Amundi

The role of the administrative, management and supervisory bodies

Reference: pages 136-139 (index entry ESRS 2-GOV-1 -> 3.1.2.1, 3.1.2.2, 3.1.2.3, page 151).

"As at 31 December 2025, the Board of Directors is composed of 13 directors, 6 women and 7 men, including 5 independent directors and 1 director elected by employees" (page 136). "Since May 2025, the Board of Directors has been composed of 50% women and 50% men, excluding the board member elected by employees"; counting that member the figure would be 46.15% (page 137). Women held 62.5% of committee seats at end-2024 and end-2025 and chair every committee (pages 137, 139).

"92.31% of board members considered ESG to be one of their areas of expertise at the end of 2025" (page 137).

Committees (page 138). Strategy and CSR recommends on responsible investment and CSR; Appointments maintains collegial ESG expertise; Compensation brings non-financial elements into pay; Risk Management monitors social and environmental indicators; and the Audit Committee, monitoring non-financial indicators since 2022, "was entrusted, in 2024, with most of the new tasks specific to the CSRD".

Executive governance. The General Management Committee delegates IRO monitoring to business-line committees with decision-making authority: the half-yearly CSR Committee, the monthly ESG & Climate Strategy Committee chaired by the CEO, the quarterly Compliance Committee and the monthly Group Risk Committee (page 138).

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: page 138 (index entry ESRS 2-GOV-2 -> 3.1.2.1, 3.1.2.2, page 151).

"It is recalled that the Board of Directors relies in particular on the in-depth work carried out by its specialised committees to take social and environmental issues into account. Each Committee incorporates this dimension into its specific tasks" (page 138).

Approval of this statement. "on the basis of the work carried out by the Audit Committee, which supervised the process for preparing sustainability information, as well as that implemented to determine the information to be published, the Board of Directors validated the principles proposed for the preparation of this Sustainability Statement, which it definitively approved in March 2026" (page 138).

Ongoing monitoring. "The Board continued to monitor the progress of the indicators related to its Climate Strategy on a quarterly basis and initiated discussions aimed at defining the future areas for its development when its Plan expires" (page 138). The Strategy and CSR Committee "formulates an opinion on the company's climate strategy and examines, at least annually, the actions taken by the Group in this area and the results obtained" (page 159).

Detail of committee activity is cross-referred to Chapter 2 "Corporate Governance" of the same document rather than restated here.

Integration of sustainability-related performance in incentive schemes

Reference: page 139 (index entries ESRS 2-GOV-3 and E1 - ESRS 2 - GOV-3 -> 3.1.2.4, page 151).

Three linkages are disclosed (page 139):

• "in 2025, the performance evaluation of the Chief Executive Officer and the Deputy Chief Executive Officer took into account the achievement of ESG (including climate commitments) and CSR objectives (reflecting the criteria relating to the finalisation of the implementation of Amundi's ESG Ambitions 2025 plan, accounting for 12.5%, and the Social and Environmental Responsibility of Credit Agricole group, accounting for 7.5%), making up 20% of the overall evaluation";
• "the implementation of Amundi's commitments in the area of ESG and CSR (which includes climate commitments) accounts for 20% of the criteria underpinning the performance shares plan applicable in 2025 to Amundi's more than 200 senior executives";
• "since 2022, Amundi has integrated ESG objectives into the evaluation of the performance of the sales and portfolio management teams, so that these objectives are taken into account in their variable compensation".

The matching metric under S1-16 shows 20% of the long-term compensation of 200 senior executives indexed to Responsible Investment objectives in both 2025 and 2024 (page 201).

Statement on due diligence

Reference: pages 139-140 (index entry ESRS 2-GOV-4 -> 3.1.2.5, page 151); Annex 1 datapoint GOV-4-30 marked Material (page 225).

