Ageas

Ageas describes its administrative, management and supervisory bodies. At 31 December 2024 the Board of Directors had twelve members: Bart De Smet (Chairman), Yvonne Lang Ketterer (Vice-Chair) and others, including three executive directors (CEO Hans De Cuyper, CFO Wim Guilliams, CRO Christophe Vandeweghe). Nine members are non-executive, of which eight are independent. There is no direct employee representation on the Board; employee interests are represented indirectly through the Executive Committee. Male and female Board members are equally represented, meeting the legal 33% gender minimum. The Executive Committee had eight members (six male, two female). Four Board subcommittees operate: Nomination and Corporate Governance, Audit, Remuneration, and Risk and Capital. Board members provided a self-assessment of expertise in sustainability-relevant matters (for example climate change effects, ESG investment, data privacy, human and labour rights); a majority confirmed sufficient expertise. Roles, competences and diversity policy are detailed.

Ageas explains how its governance bodies are informed about and address material impacts, risks and opportunities (IROs). The Board of Directors has ultimate responsibility for overseeing and addressing identified material IROs and for ensuring they are reflected in the ESG strategy, policies and risk management, and is ultimately responsible for defining and endorsing the policy framework. The Executive Committee implements policies. The material IROs addressed during the reporting period were those deemed material in the double materiality assessment (section 5.4) plus Impact24 areas of impact. The Board and its committees monitor performance through regular reports from the Executive Committee and stakeholders, drawing on materiality assessment results, due diligence, sustainability performance indicators, stakeholder engagement, and external assurance. Information is presented via board papers, management reports, dashboards, presentations and workshops. The Board and Executive Committee periodically review strategy and the business plan, supported by the internally developed Horizon Scan and an emerging risk radar discussed at the Group Risk Committee, Executive Committee and Board.

Ageas discloses how sustainability performance is integrated into incentive schemes. The updated Remuneration Policy 2024, approved by shareholders on 15 May 2024 with 93.99% of votes, introduced a revised Long-Term Incentive Plan effective from 2024 that adds an ESG component to the performance conditions alongside relative Total Shareholder Return, with stricter vesting conditions and a revised peer group. The Executive Committee's 2024 variable remuneration of EUR 4,938,134 included a long-term incentive of EUR 2,030,875 conditional on relative TSR and ESG rating performance. The Remuneration Committee advises on how to include sustainability in performance KPIs. Non-financial stakeholder objectives (customer NPS, employee engagement, gender diversity, sustainable products and investments) featured in performance assessment; the Board set the annual incentive business component at 160.8%. The LTIP granted in 2021 did not vest because relative TSR fell below the 25th percentile of the peer group.

Ageas provides a statement on sustainability due diligence. As a regulated (re)insurance group, Ageas states it will conduct sustainability due diligence on its own operations, those of its subsidiaries and its business partners in the upstream part of the value chain (supply chain), reflecting the evolving legislative framework and internationally recognised standards on corporate sustainability due diligence. Ageas commits to continue enhancing its existing due diligence practices as regulatory requirements evolve. A mapping table links the core due diligence elements to sections of the report: embedding due diligence in governance, strategy and business model (5.3, 6.3.2, 7.2, 7.5); engaging with affected stakeholders (6.3.2, 11.7, 5.3, 9.2, 10.3, 12.1); identifying and assessing adverse impacts on people and environment using a risk based approach (9.5, 10.4, 12.1, 11.7); taking appropriate actions to prevent, mitigate, end or remediate impacts; and tracking effectiveness of actions and communicating on them.

Ageas describes its risk management and internal controls over sustainability reporting. To mitigate the risk of incomplete or incorrect ESG disclosures, Ageas applies internal controls to help ensure information is reported with completeness, accuracy and integrity, and continuously improves its control framework for data quality and narrative coverage. The processes cover risk identification, assessment, mitigation and monitoring, with sustainability metrics integrated into overall risk management and continuous monitoring of controls. The risk assessment includes periodic monitoring of companies, technical checks on calculations, consistency checks and trend analysis, with risks prioritised by impact and likelihood of inaccurate conclusions from missing information. The main risks identified are missing data, misinterpretation and delays in reporting deadlines. Mitigation includes monitoring disclosed information, technical checks, consistency checks, trend analysis to detect outliers, and a centralised data glossary of term definitions. Findings are integrated through data owners and control validators and reported periodically to the administrative, management and supervisory bodies.

