Achmea B.V.

Reference: page 87

The Executive Board is "ultimately responsible for the strategy, including sustainability. The members are jointly responsible, while each member individually oversees the implementation of sustainability within the business units for which they are responsible" (page 87). The Supervisory Board supervises and advises; sustainability is written into both boards' mandates and regulations, covering strategic sustainability priorities, risk management and compliance.

Two changes land this year: a Sustainability Committee has been set up under the Executive Board "to safeguard alignment across ambition, policy and implementation", and from January 2026 the 'Achmea Sustainable Together' programme's responsibilities transfer to the regular organisation with a functional reporting line from the central Sustainability department to the business units (page 87). Delivery sits with that department plus ESG officers in the international business units.

Composition at 31 December 2025 (page 132, Table 5): Executive Board three men and three women; Supervisory Board five men and three women. "75% of the members of the Supervisory Board of Achmea B.V. qualify as independent based on the ESRS definition." Both boards and the Group Council take continuing education including on sustainability, and in 2025 "an extensive biodiversity training programme was developed and completed by our own ESG specialists" (page 87).

Reference: page 89

Sustainability priorities defined and discussed by the Executive Board in 2025 were the development and validation of the 2025 Double Materiality Assessment, the further elaboration of the ESG policy, the development and discussion of the People Strategy, the development and adoption of the 2030 sustainability strategy, and the organisational set-up for sustainability going forward (page 89).

Beyond that list, "the Executive Board and the Supervisory Board (and its committees) were regularly informed about additional sustainability topics" through quarterly reports, performance dialogues and briefing papers. Named topics include the evaluation of the 2024 sustainability statements, the Climate Transition Plan, "discussions on investments in Israel in relation to sustainability", monitoring progress on sustainability targets, ESG risk analyses, the remuneration policy including the portion linked to sustainability, and sustainability-related commitments (page 89).

Each quarter business units report to the Executive Board on financial and non-financial indicators, followed by performance dialogues with the responsible board members (page 87). The Audit and Risk Committee periodically discussed the DMA, "which determines Achmea's material topics" (page 76).

Reference: page 88

Sustainability objectives run through Stakeholder Value Management, the basis for performance management, and are translated into team and individual objectives; managers of Achmea's investment institutions carry specific sustainability objectives (page 88).

For 2025 the Executive Board's variable remuneration assessment includes, on the environmental side, CO2 reduction in own operations (58% in 2025 against 2019), in the investment and mortgage portfolio (32% in 2025 against 2020), in the motor vehicle portfolio (15-20% in 2030 against 2021), and allocation of 10% of own-risk investments to impact investments. On the social side: customer satisfaction (rNPS at least market average), "at least 8 out of 11 social impact programmes 'on track'", and gender diversity of 35% women in top management and 42% in managerial positions (page 88).

Quantified link: "In 2025, on average 22% of the variable remuneration paid to members of the Executive Board is attributable to objectives from 2024 related to sustainability, including 5.6% relating to climate objectives." Variable remuneration is capped at 20% of fixed annual salary in the Netherlands (100% abroad), and for risk takers and senior management 50% is deferred five years, released only after a sustainability-of-performance assessment (page 88).

Reference: page 153

Annex A carries the due diligence mapping table, linking each core element to its location: embedding due diligence in governance, strategy and business model, and engaging affected stakeholders, both to Governance of sustainability - Roles, responsibilities and expertise; identifying and assessing adverse impacts, taking action, and tracking effectiveness, each to the topical chapters (page 153).

The process is set out on page 89 in seven steps, from integrating due diligence into policy through to publicly communicating on it, and Achmea states the approach "differs depending on the various roles we fulfil as a financial services provider". Three channels are described. Acceptance: customer screening for sanctions, money laundering and terrorist financing under the Integrity and Fraud Policy and Customer Due Diligence Policy, with an ESG risk assessment for corporate customers and high-risk applications escalated to "a separate ESG Acceptance Committee". Procurement: "In the Netherlands, we use EcoVadis for our upstream activities to assess the ESG performance of impactful suppliers", with engagement and possible contract termination where a score falls below threshold. Investment: assessment of companies "that repeatedly violate the principles of the UN Global Compact relating to human rights, labour standards, the environment and anti-corruption" (page 89). The framework references the OECD Guidelines and the UNGPs (pages 89, 126).

Reference: page 90

Sustainability risks run through the regular Integrated Governance, Risk Management and Compliance system. Achmea defines them as "(uncertain) ESG-related events (such as the pace of climate change) that may have a potentially negative effect on the realisation of Achmea's strategy and objectives, financial results and/or reputation", materialising through other risk types rather than as a standalone category (page 90). The first line, the Risk Management, Compliance, Actuarial and Internal Audit key functions, and the Group Risk Committee and Asset Liability Committee all carry their usual duties for these risks.

A Group-level sustainability risk appetite statement is defined, with two Key Risk Indicators: Achmea B.V.'s ESG rating according to MSCI and according to Sustainalytics (page 90). Greenwashing risk is named explicitly as part of the internal control system and Control Framework (page 91).

On reporting controls, the statements are prepared under the Financial and Performance Management department; "a dedicated project team oversees the content of the CSRD reporting and assesses the accuracy and plausibility of the information provided"; the Annual Report Steering Committee approves principles and texts; the Sustainability Committee, Risk Management, Compliance and the business units review the content; the Executive Board adopts the final version and the Supervisory Board supervises (page 151).

Reference: page 82

Achmea B.V. offers non-life, health, life and income insurance plus financing, asset management and pension services, "with 16,369 internal employees, of whom 13,054 are based in the Netherlands" (page 82). It states its activities are "almost entirely concentrated in the ESRS sector of financial services and insurance. Outside these sectors, we have no other activities that may be associated with material impacts, risks or opportunities." Insurance revenue was EUR 26,764 million and net revenue used for GHG intensity EUR 27,986 million (page 155). Corporate customers span agriculture, real estate, construction, retail and wholesale, hospitality and professional services.

Sustainability reporting is structured around three activities rather than IFRS 8 segments: Insurance and services; Investments and financing, including banking; and Own operations (page 152). The value chain "is largely limited to business relationships over which Achmea can exert direct influence (Tier 1)", extending further where needed, for instance "in healthcare activities where employees of healthcare providers are also included" (page 83). A simplified value chain figure is printed on page 83. The 2030 ambitions are accelerating towards net zero and strengthening nature resilience, and promoting health, social well-being and financial resilience (page 82).

Reference: page 14

Achmea engages customers, employees, shareholders, suppliers, business partners, civil-society organisations, external experts and regulators, with a table of groups, forms and frequency on page 15 (customers and employees ongoing or periodic; shareholders annual or as required; suppliers and business partners periodic; civil-society organisations, experts and regulators project-based or as required).

The cooperative channel is distinctive. All customers are members of Vereniging Achmea, whose Members' Council "meets three times a year with the association's board and with the Executive Board of Achmea" and forms three thematic working groups a year that turn customer signals into recommendations. Groups launched in mid-2024 on social sustainability, post-fire reconstruction and Eurocross completed in mid-2025; new groups cover young people's mental resilience, access to justice and the Health Manifesto. Expert sessions in 2025 addressed "data profiling and its implications for inclusion and insurability" (page 14).

For the DMA, the 2024 survey was replaced: "With external facilitation, we organised a dialogue session with representatives of our key stakeholders", attended by shareholders, suppliers, business partners, customers, civil-society organisations, regulators, interest groups, peers and independent experts (page 15). The main outcome was that "all stakeholders consider climate adaptation to be a material topic" (page 16).

