Aktia Bank

The Board of Directors of Aktia Bank Plc oversees that the Group is managed efficiently and follows prudent business principles. It approves the business strategy, risk strategy, governance systems, and new or updated sustainability-related policies as well as sustainability program and climate strategy updates, and it appoints the CEO. The Board holds the highest governing power over sustainability issues. Per the Articles of Association it has between five and twelve ordinary members; in 2024 it consisted of 9 members, of whom 33 per cent were female, and all were deemed independent under the Corporate Governance Code 2025. The Board maintains three committees covering risk, audit, and remuneration and corporate governance. The audit committee oversees ESG development, the sustainability program, and the impacts, risks and opportunities; its members are Sari Pohjonen (Chairman), Ann Grevelius, Matts Rosenberg and Johannes Schulman. The CEO handles day-to-day management, assisted by the Executive committee. The Board has approved diversity principles for its composition.

Sustainability matters are regularly on the agendas of Aktia's Executive Committee and Board of Directors. On the Board level, the Audit Committee oversees ESG development, progress of the sustainability program, and the impacts, risks and opportunities defined in the DMA. During 2024 the Executive Committee and Audit Committee reviewed the new sustainability report implementation project quarterly and approved the results of the DMA, including material impacts, risks and opportunities. The Board maintains its understanding of the IROs through regular reviews from Aktia's CEO, management and sustainability specialists, and the auditors and external advisors held informal seminars on changes to the national Accounting Act, ESRS and their implementation. ESG matters are prepared, managed and developed by Aktia's ESG team headed by the Sustainability Director, who reports to the Executive Vice President, Group Functions. The management, strategies, policies, targets and results of sustainability work are assessed by the Executive Committee and the Board, which receive relevant IROs presented in each specific ESRS section.

The Group's remuneration system is based on the Board of Directors' directive on remuneration of personnel (the Remuneration policy) and takes existing regulations into account while promoting good risk management. The Board is responsible for ensuring the policy, including the method for identifying risk takers, is consistently applied at group, subsidiary, unit and individual level. Aktia's sustainability-related remuneration principles include connecting goals related to sustainability, risk consideration and management to KPIs of beneficiaries, with sustainability KPIs defined according to the employee's role and potentially based on Aktia's climate strategy or sustainability programme. Sustainability factors are taken into account primarily in the remuneration of management and of those for whom such consideration is an essential part of their duties. HR assesses the remuneration policy and practices annually, including whether the scheme is gender neutral. Aktia's current remuneration scheme does not include climate change criteria, but a revision is under way in which climate change criteria will be incorporated into the scheme.

Aktia provides a statement on due diligence. The main aspects and steps of its due diligence processes are embedded in sustainable investment analysis and reviews, credit decision processes in banking, and in its risk and compliance processes as well as internal audit reviews. Aktia also uses external partners as needed to assess specific areas of business or companies for possible funding or investment. Aktia sets out the core elements of due diligence and maps them to sections of the sustainability statement: 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 those adverse impacts; and tracking the effectiveness of these efforts and communicating. These elements are cross-referenced to disclosures including GOV-1, GOV-2, GOV-5, SBM-1 sustainability program and climate strategy, S4 information security and targets, and S2 workers in the value chain.

Risks and risk management are part of Aktia's business environment, with main risk areas being credit, interest rate and liquidity risks, market risks, and actuarial risks in life insurance; sustainability risks are incorporated into all risk areas. The Group's Board of Directors has ultimate responsibility for risk management, managing risk appetite by confirming instructions and allocating capital, while the Audit committee acts as the highest governing body overseeing ESG work. Since 2020, the Executive committee and Board have reviewed the Group's sustainability risks annually. Internal control uses the Three lines of defence methodology: the first line is business operations and support functions; the second line is the independent Compliance and Risk Control functions; and the third line is Internal Audit. Risk Control, Compliance and Internal Audit operate independently of the operative business and report directly to the Board and the boards of regulated subsidiaries. Their principles and annual plans are adopted annually by the Board of Directors.

Aktia Group is a Finnish asset manager, bank and life insurer that has created wealth and well-being for 200 years, serving customers in digital channels and in offices in the Capital, Turku, Tampere, Vaasa, Oulu and Kuopio regions, with award-winning asset management sold internationally. The Group has three business areas: Banking, Asset Management and Life Insurance, and operates and pays taxes in Finland while investment activities have global reach. Its vision is to be the leading wealth manager bank, and the strategy extends until 2025 around four priorities: excellent customer experience, empowering employee experience, being the best in wealth management, and growth among customers willing to increase their wealth. Aktia is not active in coal, oil, gas, chemicals production, controversial weapons, or tobacco. The value chain spans upstream suppliers, own operations, and downstream investors, shareholders, financiers and customers. Sustainability is guided by the sustainability program 2022 to 2025, organised into four themes: Prosperity, People, Principles of Governance and Planet.

