Aegon

Governance section, Aegon's sustainability governance (and Report of the Board of Directors, Board of Directors). Aegon operates a one-tier Board of Directors consisting of nine independent Non-Executive Directors, with CEO Lard Friese as the sole Executive Director responsible for day-to-day management. The Board manages and conducts the business, sets and evaluates strategy, and is accountable for Aegon's sustainability approach and reporting, including oversight of the management of sustainability impacts, risks, and opportunities. It has four committees, comprising solely of Non-Executive Directors: the Audit Committee, the Risk Committee, the Compensation and Human Resource Committee, and the Nomination and Governance Committee. Aegon's sustainability approach is overseen by the Board as a whole and in particular its Nomination and Governance Committee, with other committees covering matters within their responsibilities. The CEO and Executive Committee are supported by the Global Sustainability Board (GSB), which monitors sustainability policies, targets, and reporting for material topics.

Governance section, Aegon's sustainability governance (and Report of the Board of Directors). Sustainability topics are regularly brought to the agenda of the Executive Committee and the Board of Directors, including policy and implementation matters and progress on the double materiality assessment and resulting sustainability impacts, risks, and opportunities. In 2024, the Board was regularly updated on the progress of Aegon's sustainability approach and relevant developments, including discussions on the DMA and resultant material sustainability themes, progress on key sustainability metrics, and the controls related to sustainability reporting. The Board also participated in a sustainability teach-in on the pending implementation of the CSRD. In 2024 the CEO mandated the GSB to deliver on the governance processes, controls, and procedures used to monitor, manage, and oversee impacts, risks, and opportunities, including monitoring of targets. A CSRD Working Group was established by the end of 2024 to coordinate the approach and provide quarterly progress updates to the GSB.

Governance section, Monitoring the effectiveness of policies, and Climate change, Key performance indicators and targets. The effectiveness of policies relating to material sustainability matters is measured through KPIs and targets reported to the GSB. A subset of these KPIs was linked to the Group performance indicators used for the funding of the employee bonus pool (where applicable) and to the performance metrics of the short-term incentive of the CEO in 2024. Specifically, in 2024 the weighted average carbon intensity (WACI) target covering general account corporate fixed income and listed equity assets was included in the performance metrics of the short-term incentive of the Executive Director (CEO), to help align corporate action at a leadership level with Aegon's net-zero commitment. The Directors' Remuneration Policy demonstrates the inclusion of quantitative sustainability metrics in the Short-Term Incentive. Further detail is provided in the Remuneration Report.

Governance section, Due diligence. Aegon presents a due diligence mapping table setting out where the core elements of its sustainability due diligence process are disclosed across the Sustainability statement and other parts of the Annual Report. The table maps the five ESRS due diligence elements: embedding due diligence in governance, strategy, and business model; engaging with affected stakeholders in all key steps; identifying and assessing adverse impacts; taking actions to address adverse impacts; and tracking the effectiveness of these efforts and communicating. References point to the sustainability governance, incentives, stakeholder engagement, value chain, and per-topic sections covering impacts/risks/opportunities, policies and procedures, actions, metrics, and KPIs and targets. Due diligence processes support the DMA in assessing material impacts, risks, and opportunities. Additional due diligence mechanisms include the biennial Human Rights Risk Assessment, AML and CTF and Anti-Bribery and Corruption policies, and downstream responsible investment engagement and exclusions.

Governance section, Risk management and internal controls over sustainability reporting. Risk management and internal controls over sustainability reporting fit within Aegon's Enterprise Risk Management (ERM) framework. All material processes contributing to sustainability reporting have been identified, and the main risks and controls for each material process have been identified and documented with support from the risk functions. The risks relate to the completeness and accuracy of sustainability information and are mitigated by executing controls, which are validated internally at both the business unit and company-wide levels. Control attestations are performed each annual report cycle, whereby in-scope business units and group functions sign off on the design and implementation of the key controls via a control attestation letter. Remediation plans are developed for ineffective key controls, and gaps and remediation plans are logged. Progress is reported and monitored quarterly as part of the risk management cycle. The Risk Committee reports to the Board on the ERM framework and internal control system.

