Ackermans & van Haaren

Governance of sustainability matters

Reference: pages 267-268. The index routes GOV-1 to section 1.5 and to the "Corporate governance statement, 1. General information" (page 286); composition and diversity datapoints are incorporated by reference (page 260).

Since 2019 the ESG policy "has been coordinated by a member of the executive committee (Andre-Xavier Cooreman)" (page 267).

Bodies and cadence (page 267):

• The ESG steering committee - the two co-CEOs, the CFO, the Secretary-general and the executive committee member responsible for ESG - meets twice a year on policy, progress, ambitions and priorities.
• The ESG working group meets "on average every 4 months" and runs the operational rollout, coordinated by the Sustainability Director with the Sustainability Manager, the Chief Human Capital Officer, legal, investor relations and finance.
• The executive committee "reviews and approves the proposals from the ESG steering committee and reports at least once a year to the audit committee, remuneration committee and the board of directors".
• The 4 material topics and their IROs are reviewed at least once a year in a board ESG update.

On expertise, "a selection of board members have broad expertise to oversee the rollout of sustainable business models and specific knowledge in material topics such as responsible shareholder, climate change and energy transition".

Information provided to and addressed by the administrative bodies

Reference: pages 263, 266-267. The index points to the "Corporate governance statement, 2. Board of directors - 2.4 Activity report" for the list of topics actually addressed (page 286), so the statement itself carries only the channels.

• "The views and interests of stakeholders regarding material sustainability-related impacts, risks and opportunities are shared with the audit committee" (page 263).
• Step 6 of the double materiality assessment: "The results were reviewed by the audit committee and approved by the board of directors" (page 266).
• The executive committee "reports at least once a year to the audit committee, remuneration committee and the board of directors" (page 267).
• The four material topics and their IROs "are reviewed at least once a year during an ESG update by the board of directors. These topics are also inherently part of investment discussions and updates provided by group companies and investment managers to the board" (page 267).
• On 24 February 2026 the board assessed performance against the 2025 ESG targets (page 49); on 24 March 2026 the remuneration committee "reviewed the performance against the 2025 ESG targets, discussed the proposed ESG targets for 2026" (pages 35, 43).

No minuted list of sustainability matters per meeting, and no statement of how the bodies considered trade-offs, is given inside the Sustainability Statements.

Sustainability performance in incentive schemes

Reference: pages 260, 267, and the remuneration report at pages 49-50, incorporated by reference ("Remuneration report, 6. Remuneration of the executive committee, and 6.2.4 STI - Performance on ESG targets 2025 + STI - ESG targets 2026", page 286).

Mechanism (page 49). The short-term incentive of the executive committee is a per mille of consolidated net result; 80% is subject to return on equity and 20% "is subject to the performance on the 4 material ESG topics". There is no payout below a consolidated net result of 100 million euros and the STI is capped at 150% of base pay.

"The board linked the goals as of 2025 to the four material topics identified in the double materiality analysis (DMA). These topics are: Responsible Shareholder, Climate Change, Energy Transition, and Talent Management. For each material topic, one ESG goal and a related KPI were proposed" (page 49).

2025 outcome - "the board concluded that all four targets were fully achieved" (page 49): responsible shareholder, achieved at 100% of closed transactions and 95% of AuM; climate change, achieved at 95% of AuM; energy transition, achieved at 98% of AuM; talent management, achieved at 90% of AuM.

For 2026 the weighting shifts: governance 50%, environment (climate change and energy transition) 25%, social 25% (page 50). No share of total remuneration is expressed in euros or as a percentage of pay.

Statement on due diligence

Reference: page 267. The index routes GOV-4 to section 1.5 Governance of sustainability matters (page 286).

The statement carries the required mapping table of the five core due diligence elements to the sections where each is covered (page 267):

• (a) Embedding in governance, strategy and business model - sections 1.2.1 Strategy and business model, and 1.4.2 Impact, risks and opportunities.
• (b) Engaging with affected stakeholders - section 1.3 SBM-2.
• (c) Identifying and assessing adverse impacts - sections 1.4.2, 2.2.4, 2.2.9 and the Risk chapter.
• (d) Taking actions to address those adverse impacts - "Potential material negative impacts are related to climate change and talent management (training skills and development)", handled in sections 2.2.4 (transition plans, decarbonization levers, targets) and 3.1.5 / 3.1.6 for talent management.
• (e) Tracking effectiveness and communicating - "Sustainability Statements, section 2 - 4. Relevant datapoints are considered in function of the material topics identified."

