Addiko Bank

Section 11.1 ESRS 2 GOV-1 (p.38-41). Addiko discloses the composition of its bodies: the Addiko Bank AG Management Board has 4 executive members and the Supervisory Board 7 non-executive members (including works council); at Group level there are 22 management members and 33 supervisory members. Gender diversity is given per body, for example the Holding Management Board is 100% men and the Group supervisory bodies 61% men and 39% women. It names the seven Supervisory Board members and four Management Board members (CEO Herbert Juranek, CRO Tadej Krasovec, CMO and CIO Ganesh Krishnamoorthi, CFO Edgar Flaggl) with appointment dates, and states 80% of shareholder-delegated supervisory members are independent. It sets out the ESG governance framework, the roles of the Nomination, Remuneration and Audit, Compliance and AML Committees, the Chief Risk Officer's oversight, the ESG Working Group and subsidiary ESG SPOCs, plus annual Fit and Proper assessments and training for sustainability expertise.

Section 11.1 ESRS 2 GOV-2 (p.41-42). Addiko states that the Management Board and Supervisory Board are systematically informed about sustainability-related impacts, risks and opportunities as part of their governance duties. Under the Rules of Procedure, reporting to these bodies occurs at least twice a year, or more often if required. Reports include an assessment of Addiko's exposure to climate change risks, adaptation measures, and the monitoring of exposure limits in industries with high GHG intensity or physical risk. The Supervisory Board is updated on progress of ESG priority initiatives, which are supported by KPIs defined in the ESG strategy. The ESG strategy is reviewed annually, approved by the Management Board and presented to the Supervisory Board. The Management Board prepares the consolidated Sustainability Statement and submits it to the Audit, Compliance and AML Committee and the Supervisory Board for review and acceptance. Responsibilities are set out in the Charter and Rules of Procedure, including Attachment 2 on transactions requiring approval.

Section 11.1 ESRS 2 GOV-3 (p.42). Addiko discloses that remuneration for the Management and Supervisory Board is regulated under section 78a of the Austrian Stock Corporation Act within its Remuneration Policy. Sustainability considerations are integrated into incentive schemes for senior management, covering Management Board members and identified staff relevant to the ESG strategy (employees at B-1 level and certain key employees). ESG-related targets are set as individual KPIs during the annual performance review and defined together with the employee and their superior. These ESG targets carry a weighting of at least 5% of the total performance assessment for each eligible individual, with higher weightings depending on role. Because Addiko does not yet have specific GHG emission reduction targets and no transition plan is in place, the variable remuneration scheme currently does not include metrics tied to those criteria. Key features are outlined in the Group Remuneration Policy, approved and monitored by the Remuneration Committee. Supervisory Board members receive fixed remuneration with no sustainability-related parameters.

Section 11.1 ESRS 2 GOV-4 (p.43). Addiko provides a mapping under paragraph 32 showing where the core elements of its due diligence process are addressed across the sustainability statement. It lists five core elements and the cross-references: embedding due diligence in governance, strategy and business model is addressed under ESRS 2 GOV-1, GOV-2, GOV-3 and SBM-3; engaging with affected stakeholders under GOV-2, SBM-2, IRO-1 and S1-3 and S4-3; identifying and assessing negative impacts on people and the environment under IRO-1, SBM-2, SBM-3 and S1-3, S4-3; taking action to address negative impacts under IRO-1, SBM-3 and S1-3, S4-4; and tracking the effectiveness of these efforts under ESRS 2 MDR-M and MDR-T. The disclosure is presented as a table linking each due diligence step to the relevant paragraphs of the statement.

Section 11.1 ESRS 2 GOV-5 Risk Management (p.43-44). Addiko describes risk management and internal controls over sustainability reporting. A key component is the internal manual 'Preparation Process for the Sustainability Statement', part of the ESG Governance Policy, which defines departmental roles, control actions to verify data accuracy and timelines for preparation and review. The system covers data collection, processing and reporting, with data validation checks, manual review processes and internal audit reviews. Risks are prioritised by their potential impact on the accuracy, reliability and completeness of the statement. Four main risks are identified: completeness and integrity of data (mitigated by control functions such as the four-eyes principle), alignment with financial reporting data, risk of non-compliance with certain reporting requirements, and risk of key personnel departure (mitigated by knowledge-sharing, documentation and cross-training). Identified risks such as data gaps are discussed in the ESG Working Group and escalated to the Management Board when necessary, with findings evaluated periodically by the Working Group.