Ageas sets out its strategy, activities, business model and value chain. Ageas is a predominantly retail and SME focused insurance group offering Life, Non-Life and Health solutions to millions of customers, active in 13 countries across Europe and Asia through wholly owned subsidiaries and long-term partnerships, and engaged in reinsurance globally. In 2024 it generated total insurance revenue of EUR 7,371 million with 17,677 dedicated employees across consolidated entities. The business model rests on three core activities plus supporting activities: insurance (Life/Non-Life split roughly 70/30), reinsurance (internal since 2015, third-party underwriting under Ageas Re since 2023), and investment activities. Its purpose is to be a Supporter of your life, guided by values Care, Dare, Deliver and Share, with 2024 closing the Impact24 strategy and the successor Elevate27 (2025-2027) introduced. Key intangibles include workforce, distribution relationships, reputation and (re)insurance licences. Ageas states it is not active in the sectors mentioned under ESRS 2 paragraph 40(d) i to iv.

Ageas describes engagement with its stakeholders and how their interests shape strategy. Prior to each strategic cycle Ageas engages stakeholders, and the double materiality assessment carried out in the second half of 2023 provided further stakeholder insight; identified IROs are considered during strategy setting and review. A table maps engagement channels, needs and expectations, and the report sections addressing each stakeholder group: customers (surveys such as cNPS and tNPS, market research, complaints channels; wanting transparency, personalisation and understandable products), employees (line-manager engagement, surveys, Horizon Scan; wanting career development, adequate remuneration and an inclusive workspace), business partners (relationship managers, partnership days; wanting data security and ethical conduct), investors (investor days, shareholders meeting; wanting stable returns), and society (market research; wanting solutions to societal and environmental challenges and support for the net zero transition). Elevate27 explicitly addresses evolving stakeholder expectations across customers, employees, partners and investors. Group goals are cascaded to local realities and the new strategy is presented to the Board for approval.

Ageas explains the material IROs and their interaction with strategy and business model, situating them across its three core activities: insurance, investment and supporting activities. The material IROs stem from the double materiality assessment and are described in the relevant topical chapters. For climate change, Ageas performed a scenario-based resilience analysis using three NGFS scenarios (Net Zero 2050, Delayed Transition, Current Policies) covering market and underwriting risks across investment and underwriting activities; it concluded that while all scenarios indicate potential adverse impacts on the Solvency Ratio, none threatens Ageas's financial strength, demonstrating resilience. Time horizons are defined as short (0-3 years), medium (3-10 years) and long term (above 10 years). Transition risks dominate over the short to medium term while physical risks grow over the long term, with the greatest long-term impact under Current Policies. Ageas identified no additional current impacts of material risks or opportunities on its financial position, performance or cash flows in the reporting period. A phase-in applies for ESRS 2 paragraph 48e.

Ageas describes the process to identify and assess material impacts, risks and opportunities. In the second half of 2023 Ageas conducted its first double materiality assessment under CSRD and ESRS 1, covering all consolidated entities and equity associates, and applying both impact materiality (inside-out) and financial materiality (outside-in) over short, medium and long term. A long list of ESG topics was built from desk research of rating agency reports, the ORSA, Impact24 documentation and voluntary frameworks (UN Global Compact, UNEP FI PSI, UN PRI, NZAOA), then mapped and clustered against ESRS sub-topics and entity- and sector-specific topics across insurance, investment and supporting activities. Impacts were scored on scale, scope, remediability and likelihood; risks and opportunities on likelihood and magnitude of financial effect (from less than 5% to more than 40% of profit and loss), using expert judgement and defined thresholds. Results were validated by the Group ESG and CSRD Steering Committee, the Executive Committee and the Audit Committee. For climate, scenario analysis under three NGFS scenarios assessed risk over the short, medium and long term up to 2075.

Ageas provides a content index of the disclosure requirements covered in the sustainability report. Sections 14.1 and 14.2 present, respectively, a full list of material IROs per ESG sub-topic with IRO type (positive/negative impact, risk, opportunity), a description and a time horizon (short, medium or long term), and a content index table listing each ESRS disclosure requirement with the chapter reference, page range and links to other EU legislation (SFDR, Pillar 3, Benchmark regulation, EU Climate law). The index maps ESRS 2 general disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and the topical standards for the material topics: climate change (E1), own workforce (S1), consumers and end-users (S4) and business conduct (G1), plus entity-specific disclosures on responsible investment and responsible communications. It notes phase-in provisions (for example ESRS 2 paragraph 48e and certain S1 datapoints) and lists non-material datapoints for standards not applicable to Ageas.

Ageas discloses that under its Impact24 and successor Elevate27 strategies it is developing a climate transition plan aiming for a journey towards net zero and alignment with the Paris Agreement 1.5C goal, with a specific approach per activity component (insurance, investment, supporting/own operations). Ageas explicitly states it is not yet in a position to publish a fully developed transition plan as stipulated by CSRD/ESRS (the DR index notes no fully ESRS compliant transition plan) and is working towards an internal plan, providing transparency about outstanding information. Key transition-related ambitions include a net-zero investment portfolio by 2050, a 55% reduction of investment-portfolio GHG intensity by 2030 versus 2021 (raised from 50% under Impact24), real-estate alignment with CRREM 1.5C national pathways by 2030, and reducing own-operations emissions (30% by 2027 vs 2023). Ageas cites its NZAOA membership and states targets are not SBTi-endorsed but take into account IPCC 1.5C trajectories.