Co-operation with different stakeholder groups helps Aktia assess and respond to the expectations placed on it. Key stakeholders are customers, employees, shareholders and financiers, as well as social operators such as authorities, partners, NGOs and the media. Aktia maintains continuous open dialogue through several channels, including its website, social media, stock exchange and press releases, customer newsletters, seminars, webinars, local events and trade fairs. It participates in industry forums and collaborates with schools and universities, awarding scholarships and supporting students with thesis work, and keeps in touch with regional Aktia foundations. A stakeholder survey was conducted as part of the double materiality assessment to integrate insights and ensure a holistic view of what is material. Stakeholders included own employees, suppliers, investors and shareholders, customers, financiers, and communities and NGOs. The report presents a detailed table setting out each stakeholder, the type of engagement, purpose and themes, and the impacts on Aktia's operations and strategy, such as investments and prioritization, skills development and operational efficiency.

Aktia's sustainability program 2022 to 2025 and climate strategy outline the sustainability-related goals for its business units, own operations and wider value chain impact. Following its double materiality assessment, Aktia identified 26 material sustainability matters, while 77 matters were considered non-material. Material topics are plotted on a financial and impact materiality matrix spanning environment, society and governance, covering areas such as climate change mitigation and energy, pollution, resource use, privacy, health and safety, gender equality, diversity, work-life balance, protection of whistleblowers, corporate culture, and corruption and bribery. Aktia recognises that most of its impacts, whether economic, environmental or social, are generated by assets under management and investments, and it has therefore increased its focus on active stewardship. Each standard's impacts, risks and opportunities and their interaction with strategy and business model are presented in more detail within the respective ESRS section of the sustainability statement, with climate matters detailed under E1 Climate change.

Aktia completed its double materiality assessment with the assistance of an external consultant and their analysis tool and database, using a data-driven model that quantified Aktia's largest exposures and impacts across financial and impact materiality. To conduct the DMA, Aktia supplied data as of 31 December 2023, including its loan portfolio, fund portfolio, certain ESG related KPIs and turnover breakdown by business segment. The tool assessed materiality at company level, by geography, and at product level, with a materiality score based on four factors: scale, scope, irremediability, and likelihood of occurrence, each rated from 1 to 4. A stakeholder survey was conducted to integrate stakeholder insights. Aktia included and assessed all ESRS topics; E3 Water and marine resources and S3 Affected communities were deemed non-material. Much of the identified impacts, risks and opportunities occur in the downstream value chain. The DMA, material standards and relevant impacts, risks and opportunities were approved by the Executive committee and reviewed by the Audit committee.

This is the first year that Aktia reports according to the relevant European Sustainability Reporting Standards, alongside the Finnish Accounting Act and EU Taxonomy, so no previous year adjustments are presented. Based on its double materiality assessment, Aktia identified its material ESRS standards as ESRS 2 General disclosures, E1 Climate change, E2 Pollution, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users, and G1 Business conduct. E3 Water and marine resources and S3 Affected communities were assessed but deemed non-material and are therefore not covered. Each material standard's disclosure requirements are addressed within its respective ESRS section of the sustainability statement, where the relevant impacts, risks and opportunities are presented in more detail. The report includes a content index listing the disclosure requirements covered under the environmental standards, and emissions are reported following the GHG protocol and PCAF methodology under E1.

Aktia launched its climate strategy in 2021, setting climate targets for investments, lending and own operations to promote the transition to a low carbon economy, with targets extending to 2050. The strategy was approved by Aktia's Executive Committee and the 2025 milestones form part of the sustainability program. In the second quarter of 2024 Aktia submitted a letter of commitment to the Science Based Targets initiative and committed to align its emission reduction targets with the SBTi and the Paris Agreement, undertaking to define in more detail its pathway to carbon neutrality across investments, lending and own operations over the next two years and to update the climate strategy accordingly. Aktia is not covered by the EU's Paris aligned benchmarks. It aims to offer green loan products meeting EU Taxonomy criteria. Aktia has not identified any significant climate action related expenditures (OpEx, CapEx) required to implement the strategy and cannot yet quantify financial resources or achieved emission reductions.

