Aegon
Material Topics
Sustainability statement, in full
The complete text of Aegon’s FY2025 sustainability statement is held here – 98 pages, 405k characters, captured from the published report. Every disclosure below also links to its own passage.
ESRS 2 – General Disclosures
GOV-1The role of the administrative, management and supervisory bodiesReported
The role of the administrative, management and supervisory bodies
Reference: page 298.
The Board of Directors manages and conducts Aegon's business, including setting the company's strategy, and has four committees: the Audit Committee, the Risk Committee, the Nomination and Governance Committee, and the Compensation and Human Resource Committee. The CEO is the sole executive member of the Board and is responsible for day-to-day management. Aegon's approach to sustainability "is overseen by the Board of Directors' Nomination and Governance Committee," with other committees covering sustainability matters that fall within their own responsibilities. The Board and CEO are supported by the Global Sustainability Board (GSB), which embeds sustainability into the business. A CSRD Working Group, chaired by the Global Head of Corporate Sustainability, coordinates the overarching approach to material sustainability matters and reports quarterly to the GSB.
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reference: page 298; page 300.
The Board of Directors is accountable for Aegon's sustainability approach and reporting, including oversight of the management of impacts, risks and opportunities, while the CEO is responsible for integrating sustainability into the business. Sustainability topics, including policy and implementation matters and progress on the double materiality assessment, "are regularly brought to the attention of the Executive Committee and the Board of Directors." The CEO has mandated the GSB to deliver on governance processes for monitoring, managing and overseeing IROs, including target progress. The effectiveness of policies on material sustainability matters is measured through KPIs and targets reported to the GSB, a subset of which was linked to the CEO's 2025 short-term incentive.
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Integration of sustainability-related performance in incentive schemes
Reference: page 300; page 312.
"A subset of these KPIs was linked to Group performance indicators used to fund the bonus pool for employees (where applicable) and to the performance metrics for the CEO's short-term incentive in 2025." The clearest example given in the Sustainability statement is climate-related: the weighted average carbon intensity (WACI) target for corporate fixed income and listed equity "was also 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 our net-zero commitment." Further detail on the design of the 2025 Executive Director Remuneration Policy and the calculation of the short-term incentive is incorporated by reference from the Remuneration Report elsewhere in the Annual Report.
GOV-3(was GOV-4)Statement on due diligenceReported
Statement on due diligence
Reference: page 300.
Aegon presents a due diligence mapping table setting out where the core elements of its sustainability due diligence process are addressed across the Sustainability statement and the wider Annual Report. The table maps the five ESRS elements — embedding due diligence in governance, strategy and business model; engaging with affected stakeholders; identifying and assessing adverse impacts; taking actions to address them; and tracking effectiveness — to the "Impacts, risks, and opportunities," "Policies and procedures," "Actions (and resources)," "Metrics" and "Key performance indicator(s) and target(s)" sections of Climate change, Human capital, Business conduct, and the three Customers sub-topics. Due diligence processes related to impacts on people and the environment are disclosed under each material topic and supported by mapped policies and procedures.
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Risk management and internal controls over sustainability reporting
Reference: page 299.
"At Aegon, sustainability risk is not considered a separate risk type, but rather a risk driver that impacts multiple risks," embedded in the Enterprise Risk Management (ERM) framework. Internal controls over sustainability reporting are also embedded in the ERM framework: all material processes contributing to sustainability reporting have been identified, with main risks and controls documented for each with support from the risk functions, primarily addressing completeness and accuracy of sustainability information and compliance with regulations. Control attestations are completed for each Annual Report cycle, whereby in-scope business units and group functions sign off on the design and implementation of sustainability reporting key controls, with remediation plans logged and monitored quarterly.
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: page 295.
The Sustainability statement's value chain overview splits Aegon's main activities into upstream (procurement and capital sourcing, with suppliers and investors as key actors), own operations (the own workforce, carrying out core business and support functions), and downstream, which in 2025 was regrouped into two categories — insurance and pension, and investment management — replacing the more granular 2024 overview "to make the value chain more focused and straightforward." Distribution partners within insurance and pension are broken down into retail, workplace and institutional channels. Investment management covers general account assets (over which Aegon exercises investment decisions) and separate account assets; investments managed for third-party clients are excluded from the statement's scope.