Worth flagging: the (d) row names climate change and talent management as potential material negative impacts, while the DMA outcome table records impact materiality as "No" for both and financial materiality as a risk (page 264).

Risk management and internal controls over sustainability reporting

Reference: page 260. GOV-5 is disclosed entirely by incorporation by reference, to the "Corporate governance statement, 8.3 Principal features of the internal control and risk management systems concerning the process of financial and sustainability reporting" and to the "Annual report of the board of directors - II. Consolidated annual accounts - 1. Risks and uncertainties", covering "ESG risks at the level of AvH NV and the level of the participations" (pages 260, 286).

Inside the statement, section 1.4.5 records that "the risk process integrates financial and ESG risks into the overall risk profile and risk management processes", within a framework "structured around its three main activities: 'Responsible investor', 'Responsible and active partner' and 'Sustainable company'" (page 267).

On data controls: ESG data is collected from group companies "via the ESG questionnaire, leveraging insights from 5 years of historical data" (page 267), and "AvH NV engages with the most relevant group companies so that robust ESG processes supported by their management teams are in place" (page 268).

No risk assessment findings, control deficiencies or remediation actions over sustainability reporting are reported.

Strategy, business model and value chain

Reference: pages 258-259, 262.

Perimeter. The statement covers the statutory parent with the subholdings AvH GC and AvH India ("AvH NV") and seven fully consolidated subsidiaries: DEME, CFE, Bank Van Breda, Deep C Holding, Nextensa, Agidens and Biolectric (page 258). AvH warns the datapoints "should be read and interpreted as those of an industrial conglomerate of these 8 companies rather than those of an investment company with a highly diversified portfolio of more than 30 companies, as the market perceives AvH" (page 259).

Business model. AvH NV "positions itself as the long-term partner of choice for family businesses and management teams", through a 'Responsible investment policy' across Core Segments and Growth Capital and 'Responsible ownership' exercised via board representation (page 262). Revenue was 5,961,612 thousand euros (page 290).

Value chain (page 262). Downstream "includes the non-fully consolidated companies within its investment portfolio"; AvH NV's upstream chain - consultancy fees, office costs, building maintenance - "is considered immaterial compared to that of the Subsidiaries".

Omissions. SBM-1 40(b) and 40(c) on ESRS sectors are omitted because "the underlying risk these disclosures aim to address is already covered in the current 'Responsible investment policy'" (page 260); 40 a iv / AR 12-1 on banned products is "Not relevant" (page 289).

Interests and views of stakeholders

Reference: pages 263, 281.

Stakeholder engagement is run "both at the Group level and within the group companies". A structured survey "has been in place since 2019 and the scope was further broadened in the last exercise in 2022, which achieved a response rate of 77%" (page 263). The survey has not been repeated since 2022; in 2025 "stakeholder discussions took place with ESG rating agencies, analysts, regulatory authorities and shareholders".

The statement tabulates eight stakeholder groups with purpose, platform and frequency: investment team, group companies, board of directors and shareholders (all labelled affected stakeholders), and financial institutions, analysts, regulatory authorities and rating agencies (users of the report) (page 263).

Stated limitation. "As a diversified multi-sector investment company, AvH faces challenges in directly accessing certain stakeholders such as customers, local communities and NGOs related to its group companies. Therefor, AvH provides guidance to its group companies to include relevant stakeholders in their assessments" (page 263).

For own workforce, members of the investment team "participate in bi-annual strategic update sessions covering AvH NV and the group companies" (page 281).

Omission. SBM-2 45(c), "Description of amendments to strategy and (or) business model", is listed as "Not relevant" (page 289).

Material impacts, risks and opportunities

Reference: pages 264-265.

The DMA produced four material topics (page 264): Responsible shareholder (impact), Climate change (risk), Energy transition (opportunity) and Talent management (risk). Only two map to ESRS topics - climate change to E1 mitigation, talent management to S1 training and skills development.

"Climate change is considered financially material at the consolidated level but does not reach the threshold for impact materiality. This conclusion is based on a bottom-up assessment using an AuM approach and reflects AvH's limited direct operational impact, its proportional ownership structure and the diversified nature of its portfolio" (page 264).