Aktia has internal guiding policies, rules and training that support climate change mitigation and also adaptation, energy efficiency and renewable energy deployment. At group level the climate strategy together with the environmental policy guides all climate related activities and was approved by the Executive Committee. Investment operations follow the principles for responsible investment, approved by the Bank's Operations committee and the Fund Management Company's and Life Insurance's Boards of Directors, updated at least every three years. Lending follows the principles for responsible lending, confirmed by the Executive Committee member in charge of ESG and updated at least every two years, which describe excluded sectors and activities. The Green Procurement Guidelines, approved by the CFO with the Operations Committee, promote sustainable procurement and gradually increase eco friendly purchases. Aktia's current remuneration system does not include climate related criteria, but the system is undergoing reform in which climate related criteria will be incorporated. These policies help reduce exposure to physical risks and improve management of transition risks.

Aktia mitigates climate change through actions in investment operations, lending and own operations. In investments it holds five SFDR Article 9 funds and, at the end of 2024, roughly 98 per cent of fund capital was in Article 8 and Article 9 funds, an increase of 2.7 percentage points. Active ownership includes engagement discussions, pooled engagement, investor initiatives, proxy voting and norm based screening against the UN Global Compact via an external partner. Aktia participates in Climate Action 100+, the Net Zero Asset Managers initiative and the ASCOR Project. In lending it offers a green mortgage based on EU taxonomy criteria and green and sustainability linked loans, supported by its 2023 green and sustainability linked bond framework, a Sustainability Guarantee from the European Investment Fund, and a seven year EUR 75 million loan agreement concluded in April 2024 with NIB (Nordic Investment Bank) partly earmarked for environmental projects. In own operations it uses green electricity, compensates air travel since 2023, and cannot yet report allocated financial resources or achieved reductions.

Aktia's climate strategy sets emission reduction targets for scope 1, 2 and 3 across short, medium and long terms. In 2024 Aktia committed to the Science Based Targets initiative and will align its targets with the SBTi and Paris Agreement over the next two years. For asset management the point of reference is 2019, with 2025 milestones of a 30 per cent reduction in the carbon footprint of equity and corporate bond portfolios, a 35 per cent green bonds share of corporate credit funds, and a 50 per cent reduction and carbon neutral real estate investments by 2030, targeting a carbon neutral investment portfolio by 2050. For lending the reference year is 2020 and the target is a 30 per cent reduction in the carbon footprint of corporate and household loans by 2030, with no 2025 milestone. Own operations target carbon neutrality by 2050, with carbon neutral energy consumption at headquarters by 2025 and all premises by 2030. The 2025 and 2030 milestones were set in 2022 and approved by the Executive Committee and Board of Directors; stakeholders were not consulted.

Aktia screened its operations under the GHG Protocol and PCAF standards. No scope 1 emissions were identified (0 tCO2e). Gross location based scope 2 emissions were 281 tCO2e in 2024, down 68 per cent from the 881 tCO2e base year, with market based scope 2 at 171 tCO2e. Total gross scope 3 emissions were 152,641 tCO2e, dominated by category 15 Investments at 152,130 tCO2e, with smaller amounts for purchased goods and services (20), fuel and energy related activities (2), waste (2), business travel (168), employee commuting (279) and downstream transportation (40). Total GHG emissions were 434 tCO2e location based and 324 tCO2e market based. Financed emissions were far larger: investment activities totalled 2,330,575 tCO2e (scope 1 and 2 of 90,328 tCO2e, down 54 per cent from 194,417, and scope 3 of 2,240,247 tCO2e), and lending totalled 596,655 tCO2e (scope 1 and 2 of 61,802 tCO2e), giving a combined financed total of 2,927,230 tCO2e. GHG intensity per net revenue was 495 ton CO2e per million EUR.

In the reporting period Aktia did not participate in actions related to GHG removals or storage. To reduce the adverse impacts of emissions from its own operations, Aktia participated in planting domestic forest on a former peat production area. Aktia compensated the air travel of its personnel in 2024, amounting to 166,250 kgCO2, and has compensated air travel emissions since 2023. In addition, Aktia's payment card service provider compensated the emissions from the production of the cards. Aktia does not report acquiring or using carbon credits toward its own reduction targets, and these compensation and forest planting activities are described as measures to mitigate the adverse impacts of its operational emissions rather than as formal GHG removal projects.

Aktia has identified pollution as material indirectly through Asset Management, covering pollution of air, water and soil. Pollution is embedded in a wider environmental topic, and the group level environmental policy defines the material environmental topics based on the double materiality assessment and describes the main actions and tools to identify and manage pollution related risks. Investment operations are guided by the principles for responsible investment, with pollution considered through ESG integration, norm based screening, active ownership and corporate engagement, and impact investment across global operations and multiple asset classes. Negative pollution impacts are considered in portfolio management through PAI indicators and norm based screening, which helps identify environmental violations within the investment universe. Pollution is also a material topic in the principles for responsible lending, which exclude certain activities and impose specific conditions on financing mining operations due to their negative environmental impacts such as pollution, chemical and toxic spillage, and biodiversity harm. Aktia has not yet set exact pollution targets, which will be evaluated during the 2025 sustainability program update.