Section 11.2.1 ESRS 2 SBM-1 (p.45-49) with the value chain in 11.2.2 (p.53). Addiko is a specialist banking group serving Consumer and SME customers in Central and South-Eastern Europe, comprising the Vienna-listed Austrian parent Addiko Bank AG (supervised by the FMA and the ECB) and six subsidiary banks in Croatia, Slovenia, Bosnia and Herzegovina, Serbia and Montenegro. It serves about 0.9 million customers through 155 branches and digital channels and employs 2,726 people (headcount) as at 31 December 2024. The business runs through five segments: Consumer and SME (focus segments, nearly 90% of the gross performing loan book), plus Large Corporates, Mortgages and Public Finance (non-focus, in run-down) and the Corporate Centre. Net banking income is shown by segment, totalling EUR 315.8m. Addiko states it is not involved in fossil fuels, chemicals, controversial weapons or tobacco. Its sustainability goals align with four UN SDGs (3, 5, 8, 13), supported by 15 initiatives. The upstream value chain covers funding sources and suppliers including outsourced IT providers.

Section 11.2.3 ESRS 2 SBM-2 (p.56-58). Addiko describes how it identifies and engages its stakeholders. Stakeholder engagement is integrated into regular business processes and feeds the Double Materiality Assessment. The assessment focuses on Addiko's three 'closest stakeholders', those with a direct relationship and highest involvement in its activities: customers, employees and shareholders. Addiko notes that engagement with additional stakeholder groups is not yet as standardised and will be formalised in the following period. For its own workforce (S1), employee interests are represented by the works council, which by law holds seats and voting rights on the Supervisory Board, and are gathered through annual employee engagement surveys, with action plans presented to the Management and Supervisory Board and communicated via roadshows, townhalls and intranet, then tracked through follow-up surveys and pulse checks. For consumers and end-users (S4), engagement uses feedback mechanisms, market research, surveys, branch, digital and contact-centre channels and complaint management, with reports consolidated by the Market team and shared with local management boards and regulators.

Section 11.2.4 ESRS 2 SBM-3 (p.61-63). Addiko presents a table of its material impacts, risks and opportunities (IROs), each with a description, its place in the value chain (own operations, upstream or downstream), time horizon and type (actual or potential, direct or indirect). The material IROs span four topics: E1 Climate change, where adaptation risk (E1-IRO-1) concerns debtors' debt-service capacity being affected by physical and transition risks (downstream, long-term) and mitigation covers financed GHG emissions and financing of debtors contributing to a sustainable economy; S1 Own workforce, covering working conditions such as working time, work-life balance, health and safety, and equal treatment; S4 Consumers and end-users, covering information-related impacts and customer satisfaction; and G1 Business conduct, covering protection of whistleblowers, management of supplier relationships and payment practices, and prevention and detection of corruption and bribery. The statement notes each IRO is covered in more detail in the respective topical chapters alongside its policies, actions and targets.

Section 11.3.1 ESRS 2 IRO-1 (p.64-66). Addiko describes its process to identify and assess material impacts, risks and opportunities, applying the ESRS principle of double materiality (impact and financial materiality). The steps were: understanding the business context and value chain and identifying the three closest stakeholder groups; identifying actual and potential IROs across own operations and the value chain using ESRS 1 Appendix A, supplemented by industry-specific matters from SASB standards for Commercial Banks and Consumer Finance and a review of peer reports, producing a list of 97 sustainability matters; evaluating these matters through internal focus groups of senior management and subsidiary representatives considering scale, scope and recoverability, then presenting results to external stakeholders; a detailed Climate and Environmental (C&E) risk assessment of the credit portfolio; and setting a severity threshold so that matters scoring above it were deemed material and discussed with the Management and Supervisory Board. Addiko did not yet include quantitative cash-flow estimates and will phase these in. In 2024 the methodology was revised to focus on the potential extent of the financial effect and to assess short, medium and long-term horizons individually, in line with EFRAG IG1.