Ageas describes climate-related policies across three activity streams. For insurance, key documents are the Underwriting, Product Approval and Claims policies, which integrate sustainability and climate factors and include ESG screening as a signatory of the UNEP FI Principles for Sustainable Insurance. For investment, Ageas updated its Responsible Investment Framework in 2024, integrating ESG through exclusion, ESG integration and engagement; it excludes thermal coal extraction and power generation, unconventional oil and gas (Arctic drilling, oil sands, shale) and new oil and gas infrastructure, with commitment to phase out coal-fired electricity investments by 2030 in line with 1.5C pathways. The framework is endorsed by the Investment Committee and applied across European consolidated entities. For supporting activities/own operations, Ageas updated its Environmental policy in 2024 covering business travel, commuting and IT equipment, committing to continuous improvement, legal compliance and environmental awareness.

Ageas discloses actions and resources across its activities. Insurance actions include measuring insurance associated emissions using PCAF standards, supporting electrification (electric scooters, eco-bonus, EV partnerships), environmentally friendly claims (Ageas UK repairs one in three motor incidents with a recycled part) and engaging commercial customers. Investment actions include ESG integration, sector and company exclusions, and engagement/voting, including engaging 20 low-performing GHG emitters. Supporting actions include transitioning to green electricity, greening the car fleet, improving building energy efficiency and reducing business travel and commuting. On resources, Ageas states investment and insurance actions sit within multi-year and general team budgets, while supporting activities have a dedicated budget of more than EUR 30 million for renovation works, solar panels and greening the car fleet. Ageas also targets investing at least EUR 15 billion in positive social and environmental impact assets by 2027 (versus EUR 10 billion under Impact24), with at least EUR 7.5 billion dedicated to climate-related investments.

Ageas sets GHG reduction targets by activity. For the investment portfolio (Category 15, proprietary listed equities, corporate bonds and infrastructure, excluding unit-linked, European consolidated entities) it targets net zero by 2050 and a 55% reduction of carbon intensity by 2030, expressed in tCO2eq per million USD revenue, from a 2021 base year of 149.1 tCO2eq/million USD; no absolute target is set. This 2030 target was raised from 50% under Impact24 to 55% under Elevate27. For directly held real estate, Ageas targets GHG reductions in line with the CRREM 1.5C pathway from a 2021 base year. For own operations, the Impact24 target was carbon neutrality and a 40% reduction (scope 1, 2 and certain scope 3) versus a 2019 base year of 30,281 tCO2eq; under Elevate27 the target is a 30% reduction of main emissions (scope 1, 2 and scope 3 business travel and commuting of insurance activities) versus 2023. Targets are not SBTi-endorsed but reference IPCC 1.5C trajectories and the NZAOA framework (which identifies 40-60% absolute reduction by 2030).

Ageas reports energy consumption and mix for the consolidated group in 2024, combining insurance with non-insurance activities such as real estate and mobility services. Total energy consumption related to own operations was 260,068 MWh. Total energy consumption from fossil sources was 97,280 MWh (37% of total), including crude oil and petroleum products 15,903 MWh, natural gas 20,056 MWh, and purchased electricity/heat/steam/cooling from fossil sources 20,223 MWh; energy from fossil sources in high-impact activities was 56,191 MWh. Nuclear sources contributed 6,833 MWh (3%). Renewable sources totalled 155,955 MWh (60%), including 154,001 MWh purchased and 1,954 MWh self-generated (about 1% from solar panels at AG Insurance offices). Ageas notes an energy intensity of 0.02% MWh per Euro net revenue against 194,558 MWh and EUR 938 million revenue for high-impact activities. Energy was not considered a material topic; further real-estate detail is in chapter 13.

Ageas reports 2024 gross GHG emissions for the consolidated group (tCO2eq): Scope 1 16,238 (2023: 11,342); Scope 2 location-based 35,153 and market-based 5,368; and Scope 3 total location-based 5,290,964 (2023: 960,198) and market-based 5,291,380. Total GHG emissions location-based were 5,342,354 and market-based 5,312,985, up sharply mainly from expanded Scope 3 category 15 financed emissions (5,211,329), of which assets under management 4,688,286 (sovereign bonds 3,670,900; equity and corporate bonds 1,017,387), insurance associated emissions 501,690, and equity associates 21,352. Sovereign bonds and financed emissions dominate (about 69% and 98% of location-based total). Ageas applies GHG Protocol minimum boundaries and PCAF methodologies for financed emissions; investment portfolio coverage is 71% including project finance (80% excluding). The equity/corporate bond portfolio PCAF score is 2.12 with 94% primary data; the sovereign bond portfolio PCAF score is 2 with 100% primary data. Investment GHG intensity fell to 80.2 tCO2eq/mio USD in 2024, a 46% reduction versus the 149.1 baseline (2021).