Reference: page 85

The DMA produced "thirteen material impacts, risks and opportunities (IROs), which we cluster into nine material topics" (page 85). The table on pages 85-86 sets each topic against its IRO description, impact and financial materiality markers, SDG connection and strategic pillar. Climate change - Mitigation carries a positive impact (renewable-energy infrastructure funds, green bonds, mortgage activity), a negative impact (investing in and insuring high-emission sectors) and a transition risk from stricter CO2 regulation including "potential CO2 taxes and emissions trading schemes". Climate change - Adaptation carries a positive impact on policyholders and a physical risk to investments and claims costs. The remaining topics are Pollution of water and soil, Biodiversity, Resources inflow and waste, Sustainable collaboration, Working conditions in the value chain, Consumers and end-users, and Ethical business conduct.

On resilience Achmea is candid: "We do not yet have a complete picture of the expected financial effects of the material topics on Achmea. For the topics related to our value chain, we are in the process of collecting data." For own-operations topics such as sustainable collaboration and ethical conduct it considers the strategy "well equipped to withstand the associated risks" (page 86). Climate-specific risk identification, scenario analysis and resilience are also presented under E1-2 and E1-3 (2025 ESRS numbering).

Reference: page 16

The 2025 DMA was a reassessment built on the 2024 topics, in three steps. Step one: the project team re-analysed the 2024 topics, updated IROs across the value chain and "aligned the threshold levels more closely with our risk appetite and updated the definitions in line with the Achmea risk heatmap", producing "our shortlist of fourteen potentially material topics". Step two: business-unit experts tested validity and value-chain impact; "This did not lead to new material topics." Step three: consolidation into "thirteen material impacts, risks and opportunities, grouped into nine material topics", on the same methodology as 2024 (page 16).

Both perspectives are defined, and the materiality chart marks the cut-off as "financial <3,3, impact <3,0" (page 17). Validation ran through an externally facilitated stakeholder session, peer studies, external reviews and regulator perspectives; the list was approved by the Programme Board, validated by the Executive Board and "then approved by the Supervisory Board" (page 17).

Changes against 2024 (page 17): the financial materiality of climate mitigation fell after analysis of the real estate portfolio showed limited likelihood of simultaneous financial effects; impact materiality rose for water and soil pollution and for resources and waste; S2 impact is "indirect but higher"; and S4 financial materiality rose "because data and cybersecurity risks were added".

Reference: page 177

Annex E carries a genuine ESRS content index: "In accordance with ESRS 2 IRO-2, the content index below is included, showing where the applicable ESRS reporting requirements are addressed in the sustainability statements" (page 177). It runs across pages 177-182, one row per disclosure requirement, giving either a section and paragraph reference or the sentence "The disclosure requirement is not material." It covers BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2 and the four minimum disclosure requirements, each listing the topical DRs that carry it, then the topical standards E1, E2, E4, E5, S1, S2, S4 and G1. ESRS E3 and S3 have no section at all, consistent with the DMA.

A second index, "Content index ESRS 2 Supplement B" (pages 183-185), lists the Appendix B datapoints arising from other EU legislation with their location or a not-material statement.

Phase-in is signposted rather than hidden: E2-6, E4-6 and E5-6 each point only to Annex A, Use of transitional provisions (ESRS 1), while E1-9 points both to Annex B paragraph D and to that provision. Annex A narrows the E1-9 relief to everything "with the exception of information on corporate securities, mortgages and investment property on our balance sheet" (page 153).

Reference: page 94

The Climate Transition Plan "describes our strategy, targets and actions" across own operations, insurance and investments and financing, plus the climate risks faced and the measures taken to make Achmea and its customers more resilient. It "has been approved by the Executive Board and is updated annually. The current version is available on our website", and an update was a 2025 highlight (pages 94, 81). Senior management of the responsible division or operating company is accountable for implementation (page 95).

Alignment is stated plainly. By signing the Climate Commitment of the Dutch financial sector, "we have committed ourselves to the objectives of the Paris Climate Agreement. We aim to align our activities with a climate scenario that limits global warming to 1.5°C above pre-industrial levels", and "Achmea is not excluded from EU Paris-Aligned Benchmarks (PABs)" (page 94).

Two limits are disclosed rather than glossed. On resourcing: "With the exception of investments for the sustainability of our own buildings and investment property, no additional capital expenditure (Capex) has been budgeted." On levers: "At present, a quantification of the achieved and expected reductions resulting from these actions per lever is not or only partially possible", because outcomes depend on customers, investees and partners and value-chain information is "currently not yet fully available" (page 94).

Back-filled from ESRS 2 IRO-1 and the E1 Climate change resilience section, where this content is disclosed in the FY2025 report (pages 109-113). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: page 109

Risks are classified as paragraph 15 expects: "Our risk analysis covers both physical and transition risks ... Physical risks relate to the direct effects of climate change. These may occur acutely ... or develop gradually" (page 109). Methodology: qualitative and quantitative analysis at Group level covering Dutch and international entities over short (0-1 year), medium (1-10 years) and long term (>10-30 years), guided by the IPCC, KNMI, EIOPA application guidance and De Nederlandsche Bank, with outcomes reported in the annual Own Risk and Solvency Assessment (pages 109-110).

Scenarios are named: RCP4.5, "almost 3°C increase by 2100, most likely scenario", and RCP8.5, "5°C increase by 2100, worst-case scenario", giving 30% and 60% higher weather-related claims costs (page 111); the IPCC AR6 C1 scenario "aimed at limiting warming to 1.5°C with no or limited overshoot" and CRREM 1.5°C for investments (pages 102-105); and a Paris-aligned versus hot house scenario for investment exposure (pages 164-165). Gaps are stated: for non-Dutch insurance portfolios "long-term scenarios have not yet been analysed ... Concrete timelines have not yet been determined".

Back-filled from ESRS 2 SBM-3 and the E1 Climate change resilience section, where this content is disclosed in the FY2025 report (pages 86, 109-113). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: page 109

Achmea defines resilience as "the extent to which our strategy can continue to be executed or, alternatively, can be flexibly adjusted when we are faced with changes and uncertainties", and distinguishes strategic or policy, financial and operational resilience (pages 86, 109).

Results by activity are in Table 13 (page 109). For P&C insurance, short-term impact of natural disasters is "limited by reinsurance cover", while over the medium and long term "The financial result may become increasingly volatile as a result of more frequent and more severe climate-related events and a higher level of own retention". For corporate securities, "Stranded assets are a point of concern" on transition risk. For mortgages and investment property, "The long-term impact may increase as a result of flood risks, with stranded assets being a point of concern for specific locations." Using the DGBC Framework for Climate Adaptive Buildings on residential and healthcare assets, "the number of high and very high risks decreased from 67 to 28" (page 113).

Reference: page 96

Insurance policies (page 96). The Product Approval and Review Process policy tests products against environmental and social objectives and legislation "such as the EU Taxonomy". The ESG underwriting policy for commercial clients states: "We do not provide insurance coverage for activities related to coal, shale oil or shale gas extraction. In addition, we do not enter into new contracts for coal-fired power plants. Existing contracts are phased out gradually so that they are fully terminated by 2040 at the latest. We also do not insure companies in the oil and gas industry that do not have a credible transition plan." Health insurance works through the healthcare procurement policy (page 99).