Amundi runs no vigilance plan of its own. "The French law relating to parent companies' and ordering companies' duty of vigilance applies to Credit Agricole S.A. group. As a parent company, Credit Agricole S.A.... has chosen to draw up a vigilance action plan and to report on the effective implementation of this plan for Credit Agricole S.A. group... this vigilance plan includes specific reasonable measures to identify the risks and to prevent serious infringements of human rights and fundamental freedoms, or the health and safety of persons and the environment, which could potentially result from the activity of Credit Agricole S.A., including Amundi." The detail sits in Credit Agricole S.A.'s own 2025 Universal Registration Document (page 139).

The required mapping table (page 140) routes each core element to named paragraphs: embedding in governance, strategy and business model -> GOV-2 (3.1.2.2), GOV-3 (3.1.2.4), SBM-3 (3.1.3.3); engaging with affected stakeholders -> GOV-2, SBM-2 (3.1.3.2), IRO-1 (3.1.4.1); identifying and assessing adverse impacts -> SBM-3, IRO-1; taking actions -> 3.2.2, 3.2.3.1, 3.4.1.6, 3.4.3.2, 3.4.4.2, 3.5.2.7, 3.5.3.4; tracking effectiveness -> 3.2.3.1, 3.2.3.3, 3.2.4.3, 3.4.3.3, 3.5.2.7, 3.5.3.5.

Risk management and internal controls over sustainability reporting

Reference: page 140 (index entry ESRS 2-GOV-5 -> 3.1.2.6, page 151).

"Amundi has integrated the risks related to the production of sustainable information into its internal control system. This control system is based on both risk measurement, monitoring and control systems and a first-level permanent control system carried out by the operational units, with second-level permanent control being carried out by the Risk, Compliance and Security functions, and periodic control being carried out by Internal Audit" (page 140).

Supporting governance appears elsewhere. The Audit Committee "supervised the process for preparing sustainability information, as well as that implemented to determine the information to be published" and since 2024 carries "most of the new tasks specific to the CSRD" (page 138). Environmental-footprint indicators run on the Credit Agricole S.A. Greenway platform, in place since 2021, which "calculates and reports key indicators that are quantified, transparent and auditable" (page 168).

Gap worth noting. GOV-5 is a single short paragraph. Amundi does not describe the scope of its risk assessment over sustainability reporting, the main risks identified, the mitigation strategies applied, or how findings feed back into internal functions and processes. No control-testing results are given.

Strategy, business model and value chain

Reference: pages 141-142 (index entry ESRS 2-SBM-1 -> 3.1.3.1, page 151); Annex 1 SBM-1-40 d) datapoints marked Material (pages 225-226).

Business model. "Our business lines, embodied by the Group's 5,329 employees, are evolving to make an increasingly rich range of offerings accessible to all our clients" (page 141): active management, ETFs and passive management, private assets, structured solutions and responsible investment; technology services (Amundi Technology, Fund Channel, sub-advisory); and research. Total AuM is reported as EUR 2,380,000 million (page 173); Amundi "supports more than 200 million investors" across 34 countries (page 205).

Strategy. "On 18 November 2025, Amundi unveiled its 2028 Medium Term Plan entitled 'Invest for the future'... ESG and CSR issues are fully integrated into this Plan" (page 141). It succeeds the ESG Ambitions 2025 plan, which ended in late 2025 with ten commitments including an environmental transition rating covering EUR 400 bn of actively managed open-ended funds, EUR 20 bn in impact funds and 40% of the passive range as ESG funds (pages 141-142).

Value chain. The diagram on page 142 places shareholders, suppliers and human capital upstream, own operations in the centre, and invested corporates, clients and the general public downstream. A scope limit is stated twice: "The upstream and downstream value chains of our clients' own operations are excluded" (pages 135, 142).

Interests and views of stakeholders

Reference: pages 143-144 (index entry ESRS 2-SBM-2 -> 3.1.3.2, page 151).

"Amundi's main stakeholders are clients, employees, social partners, shareholders, suppliers, supervisory and regulatory authorities, NGOs (non-governmental organisations) and rating agencies" (page 143). Channels listed: client consultations and surveys, exchanges with employee representatives, meetings with civil society bodies, discussions with shareholders through financial and ESG analysts, interaction with non-financial rating agencies, and dialogue with supervisory authorities.