Ageas reports beyond value chain mitigation, maintaining its carbon-neutral status for the third time in 2024, covering scope 1, scope 2 and certain scope 3 categories. It supported carbon credit projects certified against international standards such as the Gold Standard and the Verified Carbon Standard, including renewable energy projects in Vietnam, a tropical rainforest conservation project in Brazil, an afforestation scheme in Ghana and hemp concrete block production in Belgium. Total carbon credits outside the value chain verified against recognised quality standards and cancelled amounted to 42,065 tCO2eq (100% from recognised quality standards). Of the GHG removals, 3% originated from removal projects and 97% from reduction projects, with 5% issued from projects in the European Union. Ageas states it focuses first and foremost on emissions reduction and only supports carbon credit projects beyond its value chain for remaining emissions.

Ageas discloses three main HR Group policies that guide its approach to own workforce: the Great place to Grow policy (covering training and skills development, health and safety, and work-life balance), the Diversity, Equity and Inclusion (DEI) policy (covering diversity and inclusion), and the Group Remuneration policy (covering adequate wages, social protection and remuneration). Core principles include a sustainable way of working, fair recruitment, employee growth, two-way engagement, treating people fairly and respectfully, equal opportunities, a zero-tolerance approach to discrimination, fairness, competitiveness and performance differentiation. The policies reflect commitments to the ILO Core Conventions, the UN Declaration of Human Rights and the UN Global Compact (section 9.6), and align with the wider Ageas Policy Framework and Human Rights policy (section 11.2). The DEI policy specifically names grounds for discrimination including racial and ethnic origin, colour, sex, sexual orientation, gender identity, disability, age, religion, political opinion and national or social origin. Policies are reviewed at least every three years, and entities have one year to adopt new Group policies.

Ageas describes how it engages with its own workforce. Employee engagement is embedded in the Group and measured through a Group-wide engagement survey held at least once a year covering engagement, diversity, equity, inclusion, health, safety and transformation. The annual Horizon Scan survey lets colleagues share views feeding strategy setting. Regular dialogue sessions run in most operating companies, with named channels such as the employee resource group in Portugal, the employee forum in the UK and the Working Environment Meeting at the Corporate Centre. Internal channels include VivaEngage, podcasts and webinars. Resulting action plans are communicated at Group-wide and local levels (section 9.4.1). On social dialogue and collective bargaining (9.4.2), Ageas engages with workers' representatives in works councils and committees where they exist, and has a European Works Council with eight Belgian, three UK and two Portuguese representatives that meets top management every six months. Highlights driven by employee feedback include greater reward transparency, an improved feedback culture, wellbeing initiatives and ongoing DEI awareness.

Ageas reports channels for its workforce to raise concerns (section 9.5). Employees are encouraged to voice grievances constructively, with procedures tailored to local contexts because local resolution is seen as most effective. Procedures may be internal, involve third-party mechanisms, or both, and can offer multiple channels depending on the topic. HR-related grievances such as remuneration or performance reviews are managed by local HR departments, while wellbeing grievances depend on local legislation. In some countries, notably Belgium and Portugal, union representatives and third-party mechanisms play a role. A Group-wide Speak Up procedure covers discrimination and other human rights breaches (linked to section 11.9). Grievance procedures are published on operating companies' intranets and discussed at induction, and include an appeal process. Companies report regularly on the number of cases and trends, and monitor effectiveness through engagement processes including psychological safety questions in the engagement survey. Whistleblowing channels align with the Whistleblower Protection Directive (EU) 2019/1937; in 2024 two cases led to confirmed breaches (section 11.5).

Ageas describes actions taken to manage material impacts, risks and opportunities on its own workforce, grouped under its "A Great place to Grow" pillar (section 9.7). These include training and skills development through the Ageas Academy, with customised leadership and financial programmes and courses accessible to all employees (Gear Up, Risk-Based Capital, the DARE Series, LinkedIn Learning, Leadership Insights and Sustainability for Impact). Internal and international mobility actions include an internal marketplace publishing vacancies Group-wide, talent committees, and short-term and virtual assignments (10 virtual and 12 short-term assignments completed across the 2022-2024 Impact24 cycle). Career preference conversations are embedded in performance reviews, supported by a career preferences tool and AG's in-house "Talk2Grow". Health and safety, work-life balance and DEI actions are also described. Ageas does not track specific CapEx and OpEx for these action plans, as they fall within teams' general budgets, and it takes a holistic approach to tracking effectiveness informed by the engagement survey rather than assessing actions individually.