Basis of preparation, Value chain (SBM-1 42c), and Human capital metrics table (SBM-1 40a iii), with the business model also shown in About Aegon and How we create value for our stakeholders. Aegon develops investment, protection, and retirement solutions for its customers. Protection and retirement together with asset management form the core of its business, supported by underwriting and investment management. Products are distributed through agents, brokers, banks, and financial advisers, or directly to customers, grouped into retail, workplace, and institutional channels. Protection and retirement is concentrated in the Americas and United Kingdom segments, while asset management is reported under the Aegon Asset Management segment. Customers pay fees or premiums or make deposits; Aegon invests these and pays out claims and benefits. Downstream activities include investment management of general account and separate account assets. Upstream activities cover sourcing, suppliers, and service providers, including facility suppliers, professional services, and ICT, with some underwriting, claims, and investment activities outsourced.

Impact, risk, and opportunity management section, Stakeholder engagement. Aegon identified its most relevant affected stakeholders and users of sustainability information based on their relevance in the value chain and their knowledge of Aegon's business. A table sets out each key stakeholder group, its position in the value chain, engagement methods, and expectations and concerns: outsourcing partners and suppliers, investors, reinsurers, employees, customers, distribution channels and related JVs, social partners (NGOs, charities, communities), investment customers and investees, and regulators (including the Bermuda Monetary Authority). Engagement uses direct and indirect methods such as town halls, employee surveys, customer panels, NPS scores, investor meetings, and NGO engagement. Stakeholder findings, incorporating views from both 2023 and 2024 activities, were considered at three main points in the DMA process: scoping and landscape research, identification and detailed assessment of IROs, and scoring of IROs. Aegon aims to conduct more extensive stakeholder engagement in 2025 covering a wider range of sources.

Impact, risk, and opportunity management, DMA results, and the Impacts, risks and opportunities sections of each material topic (SBM-3 except 48e). The 2024 DMA resulted in five material topics: Climate change, Human capital, Inclusion and diversity, Data privacy, and Business conduct, comprising 14 sub-topics assessed at the IRO level. The material impacts, risks, and opportunities for each topic and related sub-topics, and their interaction with strategy and business model, are described in detail in the respective topic sections, alongside policies and procedures, actions, targets, and metrics. Other environmental matters (pollution, water and marine resources, biodiversity and ecosystems, and circular economy) were not assessed as material due to a lower level of impact, risk, or opportunity. For each material topic, an IRO mapping table illustrates where in the value chain the material IROs arise across upstream, own operations, and downstream activities. The material topics have been integrated into Aegon's business through policies, processes, actions, metrics, and targets.

Impact, risk, and opportunity management section, Double materiality assessment process. In 2024 Aegon conducted its third DMA following a four-step methodology informed by ESRS requirements. Step 1, understanding the landscape, used a desktop analysis covering the regulatory landscape, peer benchmarking, a media scan, a review of reporting frameworks, and stakeholder input, together with a value chain assessment, to build a long list of topics and initial IRO mapping. Step 2 identified and assessed IROs against factors including business activities, business relationships, geographies, value chain position, and three time horizons (short, medium, long). Impacts were qualitatively assessed against scale, scope, likelihood, and irremediability, and risks and opportunities against magnitude and likelihood, using a five-range qualitative scale and a threshold matrix. Step 3 validated the final list with internal SMEs, with the CEO and Executive Committee approving the process and outcome. Step 4 integrated material topics into the business. The materiality threshold was set at a high level after consultation with internal stakeholders.

ESRS Disclosure Requirements section, ESRS disclosure requirements covered by Aegon's Sustainability statement. Aegon presents a table listing the ESRS disclosure requirements that are applicable given the outcome of the double materiality assessment and covered in the Sustainability statement, with references linked to the pages or paragraphs where the related disclosures can be found. The list covers ESRS 2 general disclosures (BP-1, BP-2, GOV-1, GOV-2, GOV-3, GOV-4, GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, and IRO-2) and the topical standards for the five material topics, including Climate change (ESRS E1) and the associated MDR-P, MDR-A, MDR-M, and MDR-T disclosures. A separate table addresses data points derived from other EU legislation, and an Incorporation by reference table lists disclosure requirements covered outside the Sustainability statement. A Phased-in and omissions table sets out disclosures where the phased-in option is applied.