Section 11.3 ESRS 2 IRO-2 (p.73-74). Addiko provides the list of ESRS datapoints deriving from other EU legislation and an index of ESRS disclosures, indicating for each where it is reported or why it is omitted. Datapoints are mapped to chapters, for example GOV-1 gender diversity and independence and GOV-4 due diligence to Chapter 11.1, and SBM-1 involvement in fossil fuels, chemicals, controversial weapons and tobacco to Chapter 11.2.1. Several E1 datapoints (transition plan, GHG reduction targets, benchmark exclusions and physical-risk exposure) are marked as covered by transition relief. Numerous datapoints across E2, E3, E4, E5, S2 and S3 are marked 'Not material for Addiko' or 'Not applicable for Addiko'. Material topical disclosures (E1, S1, S4, G1) are cross-referenced to Chapters 12 to 14, for example financed emissions to 12.2.5 and own-workforce metrics to 13.1.13 and 13.1.14. Paragraph 55 describes the screening process for non-material matters, referring back to the IRO-1 methodology.

Section 12.2.1 (p.108). Addiko states it does not yet have a formalised transition plan to achieve net zero. The bank explains it is currently gathering and verifying comprehensive data across its business operations so that accurate and reliable information forms the foundation for a thorough and effective plan. Once this preparatory phase is complete, a detailed transition plan will be developed to guide Addiko's contribution to the global transition towards a net-zero economy. Because there is no formal transition plan with GHG emission reduction targets yet, targets are not reported in the Sustainability Statement, though they are included in Addiko's ESG Strategy, and the concrete decarbonisation actions are also not yet in place. The bank confirms it is actively working on establishing a formal transition plan to fully align its actions and targets with GHG emissions reduction.

Section 12.2.3 (p.109 to 112). Addiko discloses policies addressing its material climate mitigation and adaptation IROs. Local actions for the purchase of electricity reflect a Group Management Board approved ESG strategic priority to increase the renewable energy share in total energy consumption, executed locally by Real Estate Management (REM) and Procurement units. The Group Travel, Car and Hospitality Policy regulates travel and hospitality and company car acquisition, promoting a transition to electric and hybrid vehicles to reduce CO2 emissions from business trips; it is available to all employees via the internal Policy app. An Environmentally Friendly Banking Services initiative supports the positive mitigation impact by offering digital services that reduce paper consumption and in-person branch visits. Policies are reviewed annually or ad hoc, with biannual ESG reporting to the Group Management Board and Supervisory Board. Since no formal transition plan exists yet, GHG reduction targets sit in the ESG Strategy rather than the statement.

Section 12.2.3 (p.110 to 112). Addiko describes actions taken under its climate policies. On electricity, entities procure clean electricity from renewable sources to raise the renewable share in total energy consumption; the goal was 25% in 2024 and over 30% in 2025, though the actual 2024 share reached 21.8%, below target, mainly due to a change of energy provider in Addiko Bank Croatia. Electricity costs are not significant OpEx (around 0.79% of Group OpEx). On the vehicle fleet, Addiko is replacing cars with electric and hybrid vehicles, targeting a 30% hybrid or electric share by end 2025; by end 2024 30.1% of the fleet was already electric or hybrid, exceeding the 20% goal for 2024. Vehicle expenses are around 0.43% of Group OpEx. Further actions include a photovoltaic plant in Sarajevo (ABSA) and a new heat pump in ABSE, plus digitalisation actions (signature pads, digital signatures) to cut paper consumption. Actions are steered via monthly, quarterly and biannual reporting to local and Group management.

Section 12.2.4 (p.120). Energy consumption data is based on actual consumption from energy bills collected annually by local Real Estate Management units and consolidated at Group level; some entities use an all-in rent model where utilities are estimated per square meter, and repossessed assets are excluded. The data was not independently validated by a body other than the assurance provider. Total energy consumption fell 19.7% from 2021 (12,443 MWh) to 2024. In 2024 total energy consumption was 9,987 MWh, comprising 68.7% fossil sources, 21.8% renewable sources, 4.9% nuclear sources and 4.6% unknown sources. By source, 2024 fossil consumption was 6,857 MWh, nuclear 494 MWh, purchased renewable electricity, heat, steam and cooling 2,173 MWh, and unknown sources 463 MWh. In some entities (ABSA, ABBL, ABM, ABH) the renewable share already exceeds 40%.