SBM-2Interests and views of stakeholdersReported
Interests and views of stakeholders
Reference: page 303; page 304.
Aegon identified its most relevant affected stakeholders and users of its Sustainability statement "based on their role in the value chain and their knowledge of specific topics or aspects of Aegon's business." The stakeholder table (page 304) covers suppliers, investors, employees, customers, distribution partners and related joint ventures, investment customers and investees, social partners (NGOs, charities, communities) and regulators, with direct and indirect engagement methods listed for each — from supplier risk assessments and EcoVadis scoring to Capital Markets Days, town halls, customer panels and dialogue with the Bermuda Monetary Authority — alongside each group's stated expectations and concerns. In 2025 Aegon also carried out direct stakeholder engagement specifically on the outcome of the DMA (step 3 of the process, page 303).
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
Material impacts, risks and opportunities and their interaction with strategy and business model
Reference: page 304; per-topic pages 307-309, 329-330, 344, 348, 352, 355-356.
"The 2025 DMA has resulted in the following material topics: Climate change...; Human capital...; Customers, including data privacy, responsible marketing practices, and financial empowerment; and Business conduct, including protection of whistleblowers and prevention and detection of corruption and bribery." Compared with the 2024 DMA, "we identified no material opportunities for climate change and no risks for human capital," and a new sub-topic, financial empowerment, was added as material in 2025. Each material topic's IROs, and their location in the upstream, own-operations or downstream value chain, are set out in a mapping table at the head of the relevant topical chapter and described individually beneath it.
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Description of the processes to identify and assess material impacts, risks and opportunities
Reference: page 302; page 303.
Aegon's 2025 DMA followed a four-step methodology: Step 0, a landscape analysis of regulatory trends, peer reports and media coverage; Step 1, key design choices on value chain segmentation and scope; Step 2, an in-depth assessment of impact and financial materiality by a core team spanning corporate sustainability, finance, legal, strategy and risk, scoring each indicator "on a 1-to-5 scale (from 'minimal' to 'critical'), with scores of 4 and 5 indicating the material topics"; and Step 3, external stakeholder interviews to sense-check the outcome. Step 4 saw the final list of material topics and IROs validated by internal subject matter experts, with the CEO and Executive Committee approving the process and outcome. The 2025 DMA drew on internal sources (EcoVadis, the Global Employee Survey, the Global Human Rights Risk Assessment) and third-party databases including ENCORE, UNEP FI's ESG Risk Tool, MSCI and S&P ESG Risk Ratings, and Moody's Social Risk Heat Map.
IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statementReported
Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reference: page 367.
Aegon presents a table of "the ESRS disclosure requirements that are applicable to Aegon given the outcome of the double materiality assessment and covered in the Sustainability statement," with page and paragraph references for each, spanning ESRS 2 general disclosures, ESRS E1-1 to E1-6 and E1-9, ESRS S1-1 to S1-11, S1-13 and S1-15 to S1-17, ESRS G1-1, G1-3 and G1-4, and ESRS S4-1 to S4-5. A companion "Incorporation by reference" table (page 369) lists disclosure requirements and data points addressed elsewhere in the Annual Report rather than in the statement itself, and a "Phased-in and omissions" table (page 370) lists the specific data points where Aegon applies the ESRS quick-fix transitional provisions.
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation
Reference: page 309.
"Aegon does not currently have a climate transition plan but is taking steps to disclose one in the coming years." In the absence of a formal ESRS transition plan, the statement instead sets out a company-wide commitment to transition the general account investment portfolio to net-zero GHG emissions by 2050 as an NZAOA signatory, with five-year interim targets set under the Alliance's Target-Setting Protocol and progress tracked through the WACI, real-estate carbon intensity and operational emissions KPIs described under E1-4. A footnote to the Impacts, risks and opportunities section separately confirms that "Aegon is not excluded from the EU Paris-aligned Benchmarks" (page 305).