Per the Climate change section (Actions and resources), Aegon states it does not currently have a formal climate transition plan but aims to disclose one in the coming years. In the meantime it describes a company-wide commitment to transition its general account investment portfolio to net-zero GHG emissions by 2050, reinforced by NZAOA membership since 2021, with interim decarbonization targets for 2025 and 2030. Aegon UK has committed to net-zero financed emissions for its default pension funds by 2050. Decarbonization is pursued through three levers: factoring carbon intensity into portfolio management, active investment in climate solutions, and engagement with high carbon emitters. Operational scope 1 and 2 targets for 2025 and 2030 are aligned with the Paris Agreement 1.5 degrees C goal, and investment targets align with recognized science-based frameworks. These commitments address the material mitigation and adaptation IROs (1, 2 and 5 to 9).

Per the Climate change section (Policies, procedures, and commitments), Aegon manages climate IROs mainly through its Group Responsible Investment Policy, which covers general account assets of all business units, sets net-zero commitments and exclusion criteria, and is executed by the Executive Committee with GSB oversight (addressing IROs 1, 2, 5 to 9). Its Commitment to the Net-Zero Asset Owner Alliance (NZAOA) uses the Alliance Target-Setting Protocol to set 1.5 degrees C-aligned targets for general account assets, with the Global Head of Corporate Sustainability accountable and progress reviewed bi-annually by the GSB. The Group Environmental Policy sets a minimum operational environmental-management standard across business units (excluding properties below 140 square meters), addressing energy IROs 10 and 11, and references standards including ISO 50001, LEED, BREEAM, and Energy Star. For suppliers, Aegon relies on its Vendor Code of Conduct and Group Procurement Policy, which reference sustainability but do not yet include specific supplier GHG requirements. All policies are publicly available on Aegon's website.

Per the Climate change section (Actions and resources), Aegon's actions span its value chain. Upstream, it works with suppliers to address climate impacts (IROs 3 and 4), and in 2024 it matured its approach by adding supplier GHG emissions to reporting and monitoring its core supply base, with Aegon UK tracking supplier net-zero commitments. For its own operations, Aegon set operational targets and focuses on the energy-efficiency decarbonization lever through more efficient natural gas and electricity use (IROs 10 and 11); fewer properties and changed work patterns cut its facilities footprint, and the Cedar Rapids Community Solar Garden opened in 2024 to power Transamerica and AAM US facilities, while Transamerica's 6400 building earned an Energy Star rating of 100. Downstream, Aegon advances decarbonization via three responsible-investment levers: factoring in company carbon intensity, active investment in climate solutions (including transition-enabling and adaptation), and engagement with high carbon emitters. It also runs five climate scenarios to assess portfolio risk exposure.

Per the Climate change section (KPIs and targets; report covers E1-4 except datapoint 34a), Aegon set interim 2025 and 2030 targets supporting its 2050 net-zero commitment, all against a 2019 base year. The weighted average carbon intensity (WACI) target for general account corporate fixed income and listed equity (base 459 tCO2e/EURm revenue) targeted a 25% reduction by 2025 and 50% by 2030; 2024 performance was a 52% reduction. Carbon intensity of directly held real estate (base 139 kgCO2e/m2) targeted 25% by 2025 and 42% by 2030, achieving 51% in 2024. Absolute operational scope 1 and 2 emissions (base 30,886 tCO2e) targeted 25% by 2025 and 75% by 2030, reaching a 75% reduction in 2024. Climate-solutions investment reached USD 2.7 billion against a USD 2.5 billion 2025 target, with an additional USD 1 billion sought by 2030. Engagement with the top 20 corporate emitters met target. Targets are approved by the CEO and Executive Committee with GSB biannual monitoring.