Section 12.2.5 (p.121 to 123). Scope 1 and 2 are calculated per the GHG Protocol; Scope 2 uses the location-based method (Ecoinvent), with market-based figures reported equal to location-based due to data unavailability. Scope 3 is dominated by Category 15 Investments (financed emissions), identified as the most material source. For FY2024 Addiko Group reported Scope 1 GHG emissions of 755 tCO2eq (2023: 824), location-based and market-based Scope 2 of 5,656 tCO2eq (2023: 6,078), and total Scope 3 of 574,942 tCO2eq (2023: 582,349), all of which is Category 15 financed emissions. Total GHG emissions (Scope 1, 2 and 3) were 581,353 tCO2eq (2023: 589,251), a decrease year on year, with GHG intensity per net revenue of 1,908 tCO2eq per million EUR (2023: 2,086). Financed emissions by segment show SME Business as the largest contributor. Emissions data was not externally validated beyond the assurance provider.

Section 13.1.2 (p.126). Addiko's internal policies aim to eradicate discrimination, prevent harassment and champion equal opportunities, adapting to local laws and cultural norms while keeping consistent Group standards. The Addiko Group Code of Business Conduct and Ethics and the 'How we work at Addiko' handbook articulate values and behaviours aligned with the EU Guiding Principles on Business and Human Rights, the ILO Declaration and OECD guidance. A new five-year People and Culture Strategy sets goals and standards. The Remuneration Policy establishes transparent, fair compensation and promotion principles, while the Group Recruitment and Selection Policy, Group Talent Management and Succession Policy, Group Training Policy and Group Diversity and Inclusion Policy support equal treatment and growth. The report lists nine social policies mapped to specific ESRS S1 topics (for example the handbook to S1-8, Diversity and Inclusion to S1-9, Remuneration to S1-10 and S1-16, Code of Conduct to S1-17). Policies are described as interconnected, reinforcing workforce well-being, growth and equitable practices.

Section 13.1.3 (p.126). Addiko engages its workforce through a structured, data-driven approach combining monitoring, employee feedback and continuous improvement. It sets clear KPIs including employee engagement scores from surveys, turnover and retention rates, diversity and inclusion metrics (gender representation, pay equity), training and development participation, and health and safety statistics such as incident and lost-time injury rates. Employee engagement surveys are conducted periodically to gauge sentiment on workplace policies, well-being and inclusion, supplemented by more frequent targeted pulse checks that capture real-time feedback on specific initiatives. ESG committees and internal managerial reports assess progress against action plans. Results are used to adjust action plans, refine policies, introduce new initiatives or allocate additional resources where needed. Details on how feedback is recorded, integrated into decision-making and communicated back to employees are described in the ESRS 2 SBM-2 stakeholder section.

Section 13.1.4 (p.126-127). Addiko addresses potential negative impacts from exploitation, unsafe conditions or human rights violations through fair wages, safe working conditions, anti-discrimination policies and strong internal process controls, and has implemented diversity programmes to promote equal opportunities. Regular feedback surveys give employees a platform to voice thoughts, concerns and suggestions (further detail in ESRS 2 SBM-2). Multiple channels are available for raising concerns on each material impact: anonymous whistleblowing boxes, trade unions where the workforce is unionised, works councils and other grievance mechanisms. Addiko has implemented a whistleblowing tool serving as an early warning system for serious wrongdoing including unethical, illegal, corrupt or inappropriate conduct, described in section 12.7 Whistleblowing. Awareness of these grievance mechanisms is supported through annual e-learning via the click&learn platform, internal policies and regular internal communications, so employees know how to use them when needed.

Section 13.1.5 (p.127-130). Employee data is reported on headcount at year-end, consolidated by Group People and Culture from a central database. The Group total is 2,726 employees, 71.09% female and 28.91% male, spread across eight entities in Austria, Croatia, Slovenia, Bosnia and Herzegovina, Serbia and Montenegro. Most employees hold permanent contracts, with about 7.7% on limited (temporary) contracts as of year-end 2024, largely covering absent employees; 92.30% of employees are permanent. Full-time employees represent 97.2% and part-time 2.8%. Addiko does not engage non-guaranteed-hours workers. In 2024, 471 employees left, giving a total turnover rate of 17.4%, calculated on voluntary departures, contract expiration, dismissal, retirement and death in service. Addiko prohibits forced and child labour, and all employment relationships rest on mutual consent.