Investment policies sit in the Socially Responsible Investment policy, approved by the Asset and Liability Committee and ratified by the Executive Board, with climate one of four core themes (pages 101-102). Exclusion thresholds are printed: no investment above 1% of revenue from coal, tar sands oil, shale oil and shale gas or Arctic oil and gas, and above 5% from thermal-coal electricity. Conventional oil and gas producers must meet "At least 15% of capital expenditure in renewable energy in 2025 and 50% in 2030; and/or an Implied Temperature Rise (ITR) score from MSCI or a Carbon Performance Alignment score from the Transition Pathway Initiative (TPI) of no more than 2°C" (page 103). Achmea Real Estate's ESG strategy applies CRREM pathways (page 106).

Reference: page 96

Insurance actions (pages 96-100): a centralised Sustainability Desk to assess new risks; research with the Institute for Environmental Studies of Vrije Universiteit Amsterdam; insuring new technologies including electric vehicles, timber construction, solar panels, hydrogen and biogas installations and electricity storage; and an ESG risk assessment implemented in commercial-lines acceptance in 2025, with high-risk applications escalated to a committee that "issues a binding decision". On claims, "By the end of 2025, 99.7% of our Dutch partner network in the residential and motor insurance domains was sustainability- or environmentally certified" (page 97).

Investment actions (pages 103-106): an engagement programme launched in 2023 with ten high-emitting companies targeting net zero by 2050, "preferably already by 2040"; Climate Action 100+ and the Dutch Climate Coalition; voting against director re-appointments where no transition plan is linked to pay; green government bonds raised "from 3.9% to 4.7%" of the portfolio; mortgage sustainability services and an A+ label interest-rate discount, extended in 2025 to green roofs, foundation repairs and water storage; and for property, "approximately EUR 19 million ... budgeted for sustainability measures in Achmea's direct property portfolio" for 2024-2029, plus the embodied-carbon phase-down pathway launched in mid-September 2025 (page 106).

Reference: page 93

Insurance: net zero insurance portfolio by 2050, and for Dutch private motor a 15-20% reduction in average emissions per kilometre by 2030 against 2021, with "Realisation 2025: -8.3%" (page 93). Investments: net zero by 2040 for corporate securities and 2050 for other asset classes. For own-risk corporate securities the 2025 revision moved off a market benchmark onto Achmea's own portfolio emissions, giving "a 32.6% reduction in financed emissions by 2030 compared to 2023", with coverage expanded "from 52% to almost 100%" (page 102). Mortgages: 33% by 2030 against 2022, with 2025 emissions of 19.70 kg CO2/m2, "which is -26% compared with 2022" (page 104). Investment property: the 55%-by-2030 target was exceeded, so a new 53%-by-2030 target against 2023 was set (page 105). Government bonds: net zero by 2050 with no interim target. Impact investments: the 10% target was met at 12.2%.

Two limits. The motor and mortgage targets are explicitly not science-based, being "therefore not based ... on a science-based scenario aimed at limiting global temperature rise, but on the 2030 projections prepared by the Netherlands Environmental Assessment Agency" (pages 96, 104). And targets cover investees' Scope 1 and 2 only: "Although we have not yet set targets for Scope 3 emissions, we have started measuring and reporting on them" (page 102).

Reference: page 154

Annex B Table 1 carries the inventory against a 2019 base year for own operations. Gross Scope 1 was 7,889 tCO2e (2024: 8,923), down 12% year on year and 30% against the 11,200 tCO2e base. Gross location-based Scope 2 was 9,369 tCO2e (2024: 10,627), down 12%; gross market-based Scope 2 was 1,155 tCO2e (2024: 1,789), down 35% and 92% against base. "Achmea has no exposures related to Emission Trading Schemes."

Total gross Scope 3 was 7,498,102 tCO2e (2024: 6,305,434), up 19%. Own-operations categories: purchased goods and services 13,216 tCO2e (2024: 1,892), waste generated in operations 449 tCO2e, business travelling 3,445 tCO2e and employee commuting 4,582 tCO2e, down 51%. Eight categories are marked "Not a significant category". Category 15 dominates: financed emissions 2,534,000 tCO2e (2024: 2,720,390, down 7%), enabled financed emissions from assets under management 2,276,310 tCO2e (2024: 1,377,000, up 65%), insurance-associated emissions non-life 719,100 tCO2e (2024: 255,100) and health 1,947,000 tCO2e (2024: 1,938,000).

Totals: 7,515,360 tCO2e location-based and 7,507,146 tCO2e market-based, both up 19%. GHG intensity was 269 and 268 tCO2e per EUR million net revenue (2024: 237 for both). Achmea attributes the rise to scope expansion and higher financed emissions "partly as a result of the acquisitions of Blue Sky Group and Lifetri" (page 155). Own-operations gross emissions were 38,950 tCO2e and net 17,373 tCO2e after compensation.

Reference: page 164

The index points E1-9 both to Annex B paragraph D, Quantitative resilience analysis investments, and to the ESRS 1 transitional provision (page 179). Annex A narrows the relief precisely: the phase-in applies "with the exception of information on corporate securities, mortgages and investment property on our balance sheet" (page 153). So the insurance side is deferred and the investment side is disclosed.

What is disclosed. For corporate securities at 31 December 2025 (Table 14, page 164), own-risk listed equity of EUR 2,246 million had EUR 2,148 million (96%) analysed, 98% low risk under the Paris-aligned scenario falling to 94% under the hot house scenario; own-risk corporate bonds of EUR 16,611 million had EUR 12,930 million (78%) analysed, 99% low risk Paris-aligned against 96% hot house. Transition risk by sector (Table 16, page 165): of EUR 19,693 million own-account corporate securities, 19% energy-intensive, 3% fossil fuel and 65% "Other sectors not at risk". Mortgage physical risks (Table 17, page 166) show precipitation 5.9% at high risk, subsidence 3.3% and flooding 0.3%; investment property (Table 19, page 167) subsidence 12.1% and heat stress 9.7%.

Reference: page 114

The material E2 impact is indirect and downstream: "Our health insurance activities have an indirect, current, negative impact on water quality in the Netherlands. Through the healthcare services we finance, medicinal and chemical residues used by healthcare providers during treatments enter surface water via the sewer system" (page 114). Scale is sourced: "According to the National Institute for Public Health and the Environment (RIVM), at least 190 tonnes of pharmaceutical residues end up in Dutch surface water each year."

The policy instrument is healthcare procurement. "In 2024, a nationally uniform procurement policy was developed together with other Dutch health insurers, which was further developed in 2025. We have applied this policy to our own procurement policies for various types of care: medical specialist care (MSZ), mental healthcare (GGZ), pharmacies, general practitioners and long-term care (Wlz)" (page 115). For pharmacists the focus is reducing medicine waste; "it was explored whether health insurers can apply a sustainability criterion in the preferential procurement of medicines. The criteria for this were established in 2025."

Reference: page 115

Actions are procurement measures rather than abatement projects, because the impact sits downstream at healthcare providers. "For medical specialist care (MSZ), mental health care (GGZ), pharmacies and general practitioners, measures to reduce the environmental impact of medicine use have been included in the healthcare procurement policy. This concerns the implemented healthcare procurement policy for 2025 for contracted healthcare providers. In addition, the procurement policy for 2026 has been drawn up and published on 1 April 2025 on the website of, for example, Zilveren Kruis. For long-term care (Wlz), this takes place on 1 June of the preceding year" (page 115).

Named 2026 actions: implementation of sustainability criteria in preferential medicine procurement, supported by a web application commissioned by the Dutch Association of Health Insurers; and "a pilot to encourage general practitioners, through a financial incentive, to structurally evaluate medicine use". Regionally, "Zilveren Kruis facilitates initiatives such as in Utrecht-Noord, where collaboration between primary and secondary care is intended to lead to a more transparent medication process". Following the 2025 exploration Sustainable Use of Medicines, the reimbursed medication review for people aged 75 and over and people on multiple medicines was identified as "well suited for this purpose. This will be further developed in 2026."