Per the Climate change section (Metrics, Energy consumption and mix), Aegon's total energy consumption for its own operations was 26,601 MWh in 2024, down 35% from 40,745 MWh in 2023. Total fossil energy consumption was 8,471 MWh (32% of the total), comprising 8,123 MWh of natural gas fuel and 347 MWh of purchased electricity, heat, steam, and cooling from fossil sources. Total renewable energy consumption was 18,130 MWh (68% of the total), made up of 13,118 MWh of purchased renewable electricity, heat, steam, and cooling plus 5,011 MWh of self-generated non-fuel renewable energy (for example from the Cedar Rapids solar farm). Energy usage is sourced from billing or meter data where Aegon holds direct energy contracts, extrapolated by floorspace where data is missing, and covers all properties Aegon owns or rents for its primary operations. Renewable consumption is evidenced through annual Green Energy Certificates and US Renewable Energy Certificates.

Per the Climate change section (Metrics, Total GHG emissions), gross scope 1 emissions were 1,480 tCO2e in 2024 (from natural gas and leased fossil cars). Gross location-based scope 2 was 6,202 tCO2e and market-based scope 2 was 1,590 tCO2e (electricity for offices and data centers). Total scope 1+2 location-based was 7,682 tCO2e, only 0.2% of total emissions. Total gross scope 3 was 3,744,413 tCO2e, dominated by investments (financed emissions) at 3,585,913 tCO2e, plus purchased goods and services of 158,500 tCO2e (of which cloud computing and data center services were 11,560 tCO2e). Three scope 3 categories are material: Investments (category 15) and Purchased goods and services combined with Capital goods (categories 1 and 2). Total GHG emissions were 3,752,094 tCO2e (location-based) and 3,747,482 tCO2e (market-based). For separate account assets, Aegon applies the ESRS phased-in option, with data-collection infrastructure implementation starting in 2025. Investment emissions cover corporate fixed income, listed equity, sovereign fixed income, and directly held real estate, calculated per PCAF guidelines.

Per the Climate change disclosures and TCFD cross-reference (report covers only E1-9 datapoint 67b), Aegon provides a qualitative assessment of anticipated financial effects from material physical and transition risks, informed by climate scenario analyses across five pathways for its general and separate accounts. Under a disorderly net-zero (transition) pathway, carbon-intensive sectors such as oil and gas and fossil-based utilities are most adversely affected, but Aegon's Transamerica general account corporate bond holdings are well diversified by sector, limiting transition risk. Under a hot-house physical-risk pathway, real estate and equity are most affected while fixed income is more resilient; the general account is heavily US-concentrated and fixed-income oriented, which Aegon believes limits physical risk. On underwriting, as a primarily life insurer, climate effects would materialize gradually through mortality and morbidity shifts, and Aegon judges the financial effects to be minimal. Aegon notes scope and methodology will continue to evolve toward quantitative disclosures in future years.

Human capital section. Aegon does not have company-wide policies on general working conditions, training and skills development, or social dialogue; instead each business unit develops its own policies specific to local conditions and regulations. Working conditions are covered by employee handbooks at Transamerica and Aegon AM, local policies at Aegon UK, and the collective labor agreement (CLA) at the Netherlands holding company. Aegon AM has a specific training and development policy. The approach is supported by three global procedures: the Global Remuneration Framework (a policy based on pay for performance, reviewed at least every two years and overseen by the Board), the Talent Principles and Talent Review Framework, and the Performance and Development Cycle. From the Inclusion and diversity section, Aegon maintains a Statement on Inclusion and Diversity, a Board Diversity and Inclusion Policy, a Statement on Human Rights (based on the UDHR, ILO core standards, and UN Global Compact), and a Code of Conduct prohibiting discrimination and harassment.

Human capital section. Aegon engages its workforce mainly through the Global Employee Survey (GES), provided by third-party Culture Amp, in which all employees plus joint venture employees of THTF Life Insurance China and MAG Seguros Brazil participate voluntarily. In 2024 Aegon ran two surveys, a Q2 pulse and a Q4 full survey, with results discussed by the Engagement Working Committee, Executive Committee, and Board, feeding into global and local engagement action plans. The engagement score reached 79% in 2024 (participation rate 81%). Other engagement channels include Employee Resource Groups (27 ERGs in 2024), regular town halls, and Works Councils. An example of engagement effectiveness: employees in the Netherlands expressed concerns about the planned a.s.r. combination in the Q3 2023 GES; Aegon responded with town halls and communication sessions, and the level of concern had decreased by the Q2 2024 pulse survey.