Works council. "the Social and Economic Committee (CSE) was consulted in February 2026" under Article L. 2312-17 of the French Labour Code (page 143); the statutory auditors confirm this formed part of their engagement (page 234).

Feeding the materiality assessment. "The 2025 rating exercise was also based on the results of surveys conducted by Amundi with its clients and investors. These studies, carried out with the assistance of Kantar..., Greenwich... and, for France, Amadeis..., are used to gather clients' expectations and perceptions on the various ESG dimensions" (page 149).

Collective initiatives (page 144): IIGCC (2003), CDP (2004), PRI (2006), SBTi (2016), TCFD and Climate Action 100+ (2017), Net Zero Asset Managers, Powering Past Coal Alliance and Finance for Biodiversity (2021), Nature Action 100 (2023), Platform Living Wage Financials (2018).

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 145-148 (index entry SBM-3 -> 3.1.3.3, page 151).

The consolidated IRO table (pages 145-147) lists 32 material IROs: ENVIRONMENT (ESRS E1, 8 rows), SOCIAL (ESRS S1, 12 rows; ESRS S4, 2 rows), GOVERNANCE (ESRS G1, 6 rows) and SPECIFIC (4 rows: market abuse, conflicts of interest and two cybersecurity IROs).

Where the impacts sit. Climate change is included "both for third-party investments and for own operations"; social themes cover own operations only, for the workforce (S1) and clients and end users (S4); governance IROs "are positioned upstream in the value chain, both for issues related to procurement and compliance matters (ESRS G1)" (page 148).

Change since FY2024. "the presentation of Amundi's offering, which was originally attached to ESRS S4..., has been moved to ESRS 2 General Information, resulting in the removal of the IROs associated with the offering" (page 145).

Current financial effects. "The financial materiality analyses conducted on the effects of physical and transition risks did not identify any risks as material with regard to the criteria used in the Sustainability Statement. At this stage, the cost-of-risk effects of these factors are therefore not significant and do not require action" (page 148).

Climate-specific risk identification and resilience content is also presented under E1-2 and E1-3.

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 149-151 (index entries IRO-1 and E1 to E5 - ESRS 2 - IRO-1 -> 3.1.4.1, pages 151-152).

Ownership. "Amundi's materiality analysis methodology is the responsibility of the CSR Department for the company's own operations. The 'third-party investments' section... was reviewed with Amundi's Risk, Responsible Investment and CSR departments" (page 149).

Scoring. "Each rating criterion is assessed on a scale of 1 to 4 and then a score is determined as follows: for risks, the likelihood score is multiplied by the potential magnitude score of the financial effects, thus giving a maximum score of 16; for impacts, the likelihood score is multiplied by the severity score", and "the materiality threshold is set at half the maximum score of 8 (i.e. 8 or higher)". Human rights IROs "are considered material, regardless of their likelihood, when severity is assessed at the highest level" (page 149).

Climate. Physical and transition risks are integrated "through the 'Environment' pillar of its proprietary ESG rating... in the short, medium and long term" (page 149). Time horizons: one year, one to five years, beyond five years (page 150).

Nature themes. Amundi explains why it cannot conclude on E2 to E5, citing the absence of a market method at portfolio level, undeveloped biodiversity indicators and no recognised method for asset managers, (pages 150-151).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 151-152 (section 3.1.4.2, "Coverage of publication requirements"); Annex 1, pages 225-233.

Amundi prints a real content index with two columns, "List of DRs" and "Reference", citing section numbers rather than page numbers.