Reference: page 115

Achmea sets no quantified pollution reduction target and explains why. The Green Deal Sustainable Healthcare 3.0 "formulates baseline targets for sustainable healthcare across the entire healthcare sector. Many of these targets, and the contribution of health insurers to them, are not yet sufficiently measurable, which means that additional effort is required to make them measurable and to establish them" (page 115). The Green Deal's fifth objective is "Reducing the environmental impact of medicines (use)" (page 99).

The measurability problem is stated concretely: "A generic reduction of pharmaceutical residues in Dutch water is not easily measurable, as external factors such as weather conditions and increasing medicine use influence the outcomes. For most measures, it is therefore more meaningful to focus on reduced usage and the prevention of waste. This includes, for example, dispensing volumes, wastage, return processes, substitution or reduction of medicines" (page 115).

The baseline now exists: in June 2025 the RIVM published its Monitor Sustainability and Health. Baseline measurement, which "forms the basis for measuring progress and for formulating further actions and improvements" (page 115). The materiality table lists the objectives column as "Under development" (page 114). This is a transparent nil return against MDR-T rather than a silent omission, unchanged from FY2024.

Reference: page 116

The index entry is itself the finding: E4-1 points to "Transitionplan: paragraph How we manage impacts, risks and opportunities. No transition plan has been established to date" plus the strategy paragraph (page 179). So Achmea reports against E4-1 with an explicit nil return on the plan.

Position disclosed: "As a financial services provider, Achmea itself has a limited direct negative impact on biodiversity. The greatest influence arises through our value chain, in particular through our investment and insurance activities" (page 116). The material IRO is negative and indirect, investing in and insuring companies "that deplete ecosystems through the over-exploitation of natural resources", with the caveat that "Further research is needed to determine how and to what extent this applies in the Dutch context" (page 85).

Route to a plan: "In 2025, a group-wide policy framework for biodiversity was developed. This forms the basis for the development of a biodiversity policy for our insurance and investment activities." And: "Assessing the impacts, risks and opportunities of our investment and insurance portfolios is a first step in the development of a transition plan for biodiversity ... In the explanation of policies, actions and metrics, we make use of the phasing-in options of the European Sustainability Reporting Standards (ESRS)" (page 116).

Reference: page 116

Two policy layers. At group level, "The Achmea Group Policy Framework for Biodiversity has been developed as part of Achmea's sustainability policy" in 2025, described as the basis for insurance and investment biodiversity policies still to come (pages 116-117). For insurance the chapter says plainly that "Policy is still under development", and for international units "At present, we have not developed specific policies for our international business units" (pages 116-117).

For investments the policy exists today: "Biodiversity is included in our Socially responsible investment policy (SRI), with biodiversity being one of the core themes. Within this theme, our focus includes the conservation and improvement of biodiversity. Our objectives are aimed at preventing biodiversity degradation in vulnerable ecosystems and combating pollution and irresponsible management of agricultural land" (page 118). The exclusion policy forms part of it, and Achmea notes that "breaches of environmental standards in relation to biodiversity often arise from soil or water pollution and/or pose a threat to biodiversity", and "The list of excluded companies can be found on our website" (page 118).

Reference: page 117

Assessment came first. For insurance, "an initial assessment was carried out in 2025 for our Dutch commercial insurance portfolio using the ENCORE database. Based on the results, we will determine in 2026 which further analyses are required" (page 116). For investments, a 2025 analysis of own-account investments and Achmea Investment Management funds used "Iceberg Data Lab's Corporate Biodiversity Footprint method", with the caveat that "the models used are sensitive. This means that the presence of a single activity can disproportionately influence the overall results" (pages 117-118).

Concrete 2025 activity: employees completed training on biodiversity impact analysis; a dedicated Impact Investment Team was established with biodiversity as a theme; biodiversity roadmaps were completed with two clients; the Triodos Food Transition Europe Fund is named as an impact investment. On the insurance side, "biodiversity strips have been created at around twenty greenhouse horticulture companies through the Innovatiefonds Hagelunie", plus the two-year Jack Bean project and encouragement of green roofs and business-park greening (pages 117-118).

Reference: page 119

The index points E4-4 to the biodiversity chapter's Metrics and targets paragraph (page 179), and what is there is a disclosed absence on the insurance side and an indirect commitment on the investment side.

Insurance: "As we will continue to work on an analysis of our insurance portfolio in 2026, metrics and targets have not yet been developed" (page 117). The materiality table lists the targets column for insurance as "Policy is still under development" and for investments and financing as "Under development" (page 116), and follow-up steps are deferred to 2026.

Investments: the one quantified commitment reaching biodiversity is the impact-investment allocation. "Achmea has committed to allocating at least 10% of its own investments to impact investments in 2025" (page 118), achieved at 12.2% (page 102), with biodiversity a theme of the new Impact Investment Team. Measurement is framed as the precondition for targets: "These insights form the starting point for developing our approach and setting concrete metrics and targets to reduce our footprint" (page 119).

No no-net-loss, net-gain, deforestation-free or area-restoration target is set, and none is aligned to the Kunming-Montreal Global Biodiversity Framework. Recorded as reported because the index references the paragraph and the paragraph gives a traceable nil return with reasons, which is MDR-T's other limb.

Reference: page 119

The index reference is candid about the ESRS-prescribed metrics: "paragraph Metrics and targets: no metrics have been established to date" (page 179). What Achmea publishes instead is an entity-specific biodiversity footprint for its investment portfolio, which the assurance report separately flags as entity-specific information whose comparability may be limited (page 359).

Table 1 on page 119 reports the Corporate Biodiversity Footprint using Iceberg Data Lab's method, expressed "as change in species abundance, Mean Species Abundance (MSA) per square kilometre of area (km2 MSA)". Own risk: listed equity EUR 2,842 million carrying amount with EUR 2,574 million (91%) measured, total impact -119 km2/MSA and relative impact -0.046 per EUR million; corporate bonds EUR 16,852 million with 76% measured, -602 and -0.047. Risk of policyholders: listed equity EUR 3,636 million with 94% measured, -135 and -0.039; corporate bonds EUR 537 million with 58% measured, -11 and -0.034. Assets under management: listed equity EUR 13,439 million with 66% measured, -393 and -0.044; corporate bonds EUR 8,966 million but only 4% measured, -11 and -0.032.

Two limits are stated: the "calculations have not been validated by an external party" beyond the assurance provider (page 119), and "The preliminary results indicate the need for further in-depth analyses" (page 117). No land-use, species or ecosystem-condition metric is given.

Reference: page 120

The material E5 impact is downstream through financed healthcare: "Our health insurance activities in the Netherlands have a current, negative impact on material use in the healthcare sector because we reimburse healthcare costs for insured persons. Healthcare requires substantial use of (medical) equipment and disposable items. This dependence on disposables also contributes to increased waste generation" (page 120). Scale is sourced to third parties: the sector "is responsible for approximately 13% of national abiotic raw material use (non-living resources)" per a 2022 RIVM report, and "approximately 328,000 tonnes of healthcare-related waste are generated annually, of which 85,000 tonnes consist of incontinence products" per Gupta Strategists.

The policy instrument is healthcare procurement: "Through our healthcare procurement policy, we aim to encourage healthcare providers within Medical Specialist Care (MSC) and long-term care under the Long-term Care Act (Wlz) to gain insight into waste streams and to reduce the volume of unsorted residual waste. Sustainability criteria are included in contracts with suppliers of medical aids, such as limiting packaging, preventing waste and promoting reuse" (pages 120-121). Zilveren Kruis's policy is updated annually and published by 1 April of the preceding year, 1 June for Wlz.