Ageas discloses targets related to managing material impacts, risks and opportunities on its own workforce. In its Impact24 strategy it set an externally disclosed employee Net Promoter Score (eNPS) target of achieving a top quartile score. It also disclosed DEI targets: a Glass Ceiling Index (percentage of women in senior management divided by the total percentage of women in the company) target of 70%; a gender-balanced succession pipeline for the top 800 positions of 50:50; and a Gender Diversity Index (equal participation of women at decision-making level) target of top quartile (sections 9.4 and 9.8.1). The IRO overview table also lists targets and metrics such as a top quartile Gender diversity index, a 70% Glass ceiling index and 50/50 gender-balanced succession, alongside several metrics with no target (average training hours, participation in performance reviews, family-related leave coverage, gender pay gap, total remuneration ratio, social protection coverage). Targets are set at Group level, with additional local targets possible.

Ageas reports headcount characteristics of its employees at year-end 2024 for consolidated entities (section 9.2). Total headcount is 17,677, up from the acquisitions of AFLIC and Touring. By gender: 9,125 male (51.6%), 8,532 female (48.3%), 5 other (0.0%) and 15 not reported (0.1%). By country: Belgium 9,877 (55.9%), India 4,179 (23.6%), UK 2,152 (12.2%), Portugal 1,399 (7.9%) and Hong Kong 70 (0.4%). By contract type: 14,755 permanent, 551 temporary and 2,371 non-guaranteed hours employees (the latter being AFLIC agency leaders without fixed hours), with a further gender split for each. Turnover: 1,840 employees left during the reporting period, a turnover rate of 12.7% (calculated on permanent headcount divided by average headcount over the year). The wider Ageas Group headcount is 50,265. Ageas notes that for AG employees, the gender options "other" and "not reported" were not collected.

Ageas reports collective bargaining coverage and social dialogue (section 9.4.2). Collective Bargaining Agreements exist in Portugal and at AG in Belgium, but not at the Ageas Corporate Centre. In Belgium, CBAs operate at three levels: national (National Labour Council, applicable to all employees and employers), sectoral (joint committee level) and company-level (between employer and employee representatives, applicable regardless of union membership). Ageas Portugal has a single collective bargaining agreement (ACT, Acordo Coletivo de Trabalho) covering both unions and addressing performance appraisals, salary increases, traineeships, promotions, mobility, working hours, holidays, absences, health and safety, remuneration, insurance, allowances and retirement plans, reviewed annually. The coverage table shows collective bargaining coverage of 80-100% for EEA employees in Belgium and Portugal, and 0-19% for non-EEA employees in Great Britain, Hong Kong and India. Workplace representation of 80-100% (EEA only) exists in Belgium and Portugal. Ageas notes there is no formal Global Framework Agreement, but adherence to local and international law and structured social dialogue ensure human rights are respected.

Ageas reports diversity metrics for its own workforce (section 9.8 and the KPI overview). Top management (defined as all senior managers, excluding Executive Committee members who are treated as non-employees) totalled 384: 261 male (68.0%), 122 female (31.8%), 0 other and 1 not reported (0.3%). Employees by age group: below 30 years old 2,566 (14.5%), between 30 and 50 years old 10,073 (57.0%), and above 50 years old 5,038 (28.5%), totalling 17,677. The overall workforce gender split is 52% male / 48% female. Additional gender splits are disclosed across management layers: middle and senior management (Top 800) 64%/36%, senior management (Top 300) 69%/31%, executive management 75%/25%, and the board of directors 50%/50%. There were 86 nationalities across consolidated entities and 23 at head office. The Glass Ceiling Index was 65 and the Gender Diversity Index 0.90 in 2024.

Ageas reports on adequate wages under its Remuneration, adequate wages and social protection section (9.9). It states that Group employees are paid an adequate wage, and that the Group continues to monitor and benchmark its remuneration packages to remain competitive and attractive. A framework is used across local entities to measure and report on performance against the remuneration policy, comprising a job grading system for positions not covered by legal pay scales, a regular pay benchmark aligning pay levels with the external market, and a regular pay gap analysis. Local action plans are developed to improve equal pay for equal work as required, upholding the adequate pay and equal pay principles in line with the Human Rights policy. The disclosure indicates that all covered employees receive at least an adequate wage.

Ageas reports on social protection (section 9.9). It states that the majority of employees enjoy social protection, with 76% of all employees having full social protection coverage. A social protection table shows 13,498 employees with social protection. It also details employees not covered by specific types: 2,371 not covered by sickness (all non-guaranteed hours), 4,179 not covered by unemployment (1,808 permanent plus 2,371 non-guaranteed), 4,179 not covered by employment injury and acquired disability, 2,371 not covered by parental leave, and 0 not covered by retirement. The 4,179 employees in AFLIC have partial social protection coverage. The disclosure covers protection against major life events including sickness, unemployment, employment injury and acquired disability, parental leave and retirement.