Aktia annually reports on the principal adverse impacts of investment decisions on sustainability factors (PAI indicators) on its website. In this reporting it uses data produced by an external provider on GHG emissions, emissions to water, and the hazardous waste and radioactive waste caused by investments, along with external analysis of the environmental impacts of investees and funds. Sub categories include impacts related to finite natural resources such as clean water and waste. Aktia also reviews other ways to integrate water related risks and impacts into its investment processes. Pollution is addressed through active ownership and engagement methods, and when environmental norm violations occur in investees, an external partner holds engagement discussions on Aktia's behalf as part of the Pooled Engagement service to prevent similar violations from recurring. These actions operate mainly in the downstream value chain through Aktia's asset management activities. No specific pollution targets have yet been set.

Aktia has identified biodiversity and ecosystems as material indirectly through Asset Management, meaning its business model and strategy are not directly connected to nature related impacts. Aktia has not directly embedded biodiversity and ecosystems in its strategy and business model or assessed their resilience in relation to biodiversity and ecosystems. Its own operations have no direct material negative impacts regarding land degradation, desertification or soil sealing, no operations affecting threatened species, and no sites in or near biodiversity sensitive areas, and it has not concluded that biodiversity mitigation measures are necessary. Aktia has not prepared a transition plan for investment operations with regard to biodiversity, so it cannot at this stage reliably assess the resilience of the current business model and strategy to physical, transition and systemic risks. It notes that climate change is one of the main drivers of biodiversity loss and, by considering both climate and biodiversity factors in investment operations, promotes the green transition, climate change mitigation and adaptation, and biodiversity. No exact biodiversity targets have yet been set.

Aktia's environmental policy provides guidelines for the group concerning all material environmental aspects, aiming to raise environmental awareness and commit Aktia to considering environmental aspects when developing products and to reporting on environmental impacts. Implementation is the responsibility of the group's Sustainability Director. Aktia's principles for responsible investment guide investment operations and take biodiversity and ecosystems related risks and opportunities indirectly into consideration through sector exclusions, consideration of sustainability factors and norm based screening under the UN Global Compact. Additional guidance comes from the Stewardship Policy and the document on identification and consideration of sustainability risks and factors in investment operations and advisory. Biodiversity is also analysed through the SFDR Principal Adverse Impacts using external service provider data at fund and target investment levels; the biodiversity PAI indicators include activities negatively affecting biodiversity sensitive areas, emissions to water, and the amount of hazardous and radioactive waste, together with climate related indicators. Article 8 and Article 9 financial products take these principal adverse impacts into account, and they are generally also considered for Article 6 instruments.

During 2024 Aktia analysed its funds' dependencies on natural capital and impacts on biodiversity, covering equity and corporate bond funds. It used the ENCORE tool, developed by Global Canopy, UNEP FI and UNEP WCMC, to assess sector dependencies on ecosystem services and their impacts on biodiversity loss, and an external net impact model using machine learning to quantify companies' overall environmental and biodiversity impacts and their contribution to the UN Sustainable Development Goals. All analysed funds scored negative net impact values, though the negative values are not significant, and the equity funds' most significant dependencies were groundwater, surface water and protection against flooding and storms. Highest dependency sectors included forest industry, fishing, textiles and apparel, food and beverages, and electricity production. Aktia applies sector exclusions, for example tobacco and electricity production. It participates in the PRI backed Spring initiative aiming to halt biodiversity loss by 2030 and in Nature Action 100. Aktia has not used biodiversity offsets and currently has no qualitative or quantitative biodiversity targets, planning to expand analysis to other asset classes as data develops.

Aktia has identified resource use and circular economy as material indirectly through Asset Management. Investment operations are guided by Aktia's principles for responsible investment, and environmental work is guided by the group wide environmental policy, which describes Aktia's methods in the area of resource use and circular economy. The Stewardship policy and the document on identification and consideration of sustainability risks and factors in investment operations provide further guidance. Resource use and circular economy are considered in the responsible investment methods of ESG integration, norm based screening, active ownership and corporate engagement, and impact investment, across global operations and multiple asset classes. The topic is addressed mainly in the downstream value chain through investee companies. Negative impacts arise from allocating investments to resource intensive sectors such as fossil fuel and biofuel production, mining and manufacturing, while target investments promoting renewable energy and the circular economy have positive impacts. Aktia has not yet set exact targets related to resource use and circular economy, which will be evaluated when the sustainability program is updated in 2025.