Reference: page 121

Actions run through procurement and sector collaboration. "The healthcare procurement policy includes actions aimed at reducing the environmental impact of the use of raw materials and materials in healthcare. This concerns the implemented healthcare procurement policy for 2025 with contracted healthcare providers. In addition, the purchasing policy for 2026 has been drawn up and adjusted to include additional sustainability criteria, and published on the websites of, among others, Zilveren Kruis" (page 121).

A baseline was created in 2025: "Together with other health insurers, an inventory has also been carried out into the reuse of medical aids. This inventory is intended as a basis for further actions and serves as a baseline measurement for monitoring progress." Two named initiatives: knowledge sharing on green initiatives "including the sustainable nutrition initiative of AxionContinu", and "the pilot project for washable incontinence products, carried out by 's Heeren Loo and Priovention, with financial support from Zilveren Kruis. This initiative explores opportunities for waste reduction and the promotion of reuse within long-term care."

Remediation is addressed directly rather than left implicit: "Although no specific remedial actions have been defined for negative impacts, these actions contribute to reducing waste and curbing raw material use within the healthcare sector" (page 121).

Reference: page 121

Achmea sets no own circular-economy target and says why. "The targets included in the implementation plan of Dutch Health Insurers under the Green Deal Sustainable Healthcare 3.0 (2022-2026) are therefore not sufficiently measurable, or baseline measurements are lacking. Health insurers continue to inventory which monitoring is available within the broader sector and to explore the possibilities for direct monitoring, with due attention to limiting the administrative burden for healthcare providers" (page 121). The materiality table lists the targets column as "Under development" (page 120).

The sector framework it works within is quantified and reported: primary raw material use down 50% and unsorted residual waste down 75% by 2030 against 2016, maximally circular healthcare by 2050, plus 2026 implementation-plan targets of 20% of directly purchased medical aids reused, 5% less incontinence material than 2022, raw material use of purchased care 20% lower and unsorted residual waste 25% lower than 2018. Achmea frames these as "shared ambitions ... the framework within which we annually translate relevant topics from the implementation plan into our own healthcare procurement policy" (page 120).

The measurement gap is specific: the RIVM Monitor Sustainability and Health. Baseline measurement of June 2025 "forms the basis for measuring performance", but "there is not yet a national measurement method for primary raw material use" (page 121).

Reference: page 120

The index points E5-4 to the resources chapter's How we manage impacts, risks and opportunities paragraph (page 179), and what is there is a qualitative description of the value-chain inflows Achmea finances rather than tonnages of its own.

What is disclosed. Sector context is quantified from third-party sources: Dutch healthcare "is responsible for approximately 13% of national abiotic raw material use (non-living resources)", and "Many raw materials are used for medical single-use products, which due to regulations are often used only once. This leads to waste and dependence on scarce materials, such as minerals for chips in medical equipment" (page 120). Management of inflows is described through procurement: sustainability criteria in contracts with suppliers of medical aids "such as limiting packaging, preventing waste and promoting reuse", and the joint inventory into the reuse of medical aids that doubles as a baseline (pages 120-121).

Reference: page 126

The anchor policy is the Human Rights and Labour Rights Statement, published on the website and approved by the Executive Board, which "is responsible for keeping it up to date", with Supervisory Board oversight (page 126). It commits Achmea to the International Bill of Human Rights and the UNGPs "based on the 'Protect, Respect, Remedy Framework'", the ILO core conventions, the OECD Guidelines, the UN Global Compact, PRI, PRB and PSI. On wages: "respect for labour rights means promoting a living wage as an essential component of decent work." On the floor: "we do not tolerate child labour, forced labour or human trafficking in any of our activities" (page 127).

A new People strategy frames the topic: "we developed the 'Sustainable working. Together' People strategy, focused on three pillars: continuous development, effective collaboration and achieving results", built with trade unions and works councils (page 126). Four sub-topic policy areas follow (pages 127-129): inclusion, diversity and equality, including a separate ID&E policy for the Executive Board and Supervisory Board; training and education, with employability principles from 2023, All You Can Learn and the TOP dialogue replacing appraisals since 2019; work-life balance; and prevention of violence and harassment, with the General Code of Conduct, the Policy on Undesirable Conduct, aggression guidelines and the Confidential Advisers Policy.

Reference: page 131

Engagement runs through formal representation and a recurring survey. "We involve our employees in the development of policies and our organisational culture. We do this through team meetings, managers, works councils and the annual Employee Engagement Survey (Medewerkers Betrokkenheidsonderzoek (MBO)), which we also conduct in our international business units in Australia, Greece, Slovakia and Türkiye. The results are discussed at team level with senior management and the Executive Board" (page 14).

Representative bodies are named: "regular consultation with Achmea's Central Works Council and the works councils for the individual units in the Netherlands", and "Dutch employees are also involved in the collective labour agreement (CLA) process, and the CLA has been discussed with the trade unions" (pages 14-15). The People strategy itself was developed with those bodies (page 126), and 90% of employees are covered by a collective labour agreement (page 132).

The survey feeds policy rather than sitting apart from it: identification of psychosocial workload risks "is based in part on the results of the Employee Engagement Survey (MBO). The outcomes of the RI&E are discussed within the relevant management teams and form the basis for action plans that are discussed with the works council" (page 128). Questions on inclusion have been added to exit interviews (page 129).

Reference: page 127

Four channels are described. The Whistleblower Scheme, "based on the Dutch Whistleblowers Protection Act and ... published both internally and externally", lets anyone working for Achmea report a suspected wrongdoing to an internal or external confidential adviser, with the reporting person's rights and privacy protected (page 127). The Policy on Undesirable Conduct covers "bullying, discrimination, (sexual) harassment, aggression and other forms of transgressive behaviour", is aligned with the Dutch Working Conditions Act and is published on the website (page 128). The Confidential Advisers Policy "applies in addition to the Policy on Undesirable Conduct and the General Individual Complaints mechanism" (page 129), and separate guidelines cover customer-directed aggression, with "preventive measures, safety instructions, aftercare following incidents, and the role of managers and incident management" (page 128).

Remediation sits in the Human Rights and Labour Rights Statement: "Where negative impacts occur and are identified by us, we aim to provide remediation or work collaboratively on solutions where it has been established that we have caused or contributed to these impacts" (page 126). Achmea does not report a measure of how far employees trust or are aware of these channels.

Reference: page 129

Inclusion actions in 2025 are concrete: "Visible inclusion measures include the introduction of quiet, rest and prayer rooms at all locations, improved accessibility of facilities, and increased attention to diversity in recruitment. Diversity criteria have been integrated into the appointment process for senior management, the Executive Board and the Supervisory Board. Looking ahead, we plan to increase diversity at entry level, monitor this, and include questions on inclusion in exit interviews" (page 129). The action list on page 125 adds a gender dashboard, an ID&E survey, inclusive workspaces and ID&E training. External commitments include the Charter Talent to the Top, the Prestatieladder Socialer Ondernemen and the Declaration of Equal Opportunities (page 127).

Development: All You Can Learn gives permanent employees and agency workers with more than three consecutive months' service "unlimited access to training programmes aligned with both their current role and their future career ambitions. Work-related training is fully reimbursed and may be undertaken during working hours. For career development outside the direct role, we offer financial support of up to EUR 5,000 per programme", plus three AYCL days a year under the collective labour agreement (page 127).