The five IRO rows (page 265):

• E1 risk - activities "are exposed to upcoming carbon taxes, including EU emissions trading systems ('EU ETS')".
• E1 risk - "Subsidiaries in real estate risk a decrease in value for buildings and assets that are less energy-efficient or have high embodied carbon."
• S1 risk - increased costs and performance loss from inadequate skills management.
• Energy transition opportunity - "Potential growth of the offshore wind business" at DEME.
• Responsible shareholder positive impact - "Supporting sustainable business models".

Omission. "The disclosure related to ESRS 2 48 (e) concerning the anticipated financial effects of IROs has been omitted." (page 260).

Processes to identify and assess material IROs

Reference: pages 263-266, 274.

Double materiality has applied "since 2019 when AvH started reporting under the NFRD". The assessment was rebuilt "in 2024 ... based on ESRS 2 and the implementation guidance from EFRAG IG1 'Materiality Assessment'" (pages 263-264). It is bottom-up: group company DMAs "covering more than 80% of AvH's Assets under Management" were consolidated upward (page 264).

Six steps (page 266): scoping; scoring AvH NV's own IROs; integrating group company DMAs; linking the 2019/2021/2022 stakeholder results and sanity-checking against ESG rating agency frameworks and SASB; calibration by external experts, financial institutions and peers; review by the audit committee and approval by the board.

Thresholds (page 266). "A topic must achieve a rating of at least 3.5 out of 5 to be considered material. Internal monitoring begins at a rating of 3." Scoring is pre-mitigation, "before any mitigating actions are applied, beyond what is expected of a typical company in the relevant industry based on its 'license to operate'". Financial materiality uses "the impact on net profit using for recurring impacts a rolling 10-year historical average".

2025. "A trigger-based review was performed in 2025... No updates were required" (page 264). Climate-specific risk identification also appears under E1-2 (2025 numbering), from section 2.2.2 (page 274).

Disclosure requirements covered

Reference: pages 286-289. The statement prints a real ESRS content index as Annex 1, plus a materiality annex and an explicit omissions index.

Annex 1 (pages 286-288) lists BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1 and IRO-2; under E1 - E1-1, SBM-3, IRO-1, E1-2, E1-3, E1-4, E1-6, E1-7, E1-8, E1-9; under S1 - SBM-2, SBM-3, S1-1 to S1-6, plus S1-7 and S1-13 each noted "Omitted in accordance with the phase-in provisions and the additional extension under the 'Quick Fix' Delegated Act"; and company-specific topics 'Energy Transition' and 'Responsible Shareholder' with MDR.P, MDR.A, MDR.M and MDR.T rows.

Annex 2 (page 288) records E1 material for "Climate change mitigation" and S1 for "Training and skills development", with E2, E3, E4, E5, S2, S3, S4 and G1 all "Not-material".

Annex 3 (page 289) names SBM-1 40 a iv AR 12-1 and SBM-2 45 c as "Not relevant", and E1-5, S1-1 (20, 20a, 20c, 21-24), S1-2 (27 d, 28) and S1-17 as "Not material based on the DMA performed". "AvH did not exercise the option to omit specific information related to intellectual property, know-how, or innovation results."

No ESRS-numbered disclosure appears outside these lists.

Transition plan for climate change mitigation

Reference: pages 274-275, 277. Indexed to section 2.2.4 (page 286).

AvH discloses that it has no transition plan. "AvH NV and the Subsidiaries do not yet have a Transition plan in accordance with CSRD, since a commitment to the 2050 horizon cannot currently be guaranteed, due to current technological limitations, missing innovation or lack of infrastructure readiness" (page 274). Instead they "will disclose their GHG reduction plans outlining their decarbonization efforts towards 2030, which are largely inspired by and, where feasible, adhere to SBTi or sector-specific frameworks".

Coverage datapoints (page 275):

"These targets have not been validated by the SBTi to demonstrate alignment with the Paris Agreement."

Locked-in emissions (page 277). "At DEME, the risk of locked-in GHG emissions from new vessel investments is mitigated by preparing new vessels for the transition to alternative fuels. The newly ordered dual-fuel vessels are methanol-ready. At CFE, CapEx with potential lock-in was assessed and considered non-material."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, the E1 IRO-1 section and E1-9 (pages 264-266, 274, 280). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical and transition split. "In line with the CSRD, AvH discloses climate-related risks including both physical and transition risks, on the basis of a qualitative assessment" (page 280). Both material E1 risks are transition risks: exposure to "upcoming carbon taxes, including EU emissions trading systems ('EU ETS')" and devaluation of real estate "that are less energy-efficient or have high embodied carbon" (page 265). EU ETS bites "as from 2027" for some subsidiaries.