Section 13.1.6 (p.130). Addiko had 118 non-employees in its own workforce at year-end 2024, all classified as other workers on site, with zero self-employed people. These are external IT developers, administration, call centre and collections call centre staff engaged through service contracts or external agencies. Data is reported on headcount at the end of the period, provided by local People and Culture teams and not validated by any external body other than the assurance provider. Separately, security and facility management services are subcontracted to external companies whose employees are treated as value chain workers, with those employers responsible for compliance with labour law, working conditions, health and safety and grievance mechanisms. Addiko's procurement process evaluates such suppliers on compliance with workplace health and safety regulations, history of complaints or sanctions, and occupational accident records from the past two years. While value chain worker risks are deemed immaterial, Addiko engages suppliers to promote transparency and improved working conditions.

Section 13.1.7 (p.131-132). Addiko affirms its commitment to freedom of association and the right to collective bargaining, guided by the 'How we work at Addiko' handbook (reviewed annually). In line with the Austrian Labour Constitution Act, works council representatives of Addiko Bank AG hold seats and voting rights on the Supervisory Board. Named trade unions include GPA, SBF-SP, SBO and the Bank Employees Union of Slovenia. Coverage varies by country: in Austria, considering only Austria-based employees, 84.03% are covered by the banking collective agreement with 5.88% union members; covering all Addiko Bank AG employees including the Zagreb branch, coverage is 63.69% with 4.46% union members. Croatia has no bargaining agreement but a works council covering all employees with 27% union members; Slovenia has 93.13% coverage. Reported headcounts covered by collective bargaining agreements: Vienna 100 of 157, Zagreb 0 of 723, Ljubljana 343 of 346.

Section 13.1.8 (p.132-137). The Group Diversity and Inclusion Policy promotes diversity, inclusion and equal opportunities and sets targets for underrepresented gender in managerial positions. At year-end 2024, women held 71.09% of the total workforce, 38.7% of Group supervisory board seats, 18.2% of Board Member roles and 47.1% of B-1 director roles, totalling 42% female executives across the Group. Age distribution: average age 43, with 14.12% under 30, 67.13% aged 30-50 and 18.75% over 50. The D&I target is over 50% female executives by end of 2025, with a 2025-2027 plan targeting Supervisory Board 30%, Management Board 30% and B1 40% female. In 2024 six female supervisory board members were internally promoted, 60% of internal managerial promotions were female, and the internal filling rate for managerial roles was nearly 80% over three years. Initiatives include the Women's Mentoring Network (52 mentors, 200+ women trained since 2021), WOBA partnership and MAMFORCE awards.

Section 13.1.13 (p.146-148). Addiko confirms that wages in all countries are adequate. Minimum wages are set in accordance with Directive (EU) 2022/2041 on adequate minimum wages, and calculations based on that Directive showed Addiko pays employees above the adequate wage in all entities. For both EU and non-EU countries, national legislation and existing collective bargaining agreements are considered. In Austria the minimum wage is defined by the Collective Agreement of Bank Employees and Bankers; for all other entities local legislation or government decisions set annual minimum wage levels. The remuneration strategy combines fixed and variable pay, is market-based and is governed by applicable legislation and EBA guidelines. Regular market benchmarks maintain fair compensation and benefits, and adjustments to salaries and benefits are made based on benchmarking results within the approved budget.

Section 13.1.5 (p.130, tagged [ESRS S1-11]). All Addiko employees are covered by social protection measures in every Addiko entity, provided through public programmes. These programmes protect employees against loss of income arising from major life events, specifically sickness, unemployment (except in cases of mutual agreement), work-related injury and acquired disability, parental leave, and retirement. The disclosure confirms full coverage across all entities of the Group and does not identify any category of employee left unprotected against these events.