Listed. ESRS 2: BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2. E1: E1 - ESRS 2 - GOV-3, E1-1, E1 - ESRS 2 - SBM-3, E1 - ESRS 2 - IRO-1, E1-2, E1-3, E1-4, E1-5, E1-6. E2, E3, E4, E5: the ESRS 2 - IRO-1 entry only, each pointing to section 3.1.4.1; no topical E2 to E5 requirement is listed. S1: SBM-2, SBM-3, then S1-1 to S1-6 and S1-8 to S1-17 (S1-7 absent). S4: SBM-2, SBM-3, S4-1, S4-2, S4-5. G1: GOV-1, IRO-1, G1-1, G1-2, G1-3, G1-4, G1-6 (G1-5 absent).

Annex 1 (pages 225-233) lists datapoints required by other EU legislation with a Materiality column taking four values: Material; Not material (S2-1, S2-4, ESRS 2 SBM3-S2, S3-1, S3-4, S4-4-35, E1-7-56); Phase-in (all four E1-9 datapoint groups); and Not conclusive (E2-4, E3-1, E3-4, E4-2, E5-5).

Basis of preparation. The 2023 ESRS as amended by the "quick fix" Delegated Regulation 2025/1416, which froze exemptions and datapoints "at the level of the first reporting on 2024" (page 136). This is Amundi's second CSRD statement (page 135).

Transition plan for climate change mitigation

Reference: page 160 (index entry E1-1 -> 3.2.2 "ESG Ambitions 2025 plan", page 151); Annex 1, page 226.

Amundi presents the ESG Ambitions 2025 plan as its transition plan; it "was developed prior to the definition of the ESRS" (page 160).

Alignment. "The 2025 plan... is aligned with a pathway aimed at limiting global warming to 1.5C and covers own operations and third-party investments, for its Net Zero range" (page 160).

Own operations. "Amundi has committed to reducing its direct greenhouse gas emissions by nearly 30% per full-time equivalent (FTE) by the end of 2025, compared to 2018... related to energy consumption (scopes 1 and 2) and business travel (scope 3)" (page 160).

Investments. A "Net Zero investment framework based on the Net Zero Emissions by 2050 (NZE) scenario developed by the International Energy Agency (IEA) to set decarbonization targets for 2025 and 2030" (page 160).

Successor. The 2028 Medium Term Plan of 18 November 2025 commits Amundi "to reducing its direct greenhouse gas emissions by 50% per FTE by 2030, compared to the year 2019" (page 160).

Benchmarks (E1-1-16(g)). "Amundi is not excluded from climate indices aligned with the Paris Agreement, namely, CTB... and PAB... as an asset manager, Amundi is not subject to the specific exclusions of these indices" (page 160).

Absent: no locked-in emissions assessment; no CapEx or OpEx allocated to the plan.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 149-150) and SBM-3 (page 148), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk identification. "Regarding its investments, Amundi has relied on its expertise in climate change... through the 'Environment' pillar of its proprietary ESG rating[, which] allows for the integration of physical climate risks - wildfires, cold waves, heat waves, water stress, coastal flooding, hurricanes, flooding and droughts - as well as transition risks, in the short, medium and long term" (page 149).

Own operations. "Amundi does not own any buildings, which significantly reduces its exposure to physical risk. Additionally, as part of its Business Continuity Plan (BCP), Amundi has been able to conduct an analysis to identify, assess and manage potential threats" (page 150).

Scenario used. The IEA NZE 2050 scenario, whose reductions are "in line with the reductions expected in the 1.5C warming scenarios, with a zero or limited temperature overshoot assessed by the IPCC" (page 162).

Gaps. No high-emission physical scenario is named (no SSP or RCP pathway appears in the report), no temperature projection is given per scenario, and no date is given for when a scenario analysis was carried out or updated.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, "Resilience of the strategy and business model" (page 148). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

What Amundi says. "Since its inception, Amundi has been able to adapt to a constantly evolving environment, particularly to new regulatory and climate constraints by taking sustainability factors into account. This consideration draws on a structured ESG analysis, based on a best-in-class approach combining: non-financial data from third-party suppliers; qualitative sector and thematic analyses; a quantitative assessment expressed on a scale from A to G." It closes: "For material issues, policies and action plans... allow us to adapt to events and demonstrate resilience" (page 148).