Reference: page 125

Six targets with 2025 outcomes are published, four met and two missed. Gender diversity: "We aimed for 35% of top management positions to be held by women in 2025, with an ultimate ambition of 40% in 2030 ... At the end of 2025, 34.9% of top management positions among employees employed by Achmea Interne Diensten and Achmea B.V. were held by women; for Achmea as a whole, this percentage was 35.5%" (page 132). Social entrepreneurship: target 1.16% of FTE from the PSO target group, actual 1.2%. Training: target 50% participation in All You Can Learn, actual 61%; target AYCL evaluation score 7.5, actual 8.5. Vitality: target MBO score 7.2, actual 7.3 (pages 125, 134). Inclusion: "Our objective was to achieve a minimum inclusion score of 8.0 in the MBO in 2025 ... This target was not achieved in the 2025 MBO", the score being 7.9 against 7.8 in 2024 (page 133).

Two forward points. For 2026, "following the completion of the new corporate and People strategy, a working group will define new ID&E objectives and interventions" (page 133). And a KPI was dropped: "In the previous year, Achmea reported a KPI for the absenteeism rate. For 2025, no separate target has been set, as absenteeism did not require additional steering" (page 134).

Reference: page 132

Headcount at 31 December 2025 was 16,369 against 15,762 a year earlier: 12,159 in the Netherlands excluding third-party companies, 895 at third-party companies in the Netherlands, 3,178 in the rest of Europe and 137 in the rest of the world. The geographic split of third-party company employees "has been revised compared to the 2024 report. Employees of third-party companies, in particular Eurocross Assistance, do not work exclusively in the Netherlands" (page 132).

By gender the total is 8,087 men and 8,282 women (2024: 7,769 and 7,993). By contract type, permanent 7,698 men and 7,640 women, temporary 389 men and 642 women, with 7 men and 7 women on zero-hours contracts included in the temporary row. By working time, full-time 7,277 men and 5,356 women, part-time 810 men and 2,926 women, a distribution Achmea later uses to explain the pay gap. By age, under 30: 802 men and 1,107 women; 30 to 49: 3,931 and 4,466; over 50: 3,354 and 2,709 (Tables 1, 2, 4, page 132).

Turnover and flows: outflow 1,506 (2024: 1,648), turnover rate 10% (11%), and "The number of employees who joined in 2025 was 2,113, and the percentage of employees covered by a collective labor agreement is 90% as of December 31, 2025". Workforce cost is cross-referenced to Consolidated Financial Statements Note 24.

Reference: page 132

The index directs S1-7 to the Metrics and targets, Workforce characteristics paragraph (page 180), and what is reported there is a single figure: "Number of Non-employees 2,136" for 2025 against 2,327 for 2024 (Table 3, page 132).

Scope is defined earlier, which matters for reading that number. The chapter descriptions cover "employees employed by Achmea B.V. or its subsidiaries, individual contractors (self-employed professionals) working for us, and persons working for us through entities primarily engaged in labour intermediation, such as temporary employment agencies. Employees of outsourced services, suppliers and external advisers fall outside this scope" (page 125). Separately, 895 employees of third-party companies in the Netherlands sit inside the 16,369 headcount, so the two populations are distinct.

What is missing is the split the requirement asks for. The 2,136 figure is not broken down between self-employed people and people provided by undertakings primarily engaged in employment activities, and is not disaggregated by country or gender. The All You Can Learn entitlement does reach part of this population: agency workers "who have worked for Achmea for more than three consecutive months are given unlimited access to training programmes" (page 127). Recorded as reported because the index gives a reference and a quantified metric is published, with the incompleteness stated rather than inferred.

Reference: page 132

The index points S1-8 to Metrics and targets, Workforce characteristics (third table) (page 180). Table 3 on page 132 reports the coverage figure in its narrative: "the percentage of employees covered by a collective labor agreement is 90% as of December 31, 2025".

Social dialogue structures are described in the surrounding chapter. Achmea holds "regular consultation with Achmea's Central Works Council and the works councils for the individual units in the Netherlands. Dutch employees are also involved in the collective labour agreement (CLA) process, and the CLA has been discussed with the trade unions" (pages 14-15). The agreement is the vehicle for several reported employment terms, including the 34-hour week since 2021 and three All You Can Learn days a year (page 127). At the foreign unit Union, "ID&E forms an integral part of the collective labour agreement, which stipulates that all employees are treated equally" (page 127).

What the requirement asks for and does not get: the 90% is a single global figure, with no breakdown by country or region, no separate European Economic Area figure, and no disclosure of the percentage of employees in countries with workers' representatives. The 10% not covered is not characterised. Recorded as reported because the index gives a specific reference and the coverage percentage is published.

Reference: page 132

Board and top management. Table 5 on page 132 gives headcount by function at 31 December 2025: Supervisory Board 5 men and 3 women (2024: 6 and 3); Executive Board 3 men and 3 women, unchanged; other top management 248 men and 135 women (2024: 241 and 128); total Achmea 8,087 men and 8,282 women. A footnote adds that "75% of the members of the Supervisory Board of Achmea B.V. qualify as independent based on the ESRS definition, in combination with principle 2.1.8 of the Dutch Corporate Governance Code".

Female share by country (Table 6, page 133): the Netherlands excluding third-party companies 34.9% of top management and 47.8% overall; Greece 14.3% and 48.8%; Slovakia 37.5% and 71.4%; Türkiye 16.7% and 56.9%; other including third-party companies 44.2% and 64.8%; total Achmea 35.5% and 50.6%, against 34.9% and 50.7% in 2024.

Age distribution (Table 4, page 132): under 30, 802 men and 1,107 women; 30 to 49, 3,931 and 4,466; over 50, 3,354 and 2,709. Achmea reads the profile back into pay: "The average age of women is lower than that of men. This may indicate that men more often reach higher positions within the salary scales because they have more work experience" (page 133).

Reference: page 134

Training hours are reported by gender and region (Table 13, page 134). Average training hours per employee in 2025: the Netherlands excluding third-party companies 16.8 for men and 20.2 for women, against 22.0 and 25.0 in 2024; other 15.5 and 19.9, against 8.4 and 9.2; total 16.1 for men and 19.5 for women, against 19.1 and 20.2. So hours fell in the Netherlands and rose sharply elsewhere, a movement the statement does not explain.

Performance and career development reviews carry an explicit gap for the largest population: the Netherlands excluding third-party companies is reported as N/A for both genders in both years, footnoted "Since 2019, we have replaced the traditional career and appraisal discussions with TOP, a new approach focused on continuous learning and intrinsic motivation. The holding of TOP discussions is not recorded." For other entities, 70% of men and 63% of women participated in 2025, against 95% and 95% in 2024.

Achmea adds its own programme metrics. "We annually measure employee participation in the AYCL programme. In 2025, this percentage amounted to 61%, thereby exceeding our target of 50%", against 68% in 2024, with an employee satisfaction score for All You Can Learn of 8.5 against a 7.5 target and 8.6 in 2024 (Table 12, page 134).

Reference: page 134

Entitlement and take-up are both reported. "99% of Achmea employees are entitled to family-related leave. The remaining 1% concerns employees above collective labour agreement (CLA) level, working in countries where family-related leave is not regulated by law" (footnote to Table 15, page 134).

Take-up by gender (Table 15, page 134): the percentage of employees who have taken family-related leave was 7% for men in 2025 against 8% in 2024, 14% for women against 17%, and 10% in total against 13%. Both genders and the total declined year on year; the statement does not explain why.