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysisReported
Identification of climate-related risks and scenario analysis
Back-filled from ESRS 2 IRO-1 and the "Assessment of anticipated financial effects and resilience" subsection of Climate change, where this content is disclosed in the FY2025 report (pages 306-308, 318-327). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Climate risks are classified by physical and transition type in the annual Group-level Climate Risk Assessment (GCRA, pages 306-307), which scores identified risks across investment, underwriting and operational risk categories over short-, medium- and long-term horizons. For its general account investment portfolio, Aegon runs a quantitative climate scenario analysis with Ortec Finance's Climate MAPS tool across five plausible pathways: Net-zero, Net-zero Financial Crisis, Delayed Net-zero, Limited Action and High Warming, with average global warming outcomes by 2100 ranging from 1.6°C to 3.7°C (page 325) — satisfying both the high-emission and 1.5°C-aligned scenario elements of paragraph 17. The scope covers the general account only over a 40-year horizon; the assessment was performed in 2025, complemented by a new bottom-up physical risk analysis of Transamerica's commercial mortgage loan portfolio (page 318).
E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate changeReported
Resilience in relation to climate change
Back-filled from the "Assessment of anticipated financial effects and resilience" subsection of Climate change, where this content is disclosed in the FY2025 report (pages 318-328). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
"Overall, our projections and assessment of climate change effects demonstrate resilience across Aegon's business activities, including our investment activities," attributed largely to the general account's roughly 80% fixed-income allocation, which "serves to limit the cumulative climate-related impact on returns." Business continuity measures (Business Impact Analyses, disaster recovery plans) address physical risk to operations, while limited non-life underwriting exposure limits direct climate-related claims impact. Aegon explicitly flags "the high degree of uncertainty with respect to projected outcomes" and notes the tension between 40-year scenario horizons and its shorter, three-year budget and medium-term-plan cycle. Both scope and methodology "will continue to evolve as Aegon works toward quantitative disclosures in the future" (page 324).
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: page 308; page 309.
Aegon's climate policies are mapped by place in the value chain: the Group Responsible Investment Policy "sets the framework for how Aegon's general account assets should be managed... consistent with its responsible investment objectives," outlining net-zero commitments and exclusion criteria; the NZAOA commitment applies the Alliance's Target-Setting Protocol to set 1.5°C-aligned targets; and the Group Environmental Policy sets minimum standards for own-operations environmental management, covering all business units with operational control except properties under 140 square metres. The Executive Committee holds ultimate responsibility for the Responsible Investment Policy and the NZAOA commitment, with the GSB monitoring implementation; the Global Head of Corporate Sustainability oversees the Environmental Policy.
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: pages 309-311.
Aegon's principal climate actions run through its downstream general account investment portfolio: three levers — factoring investee carbon intensity into portfolio management, active investment in climate solutions, and engagement with the highest carbon emitters — support the 2050 net-zero commitment. In 2025 Aegon "engaged with all 20 of the companies identified as the highest carbon emitters in our general account" and made further climate-solutions investments including a USD 10 million debt-for-nature swap in Ecuador. Own-operations actions (labelled "not material" in the DMA but disclosed voluntarily) include energy-efficiency upgrades, LED conversions and the relocation of Aegon's headquarters to Schiphol, which reduced Scope 1 and 2 emissions through a smaller floor area.
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: pages 311-312.
Aegon's headline climate KPI is the weighted average carbon intensity (WACI) of corporate fixed income and listed equity in the general account, targeted at a 50% reduction against a 2019 baseline by 2030; 2025 performance was a 52% reduction (219 tCO2e/EURm revenue). Three further 2030 targets, each against a 2019 baseline, cover directly held real estate carbon intensity (42% target, 55% achieved), absolute operational Scope 1+2 emissions (75% target, 77% achieved) and climate-solutions investment (an additional USD 1 billion on top of USD 2.5 billion previously invested, USD 0.4 billion achieved in 2025). Targets were approved by the CEO with Executive Committee support and GSB endorsement; the intensity-based approach for scope 3 investment targets uses the ESRS phase-in for financial institutions rather than an absolute-value target (page 370).
E1-7(was E1-5)Energy consumption and mixReported
Energy consumption and mix
Reference: page 317.