Human capital section. All members of Aegon's workforce, including non-employees and joint venture employees, can raise concerns about suspected or observed misconduct through the Aegon Speak Up program, which offers multiple confidential or anonymous reporting channels and protection from retaliation. Depending on the channel used, concerns are addressed directly at local level or monitored and addressed through Speak Up. In the Netherlands, employees can speak in strict confidence with independent, trained Confidential Advisors, whose conversations produce no documentation and preserve anonymity; the advisor can support raising a formal Speak Up report if the employee wishes. Employees may also bypass line management and Speak Up to take concerns directly to the Chairman of the Audit Committee via a dedicated letter where other channels are not appropriate, such as conflicts of interest. Additional routes include the GES, union representatives (UK and Netherlands), Works Councils, and managers, HR, risk, audit, or compliance representatives. Personal work-related matters are expected to be resolved locally.

Inclusion and diversity section. Aegon manages its material I&D impacts and opportunities through actions resourced by its global human resources team. In 2022 it created a company-wide I&D approach, agreed by the Executive Committee and adopted by each business unit, led by the Global Head of Talent, Leadership and Inclusion. Key actions include the network of 27 Employee Resource Groups (such as Menopause Matters, the Women's Impact Network, and Race and Ethnicity groups), the annual Global Employee Survey and the 2023 international I&D Survey (82% response rate, around 2,000 comments), and participation in the annual Global Workplace Pride benchmark, where Aegon has held ambassador status for six consecutive years. In 2024 it extended the Global Head of Inclusion and Diversity role to cover leadership and talent and appointed dedicated I&D community specialists in all business units. It also promotes inclusion in its distribution network through WFG's more than 86,000 independent agents. Effectiveness is monitored via reporting to the GSB, Executive Committee, and Compensation and Human Resources Committee.

Inclusion and diversity section. Aegon's key I&D target is the proportion of women in senior management globally. For 2024 the target was 40% and performance was 39%, just below the company-wide goal; there is no target set for 2025. Aegon reports progress from 32% in 2020 to 39% in 2024 (also cited as up from 20% female representation on the Executive Committee in 2021 to 27% in 2024). The women in senior management target was included in the performance metrics of the CEO's short-term incentive in 2024. The Board of Directors reviewed the KPI and related progress. Aegon has no defined target for the sub-topic Measures against violence and harassment in the workplace. I&D ambitions are managed and agreed locally by local sustainability boards, recognizing specific local legal requirements, with effectiveness monitored quarterly with the Chief Human Resources Officer and half-yearly with the GSB.

Human capital section. Aegon had 11,952 direct employees at year-end 2024 (11,526 in 2023), of whom 11,781 were permanent and 171 temporary, with no non-guaranteed-hours employees. By region, 7,242 were in the Americas, 4,520 in Europe, and 190 in Asia. By country the largest populations were the United States (7,141), United Kingdom (3,064), Netherlands (596), Spain (553), and Hungary (300). Most direct employees hold standard permanent contracts subject to local conditions and work in an office or from home. There were 1,929 new hires and 1,491 leavers in 2024. The overall turnover rate was 12% (8% voluntary, 4% involuntary), and of leavers 66% were voluntary and 34% involuntary. Total employment costs were EUR 1.8 billion and salary costs EUR 1.2 billion. Headcount is collected from the Workday HR system and covers Aegon Ltd. and its wholly owned subsidiaries only.

Human capital section. Aegon reports a relatively large number of non-employee workers in its own workforce, totaling 2,787 at year-end 2024, down 10% from 3,093 in 2023. Non-employee workers are defined as individuals who have a contract with Aegon to supply labor (self-employed workers) and workers provided by third-party companies primarily engaged in employment activities. Workers hired from third-party companies typically perform the same kind of work as direct employees, such as filling in for employees who are temporarily absent due to illness, holiday, or parental leave. The figure reflects the headcount on the last day of the reporting period. Aegon notes that its workforce also includes indirect employees at joint ventures and tied agents, but these are counted separately from the non-employee worker figure reported here.