Policy context sits under S1-1. "Promoting wellbeing and enabling a healthy work-life balance are key principles of our personnel policy", with arrangements in the Dutch collective labour agreement "for informal care leave, remote working, leave-saving schemes, sabbatical leave, unlimited bereavement leave, and benefits for birth and maternity leave that exceed statutory requirements" (page 129). Achmea aligns with ILO standards "particularly in the area of workers' rights and maternity protection". Dutch CLA employees have had a 34-hour working week since 2021 (pages 125, 129). Eureko Sigorta offers extended parental leave and Interamerican family-friendly events and remote working (page 128). Work-life balance is tracked through the MBO vitality score of 7.3 against a 7.2 target.

Reference: page 133

The unadjusted gender pay gap is reported on two scopes and three years (Table 7, page 133): the ratio of average gross hourly wage in the Netherlands excluding third-party companies was 16.9% in 2025, 16.6% in 2024 and 17.9% in 2023; for total Achmea 20.8% in 2025 and 20.9% in 2024, with 2023 not available. a "positive percentage means that the average gross hourly wage of men is higher than that of women", and calculations use gross hourly wage "so that differences between part-time and full-time positions do not affect the outcome".

Achmea then decomposes it. By salary scale (Table 8), the Netherlands excluding third-party companies shows top management 2.2%, CLA scales J and K 5.6%, G, H and I 4.3% and F or lower 0.8%; for total Achmea the same rows read 4.2%, 7.4%, 11.0% and -6.2%. A 2025 analysis of Dutch CLA employees, adjusted "for, among other things, years of service and job levels", concluded "that, when taking factors such as salary scale and number of years of service into account, gender has no influence on the salary of these employees within Achmea".

Reference: page 134

Four channels report numbers for 2025. "The Committee for the General Individual Complaints mechanism received 1 complaint, which was declared inadmissible. In addition, 2 reports were made in 2025 under the Whistleblower Scheme (2024: 3 reports)." The Committee on Undesirable Conduct "received 9 complaints, of which 1 was declared unfounded. Three complaints were declared inadmissible and three complaints were resolved. The committee is still handling 2 complaints." Confidential advisers "supported 131 cases (2024: 140 cases). Most complaints related to a disrupted employment relationship (50%), bullying (15%) and (sexual) harassment (13%)" (page 134).

Severe human rights impacts are a nil return with the consequence stated: "In 2025, we received no indications of reports relating to serious human rights incidents involving employees. No fines, penalties or compensation payments were made" (page 134).

One forward commitment is recorded: "In 2025, we plan to expand these data to include incidents involving external customers directed at our employees", (page 134), which fits the separate guidelines for dealing with customer aggression (page 128). Foreign units "apply their own processes. At Eureko Sigorta, these include, among other things, the identification of discrimination, corrective actions and monitoring" (page 132).

Reference: page 136

The overarching policy is the Human Rights and Labour Rights Statement, which "describes our policy on human rights and labour standards, both for our own operations and for our relationships within the value chain" (page 136). Expectations are explicit: "We expect healthcare providers to ensure safe working conditions, protect the physical integrity of workers, and promote personal development and training." The operational instrument is the healthcare procurement policy, which incorporates the national IZA, TAZ and AZWA objectives, with "reducing the high workload and administrative burden for workers in healthcare" as an integral part.

For investments, "we have incorporated policies on human rights and labour standards into our Socially Responsible Investment policy. This policy is a translation of the Achmea Human Rights and Labour Rights Statement", with a due diligence process weighing "the severity, scale, irremediability and likelihood of the violations" and an exclusion limb: "We exclude companies that systematically violate international standards, including labour rights. We do not tolerate forced labour, modern slavery, human trafficking or child labour" (page 138). The Appendix B index references the S2-1 paragraph 18 datapoint (page 185).

Reference: page 136

Engagement with healthcare workers is indirect and mediated by sector structures, which Achmea states openly: "Employees of healthcare organisations are represented through their professional associations, industry organisations and trade unions in the drafting of the IZA and TAZ, the AZWA and collective labour agreements", with the perspectives of employees incorporated "Through consultations with a broad coalition of parties, coordinated by the Ministry of Health, Welfare and Sport (VWS)" (page 136).

The newest agreement puts worker involvement at its centre: "The AZWA emphasises the importance of involving healthcare workers in reducing administrative burdens. The approach explicitly focuses on placing the day-to-day work of healthcare professionals at the centre and safeguarding their influence and involvement in the implementation of measures aimed at reducing regulatory pressure. Consultations take place at sector level, with the frequency and format depending on the policy phase and the subject matter" (pages 136-137). The AZWA was "concluded in July 2025" (page 135).

A value-chain risk mapping is under way: "In 2025, the Dutch Association of Health Insurers (Zorgverzekeraars Nederland) carried out an analysis to gain insight into the key potential human rights risks in the healthcare value chain ... These outcomes will be incorporated into the Double Materiality Assessment for 2026" (page 137).

Reference: page 137

Achmea is unusually direct about the limits. "Within the framework of the IZA/AZWA, we do not have our own dedicated processes. Through our complaints policy, workers in the value chain can directly raise their concerns and needs with us. The privacy of the reporting party is protected in line with the statutory framework, and the details of the complainant are not shared unless consent has been given. Complaints can also be submitted anonymously. At present, we are not yet able to report on how we assess the extent to which workers in the value chain are aware of, and have confidence in, our complaints policy" (page 137).

For investee workers the mechanism is leverage rather than Achmea's own channel. "In cases where companies in which we invest have actually caused or contributed to negative impacts, we require them to take remedial action and/or provide compensation to affected parties. These companies must offer grievance mechanisms for affected workers ... In extreme cases, we may decide to remove a company from our portfolio and exclude it from future investments" (page 138).

A nil return is reported for the healthcare limb: "In 2025, we received no indications of reports concerning serious human rights issues or incidents involving workers in the value chain at healthcare providers in the Netherlands" (page 136).

Reference: page 137

The principal action is the allocation of national transformation funding. "Health insurers play an important role in the allocation of the financial resources made available by the Ministry of Health, Welfare and Sport (VWS) following the IZA. The allocation of financial resources to healthcare providers is based on plans assessed by health insurers. Payments to healthcare providers, based on achieved KPIs, are proportionate to the market share of the health insurers. The IZA runs from 2023 to 2026" (page 137). Table 1 quantifies Achmea's share: of transformation plan amounts agreed with health insurers, EUR 740 million total and EUR 222 million Achmea; estimated available for approved plans EUR 615 million and EUR 184 million; final payable and paid EUR 126 million and EUR 38 million.

Monitoring is explicitly someone else's: "Monitoring of progress towards the objectives linked to the IZA, TAZ and AZWA is the responsibility of the Ministry of Health, Welfare and Sport (VWS)", and Achmea uses that monitoring in the "design and further development of our own monitoring of objectives within the healthcare procurement policy". It also states the causal limit: workload "is influenced by multiple factors, some of which fall outside the direct sphere of influence of health insurers" (page 137).

Reference: page 138

The index itself records the nil return: S2-5 points to the Metrics and targets sub-paragraph "no targets have been established (Insurance & services and Investments & financing)" (page 181). The chapter states it twice. For investments: "for the 2025 reporting year no specific targets have been defined, nor do we envisage any specific targets for the coming years" (page 138). For insurance: "Our objectives focus on keeping healthcare affordable and accessible and are derived from the objectives set out in sectoral healthcare agreements. Currently under development" (page 135).

What is reported instead are sector targets Achmea contributes to. "Under the AZWA, a labour market target has been set for 2028 aimed at preventing the need for an additional 100,000 FTE. A large part of this target is to be achieved through measures focused on reducing workload, administrative burdens and improving the use of technology" (page 137). And: "Within the AZWA, health insurers and healthcare parties have committed to a target of a maximum of 20% administrative time for healthcare providers by 2030."