Aktia has provisionally assessed its investment operations to identify actual and potential impacts, risks and opportunities. Because the topic is indirectly material through investment operations, it has not assessed resource use and circular economy on a broader scale in terms of resource inflows, resource outflows and waste, and has not at this stage drawn up an action plan; the situation will be re evaluated in connection with the update of the double materiality assessment and the sustainability program in 2025, after which an action plan taking account of related financial resourcing will be created if necessary. Resource use and circular economy are integrated into investment operations through responsible investment methods. Norm based screening under the UN Global Compact helps identify environmental violations in the investment universe, and an external net impact model assesses investments' overall environmental impacts, considering factors such as habitat destruction, land use, land degradation, desertification, soil sealing and ecosystem services. Adverse impacts are considered in portfolio management through SFDR Principal Adverse Impact indicators, including emissions to water and the amount of hazardous and radioactive waste, applied especially to Article 8 and Article 9 products.

Aktia states that all employees are subject to policies and guidelines related to its own operations. The Board of Directors is the highest governing body, establishing the policies and monitoring their implementation annually, while HR leads and coordinates employee actions. Aktia has no separate human rights policy because its employees work in Finland where legislation ensures human rights, and Finland has committed to the UN Guiding Principles on Business and Human Rights. Key policies include the Code of Conduct (foundation for equal treatment, overseen by Compliance, committed to at recruitment), a zero-tolerance policy for harassment and violence, a policy for harassment and inappropriate behaviour, the non-discrimination plan updated in 2024 under the Non-Discrimination Act, the diversity policy, the remuneration policy (gender neutral, equal pay for equal work), recruitment principles, and directives on physical safety, competence, information security and privacy. Aktia complies with binding collective agreements of the banking and insurance sectors and Finnish labour law.

Aktia engages in continuous dialogue with personnel in accordance with the Act on Co-operation. Dialogue takes place in the co-operation committee (SAD), which meets four times a year and consists of elected representatives, workers' safety representatives and non-permanent employer representatives, addressing personnel matters according to an annual plan on the intranet. Individual businesses regularly engage with shop stewards on relevant topics. Twice a year Aktia conducts a Siqni personnel survey to gather feedback and improvement ideas; results are processed with employee representatives for the whole Group and each supervisor reviews results with their own team, agreeing development measures. Every employee engages in continuous dialogue with their supervisor through A-talk discussions held twice a year, plus one-on-one discussions at least once a month. Matters related to occupational health and safety, working conditions and well-being are reviewed quarterly in the co-operation committee where shop stewards and regional OHS representatives can raise topics with the employer's representative.

Aktia provides employees multiple channels to raise concerns. Concerns can be raised immediately with one's own supervisor, HR, shop stewards or OHS representatives, including during regular one-on-one discussions. If an employee prefers not to raise a concern with their supervisor, they can contact HR, a shop steward or an OHS representative directly, with contact details on the intranet. HR is responsible for investigating and addressing concerns raised. If a concern relates to another employee's conduct or behaviour, such as harassment or inappropriate behaviour, the matter is addressed in accordance with Aktia's disciplinary procedures on the intranet. Aktia has a whistleblowing channel in place for internal and external stakeholders, with further information in the G1 Business conduct section. Raised harassment incidents are also monitored through the Group's risk reports so management has a clear picture and can take corrective action if issues arise.

For working conditions, Aktia introduced a new working time management system in 2024 to improve monitoring and transparency of working hours, alongside flexible working hours and Group-wide hybrid work principles. The Siqni survey shows freedom to work regardless of time or place scored highest of all measured factors at 88/100. Aktia continued co-operation with an external healthcare provider through the AktiaWellbeing program, which supports proactive well-being, prevents occupational disease and accidents, reduces absenteeism, and includes a work ability indicator for early intervention. It continued a mental health pilot launched in 2023, arranging psychotherapy and occupational guidance for selected groups, with positive results. For equal treatment, the equality plan aims to reduce gender differences across positions and promote pay equality; Aktia introduced mandatory DEI training for all in 2024. Recruitment emphasises competence, experience and willingness to develop, prefers internal candidates and job rotation, and requires both genders among the final three candidates.