Human capital section. In EEA countries, 99.5% of Aegon's direct employees were covered by collective bargaining or labor agreements in 2024, with 100% coverage in the Netherlands, Spain, and Hungary and 0% in Germany. In non-EEA regions, 29.2% were covered, with 87.0% in the UK and none in the Americas or Asia. Coverage by workers' representatives (Works Councils) in EEA countries was 99.5% (up 5.5 percentage points from 94.0% in 2023). Social dialogue is supported through CLAs, unions, and Works Councils. In the UK, colleagues can seek representation through the Unite and Aegis unions; all Netherlands employees other than senior management are covered by a CLA, with new terms agreed in November 2024. Two active Works Councils in the Netherlands represent the Corporate Center and Aegon AM, and a European Works Council covers EU employees across the Netherlands, Spain, and Hungary. The Works Council is consulted on company policy and personnel matters.

Inclusion and diversity section. At year-end 2024 Aegon had 11,952 direct employees. Among permanent employees, 5,605 were male, 5,996 female, 74 Other (non-binary or not wishing to disclose), and 106 not reported; among temporary employees 91 were male and 80 female. Total female employees numbered 6,076, giving a proportion of female employees of 51%, unchanged from 2023. By age, 11% of employees were under 30, 57% were 30 to 50, and 32% were over 50 years old. In senior management there were 167 women, equal to a 39% proportion of women in senior management (up from 38% in 2023). Governance diversity is also reported: the Executive Committee had eight men and three women (27% female) across five nationalities, and the Board of Directors had five men and four women (44.4% female) across five nationalities. The gender classification uses Workday data.

Human capital section. Aegon reports that in 2024 no employees earned below the applicable adequate wage benchmark (the number and percentage of employees paid below benchmark were both nil; the 2023 figures were not measured). The benchmark is assessed using internal headcount and calculated on base salary in Workday plus variable pay, compared against the benchmark for the respective country or state. For the Netherlands and Spain, Aegon assumes the legal minimum wage covers the adequate wage benchmark. For other countries it uses open-source benchmarks where available, and where public benchmarks are not available it performs further analysis of the characteristics of employees in those countries. Aegon's approach to remuneration is governed by its Global Remuneration Framework, which is based on the principle of pay for performance and applies general guidelines to all employees across the group.

Human capital section. In 2024, 98.4% of Aegon's direct employees were covered by social protection, unchanged from 98.4% in 2023. This covers protection against loss of income due to sickness, unemployment, employment injury and acquired disability, maternity leave, and retirement, provided either through government policies or company plans. Full social protection is not available in Hong Kong and Singapore, where regulation requires maternity leave and sick leave pay but does not cover loss of income or disability unless offered through the employer's group insurance plan, which accounts for the gap from full coverage. The metric is based on direct employees of Aegon Ltd. and its subsidiaries.

Human capital section. In 2024, 98% of Aegon's direct employees participated in performance and development reviews, up 9 percentage points from 89% in 2023, with equal 98% participation for male and female employees, 97% for the Other category, and 98% for Not reported. Investment in training and career development was EUR 5.9 million (EUR 5.5 million in 2023), equal to an average of EUR 491.6 per employee (EUR 479.4 in 2023). Aegon supports skills development through several initiatives: the AI-powered Global Talent Marketplace tool for internal mobility, mentoring, and gigs; the We Learn global learning platform offering e-learning, live virtual training, and audiobooks; and an Accelerated Leadership executive development program launched in 2024 targeting around 90 critical leadership roles. Effectiveness is tracked through usage rates against industry benchmarks, career scores in the GES, and succession-pipeline measures. The Performance and Development Cycle governs the year-end review process.

Human capital section. In 2024, total employee absence was 25,826 days (up 4.3% from 24,760 in 2023), equal to an absence rate of 1.8% (down from 1.9%); the absence rate excludes Transamerica employees because that type of absence is not separately registered in the US. All employees (100%) were entitled to take family-related leave in 2024, up from 87% in 2023, after correcting a prior-year exclusion of some Transamerica employees. Of entitled employees, 9% took family-related leave (up from 7%), broken down as 8% male, 11% female, and 5% not reported. Family-related leave includes maternity, paternity, parental, and caregiver leave. Aegon supports work-life balance through flexible and hybrid working arrangements, with local policies at business units and the Netherlands CLA covering flexible working and parental leave.