Ageas does not report the S1-12 metric on the percentage of persons with disabilities in its own workforce. In its double materiality assessment, Ageas assessed "Own workforce: metrics on disabilities" as not material. Disability is nonetheless referenced within the DEI framework: it is one of the grounds for discrimination specifically covered by the DEI policy, and it is among the characteristics the Group's diversity and inclusion strategy addresses regardless of sex, age, gender identity, disability, ethnicity, nationality and sexual orientation. Ageas UK, for example, established Colleague Resource Groups covering gender, ethnicity, LGBTQ+ and disability. However, no headcount or percentage figure for persons with disabilities is disclosed, consistent with the non-material assessment of disability metrics.

Ageas reports on training and skills development metrics (section 9.7). The average number of training hours per employee in 2024, disaggregated by gender, was 31 for male, 34 for female, 35 for other and 24 for not reported employees, calculated as total training hours offered and completed divided by total employees at 31 December. The Group-level average was 33 training hours per headcount (versus 34 in 2023). Employee participation in training was 93% (up from 88% in 2023). On performance reviews, the percentage participating in regular performance and career development reviews was 73% (male), 66% (female), 100% (other) and 100% (not reported); overall 70% of employees participated, rising to 93% when excluding Anima and non-guaranteed hours employees. Participants per training series in 2024 are also disclosed (for example Leadership Insights 517, Gear Up 295, DARE Series 272, Risk-Based Capital 229, LinkedIn Learning 102, Sustainability for Impact 47).

Ageas reports health and safety metrics for its own workforce (section 9.7.2), noting that phase-in applies to non-employees. Every operating company has a health and safety management system in line with local regulation, and 100% of employees are covered by a health and safety management system. In 2024 there were 178 recordable work-related accidents and 0 fatalities as a result of work-related injuries. The number of days lost due to work-related injuries and fatalities from work-related accidents was 5,018, and the rate of work-related accidents was 8.1. Work-related accidents in Belgium also include commuting accidents. The accident rate is computed as the number of cases divided by total hours worked and multiplied by 1,000,000, representing cases per one million hours worked. As an office-based insurer, the focus is on workplace ergonomics, comfort and encouraging accountability for physical and mental wellbeing, with attention to psychosocial risks.

Ageas reports work-life balance metrics on family-related leave (section 9.7.3). It puts a high priority on healthy work-life balance, with remote and flexible working available to the majority of employees and parental leave extended beyond legal minimums in many operating companies. For family-related leave, the percentage of employees entitled to take it was 84% (male), 89% (female), 100% (other), 100% (not reported) and 87% overall. The percentage that took family-related leave was 9% (male), 17% (female), 0% (other), 7% (not reported) and 13% overall. Every employee is entitled to take family-related leave except non-guaranteed hours employees working as agency leaders for AFLIC. An entity-specific example is Ageas UK, which offers one week of paid carers' leave (going beyond the UK Carers Leave Act's unpaid week); in the first six months, 55 employees requested a total of 115 days.

Ageas reports remuneration metrics including pay gap (sections 9.8/9.9). The gender pay gap is 7.6%, defined as the difference in average pay levels between female and male employees expressed as a percentage of the average pay level of male employees (using the new CSRD-compliant calculation method with enlarged scope; the prior headcount-weighted method showed 21 in 2023). Ageas states its analysis does not show unequal pay for equal work but reflects over-representation of female employees in lower-paying functions and under-representation in higher-paying functions. The annual total remuneration ratio is 54, being the ratio of the remuneration of the highest-paid individual to the median annual total remuneration of all other employees. The KPI overview also reports a ratio of average to CEO salary of 32.5 (versus 23.1 in 2023) and total employment costs of EUR 1,189 million (versus EUR 1,048 million in 2023).

Ageas reports on incidents of discrimination (section 9.8). During 2024 there were 64 cases of discrimination reported. The DEI policy specifically covers grounds for discrimination including racial and ethnic origin, colour, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction or social origin, and all other forms covered by EU regulation and national law. To ensure discrimination is prevented, mitigated and acted upon, local anti-bullying and harassment policies and grievance procedures are being implemented across all operating companies, and a Group-wide Speak Up procedure applies to matters of discrimination and other human rights breaches. Entity examples include Ageas Portugal's Respect at Work Campaign launched in 2024 to combat harassment and discrimination, introducing a new reporting channel. The IRO overview also lists the number of incidents of discrimination as a monitored metric.