Energy is voluntarily disclosed under Climate change and labelled "not material," since Aegon's own operational footprint was not assessed as material in the 2025 DMA. Total energy consumption fell 12% year on year to 23,415 MWh, with the share of fossil sources rising from 32% to 52% and renewable sources falling from 68% to 48%, driven by the discontinuation of purchased Renewable Energy Certificates (RECs) in favour of direct renewable procurement. Natural gas consumption was 8,308 MWh; self-generated non-fuel renewable energy, including the Cedar Rapids Solar Farm, contributed 5,159 MWh. Aegon does not operate manufacturing or energy-intensive processes; its energy use is concentrated in offices and data centres.
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scopes 1, 2, 3 and Total GHG emissions
Reference: pages 313-315.
Gross Scope 1 emissions were 1,480 tCO2e (2024: 2,364) and gross market-based Scope 2 was 1,590 tCO2e (2024: 1,426), both voluntarily disclosed as "not material" to Aegon's own operations. Scope 3 is dominated by the Investments category (category 15), the only Scope 3 category assessed as material: general account corporate fixed income and listed equity carried total carbon emissions of 1,852,320 tCO2e (down 21% year on year, 95% data coverage), and sovereign fixed income 953,645 tCO2e including LULUCF. Total GHG emissions (market-based) were 2,997,378 tCO2e, down 20% on 2024, driven by lower investee emissions. Purchased goods and services, business travel and employee home-office emissions are disclosed voluntarily as non-material Scope 3 categories.
E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon creditsReported
GHG removals and GHG mitigation projects financed through carbon credits
Reference: page 311.
Aegon states plainly that "Aegon does not use carbon offsetting to meet its operational carbon footprint target," which it instead pursues through a 75% absolute Scope 1+2 reduction against its 2019 baseline (77% achieved by end-2025). No GHG removal activities, own carbon credit purchases, or reliance on removals to meet investment-portfolio decarbonisation targets are described anywhere in the Climate change section; the general account net-zero and WACI targets are similarly framed as reduction-based rather than offset-based. The ESRS 2 disclosure requirements table separately marks the "GHG removals and carbon credits, paragraph 56" data point from EU Benchmark Regulation legislation as not material for Aegon (page 371).
E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunitiesReported
Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Reference: pages 318-328.
Aegon discloses a qualitative and partly quantified assessment rather than monetised anticipated financial effects, which it applies the ESRS quick-fix phase-in to omit "for financial years 2025 and 2026" (page 370). The Ortec Climate MAPS scenario analysis (pages 319-327) projects general account portfolio return impacts under five pathways over a 40-year horizon at asset-class, sector and regional level, finding transition risk concentrated in carbon-intensive sectors and physical risk concentrated in real estate and alternatives, with the High Warming pathway producing the largest cumulative impact. The one quantified metric carried through to the E1-9 metrics table is the carrying amount of real estate assets by energy-efficiency class: EUR 45.1 million total in 2025 (2024: EUR 49.9 million), of which EUR 7.4 million falls in the least efficient (>500 kWh/m2) band.
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies related to own workforce
Reference: pages 331-332.
Own-workforce IROs are addressed through a set of global policies mapped to specific IROs: the Global Remuneration Framework supports general working conditions; the Talent Principles and Talent Review Framework and the Performance and Development Cycle support training and skills development; the Statement on Inclusion and Diversity and the Board's Diversity and Inclusion Policy support equal treatment and opportunities; and the Statement on Human Rights, "based on the Universal Declaration of Human Rights, the core standards of the International Labor Organization... and the principles of the UN Global Compact," underpins both equal treatment and measures against violence and harassment. Aegon notes there is no dedicated policy for social dialogue (IRO 2); this is instead addressed through actions described in the Actions and resources section.
S1-2Processes for engaging with own workforce and workers' representatives about impactsReported
Processes for engaging with own workforce and workers' representatives about impacts
Reference: pages 333-334.
Aegon's "most important and broadest channel for listening to our employees" is the annual Global Employee Survey (GES), run through third-party provider Culture Amp, which covers all direct employees plus the joint ventures Aegon THTF and MAG Seguros and is discussed with the Engagement Working Committee, Executive Committee and Board of Directors. Formal worker representation runs through collective labour agreements (CLAs) in the Netherlands — including a new CLA from January 2026 and a 2025 Social Plan agreed with unions covering the announced US headquarters relocation — plus UK union representation through Unite and Aegis, and two active Dutch Works Councils and a European Works Council, which have rights of consultation and, for certain personnel decisions, approval.