Aktia has set goals and metrics regarding employee experience, management and diversity as part of its Sustainability program for 2022 to 2025. Good leadership is measured with the fair supervisor indicator, which reached 83 in 2024. Employee experience is measured with eNPS, which was 19 in 2024 against a 2025 goal of 20, and the Siqni Flame-index, which was 75 against a 2025 target of 80. Diversity and equal treatment are measured with the SHE-index, which was 82 against a target of 85, and the share of women in management positions, which was 51% against a goal of 50%. The targets track empowering employee experience, strong values-based leadership, and shared culture. Metrics such as eNPS and Siqni Flame-index measure employee experience and well-being, while the SHE-index and proportion of women in management measure diversity, equal treatment and equal opportunities for all.

At the end of 2024 Aktia had 921 employees in total. By gender there were 411 men, 509 women, 0 other, and 1 not specified. By contract type Aktia had 831 permanent employees (461 women, 370 men) and 90 temporary employees (48 women, 41 men, 1 not specified). There were 82 employees with an on-demand contract (41 women, 40 men, 1 not specified). By working time there were 799 full-time employees (433 women, 366 men) and 40 part-time employees (35 women, 5 men). Total employee turnover was 10%, with 47 women and 45 men leaving. There were 194 new hires in total (97 women, 96 men, 1 not specified). All Aktia employees work in Finland. The number of employees represents people with an employment contract valid on the last day of the reporting period, including active and non-active employees, with gender as self-stated.

Aktia reports diversity metrics covering the gender distribution of its management team and the age distribution of all employees. At management level there were 8 people in total, of whom 3 were women, representing 37.5%, and 5 were men, representing 62.5%. For the age distribution of employees, 196 employees, or 21%, were under 30 years old, 457 employees, or 50%, were 30 to 50 years old, and 268 employees, or 29%, were over 50 years old. In addition, the share of women in management positions was reported at 51% for 2024, against a 2025 goal of 50%, as part of Aktia's diversity metrics. Gender is stated by the employees themselves. These figures support Aktia's equality plan aim of reducing differences in the representation of genders across positions and promoting equal opportunities.

Aktia reports that 98.0% of employees participated in regular performance and career development reviews in 2024, comprising 98.2% of women and 97.8% of men. The average number of training hours per employee was 9 hours, with women averaging 10 hours and men averaging 7 hours. Information on performance and career development discussions and training applies to all Aktia personnel, with the exception of persons belonging to Aktia's management team. Competence development priorities are the digital AktiaWay studies, role-specific training and leadership development. Every employee has A-talk discussions twice a year plus regular one-on-one discussions, and development plans are created and monitored in connection with development discussions in the online learning environment. The competence directive describes required competencies for roles such as granting credit and offering investment and insurance products. Aktia focuses on internal recruitment, job rotation and a job shadowing concept launched in 2023 to support career development.

Aktia reports that 100% of people in its own workforce are covered by the undertaking's health and safety management system based on legal requirements and recognised standards or guidelines. In 2024 there were 0 fatalities as a result of work-related injuries and work-related ill health, and 0 fatalities among other employees working at the company's facilities. There were 2 recordable work-related accidents, and the rate of recordable work-related accidents was 0.2%. There were 0 cases of recordable work-related ill health. Days lost to work-related injuries and fatalities from work-related accidents, work-related ill health and fatalities from ill health totalled 12. All employees are covered by Aktia's occupational health and safety system. Incidents related to work-related injuries, ill health and fatalities are those reported to the occupational health service or directly to HR by employees or managers. Aktia conducts regular workplace surveys jointly with occupational health professionals to assess workplace health and safety needs.

Aktia reports that all of its employees are entitled to family leave according to collective agreements and Finnish legislation, with 100% of employees entitled to take family-related leave. In 2024, 2% of employees took family-related leave. The breakdown by gender of those who took family-related leave was 58% women and 42% men. The percentage is based on the total number of employees who took family leave during the year divided by the number of employees at the end of the reporting period, with employees divided by gender. National legislation guarantees personnel the right to family-related leave regardless of gender. Work-life balance is further supported by flexible working hours available to all employees and the possibility of hybrid work in most positions, restricted only in roles requiring physical presence such as customer service points. Based on the Siqni survey, freedom to work regardless of time or place scored the highest of all measured factors at 88/100.

Aktia reports compensation metrics for 2024. The ratio of women's to men's total wages was 19.5%, described as an unadjusted gender pay gap that does not take into account the different positions held by women and men. The annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees, excluding the highest-paid individual, was 8. The ratio between men's and women's total salaries was calculated based on total compensation paid in 2024. The ratio between the compensation of the highest paid employee and the median compensation of other employees was calculated based on total compensation, dividing the total compensation of the highest paid employee by the median of total compensation of the other employees. Aktia's remuneration policy is gender neutral and aims to ensure equal pay for equal work, with the gender pay gap monitored regularly and reviewed annually with personnel representatives.