Ageas discloses its policies for managing consumer and end-user impacts, risks and opportunities (section 10.2). The most essential policies are the Product Approval policy (PRAP), Underwriting policy and Claims Management policy. These are supplemented by cross-cutting policies detailed in chapter 11 governance disclosures, including the Human Rights policy, Code of Conduct, Conflict of Interest policy and Complaints-Handling policy. A specific Treating Customers Fairly (TCF) policy ensures customers are treated honestly, fairly and professionally with a focus on their best interests and adherence to sustainability and human-rights principles. The Product Approval policy keeps products attractive, profitable and aligned with strategy and risk appetite, embedding ESG screening. The Underwriting policy covers customer fairness, clear communication, appropriate pricing and sustainability factors, made concrete in the Standards for Responsible Underwriting. Ageas Re has its own Underwriting policy. The Human Rights policy commits Ageas to make no unauthorised distinctions based on gender, age, religion, background or sexual orientation, and requires screening of customers to avoid relationships with human-rights violators. All Conduct policies are set and supervised by the Board and Executive Committee.

Ageas describes its engagement with consumers and end-users (section 10.3). Engagement is treated as essential across the entire product life cycle, with accountability residing with members of local Executive Committees. During product design, Ageas collaborates with sectoral insurance organisations and uses customer panels; examples include AG's Employee Benefits Lab and its Sound of Customer initiative, which gathered insights via over 1,500 phone conversations in 2024, and Portugal's Medis developing propositions like Medis Dental and Vintage. From design to end-of-contract, Ageas runs a Voice of the Customer (VOC) programme and tracks a Net Promoter Score (NPS). Effectiveness is measured through customer experience surveys; the competitive NPS (cNPS) is a strategic KPI in the Impact24 and Elevate27 strategies and forms part of management variable remuneration, with an ambition of top-quartile cNPS in all consolidated entities. In 2024, 25% of consolidated entities were in the top quartile (same as 2023). Engagement is also applied to the reinsurance business through regular client contact such as visits and market events.

Ageas discloses its channels for consumers and end-users to raise concerns and have them remediated (section 10.4, Complaints handling). Customers can submit complaints through various channels (phone, email, mail, ombudsman), with a process designed to be transparent and accessible and clear information on how complaints are handled. Complaints are investigated impartially, with timely responses usually within one month, and processed in compliance with personal-data rules. Customers can also use the whistleblowing channels (section 11.5) to raise concerns. The CEO and senior management appoint personnel to ensure compliance with the Complaints-Handling policy and avoid conflicts of interest; complaints are recorded securely and reported at least annually. Distribution partners address issues before formal escalation. Ageas tracks the number of complaints resolved within the target time frame and those handled by an external authority. In 2024 there were 25,706 total complaints related to products and services, of which 24,526 (94%) were handled within maximum handling time and 2,425 (9%) were filed through an insurance ombudsman. Examples include Ageas UK's Complaints Forum and AFLIC's Policy Protection Board.

Ageas describes actions taken in response to consumer-related impacts, risks and opportunities and their effectiveness (section 10.5). It focuses on product design, customer experience and distribution through Product Performance Monitoring, enhanced distribution collaboration (including mystery shopping to verify proper information presentation) and continuous improvement and training. In Portugal, distributors and customer-facing teams complete an initial 80 hours mandatory training plus a yearly 15-hour update; in Belgium the AG Business Academy trains distribution partners. In 2024, 9,800 participants completed 66,000 hours of training. Ageas stimulates customers towards a more sustainable world across mobility, home, healthcare/wellbeing/pensions and save-and-invest offerings, with concrete examples such as AG's 10% household discount for green-certified homes, Ageas UK's use of green parts in nearly 30% of qualifying repairs, and Portugal's Medis senior initiatives. It tracks the percentage of GWP from products promoting the sustainable transition, reaching 29% in 2024 (28% in 2023) against a 25% Impact24 target, with an Elevate27 target of 35%+ by 2027. New technologies (speech analytics at Ageas UK, SPARK automated underwriting at AFLIC) also support customers.

Ageas discloses targets related to managing consumer and end-user impacts, risks and opportunities (sections 10.2 and 10.5). The overview table sets out metrics and targets under the Impact24 and Elevate27 strategies: a competitive NPS (cNPS) with a top-quartile ambition; the percentage of GWP from products that stimulate customers in the transition to a more sustainable world, with a target of 25% rising to more than 35%; the number of complaints, for which there is no target; and products reviewed for transparency, with a 100% target. On effectiveness, in 2024 25% of consolidated entities achieved a top-quartile cNPS. GWP from products promoting the sustainable transition reached 29% in 2024, exceeding the 25% Impact24 target, with the Elevate27 target raised to 35%+ by 2027 using a refined methodology focusing on inclusion and including taxonomy-aligned GWP. Ageas reached its Impact24 target of reviewing all products for transparency. Ageas states it does not currently track specific CapEx and OpEx amounts for these action plans, which are part of general team budgets and planning processes.