S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concernsReported
Processes to remediate negative impacts and channels for own workforce to raise concerns
Reference: page 334.
All members of the workforce, including non-employees and joint-venture employees, can raise concerns about suspected or observed misconduct through the Aegon Speak Up program, which offers confidential or anonymous reporting. In the Netherlands, employees can additionally consult an independent Confidential Advisor in strict confidence, and in circumstances requiring escalation or bypass of normal channels, concerns can go directly to the Chairman of the Audit Committee. Concerns related to personal work matters such as employment conditions or performance reviews "are matters for the local workplace and are expected to be resolved locally with direct managers or human resources representatives," with escalation to a local complaints procedure if not resolved.
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Taking action on material impacts on own workforce
Reference: pages 333-337.
"All material impacts related to human capital are positive," and Aegon's actions are organised by sub-topic: the GES for general working conditions and social dialogue; the Global Talent Marketplace, We Learn platform and ADVANCE leadership programme for training and skills development, including a Wharton-co-designed "Accelerating Growth" journey for 90 key leaders; Employee Resource Groups (36 in 2025), Workplace Pride benchmarking (maintaining "Ambassador" status above a 70% score) and monitoring of gender representation and pay gaps for equal treatment and opportunities; and the Speak Up programme, supported by Code of Conduct training, for measures against violence and harassment. All actions use existing global human resources budgets.
S1-4(was S1-5)Targets related to own workforceReported
Targets related to own workforce
Reference: page 337.
Aegon's only quantified own-workforce target is the employee engagement score derived from the GES, revised during the year from 80% to 76% "to reflect organizational developments" and achieved at 76% in 2025, with a further 76% target set for 2026. The target feeds into Group performance indicators used to fund the employee bonus pool and was included in the CEO's 2025 short-term incentive metrics. "Aegon has no defined target for the material impacts related to the sub-topics of equal treatment and opportunities and measures against violence and harassment in the workplace," which are instead monitored through GES responses and the Speak Up programme.
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of the undertaking's employees
Reference: page 338.
Aegon had 11,806 direct employees at year-end 2025 (2024: 11,952), of whom 11,672 were permanent and 134 temporary, split across the Americas (6,207), the United Kingdom (2,564), International (790), Asset management (1,036) and Holdings and other activities (1,075). Aegon reports zero non-guaranteed-hours employees. There were 1,162 new hires and 1,287 leavers in 2025, giving an 11% total turnover rate (8% voluntary, 3% involuntary), down from 12% in 2024. The employee headcount is sourced from the Workday HR system and reflects the last day of the reporting period.
S1-6(was S1-7)Characteristics of non-employee workersReported
Characteristics of non-employee workers
Reference: page 338.
Aegon reports 2,705 non-employee workers in its own workforce for 2025 (2024: 2,787), a 3% decrease. Non-employee workers are defined as "individuals with a contract with Aegon to supply labour ('self-employed worker') and workers provided by third-party companies primarily engaged in 'employment activities,'" who typically perform the same work as employees, such as covering for staff who are temporarily absent due to illness, holiday or parental leave. The Sustainability statement does not further disaggregate this population by region or contract type in the metrics table.
S1-7(was S1-8)Collective bargaining coverage and social dialogueReported
Collective bargaining coverage and social dialogue
Reference: page 340.
Coverage by collective bargaining or labour agreements is disclosed by EEA country and non-EEA region for 2025: 100% in the Netherlands, Hungary and Germany-equivalent scope, 100% in Spain, and figures of zero for the Americas and Asia, "because these jurisdictions typically do not mandate collective agreements at the regional or industry-wide level." Employees in Germany are not covered by a collective labour agreement but are covered by workers' representatives, disclosed separately for EEA countries. Aegon notes the coverage figures also include employees in higher salary scales who are not directly covered by an agreement "but because the salary scales are also determined or influenced by these agreements, they are included in the coverage."