Section 13.1.9 (p.137). Addiko employs a total of 41 individuals with disabilities, comprising 31 female and 10 male employees, which constitutes 1.5% of the overall workforce. Disability data is collected from employees on a strictly voluntary basis, with no obligation for employees to report their disability status unless they wish to exercise certain rights provided by Addiko, such as additional holiday days or payroll deductions. Due to data privacy considerations and out of respect for the rights of Addiko employees, no further details are disclosed.

Section 13.1.10 (p.137-140). Training and skills development is governed by the Group Talent Management and Succession Policy and the Group Training Policy. Employees access on-the-job training, classroom sessions and digital learning (Click&Learn), guided by a 10-20-70 development principle. The Addiko Academy focuses on leadership, banking, risk management, sales and compliance, with ESG added as a focus area in 2024. The average training in 2024 was 20.9 hours per employee (24 hours for female, 16.3 hours for male employees). By category, 8% of hours went to managerial soft skills, 15% to managerial expert topics, 13% to non-managerial soft skills and 64% to non-managerial expert topics. Every employee must undergo regular performance and career development reviews after three months; participation reached 97% of female and 97.1% of male managerial employees, and 89.8% female and 91.9% male non-managerial employees. Key 2024 actions included the new Lead WISE leadership programme and D&I training.

Section 13.1.11 (p.141-142). Health and safety is governed by the Physical Security Policy, aligned with Austrian legislation (ASchG, AngG, EFZG), DORA, GDPR, ISO 27001/27002 and EBA guidelines. Addiko appoints internal safety officers and safety representatives who identify hazards, propose corrective actions and escalate issues, operating independently of management. For 2024, 100% of the own workforce is covered by a health and safety management system based on legal requirements (target 100%). There were zero fatalities among own workforce from work-related injuries or ill health, and zero fatalities among other workers on Addiko's sites. Recordable work-related accidents for own workforce totalled 5 (against a target of 0), a rate of 0.18%. There were zero cases of recordable work-related ill health, and 117 days lost to work-related injuries and ill health. Well-being initiatives included sports and health-promoting events, with participation targets of 25% in 2025 and 40% in 2026.

Section 13.1.12 (p.143-145). Work-life balance is anchored in the People and Culture Strategy, which defines 16 focus areas covering well-being, future-of-work models and flexible arrangements, remedying negative impacts such as overload, burnout and quiet quitting. In 2024, 8.5% of female employees used maternity leave and 2.2% of male employees used paternity leave; all employees are entitled to family-related leave through local legislation, social policies or collective bargaining agreements, with lengths varying by entity. Addiko fosters a smooth return to work through an on-ramping programme for parents in Addiko Bank Serbia, and offers family-related days off (family day, first day of school, marriage, childbirth, and a free birthday day currently in four entities). Flexible and hybrid working arrangements and remote work options help employees balance responsibilities. Well-being programmes include gym access, business runs, health checks, free vaccinations and the 'Rezilijent'-recognised resilience programme in Serbia. Targets focus on rolling out flexible working formats in 2025 and 2026.

Section 13.1.13 (p.148-149). Gender pay gap is monitored under EBA guidelines and the Capital Requirements Directive methodology; analysis of all employees' wages found no structural deficiencies or discriminatory practices and no significant deviations between comparable positions. The gender pay gap (ESRS 97a, difference in average pay as a percentage of male average pay) is reported per entity: Vienna 30.78%, Zagreb (Croatia) 28.32%, Ljubljana (Slovenia) 23.43%, Sarajevo 42.98%, Banja Luka 42.19%, Beograd (Serbia) 37.38% and Podgorica (Montenegro) 24.59%. The annual total remuneration ratio of the highest-paid individual to the median (ESRS 97b) is also reported per entity, ranging from 1:10.36 in Slovenia to 1:26.69 in Croatia (Vienna 1:13.66). The job structure has 13 grades across managerial and non-managerial paths. Addiko Bank Croatia won the 2024 Equal Pay Champion Award. A full Gender Pay Gap Report using total remuneration data is expected by end of Q2 2025.