Ageas discloses its business conduct policies and corporate culture (sections 11.2, 11.5, 11.6 and 11.8). The Ageas Policy Framework is centred on the Code of Conduct and adheres to the UNEP FI PSI and UN PRI. Named policies include Anti-Bribery and Corruption, AML/CFT, Compliance Charter, Complaints-Handling, Conflict of Interest, Human Rights, Integrity, Lobbying, Outsourcing, Personal Transactions, Procurement (with a Code of Conduct for Suppliers), Sanctions, Speak Up (whistleblowing), Suitability and Treating Customers Fairly. Policies are reviewed at least every three years and entities have one year to adopt new Group policies. The Board and Executive Committee set the tone from the top. In 2024 Ageas ran an ethical climate survey targeting all employees to evaluate corporate culture. On whistleblowing (11.5), Ageas provides multiple channels for staff and external stakeholders, compliant with the EU Whistleblowing Directive (2019/1937), with protection against retaliation and handling by the Compliance function; a public document 'Our approach to Whistleblowing' is available. In 2024, two whistleblowing cases were reported that, after investigation, confirmed breaches of internal rules and policies. Training (11.6) on ethics and business conduct is delivered in every subsidiary, with mandatory refresher training at least every three years.

Ageas discloses its management of relationships with suppliers (section 11.7). Ageas is committed to sourcing goods and services from suppliers who do not participate in or contribute to adverse human rights impacts, and human rights considerations are included in supplier selection. Procedures under the Procurement policy include screening all new and renewed supplier relationships against sanctions; requiring suppliers to adhere to human-rights principles; requiring potential suppliers to complete an ESG questionnaire during the tender phase and to be listed as a preferred supplier; and, for contract renewals or new contracts above EUR 100,000, performing a financial health check and an ESG check covering adherence to the UN Guiding Principles on Business and Human Rights. In 2024, Ageas developed a specific Code of Conduct for suppliers applying to all suppliers, who are expected to share the same ethical, sustainability and social responsibility standards and to adhere to the UN Guiding Principles. Non-compliance triggers engagement to agree corrective actions, potential review of the relationship, and escalation to management if required. Suppliers are subject to a risk assessment considering ESG factors, fair competition and information security.

Ageas discloses its systems for preventing and detecting corruption and bribery (sections 11.8 and 11.9). The Anti-Bribery and Corruption policy prohibits active or passive corruption in any form, with strict criteria on gifts, advantages, invitations and hospitality and an obligation to notify the Compliance Department in certain cases; material irregularities are reported to the Executive Committee and Board. The independent second-line compliance functions deploy the controls. Other framework policies (Procurement, Outsourcing, personal transactions, AML, sanctions, fit and proper) add preventive, detective and monitoring requirements. Suspected internal violations are investigated promptly, objectively and independently, and confirmed breaches lead to disciplinary measures such as warning letters or contract termination and new mitigation actions. Functions most exposed to bribery and corruption risk are identified (by default members of administrative, management and supervisory bodies and key decision-makers in underwriting, claims, distribution and procurement). A tri-annual training is provided for functions deemed most at risk, with 91.2% of those functions trained in 2024. New Board members complete an induction programme including specific anti-bribery and corruption training. Relevant policies are made available internally and a public version is on the Ageas website.

Ageas discloses confirmed incidents of corruption and bribery (sections 11.8 and 11.9). It reports zero convictions for violation of anti-corruption and anti-bribery laws in 2024, and zero amount of fines (in euros) for such violations. The disclosure sits alongside the description of investigation and remediation processes: suspected internal violations are investigated promptly, objectively and independently; violations by staff are reported internally and, where legally required, to relevant regulatory bodies; and confirmed breaches lead to disciplinary action (such as warning letters or contract termination) and additional mitigation where controls are found insufficient. Breaches include cases of internal fraud, defined as misconduct or abuse using deception for enrichment or benefit of the perpetrator, Ageas or a third party. The functions most exposed to bribery and corruption risk are identified and receive tri-annual training, with 91.2% trained in 2024. Relevant anti-corruption and anti-bribery policies are made available on internal platforms and in a public version on the Ageas website.

Section 11.10 (Lobbying, political contributions and memberships) provides a substantive disclosure rather than a bare non-materiality statement, even though the DMA materiality outcome table lists lobbying and political influence as not-material. Ageas's Lobbying policy states that Ageas does not make any political contributions, and Ageas confirms no such contributions were made during 2024. Lobbying activities are overseen by members of the Executive Committee according to their roles; local lobbying and membership actions are managed locally and reported to the local Executive Committee. Ageas keeps a list of all professional associations of which its employees are members and annually surveys subsidiaries on their lobbying activities. It reports concrete figures: the amount spent on lobbying activities equals EUR 2.4 million (2023: EUR 1.7 million); political contributions of EUR 0 in both 2024 and 2023; and total corporate membership expenses of EUR 3.6 million in 2024 (2023: EUR 3.9 million). The three highest membership contributions amount to EUR 2.5 million, or 71% of the total, unchanged from the prior year, covering car safety research and testing, an employee-benefits insurance network, and a broker marketing platform. The full membership list is on the website.