S1-8(was S1-9)Diversity metricsReported
Diversity metrics
Reference: pages 336, 341.
Female employees represented 51% of the direct workforce in both 2025 and 2024. By age, 11% of employees are under 30, 56% are 30-50, and 33% are over 50. Women held 39% of senior management positions in 2025 (167 in 2024, 161 in 2025), unchanged from 2024, though the absolute number fell alongside overall headcount. At Executive Committee level, female representation reached 27% (up from 20% in 2021), across five nationalities; at Board of Directors level, female representation was 36.3% across four nationalities. Aegon removed its target for women in senior management in 2025 "after considering the range of stakeholder expectations... [and] progress from 2020 to 2025, with the metric increasing from 32% to 39%."
S1-9(was S1-10)Adequate wagesReported
Adequate wages
Reference: page 338.
Aegon reports zero employees earning below the applicable adequate wage benchmark in both 2025 and 2024. For the Netherlands and Spain, the benchmark is assumed to be the legal minimum wage; elsewhere the assessment draws on employees' base salary plus variable pay recorded in Workday. Because "results show that Aegon's salaries are well above the applicable adequate wage benchmarks," the assessment is refreshed only every two years, with the 2025 figure based on the prior year's assessment; Aegon states it will reassess this approach following organisational changes such as mergers or acquisitions.
S1-10(was S1-11)Social protectionReported
Social protection
Reference: page 338.
98.0% of Aegon's direct employees were covered by social protection against loss of income due to sickness, unemployment, employment injury and acquired disability, maternity leave and retirement in 2025, unchanged from 2024. Coverage is achieved "either through government policies or company plans." Aegon flags an explicit gap: "There is no full social protection in Hong Kong and Singapore. The regulation requires maternity and sick leave pay, but there is no coverage for loss of income or disability, unless offered by the employer's group insurance plan," which is the source of the residual 2.0% shortfall from full coverage.
S1-12(was S1-13)Training and skills development metricsReported
Training and skills development metrics
Reference: pages 340-341.
Average training hours per employee were 11.6 in 2025, a metric added this year now that data is available through the Absorb and We Learn training platforms (2024: not measured, phased in). 99% of employees participated in performance and development reviews in 2025 (2024: 98%), with participation broken down by gender (99% male, 99% female, 100% "other"). Average investment in training and career development per employee was EUR 6.3 thousand (2024: EUR 5.9 thousand). Aegon applies the ESRS phase-in to the gender split of average training hours: it "discloses the average number of training hours per employee, but not the split per gender," with the split deferred pending the ESRS simplification package (page 370).
S1-14(was S1-15)Work-life balance metricsReported
Work-life balance metrics
Reference: page 338.
99.5% of employees were entitled to take family-related leave (maternity, paternity, parental and caregiver leave) in both 2025 and 2024. Of entitled employees, 100.0% of both male and female employees took family-related leave in 2025, unchanged from 2024, alongside a small "Other" and "Not reported" gender category. Aegon defines family-related leave as covering "maternity leave, paternity leave, parental leave, and caregiver leave," with take-up calculated as employees who took the leave divided by the number entitled to take it; the gender split of this metric was not revised for 2024 comparability "because it was impracticable to recalculate these figures."
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)Reported
Compensation metrics (pay gap and total compensation)
Reference: pages 341-342.
The unadjusted gender pay gap was 32.1% in 2025 (2024: 30.4%), and the adjusted gap, which controls for job level, function, country, age and performance rating, was 11.6% (2024: 11.2%). The ratio of CEO compensation to median employee compensation was 40:1 on Aegon's continuing basis (2024: 36:1); calculated on the ESRS-required basis including LTI fair value for the period, it was 71:1 (2024: 61:1). Compliance with the Global Remuneration Framework was 100% in both years. Aegon notes the CEO was not the highest-paid individual under this metric's definition in 2025 "because the new LTI plan for the CEO is being phased in."
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Incidents, complaints and severe human rights impacts
Reference: pages 341-342.