Section 13.1.14 (p.150). Incidents, complaints and severe human rights impacts are monitored under the Group Code of Business Conduct and Ethics, approved by the Group Supervisory Board and steered by the Managing Director, Group Compliance and AML. Addiko maintains a workplace free from sexual, racial and other unlawful harassment and from violence or intimidation, and does not tolerate abusive conduct. While no specific actions or targets have been set yet, ongoing evaluations will determine necessary measures. For 2024, Addiko reported zero work-related incidents of discrimination and zero incidents of harassment. One complaint was filed by Addiko's own workforce, which was thoroughly analysed with follow-up measures concluded. There were zero identified cases of severe human rights incidents. The total amount of fines, penalties and compensation of damages was 0 EUR both for incidents and for human rights incidents. Data was collected from entities and not validated by any external body.

Section 13.2.2 (S4-1, p.153). Addiko manages impacts on consumers through two main policies. The 'How We Work at Addiko' handbook sets high-level guidance on vision, strategy and responsible business conduct, and incorporates Addiko's Charter of promoting Human Rights and commitment to ILO principles, OECD Guidelines and the UN Universal Declaration of Human Rights. The Group Code of Business Conduct and Ethics, approved by the Group Supervisory Board and steered by the Managing Director, Group Compliance and AML, applies across all entities and to employees, affiliates, service providers and business partners. For clients it sets principles on fair and responsible business practices, client asset and account protection, and complaints handling. Both policies are available to employees via the internal policy app or SharePoint, and to external stakeholders through public disclosures and training. Consumers can expect ethical treatment, clear communication and secure handling of assets and personal data.

Section 13.2.3 (S4-2, p.155). Addiko engages with consumers primarily through market research. It uses the Net Promoter Score (NPS) to gauge customer satisfaction and loyalty via systematic surveys collecting both numerical scores and qualitative comments. Quarterly local Customer Experience Committees, led by the Head of Sales/Product and the responsible board member of each local entity, evaluate NPS results and drive improvements to products, processes and services, drawing in functions such as Operations, Risk, Compliance and IT as needed. For SME clients, subsidiaries conduct Voice of Customers (VOC) feedback. In 2024, focus group interviews were run in five subsidiaries (excluding Croatia, covered in 2023), steered by external market research teams and involving Addiko and non-Addiko clients on satisfaction and reasons to switch banks. Results are reported to local Management Boards, who assess outcomes and adapt strategy.

Section 13.2.4 (S4-3, p.155). Addiko operates a complaint management system defined in the Addiko Group Complaint Management Policy, covering grievances from customers, suppliers, business partners, investors and other stakeholders. Complaints are received through channels operated directly by Addiko, including contact centres, digital channels (email, chat boxes), written post/fax and books of complaints; all channels are managed internally with no reliance on external factors. Complaints are logged, reviewed, investigated and addressed, with periodic controls, and local success committees analyse root causes and trends to propose one-time or systemic remediation. Customer-facing employees receive tailored training on complaint handling, conflict resolution and mediation. Whistleblowing reports are handled accordingly. Reports are consolidated and shared with relevant stakeholders and local management boards and regulators. In 2024, all complaints were handled per internal policies, and no severe human rights issues or incidents related to consumers were reported.

Section 13.2.5 (S4-4, p.157). Addiko takes action on material consumer impacts across privacy, information and access. On Privacy and Data Security it runs the Addiko Data Protection Programme across all subsidiaries with GDPR as the benchmark, supported by local Data Protection Officers, a Group DPO, local and Group Chief Information Security Officers, internal policies, employee training and technical and organisational security measures. A key action is harmonisation with the Digital Operational Resilience Act (DORA), with implementation targeted for January 2025. On access to quality information and financial literacy, Addiko runs local initiatives, including landing pages, an online financial literacy quiz for schoolchildren in Croatia (256 schools, 1,800 students) and a four-part podcast series in Montenegro, targeting at least one initiative per entity per year. Preparation to meet the European Accessibility Act, including branch and ATM accessibility, is also underway with a 2025 horizon.