Methodology. Bottom-up: group companies "assessed in their DMA the list of ESRS topics, including ESRS E1 climate change" (page 274), and "Group-wide guidance was issued in 2024" (page 280). Perimeter: "the Subsidiaries, with a primary focus on those that could materially influence the Group's balance sheet or income statement (i.e., DEME, Bank Van Breda and Nextensa)... based on a systematic review of assets (balance sheet) and revenue streams (income statement)".

No scenario analysis. None is described at consolidated level, and no high-emission physical scenario or 1.5 degree transition scenario is named for risk purposes; the scenario references in the report are target-setting pathways (pages 275-276).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and E1-9 (pages 274, 276-277, 280). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No ESRS-defined resilience analysis is reported. What the statement gives is the conclusion of its qualitative climate-risk assessment: "the Group's residual exposure to physical and transition risks, both in relation to assets and turnover, is considered limited. No material impact on the Group's financial position, financial performance or cash flows is anticipated over the short, medium or long term, after factoring in the mitigating actions implemented by the Subsidiaries" (page 280).

Implications for the business model (page 274). "Business models need to continue their transition but face several challenges, including lack of availability and scalability of new technologies, supply chains that cannot support scaling up, and customers' limited willingness to pay a price premium."

Uncertainty (pages 277, 280). Disclosures "remain qualitative, as the quantification of anticipated financial effects is currently impracticable".

Capacity to adjust (pages 276-277). Bank Van Breda "applies relatively short loan terms compared to the sector, which allows quick adjustments to changing regulations, market conditions and technological developments"; Nextensa aligns leased assets to CRREM; DEME's new dual-fuel vessels are methanol-ready.

Policies related to climate change mitigation and adaptation

Reference: page 274. Indexed to section 2.2.3 (page 287).

Scope. The policies "described in this chapter focus on climate change mitigation". Adaptation is out of scope by design: the material subtopic "excludes climate change adaptation (e.g. dykes)" (page 264).

Exclusions. "AvH NV's exclusion policy excludes investments in activities primarily related to the extraction and production of thermal coal. The AvH internal investment guideline further addresses oil- and gas-related activities." The exclusion policy is published on the website (page 284).

Targets inside the policy. A 55% GHG reduction by 2030 against a 2022 baseline at AvH NV level, and a portfolio goal "targeting for over 80% of AuM by the end of 2025 to have a GHG reduction plan with a view towards 2030"; in 2025 "95% of the AuM already have a GHG reduction plan towards 2030, even in emerging countries (SIPEF, Sagar Cements, etc.)".

Stated limits. "Target setting for Scope 3 emissions is not requested at this stage due to the heavy reliance on estimated data, mainly based on converting euros to CO2 equivalents ('spend-based method'), rather than on activity data." And: "Rather than setting bold ambitions without a well-defined and achievable plan, AvH believes in year-on-year progress substantiated by operational excellence, available technologies and innovation efforts."

Actions and resources in relation to climate change policies

Reference: pages 275-277. Indexed to section 2.2.4 (page 287).

AvH NV (page 275). "The reduction plan is based on an energy scan that identified potential energy saving measures. In the coming years, cooling systems will be replaced, heating will be provided through a heat pump, and solar panels will be installed to generate renewable energy."

DEME (pages 275-276). Three levers: "Operational efficiency: increasing productivity while reducing energy consumption; Technical efficiency: delivering more energy aboard with less fuel; and Fuel shift: transitioning to less GHG-intensive fuels". Its voluntary 17%-low-carbon-fuel target for 2026 is behind: "the 2024 (11%) and 2025 (14%) targets were not achieved. In 2024 and 2025, low-carbon fuels accounted for 5.8% and 5.5% of total fuel consumption, primarily due to limited availability and slower industry-wide adoption".

Others (page 276). CFE: renewable electricity on sites, fleet electrification, supplier engagement, an LCA "sustainability knowledge centre", and Pulse.