Work-related complaints reported through Speak Up and SHARE channels rose to 87 in 2025 (2024: 63), and work-related incidents of discrimination rose to 13 (2024: 2); Aegon attributes the increase partly to "ongoing promotion of Speak Up," which may itself be driving higher reporting rather than higher incidence. No material fines, penalties or compensation (above the EUR 100,000 aggregate reporting threshold) were recorded in either year. Separately, under Governance, Aegon states that its biennial Human Rights Risk Assessment "identified no severe human rights incidents related to our workforce," with the most recent assessment (2024) finding adequate management proficiency in higher-risk locations such as China and Brazil.
S4 – Consumers and End-Users
S4-1Policies related to consumers and end-usersReported
Policies related to consumers and end-users
Reference: pages 345, 349, 352.
Aegon's customer-facing policies are mapped to each of the three material sub-topics: the Aegon Privacy Control Framework and local privacy policies and statements, together with the Global Information Security Policy (rebuilt in 2025 around NIST CSF v2.0), address data privacy; the Pricing and Product Development Policy and the Market Conduct Compliance Policy address both responsible marketing practices and financial empowerment. The Group Chief Privacy Officer holds accountability for the APCF, the Global Chief Information Security Officer for information security, and the Global Chief Actuary and Group Chief Compliance Officer respectively for pricing/product and market-conduct policy, with local Data Protection Officers responsible for implementation in each business unit.
S4-2Processes for engaging with consumers and end-users about impactsReported
Processes for engaging with consumers and end-users about impacts
Reference: pages 346, 350.
For data privacy, customers are informed of how their personal data is processed through publicly available local privacy statements, with complaints directed to local Data Protection Officers or the Aegon Speak Up channel. For responsible marketing practices, business units use "customer feedback to improve marketing practices and customer satisfaction," through customer panels, customer support lines, Net Promoter Score tracking and analysis of risk events, with the effectiveness of these channels "assessed through periodic reviews, compliance monitoring, and independent audits." Financial empowerment, disclosed as an opportunity rather than an impact or risk, does not carry a separate dedicated engagement-channel description in the statement.
S4-2(was S4-3)Processes to remediate negative impacts and channels for consumers and end-users to raise concernsReported
Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
Reference: pages 346, 350.
Customers can raise data privacy complaints through the contact persons listed in local privacy statements, typically the local Data Protection Officer, with "ongoing monitoring... to review that when breaches occur, appropriate action is taken and that remedies are effective." The Aegon Speak Up channel is also available to customers to raise concerns about potential misconduct, including marketing-related complaints, alongside business-unit-specific customer feedback and complaints channels and, for escalation, the chairman of the Audit Committee and local ombudsman. Marketing complaints feed processes "to identify and address the root causes of complaints to improve processes."
S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actionsReported
Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions
Reference: pages 346-347, 350, 352-353.
Data privacy and information security actions in 2025 included a major rebuild of the Global Information Security Policy around the NIST Cybersecurity Framework v2.0 with expanded, mapped key requirements. Responsible-marketing actions included periodic risk assessments, internal audits and compliance checks on marketing materials, plus local training for marketing teams. Financial-empowerment actions targeted underserved segments: Aegon UK launched the Mylo pension-consolidation app and the Pension Geeks education platform, while Transamerica's World Financial Group agency, whose licensed agents "represent more than 75 different spoken languages," continued recruiting from the communities it serves to expand financial inclusion.
S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reference: pages 350, 353.
Aegon sets one quantified customer target: "Significant fines to address cases of mis-selling," targeted and achieved at EUR 0 in both 2025 and 2026 targets, monitored by Group Compliance and reported to the GSB at least twice a year, using a EUR 100,000 reporting threshold. No KPI or target is set for data privacy or financial empowerment. For financial empowerment specifically, Aegon states plainly: "We have not set KPIs for the topic of financial empowerment. However, as this is an opportunity, we hope to see the effects reflected in increased market share and revenue," tracked instead through Net Promoter Score trends.
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Business conduct policies and corporate culture
Reference: page 355; pages 356-359.