Aktia reports incidents, complaints and severe human rights impacts for 2024. The total number of incidents of discrimination was 2. The number of complaints filed through channels for people in the undertaking's own workforce to raise concerns was 0. The number of complaints submitted to the OECD National Contact Points for Multinational Enterprises was 0. The total amount of fines, penalties and compensation paid for the reported cases of discrimination and harassment was 0. Severe human rights incidents numbered 0. The number of work-related incidents refers to all cases of discrimination, bullying, sexual harassment and other types of harassment that may occur in the workplace. Cases are reported to HR by employees, managers, unions or employee representatives, or via the Whistleblower channel. Aktia reconciles fines, penalties and compensation resulting from violations of work-related discrimination and harassment against the most relevant amount stated in the financial statements.

Aktia identifies workers in the value chain as material indirectly through asset management. Its policies are Aktia Group's principles for responsible investment, based on the idea that investees operating responsibly are more profitable with a better long term risk profile. The policies are aligned with international human rights commitments, and Aktia is publicly committed to the UN Declaration on Human Rights and other UN treaties, the UN Sustainable Development Goals, ILO treaties, and OECD Guidelines for Multinational Enterprises. Activities are further guided by the Board of Directors' instruction for responsible investments, the principles for corporate governance, Aktia's sustainability programme, and climate strategy. The main negative impact identified is that investment activities may affect investee employees in sectors with high accident risk, relating to working conditions, health and safety. Methods include exclusion, ESG integration, norms based screening, active ownership and engagement, and impact investing. During 2024 there were no serious human rights violations in Aktia's investee companies.

Aktia engages with value chain workers through its responsible investment processes, targeting the company rather than the individual worker. Engagement takes place through direct contact with the company, an investor initiative, or an ESG service provider or analysis company. The ESG Committee and the Sustainability Director are responsible for sustainability work, engagement, and measures at Aktia and monitor the development of matters and the effectiveness of activities case by case. The effectiveness of engagement regarding individual workers is not assessed, since engagement targets the company, not an individual. Engagement and communication may take place immediately after a matter is raised or at regular meetings with the investee. Aktia does not have a separate channel for workers in the value chain to raise concerns and instead uses norms based screening. If a possible or verified norms violation or critical observation is detected, engagement dialogues may be initiated and, following an escalation method decided by the ESG Committee, measures may include divestment, refraining from further investment, or continuing dialogue.

Aktia identifies consumers and end users as material through asset management and lending, covering information related impacts, personal financial security, and social inclusion. Customer relationships are the most valuable aspect of Aktia's business, so its Code of Conduct includes key rules on information security, processing of personal data, handling customer complaints, and ethical principles of responsible customer work, which all employees must follow. Ultimate operational responsibility for customer communications and engagement lies with the Executive Vice President, Group Functions. Numerous internal directives govern the topic, including the directive on information security and data protection (based on the Board's operational risk guidelines), the directive on data protection (owned by Compliance and the Data Protection Officer, updated annually), directives on marketing, on client asset handling and depositing, on suitability assessment and know your customer obligations, and the handling of customer complaints. Aktia also complies with MiFID II, SFDR, the act on payment services, and the European Accessibility Act. It offers statutory basic banking services and applies best execution and customer classification principles.

Aktia actively engages with customers in matters related to information security and data protection. Customers are notified immediately if there are disturbances in Aktia's services, if phishing campaigns are implemented in Aktia's name, or if other threat actor activity is observed. In case of a data leak, data breach, or other incident putting customers' assets or personal data at risk, customers are immediately notified and given instructions on what to do. Aktia's communications team informs customers in extensive disturbances or exceptional situations with the crisis team, while customer service engages individual customers directly. Customers regularly receive communications about information security and data protection and are provided training in secure digital interaction. Aktia communicates through multiple channels including its website and social media. Customer service is trained to help with information security and data protection issues, and feedback is collected after training events and can be given directly through customer service. Based on feedback, operations are developed to respond to customers' wishes.

The directive on the handling of customer complaints instructs employees to resolve matters at once, fairly, and in accordance with regulatory requirements. It is the responsibility of Aktia's Chief Compliance Officer and is reviewed annually. To avoid conflicts of interest, when a complaint concerns a specific person, that person may not participate in handling it; the complaint is handled by an independent colleague or supervisor. Consumers and end users can lodge complaints through Aktia's website www.aktia.fi or directly to the responsible Aktia employee who records the matter in the customer feedback system. The website must provide readily available, clear information on at least one out of court dispute settlement body, FINE, including its website address, and this information must also appear in the standard terms and conditions. Customers can also report misconduct or unethical conduct through the digital WhistleB reporting channel, with instructions on Aktia's website. Aktia's website also provides clear instructions on what to do if online banking codes or bank cards are compromised, with 24 hour blocking services and a phishing reporting address.