Financial resources (page 277). "At DEME, a separate budget is allocated to support the transition to low carbon fuels... monitored by management and periodically reviewed in the board", with no amount: "estimating the precise investment required... is challenging." No group-level climate CapEx or OpEx figure is disclosed.

Targets related to climate change mitigation and adaptation

Reference: pages 275-277. Indexed to section 2.2.4 (page 287).

AvH sets no group target: it "will not specifically define a target for its CSRD reporting scope... Instead AvH's disclosure will indicate how many Subsidiaries have set a target" (page 275).

Targets per entity (pages 275-277):

• AvH NV - Scope 1+2 minus 55% by 2030 vs 2022, "considered compatible with the Paris Agreement, taking into account the SBTi near-term framework for 2030 (1.5 degree C scenario)".
• DEME - "has not yet set absolute targets"; fleet intensity minus 40% by 2030 vs 2008 "measured per dredged cubic meter or installed megawatt", aligned to the 2023 IMO GHG strategy, the 2024 verified assessment confirming "a 30% reduction".
• CFE - Scope 1+2 minus 40% by 2030 vs 2020.
• Deep C Holding - Scope 1+2 minus 72% by 2030 vs 2024 (IPCC-aligned); Scope 3 minus 23%.
• Bank Van Breda - Scope 1, 2 and selected operational Scope 3 more than 55% lower by 2030 vs 2017.
• Nextensa - Scope 1+2 minus 95% by 2030 vs 2021; leased-asset Scope 3 minus 55% via CRREM.
• Agidens - minus 62% by 2030 vs 2023; Biolectric - none.
• Value chain: Sagar minus 18.8% per tonne cementitious by 2030 vs 2020, net zero 2050; SIPEF minus 42% E&I vs 2024 and minus 30.3% FLAG.

"Only Subsidiaries CFE, Deep C and Nextensa have defined Scope 3 targets", and none is SBTi-validated (page 275).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 277-279. Indexed to section 2.2.6 (page 287).

Scope 1 fell 16%, "mainly driven by DEME's activity mix, vessel occupancy and continued improvements in GHG intensity"; over 95% is DEME's. The percentage subject to regulated emission trading schemes is left blank (page 278).

Scope 2 was "broadly stable"; "30% of these emissions were attributable to DEME, 36% to CFE and 22% to Deep C Holding".

Scope 3 rose 15%. Largest categories: financed emissions 1,664,314 (up 7%), purchased goods and services 800,792, capital goods 351,252 (up 184%, "mainly driven by the acquisition of Havfram and the addition of two offshore installation vessels"), fuel and energy-related 271,450, upstream transport 240,937 ("newly identified and included in 2025"), use of sold products 157,561. Categories 9, 10 and 14 are "not considered relevant"; figures are "preliminary estimates... primarily derived from financial spend and estimated data (45%) and from primary data (55%)".

Intensity (page 279). Scope 1+2 141 tCO2/m euro (2024: 166); Scope 1+2+3 768 (706). The footprint "covers 98% of the AuM".

GHG removals and mitigation projects financed through carbon credits

Reference: pages 279-280. Indexed to section 2.2.7 (page 287).

Removals - a nil return. "AvH NV and the Subsidiaries have no GHG removals nor storage resulting from projects developed in their own operations or contributed to in their upstream and downstream value chain" (page 279).

Carbon credits (page 279). "The subsidiaries DEME and Bank Van Breda purchased and (partially) retired certified carbon credits. DEME acquired 250 tonnes of credits from a marine ecosystem restoration project to compensate the remaining emissions of its head office during renovation works. Bank Van Breda purchased and retired 1,786 tonnes of credits from a certified clean cookstove project to offset its Scope 1, 2 and 3 emissions related to its own operations."

The table reports 1,952 tCO2eq cancelled in 2025 (2024: none), of which 100% "share from removal projects" and 100% "share from Verified Carbon Standard", with 0% from reduction projects and no share of projects in the EU or qualifying as a corresponding adjustment. A further 84 tCO2eq is planned for cancellation "until 2027", totalling 2,036 tCO2eq, which ties to the 250 plus 1,786 tonnes described (page 280).

Two things a reader should check: the 2025 credits are classed 100% removal although the clean cookstove project supplying most of the volume is a reduction project, and the table carries a stray review marker, "Total (tCO2eq[BV1.1])".