"Business conduct at Aegon is underpinned by our Code of Conduct, which outlines how our employees should conduct business and exercise sound judgment in reaching ethical business decisions in the long-term interests of our stakeholders." All direct employees must complete an annual Code of Conduct attestation, and violations "may qualify as violations of the law and result in civil or criminal exposure." The Code sits alongside a wider compliance framework — the Anti-Bribery and Corruption Policy, Conflict of Interest Policy, and Financial Crime policies (Anti-Money Laundering, Anti-Fraud, Sanctions) — all under the accountability of the Group Chief Compliance Officer, supported by mandatory periodic training delivered through the Absorb e-learning platform.
G1-2Management of relationships with suppliersReported
Management of relationships with suppliers
Reference: page 358; page 378.
The Global Procurement Policy "define[s] the minimum requirements and establish[es] the standards that must be adhered to when procuring goods and services or engaging third-party vendors," while the Vendor Code of Conduct, combined with contract terms, "sets the standards for the business relationship between Aegon and its vendors," including ESG-related performance assessed on a risk basis. Aegon's Specific Circumstances disclosure notes that "prevention and detection of corruption and bribery for sourcing activities" was reassessed as not material in 2025 (page 296). Voluntary supplier metrics (page 378) show EUR 1.5 billion total spend on goods and services, of which EUR 1.1 billion (71%) went to 150 in-scope suppliers, 99 of whom were assessed for ESG performance.
G1-2(was G1-3)Prevention and detection of corruption and briberyReported
Prevention and detection of corruption and bribery
Reference: pages 355-361.
Aegon's material risks (IROs 2 and 3) cover failure to implement effective anti-corruption controls and incidents of corruption or bribery, managed through a policy framework spanning the Code of Conduct, Anti-Bribery and Corruption (ABC) Policy, Conflict of Interest Policy and Financial Crime policies, all under Group Chief Compliance Officer accountability. Actions include a Compliance Framework, the Policy Attestation Process, an Annual Compliance Risk Assessment (ACRA, which replaced the group-wide SIRA following the move of group supervision to the Bermuda Monetary Authority), and mandatory ABC and Code of Conduct training with a minimum 95% completion target. Aegon prohibits facilitation payments in all circumstances and monitors Gift and Entertainment registers locally for trend review.
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct
Back-filled from the Business conduct chapter's Key performance indicator(s) and target(s) section, where this content is disclosed in the FY2025 report (page 361). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Aegon states plainly that it has no outcome target for corruption and bribery itself: "We also monitor the resolution of incidents of corruption and bribery, including the protection of whistleblowers. However, we have not set a target for these sustainability matters." Effectiveness is instead tracked through a proxy compliance KPI — "Proportion of employees who completed the Code of Conduct attestation" — targeted at 95% for both 2025 and 2026, and achieved at 100% in 2025 (2024: 98%). This satisfies the MDR-T "effectiveness tracked in the absence of a target" limb, and is reported to the GSB at least annually with action plans created if progress falls behind target.
G1-4Incidents of corruption or briberyReported
Incidents of corruption or bribery
Reference: pages 361-362.
Aegon recorded zero incidents of bribery or corruption in both 2025 and 2024, zero convictions, and zero value of fines. Reported fraud incidents rose sharply to 3,846 in 2025 (2024: 711, a 441% increase), which Aegon attributes to "an increase in account takeover attempts" rather than a rise in confirmed loss: "90% did not result in a loss," with just 0.25% of cases falling into the most significant loss category (EUR 100,000 to EUR 5 million) and total losses in that category under EUR 1.5 million. Incidents still under investigation at period-end are excluded from all figures, and the number of convictions reflects only cases where Aegon or an employee was actually convicted.
G1-5Political influence and lobbying activitiesReported
Political influence and lobbying activities
Reference: pages 378-379.
Lobbying and political engagement is disclosed as an "Additional metric" that "goes beyond specific reporting requirements and is not linked to Aegon's material topics identified through the DMA." Internal and external lobbying expenses were EUR 0.2 million in 2025 (2024: EUR 0.3 million), monetary political contributions were EUR 0.7 million (unchanged), and membership fees to lobbying associations were EUR 4.0 million (2024: EUR 3.5 million). Political contributions "consist of those made by Transamerica's Political Action Committee (PAC), which acts independently from Aegon or Transamerica" and receives only voluntary employee donations, distributed by the PAC's own independent board rather than by Aegon management.