Section 14.1.2 (G1-1, p.164). Addiko's business conduct and corporate culture rest on the Group Code of Business Conduct and Ethics, the foundation framework shaping a culture rooted in integrity, accountability and ethical practice. It covers Addiko values, equal treatment, dignity, ethics, human rights, anti-corruption, conflicts of interest, data protection and grievance mechanisms, and is approved by the Group Supervisory Board, steered by the Managing Director, Group Compliance and AML, and applied across all entities. Whistleblower protection is addressed under EU Directive 2019/1937 and the Group Compliance Policy: Addiko commits to no retaliation, confidential handling of disclosures, and a Whistleblowing Office (works council, data protection office and a compliance officer) that investigates and reports to the Management Board. A Whistleblowing Register is kept, with an annual report to the Board. Addiko also states it is politically neutral and makes no political party donations.

Section 14.1.3 (G1-2, p.166). Addiko relies on suppliers for various services and goods, and, apart from software and IT service providers, most suppliers are SMEs. Supplier selection is conducted transparently, neutrally and without discrimination, in line with the Group Policy on Business Conduct and Ethics. Under the Procurement Policy, approved by the Management Board, an ESG assessment via a comprehensive questionnaire is mandatory for all bidders in tenders where estimated annual gross purchase value exceeds EUR 500,000, and an annual ESG assessment is required for suppliers with aggregated annual spending of EUR 500,000 or more. As part of its ESG Strategy, Addiko conducted an ESG evaluation of the top 10 suppliers in each entity during the reporting period. Standard contract terms emphasise timely payment, with delays occurring only in exceptional cases, generally attributable to factors outside Addiko's control such as late or non-compliant invoices.

Section 14.1.5 (G1-3, p.167). Addiko has a zero-tolerance approach to bribery and corruption, stating it does not pay or accept bribes or improper incentives and expects the same from customers, business partners, employees, consultants, advisors and third parties. This is governed by the Group Compliance Policy, approved by the Group Supervisory Board and steered by the Managing Director, Group Compliance and AML, referencing OECD and UN anti-bribery standards, the Austrian Civil Code, the FCPA and the UK Bribery Act. Addiko recognises corruption risk is uneven across roles but trains all employees uniformly. Key actions in the year included anti-bribery and corruption training covering invitations, gifts, whistleblowing and capital market compliance, and inclusion of anti-bribery clauses in all commercial contracts from 2024. The target is that 100% of all employees and Management and Supervisory Board members receive ABC training, with a 2025 milestone of 80% and full coverage by 2026.

Section 14.1.6 (G1-4, p.170). During the reporting period, Addiko reports that no incidents of bribery or corruption were recorded. The bank states it was not involved in any legal proceedings related to bribery or corruption. No fines are disclosed, consistent with the statement that no incidents or proceedings occurred. In 2024, Addiko conducted dedicated anti-bribery and corruption training for Addiko Bank AG employees, with customised courses intended to be delivered across all Addiko countries of operation in 2025. Training coverage is reported by entity and audience: for example, at Addiko Bank AG (ABH) 78% of all-function headcount and 50% of Management Board members received training, while other entities show varied coverage, with Addiko Bank Slovenia (ABBL) reaching 100% across all functions, Management Board and Supervisory bodies. Training was delivered as one-hour annual classroom sessions covering invitations, gifts, whistleblowing and capital market compliance.

Section 14.1 (G1-5, addressed inline within G1-1 corporate culture and governance, p.164). Addiko describes itself as a politically neutral organisation. It states that it does not engage in party political campaigning and does not make political party donations. Addiko presents this stance as further demonstrating its commitment to ethical governance and independence. No financial contributions to political parties, elected officials or candidates are reported, and no lobbying activities or related expenditure are disclosed. The report treats political neutrality as part of Addiko's broader business conduct and corporate culture framework rather than a separate programme with dedicated actions or targets.

Section 14.1.4 (G1-6, p.167). Under Addiko's standard contractual payment terms, supplier invoices are settled within 30 days of receipt. During this period invoices are reviewed for accuracy and proper documentation of goods or services received, with internal approvals required before payment. For ongoing services such as telecommunications and rental agreements, terms of 'upon receipt of invoice' are often specified by suppliers and may deviate from Addiko's standard terms. Addiko notes that its invoice-entry process records the booking entry date, invoice date and payment date, but that the average time to pay an invoice from the start of the contractual or statutory payment period cannot be analysed once payment is made. As of 31 December 2024 there are no open lawsuits initiated by suppliers claiming late payment. Addiko has not set specific actions or quantitative targets, but works to reduce invoice processing time.