical wheel, and a Privacy policy aligned with the GDPR. Discrimination is not tolerated. Senior management oversees implementation.

Reference: page 139

Vereniging Achmea (Achmea Society), of which all customers are automatically members, safeguards collective customer interests. For access to quality information and access to products and services, Achmea involves customers in evaluating and enhancing its information through targeted surveys, councils, panels and NPS measurements, and customers can provide feedback through websites and social media, which is used to refine communication strategies. On responsible advertising, Achmea does not engage directly with consumers but conducts market research to evaluate advertisement effectiveness and regularly reviews its marketing strategies and campaigns. It also conducts market research to understand the needs of different customer segments to better tailor products and pricing. There is no engagement with customers when setting goals or monitoring performance against objectives.

Reference: page 139

Through its complaints mechanism (or grievance mechanism), customers and other stakeholders can directly express their concerns and needs; a full description is provided in the chapter on Working conditions in the value chain. Reporters receive an initial substantive response within five working days and can request a second review if dissatisfied, with referral to dispute resolution bodies or the court where no resolution is reached. For privacy, customers are informed about the procedure for submitting complaints through privacy and cookie statements on Achmea websites. Employees can use the whistleblower policy to report incidents, which are then investigated. In the event of an insurance application rejection, an alternative solution is offered along with information on how to submit an objection or complaint.

Reference: page 139

Achmea states its consumer actions are part of an ongoing process guided by its policies, guidelines and codes, and that implementation does not require a separate detailed action plan, so it has no distinct list of key actions for 2024. Concrete practices include the PARP for introducing and periodically reviewing products with follow-up in the Product Review Committee, the Legal framework for customer communications (JKK) and Tactical campaign management to mitigate risks of incorrect or unclear information, prevention campaigns such as Zilveren Kruis sunscreen, Interpolis bicycle lights and Centraal Beheer 'Small dents days', and a fixed assessment and approval process for mass media communication. For privacy, incident reports outline corrective measures and relevant authorities and stakeholders are informed. Financial resources are considered part of regular operations.

Reference: page 139

Central objectives regarding customer interests are outlined in Stakeholder Value Management (SVM), which sets strategic themes and KPIs agreed between the Executive Board and senior management. For access to quality information, a Trusted communication training target was set: 80 percent of Dutch employees to complete training at Knowledge level, with an 84 percent result in 2024. Achmea received approximately 3,700 complaints regarding information in 2024, all addressed individually, and no AFM fines were imposed. For responsible advertising, a new theme, no specific metrics and targets were established in 2024, with the intention to define them in 2025. No targets are published for access to products and services. For privacy, the target was 100 percent of Dutch employees completing the mandatory privacy e-learning, with a 96.5 percent result in 2024, and no material privacy breaches were identified.

Reference: page 150

Achmea's corporate culture promotes ethical business practices and integrity, with no room for corruption and fraud. Key policies include the Achmea General code of conduct and the Whistleblower policy. All employees, domestically and internationally, must act in accordance with the code of conduct, and Dutch employees are obligated to take an oath or promise for the financial sector. New internal and external employees must complete training on the code of conduct. A Group Ethics committee, consisting of colleagues and external parties, provides advice on ethical issues such as digitalisation, experimental healthcare needs and socially responsible investing. Achmea has committed to external codes including the Dutch Code of conduct for insurers. Incidents reported by external parties follow the complaints mechanism, while the Incident policy and Whistleblower policy apply to employee reports, with integrity incidents communicated to the Executive Board and the Audit and Risk Committee. Senior management oversees implementation.

Reference: page 150

Achmea's Integrity and fraud policy highlights integrity risks including corruption, gifts, secondary activities and third party involvement, with the primary principle of preventing any form of corruption or bribery, and outlines the Systematic Integrity Risk Analysis (SIRA). A Supplier due diligence process in the Netherlands screens potential suppliers and manages risks related to corruption, bribery and conflicts of interest. A Risk framework for integrity management addresses organisational and customer or relationship perspectives, supported by Customer Due Diligence under the Wft, Sanctions Act and Anti-Money Laundering and Anti-Terrorist Financing Act. The SIRA is conducted annually for each entity, including foreign business units, aligned with DNB best practices, and in 2024 introduced a new scenario for socially responsible investing and greenwashing. A mandatory Integrity e-learning applies to all employees including the Executive and Supervisory Boards; 97.3 percent of Dutch employees completed it in 2024 against a 100 percent target.

Reference: page 152

Achmea reports its indicators of ethical corporate culture in a metrics table. The number of convictions for violating anti-corruption and anti-bribery laws in 2024 was 0, against a target of 0, and the amount of fines for violating anti-corruption and anti-bribery laws in 2024 was 0, against a target of 0. Reporting is in accordance with data point ESRS G1-4-24a. The scope of these figures pertains to Achmea and all its group companies, both domestically and internationally. Detected integrity violations, including corruption and bribery, are followed up in accordance with the Incident policy. The metrics table also reports that 97.3 percent of Dutch employees successfully completed the integrity e-learning in 2024 against a 100 percent target.