Aktia takes action on material impacts for consumers across responsible marketing, information security and data protection, and financial security and non-discrimination. Marketing processes are continuously developed to reflect regulation and internal changes, with increased co-operation with Legal and ESG units in preparing marketing materials in 2024 and updated process descriptions; two training events on the marketing directive were held in 2024. For information security, Aktia manages risks in line with ISO 27001, protecting services through access control and encryption, assessing new suppliers, and training employees and customers. Each employee must complete mandatory annual information security and data protection online training, topics are covered almost weekly, and an information security awareness programme was established in 2019. A Data Protection Impact Assessment is carried out as needed. Aktia trains and communicates to customers through webinars and live events on secure digital banking. For financial security, availability, and non-discrimination, internal training and compliance with legislation are the most important measures. No severe human rights issues or incidents related to customers were reported during the period.

As part of its sustainability programme for 2022 to 2025, Aktia has set targets for trust and reputation measurement and information security. Trust and reputation are measured through the T-media Reputation and Trust research model, which measures the organisation among stakeholders across eight dimensions: Governance, Financial performance, Leadership, Innovations, Dialogue, Products and Services, Workplace, and Responsibility. Participating stakeholders were Aktia's customers, employees, and retail investors. The T-media reputation and trust score for 2024 was 3.52, against a 2025 target of at least 3.50. Another target is that a wealth plan is done when a mortgage loan is granted, with a 2025 target of 90 percent and a 2024 result of 68 percent. Employees' own information security competence is measured using the Inreach programme, based on an employee survey and an estimate of competence and awareness, while supplier assessments and stakeholder meetings related to information security are measured through the Outreach programme.

Aktia identifies business conduct as material through its own operations, covering corporate culture and business conduct policies, protection of whistleblowers, and corruption and bribery. Aktia's corporate culture is based on three values: Courageously, Skilfully, Together, providing a shared culture aiming for positive customer and employee experiences. The most important rules and ethical principles are compiled in Aktia's Code of Conduct, which all operational management including the Group CEO and all employees must observe. The Code covers representatives' roles, handling of one's own and family members' affairs at Aktia, anti-corruption, secondary occupations and positions of trust, business secrets, insider regulation, prevention of money laundering and financing of terrorism, compliance with financial sanctions, confidentiality, and customer complaint handling. Training on the Code of Conduct is mandatory for all employees and operational management, carried out annually on the internal digital training platform, and during 2024, 99.7 percent of intended Aktia employees completed it. Breaches may lead to action under Aktia's disciplinary procedure. Aktia's ESG classifications targets include achieving at least the industry average, with 2024 ratings MSCI AA, Sustainalytics medium risk, and ISS D+.

Aktia works proactively to identify and prevent breaches of its Code of Conduct and internal and external rules. Employees are encouraged to discuss compliance matters with managers and to report suspected infringements. An established whistleblowing procedure uses the third party WhistleB digital channel, which can be used internally and externally and anonymously by employees, management, and customers. Aktia has an organisational structure and appointed recipients for reports; infringements are handled by the Chief Compliance Officer and Chief Audit Executive or appointed persons in Compliance and Internal Audit, who are continuously trained. Reports are summarised at header level in Compliance reports to management and the board. On anti-corruption, Aktia has a zero tolerance policy for corruption, bribery, and undue influence, with guiding principles of transparency and moderation. Internal anti-corruption rules approved by the Group CEO apply to all employees, management, and consultants and cover conflicts of interest, gifts, and entertainment. Aktia does not support political parties, politicians, or candidates. All employees complete training at the start of employment and annually. Benefits exceeding a certain value must be reported through the internal incident management system.

Aktia discloses confirmed incidents of corruption and bribery for 2024. The number of convictions for violation of anti-corruption and anti-bribery laws was 0, and the amount of fines for violation of anti-corruption and anti-bribery laws was 0. No cases of corruption and bribery were reported in Aktia during the reporting period, and no reports of corruption or bribery were received during the year. Cases concerning corruption and bribery can be reported through various channels, including Aktia's internal incident management system, managed by the independent Risk Control function, and the WhistleB whistleblowing channel. If a report is made through the incident management system, Risk Control informs the Compliance function. Reported cases are handled by the Chief Compliance Officer and Chief Audit Executive, who are independent from those involved. The Compliance function is responsible for including any bribery and corruption reports in its quarterly report to the operational management and the board of directors. Regarding Code of Conduct training completion, the number of training participants was 887 with a participation rate of 99.7 percent.