Inclusion and diversity section. In 2024 Aegon began disclosing its global gender pay gap for the first time. The unadjusted gender pay gap was 30.4%, calculated as the difference between the average gross hourly earnings of male and female-paid employees as a percentage of male earnings, based on total compensation (base salary plus variable pay). The adjusted gender pay gap, which accounts for factors such as job function, job level, country, tenure, age as an indication of experience, and performance rating, was 11.2%. Neither figure was measured in 2023. The ratio of CEO compensation to median employee compensation was 36:1 (not measured in 2023). Compliance with the Global Remuneration Framework was 100%, unchanged from 2023. Aegon continues to work on gender balance in senior management, including requiring diverse candidate short-lists for senior roles where no internal successor is pre-determined.

Inclusion and diversity section. Through the Speak Up program, all members of Aegon's workforce, including non-employees and joint venture employees, can report incidents of unfair treatment, discrimination, harassment, or human rights violations confidentially or anonymously, with protection from retaliation. In 2024 there were 63 work-related complaints reported (up 19% from 53 in 2023) and 2 work-related incidents of discrimination (down from 3 in 2023). The total amount of material fines, penalties, and compensations was nil (also nil in 2023). Aegon states it identified no severe human rights incidents related to its workforce. These figures relate to complaints and incidents reported through the online Speak Up platform and cover employees of Aegon Ltd. and its subsidiaries. Effectiveness of measures against violence and harassment is monitored through GES wellbeing metrics, confidential advisor and Speak Up inquiries, and frequent policy and reporting-channel reviews overseen by the Global Compliance team.

Per the Data privacy and Responsible marketing practices sections, Aegon manages impacts on consumers and end users (its customers, in particular end consumers) through several policies. Data privacy is governed by the Global Information Security Policy and the Aegon Privacy Control Framework (APCF), supported by local privacy policies, notices and statements, with Transamerica running a similar local program. Responsible marketing is governed by the group Pricing and Product Development Policy and the Market Conduct Compliance Policy, supported by local business-unit policies covering mis-selling prevention, product approval and target market assessments. The policies aim to protect confidentiality, integrity and availability of data, ensure fair treatment of customers and align with regulations such as GDPR, CCPA/CPRA, HIPAA, IDD and MiFID. Senior accountability sits with the Group Chief Privacy Officer, Global CISO, Global Chief Actuary and Group Chief Compliance Officer. Effectiveness is assessed through annual attestation and audits.

Per the Data privacy and Responsible marketing practices sections, Aegon engages with customers about impacts through publicly available privacy statements that explain how personal data is processed and provide contact persons, usually local Data Protection Officers, for complaints. Business units operate different channels to collect customer feedback and complaints. For marketing, business units use customer feedback to improve practices and satisfaction, with local channels including customer panels and customer support lines where Aegon listens to concerns and reviews customers' information needs. Insights from customer experience and complaints analysis are incorporated into processes to improve the clarity of information and identify risks from misleading information. Data from tools such as the Net Promoter Score (NPS) and analysis of risk events provide insight into satisfaction and potential risks. Ongoing monitoring reviews whether appropriate action is taken and remedies are effective. The report does not describe how the perspectives of vulnerable or marginalised consumer groups are specifically gathered.

Per the Data privacy and Responsible marketing practices sections, customers can raise data-privacy complaints through contact persons named in privacy statements, usually the local DPOs, and ongoing monitoring reviews that when breaches occur appropriate action is taken and remedies are effective. The Global Information Security Policy includes standardized procedures to remediate data breaches and minimize the influence of future privacy incidents. The Aegon Speak Up channel is available should customers wish to raise concerns about potential misconduct, offering online and toll-free reporting in all countries where Aegon operates, with anonymity possible. For marketing, if customers complain, Aegon aims to deal fairly and effectively with concerns, take action to remedy negative impacts, and address root causes to improve processes. Alternative channels include reporting to the chairman of the Audit Committee and the local ombudsman. Channel effectiveness is assessed through periodic reviews, compliance monitoring and independent audits.