Reference: page 142

The policy set is listed in the materiality table on page 139: the Human Rights and Labour Rights Statement, Achmea Code of Conduct, Product Approval and Review Process, Privacy Policy, Information Security Policy and AI policy, plus for the Netherlands Trusted Communication and the Achmea Ethical Wheel.

On information quality, Trusted Communication applies "to all customer communications, regardless of brand or channel", with mandatory e-learning every three years: "We use plain language, avoid jargon and small print, and write for private customers at B1 level according to the Common European Framework of Reference for Languages (CEFR)" (page 142). Websites "largely comply with level AA of the international accessibility standards set out in the Web Content Accessibility Guidelines (WCAG 2.1)". On product access, the Product Approval and Review Process "ensures that products and services are only marketed or distributed after due consideration of the interests of consumers" (page 143).

On privacy and AI, the privacy policy covers data security, breach procedures, data subject rights and external processors, with mandatory privacy impact assessments for new processing (page 143). "We are committed to human-centred and trustworthy AI. Our AI policy applies to all business units ... AI systems are classified in advance according to risk, registered in a central register and monitored", aligned with the EU AI Act (page 142).

Reference: page 145

Engagement runs through several standing channels. "We involve customers in evaluating and improving our information through various methods, such as targeted surveys, councils, panels and Net Promoter Score (NPS) measurements. Customers can provide feedback, both positive and negative, via our websites and social media. We use this feedback to adjust and refine our communication strategies" (page 145).

The cooperative structure gives customers a formal voice: "The Vereniging Achmea plays an important role in representing the interests of Achmea's customers. All Achmea customers are automatically members of this association, which focuses on representing collective customer interests, safeguarding Achmea's continuity and creating value" (page 145). Its Members' Council meets three times a year with the association board and the Executive Board, runs three thematic working groups a year, and held 2025 expert sessions on "data profiling and its implications for inclusion and insurability" (page 14).

Two limits. No Executive Board member is named with operational responsibility for consumer engagement, and Achmea states that "As our policies and actions are part of an ongoing process, we do not specifically monitor the effectiveness of policies and actions in relation to the material impacts, risks and opportunities associated with the material topics described in this chapter" (page 145).

Reference: page 144

The complaints policy is set out at length in a dedicated text box. Customers, consumers "and other stakeholders in the value chain" can report concerns "about, for example, communication, the environment and human rights" through websites, email and telephone. "Our complaints policy explains how we follow up on reported issues. We record the details of each report, including where and why something went wrong, as well as the specific products or topics involved" (page 144).

Service standards are specific. "We aim to maintain telephone contact with complainants wherever possible. Reports that may cause significant harm to the complainant or to Achmea receive additional attention ... Our complaints policy ensures that submitting a complaint has no negative consequences for the complainant." Internal transfers carry context forward "so that the complainant does not have to repeat their story multiple times", and "They receive an initial substantive response within five working days."

Escalation is described: "If a complainant is not satisfied with the response, we offer a second review ... If the matter still cannot be resolved, we inform the complainant about the next steps, including the option to refer the matter to dispute resolution bodies or the courts." Quality is tracked: "Using KPIs, we monitor our performance in complaints management, including the timeliness of the initial substantive response and the accuracy of assessments."

Reference: page 145

Achmea states the position on actions plainly rather than constructing a list: "Actions relating to the topic Consumers and end-users form part of a continuous process and follow from the policies, guidelines and codes described above. Their implementation does not require specific actions or a detailed action plan. We therefore do not have a list of key actions undertaken in 2025 or planned for the future" (page 145). It also says it does "not specifically monitor the effectiveness of policies and actions" for this topic, with senior management overseeing implementation.

What is nonetheless reported as delivered. On information quality, "In 2025, Achmea received approximately 3,500 complaints relating to information provision, ranging from language use to unclear communication. Where possible, improvements were made to communications, policy conditions or websites. In 2025, no AFM fines were imposed in relation to consumer information obligations" (page 146). On privacy, "In 2025, no material privacy breaches were identified that led to supervisory intervention (2024: nil)", and "We have a cybersecurity insurance policy for incidents with a material impact. To date, no claims have been submitted under this policy" (pages 145-146).

Reference: page 145

Four metrics are reported, and each carries an explicit statement about whether a target exists.

Access to healthcare: "Two metrics have been defined to measure access to healthcare: a. Percentage of insured persons registered with a general practitioner ... b. Clients placed in a long-term care (Wlz) delivery form" (page 145). On primary care, 98.8% of insured people were registered with a GP, 17,353,848 in absolute terms, a 0.1 point decline; "The data are sourced directly from the external party Vektis. No specific target has been formulated" for 2025. On long-term care, "99.5% of Wlz clients under the responsibility of the Zilveren Kruis care office received some form of Wlz care", sourced from the National Health Care Institute, again with no target for 2025 (pages 145-146).

Training, where targets exist and were missed: Trusted Communication 2.0 completion among Dutch employees rose from 84% to 87% against a 100% target, and the privacy e-learning fell from 97% to 94%. "The annual target of 100% was not achieved because some employees were still within the three-month period or had other valid reasons for non-completion, such as prolonged absence" (page 146).

Two further metrics are in development "To better substantiate our impact on access to healthcare and health" (page 141). No target is set for privacy incidents or information-provision complaints.

Reference: page 148

The policy set in the materiality table comprises the Human Rights and Labour Rights Statement, Achmea's General Code of Conduct, the Whistleblower Scheme, the Integrity and Fraud Policy, the Tax Policy Management Policy, the risk management policy (SIRA) and the complaints policy (page 148). The Code of Conduct is mandatory for all employees in the Netherlands and abroad; "Failure to comply with the code may have serious consequences, such as dismissal or legal action", and it covers conflicts of interest, use of company assets and prevention of corruption, while encouraging employees to "acknowledge and share mistakes in order to learn and improve" (page 128). All employees in the Netherlands "are required to take an oath or affirmation for the financial sector" (page 148).

Governance mechanisms: "At group level, there is an Ethics Committee, consisting of colleagues and external parties, which provides advice on ethical issues" (page 149). A Systematic Integrity Risk Assessment runs annually "within all business units, including our international entities". Training is mandatory and monitored: "The e-learning Integrity is mandatory for all Achmea employees and for the Supervisory Board", and "Participation in all mandatory training programmes is monitored and appropriate measures are taken if the training is not completed" (page 149). Tax policy holds that profit "is taxed where the profit-generating activity takes place".

Reference: page 150

G1-3 Targets related to business conduct is a standalone disclosure requirement only from the 2025/2026 ESRS. Achmea's statement was prepared under the 2023 ESRS, where business conduct targets fell under MDR-T, and the content index routes that content through G1-1. Its MDR-T row, "Tracking effectiveness of policies and actions", reads: "See the information included below under Disclosure Requirements: E1-4, E2-3, E4-4, E5-3, S1-5, S2-5, S4-5, G1-1." (page 177).

A stated target exists. The materiality table sets the target at 100% of Dutch employees completing integrity training, with a 2025 result of 95% (page 148), and Table 1, Indicators of ethical corporate culture, reports "% of Dutch employees who have successfully completed the integrity e-learning" at 95% in 2025 against 97% in 2024 and a 100% target, alongside nil targets and nil outcomes for the number of convictions and the amount of fines for violating anti-corruption and anti-bribery laws (page 150). The shortfall is explained: "Due to absences and the three-month period for new employees, the completion rate is below 100%."