Internal carbon pricing

Reference: page 280. Indexed to section 2.2.8 (page 287).

A nil return with a qualification: "AvH NV and the Subsidiaries do not have structural internal carbon pricing schemes to support decision-making or incentivize the implementation of climate-related policies and targets. However, as some Subsidiaries are subject to the EU ETS as from 2027, this is implicitly considered by factoring in the EU ETS price into operational and capital expenditure decisions" (page 280).

No carbon price level, no price trajectory, no share of emissions covered and no description of how the implicit EU ETS price is applied in capital allocation is given. The underlying exposure is the E1 transition risk in the IRO table: "Specific activities of Subsidiaries and across the value chain are exposed to upcoming carbon taxes, including EU emissions trading systems ('EU ETS') and other GHG emission regulations", naming DEME, CFE and Nextensa as "currently or potentially subject to these measures" (pages 265, 274).

Anticipated financial effects from climate risks and opportunities

Reference: page 280. Indexed to section 2.2.9 (page 287).

Qualitative only, and phased in to 2029. "For the reporting year ending December 31, 2025, disclosures will remain qualitative, as the quantification of anticipated financial effects is currently impracticable." And: "In line with the ESRS phase-in provisions, disclosure of financial quantification was planned as of 2027. This timeline has been further extended by the European Commission's 'Quick Fix' Delegated Act, granting an additional two-year deferral, i.e. until the reporting year 2029."

Method and perimeter. The assessment "covers the Subsidiaries, with a primary focus on those that could materially influence the Group's balance sheet or income statement (i.e., DEME, Bank Van Breda and Nextensa)", with "emphasis on residual exposure after considering current adaptation and mitigation measures".

Conclusion. "the Group's residual exposure to physical and transition risks, both in relation to assets and turnover, is considered limited. No material impact on the Group's financial position, financial performance or cash flows is anticipated over the short, medium or long term."

Opportunities are cross-referred to section 2.3 Energy transition; aligned turnover for "4.3 Electricity generation from wind power" was 30% of AvH turnover in 2025 against 26% in 2024.

No monetary amounts are given.

Policies related to own workforce

Reference: pages 281-282. Indexed to section 3.1.3 (page 287).

Scope statement. "The policies described in this section focus on training and skills development, not on other aspects related to own workforce" (page 281). The model is decentralised: "The HR functions at individual company level manage their employee-related policies, tailoring them to their specific business models and needs... each function maintains its autonomy in policy management".

AvH NV. "training and skills development are guided by the talent development policy. This policy outlines the framework and supports individual growth, with the AvH career model serving as its backbone. It aims to develop individuals aligning with the company's purpose, strategy, and 'who do we want to be' charter" (page 281). Annual "'looking back & forward' meetings" anchor development discussions, supported by the AvH Academy (page 282).

Subsidiaries (page 282). DEME and CFE are described because together they are "more than 85%" of headcount. Bank Van Breda "launched a new HR sub-department, Learning & Development (L&D)" in 2025. CFE uses "the CFE Academy, a digital training platform".

Declared omissions (page 289). S1-1 paragraphs 20, 20a, 20c, 21, 22 (human rights policy), 23 (accident prevention) and 24 (discrimination and diversity) are all omitted as "Not material based on the DMA performed".

Processes for engaging with own workers and workers' representatives

Reference: page 282. Indexed to section 3.1.4 (page 287).

Engagement is decentralised: "The HR functions at individual company level manage their processes for engaging with their own workers and, if applicable, with workers' representatives. Consequently, the approach for engagement with workers and their representatives may vary and is primarily determined by the company's business model. This approach can incorporate frameworks like eNPS and Great Place to Work and is, in principle, accessible to all employees."

Named processes (page 282):

• "At AvH NV, workforce engagement is assessed every two years using the eNPS methodology, integrated into a third-party well-being survey. Additionally, individual employee engagement is addressed during the annual performance review."
• "At Bank Van Breda, workforce engagement is also assessed by an external party every two years as part of the Great Place to Work survey."
• "DEME and CFE have similar processes in place. Engagement with workers' representatives is also conducted, if applicable."

Declared omissions (page 289). S1-2 paragraph 27(d) on a Global Framework Agreement and paragraph 28 on insight into vulnerable or marginalised workers are both omitted as "Not material based on the DMA performed". No senior person with operational responsibility for engagement is named and no assessment of its effectiveness is given.