Per the Data privacy and Responsible marketing practices sections, Aegon takes action on material impacts through two broad categories, data privacy and information security. It applies a specific approach to securely manage highly sensitive information across its lifecycle, provides regular mandatory training for all employees, and operates an Information Security Incident Response Program supported by tools, analysis and remediation measures to prevent data loss and respond to incidents. A risk scoring methodology assesses protection levels for external and internal threats, with progress monitored quarterly. Third-Party Risk Management standards and Privacy Impact Assessments mitigate supplier risk. For responsible marketing, actions include regular monitoring and assurance activities, periodic risk assessments, internal audits and compliance checks on marketing materials, plus local training for marketing teams and approvers (some via the third-party We Learn platform). Existing budgets and resources from the standing data privacy, information security and compliance organizations fund these actions. Effectiveness of channels is assessed through periodic reviews and audits.

Per the Data privacy and Responsible marketing practices sections, Aegon has set measurable targets related to consumers and end users. For data privacy, the target for both the proportion of employees who completed specific data privacy training and the proportion who completed the annual Information Security training was 95% for 2024, with 98% achieved for each, and the target remains 95% for 2025. These targets are set by the Chief Information Security Officer and Chief Privacy Officer and allow a margin for employees unable to complete training on time. For responsible marketing, the KPI is significant fines to address cases of mis-selling, with a target of 0 EUR for 2024, performance of 0 EUR, and a 0 EUR target for 2025, monitored by Group Compliance. Measurement frequency is annual. The report does not describe direct engagement with consumers in setting these targets.

Per the Business conduct section, Aegon's corporate culture is underpinned by its purpose, values and Code of Conduct, which is publicly available and sets mandatory conditions for how employees conduct business and make ethical decisions in stakeholders' long-term interests. Annual Code of Conduct attestation is mandatory for all direct employees, and violations may lead to disciplinary action up to termination. Core Compliance policies include the Anti-Bribery and Corruption Policy (zero tolerance), the Conflict of Interest Policy, and Financial Crime policies (AML & CTF, Anti-Fraud, Sanctions), plus the Global Procurement Policy and Vendor Code of Conduct for suppliers. Whistleblower protection is provided through the Aegon Speak Up Policy, aligned with the Dutch Whistleblower Authority Act 2023 transposing EU Directive 2019/1937. It allows confidential or anonymous reporting via an independent third-party service, protects reporters from retaliation, and offers Confidential Advisors in the Netherlands and escalation to the Audit Committee chair. The Group Chief Compliance Officer oversees the program.

Per the Business conduct section, Aegon has a comprehensive approach to prevent and detect corruption and bribery, including a zero-tolerance stance covering active and passive forms. The Anti-Bribery and Corruption (ABC) Policy sets mandatory principles, key requirements and responsibilities, outlines rules on gifts and entertainment and an approval process, and references the U.S. FCPA and UK Bribery Act. Local business units regularly monitor the Gift and Entertainment register to identify issues and trends, with internal escalation procedures to report suspicions or attempts. Identified issues are reported to local management, escalated as necessary, and reported to regulatory authorities or law enforcement where a criminal offence is suspected. All employees must complete ABC training at least every two years; senior management develops and conducts sessions and sets the tone at the top. Training is delivered via the global e-learning tool Absorb, with a minimum 95% completion rate and an 80% knowledge pass rate. Group Internal Audit independently audits adherence. Investigators and compliance functions operate independently of management.

Per the Business conduct section metrics table, Aegon reported no confirmed incidents of bribery or corruption for 2024 (and 2023): the number of incidents of bribery or corruption, the number of convictions, and the value of fines are all reported as nil (shown as a dash). These figures include confirmed incidents conducted by employees, excluding incidents still under investigation at period end. Compliance with anti-bribery policy requirements was reported at 100% for both 2024 and 2023, and compliance with conflict of interest policy requirements at 97% for both years. Separately, and distinct from bribery and corruption, Aegon reported 711 confirmed fraud incidents in 2024 (2023: 156), of which 7% involved intermediaries and 93% third-parties; 95% of these did not result in a loss or were recovered, 4% caused individual losses below EUR 100,000, and 1% below EUR 1 million. No target has been set for the resolution of corruption and bribery incidents.