Processes to remediate negative impacts and channels to raise concerns

Reference: page 282. Indexed to section 3.1.5 (page 287).

"Rooted in family values, AvH address material negative impacts on their own workforce through a structured and responsible approach, emphasizing ethical business practices and sustainability. When issues arise, they are appropriately investigated, and remedies are implemented as necessary. The effectiveness of these remedies is evaluated through case monitoring and, where relevant, employee feedback gathered via engagement or well-being surveys."

Channels. "The compliance functions at AvH NV and the Subsidiaries manage a whistleblowing process for reporting concerns or grievances. Employees are informed about these channels during onboarding and periodic training. Case reporting and monitoring are directed to the audit committee or board of directors, depending on the company."

Oversight and protection. "The audit committee or board of directors of group companies are deemed to annually review the appropriateness of the integrity code and the effectiveness of the integrity program and channels used to raise concerns, including whistleblowing. Policies at AvH NV and the Subsidiaries related to whistleblowing include protection against retaliation."

No number of cases raised or resolved is given, and no evidence on worker awareness or trust in the channels is reported.

Taking action on material impacts on own workforce

Reference: pages 281-283. Indexed to section 3.1.6 (page 287).

The action is engagement, not direction. "AvH engages with group companies so that remuneration committees, in which AvH NV is often represented, are actively involved in HR policies, management composition, succession planning and attraction of diverse talent. Depending on the company, these committees, together with the board of directors, oversee areas such as recruitment, training, personal development, performance appraisal and well-being" (page 282).

"AvH NV facilitates knowledge-sharing sessions and workshops for its group companies on HR-related topics such as talent management, training and skills development. Group companies are encouraged to adopt best practices in talent management and align their human capital strategy with business objectives and ESG vision" (page 283).

2025 initiative (page 281). "a strategic initiative was launched in 2025 to align business priorities with talent management in a focused way".

Resources and effectiveness (page 283). "Management teams at each entity determine the allocation of resources needed for talent management aspects. Effectiveness is monitored where possible and relevant through the evolution and trends in employee engagement." No CapEx or OpEx amount is attached to the actions.

Targets related to own workforce

Reference: page 283. Indexed to section 3.1.7 (page 287).

Portfolio coverage goals, not workforce outcome targets. "Goals are defined at the portfolio level, aiming for at least 80% of AuM to have a business-relevant talent strategy aligned with their strategy, and an employee engagement approach based on eNPS, Great Place to Work, or similar framework. AvH's approach to engage with the group companies aligns with to the UN PRI framework. Stakeholders, including workers at the investment company level via the ESG working group, were involved in the target setting."

"AvH does not impose top-down targets on the Subsidiaries but engages with them to have relevant targets in place. Performance will be monitored through the annual ESG questionnaire."

2025 performance. "In 2025, 95% of AuM reported having a business-relevant talent management policy, and 90% of AuM reported having an employee engagement approach." The same KPI carries remuneration weight: the 2025 talent management goal was "At least 80% of AvH's AuM have a business-relevant talent strategy and an employee engagement approach", recorded as achieved at 90% of AuM (page 49), and is kept for 2026 at 80% with a 25% weighting (page 50).

No baseline year, no interim milestones and no target on any training metric are given. Because S1-13 is omitted under the phase-in (page 287), there is no measured workforce outcome against which to read the target.

Characteristics of the undertaking's employees

Reference: page 283. Indexed to section 3.1.8 (page 287).

Headcount at 31 December 2025, covering AvH NV and the seven Subsidiaries:

Against 2024: total 10,091 - male 8,007, female 2,062, other 0, not reported 22.

By country. Belgium 6,849 (2024: 6,813), others 3,334 (3,278). "Belgium is displayed separately in accordance with ESRS as it represents over 10% of the total headcount. There are no other countries that represent over 10% of the total headcount."

Turnover. 1,095 leavers (2024: 1,139), a rate of 11% in both years, "defined as the number of leavers divided by the headcount at the end of the reporting year". "The highest relative employee turnover was recorded at CFE following organizational changes."

Two scope caveats. The table "only contains employees considered as own workforce and not yet the non-employees part of own workforce (as per the phase-in provision and the additional extension under the 'Quick Fix' Delegated Act)", and the numbers "do not match the pro forma headcount in the '2025 at a glance' section", reconciled via Note 24: Employment.