Financial effects. "The financial materiality analyses conducted on the effects of physical and transition risks did not identify any risks as material... the cost-of-risk effects of these factors are therefore not significant and do not require action" (page 148). Amundi owns no buildings, "which significantly reduces its exposure to physical risk" (page 150).

Assessment. No climate resilience analysis in the ESRS sense is presented. The phrase "resilience analysis" appears nowhere in the report: no scenario-based result, no statement of significant uncertainties, and no analysis of capacity to adjust or adapt over the three time horizons.

Policies related to climate change mitigation and adaptation

Reference: pages 161-169 (index entry E1-2 -> 3.2.3 and 3.2.4, page 151).

Net Zero investment framework. "To be considered as being on a Net Zero pathway, an investment portfolio managed by Amundi must have a decarbonisation pathway... compatible with a maximum temperature increase of 1.5C above pre-industrial levels" (page 162). It rests on the IEA NZE scenario, the NZAOA Target Setting Protocol and the IIGCC framework, and "does not take negative emission technologies into account" (page 162).

Thermal coal. In place since 2016. "Amundi is committed to phasing out thermal coal from its investments by 2030 in the OECD and EU countries, and by 2040 in the rest of the world" (page 163). Exclusions cover companies developing authorised or under-construction coal projects, over 20% of revenue from coal extraction, extraction of 70 Mt a year or more, over 50% of revenue from coal mining and coal power, and 20-50% "with an insufficient transition pathway" (pages 163-164).

Unconventional hydrocarbons. "Amundi excludes companies whose activity in unconventional hydrocarbons (including shale oil, shale gas and oil sands) represents more than 30% of their revenue" (page 164).

Own operations. "Amundi's activities do not generate a major direct impact on the environment. Nevertheless, Amundi is aware that its leadership position gives it a duty to set an example" (page 166).

Actions and resources in relation to climate change policies

Reference: pages 163-165 and 167-169 (index entry E1-3 -> 3.2.3.2 "Action plan" and 3.2.4.2 "Climate action plan", page 151).

Investment actions (2025). Three new Net Zero active funds: "BFT Rendement 2030 Climat...; Selection Euro Climat...; Amundi S&P 500 Climate Transition UCITS ETF" (page 163), alongside "35 climate ETFs aligned with the objectives of the Paris Agreement".

Engagement and voting. "In 2025, Amundi engaged with 340 additional companies on the subject of climate change, bringing the total number of additional companies engaged with on the subject to 1,818 since 1 January 2022" (page 164). "In 2025, we thus recorded 86% of votes in favour of climate-related shareholder resolutions" (page 165).

Own operations. Energy sobriety measures across countries: motion-sensor lighting in Ireland, a smart-platform-managed HVAC system in Hong Kong, and "In Germany at aixigo, a heat pump replaces a gas installation" (page 167). "Since 2016, the main buildings in Paris have been supplied with electrical energy from 100% renewable energies"; Japan has been 100% green since 2022; "At SABAM in Spain, 25% of energy is produced by solar panels" (page 167). The Paris head office is BREEAM In-Use certified "Very Good". The travel policy "imposes... compulsory rail travel for journeys of less than three hours" (page 168).

Resources. No CapEx or OpEx amount is attached to any of these actions.

Targets related to climate change mitigation and adaptation

Reference: page 165 (index entry E1-4 -> 3.2.3.3 "Metrics", page 151); own-operations targets pages 160 and 166.

Investment targets. Carbon intensity relative to revenue on scopes 1, 2 and upstream 3, against a 31 December 2019 base and assessed portfolio by portfolio: "30% reduction by 2025" and "60% reduction by 2030" (page 162).

Result. "Percentage of portfolios in the Net Zero range that reached -30% carbon intensity compared to a 31/12/2019 baseline: 100%". "The indicator's scope covers so-called 'transition' solutions, amounting to EUR 316 billion... NZ 'contribution' solutions are excluded" (page 165).

Engagement target. "Additional number of companies committed to climate since 1 January 2022: + 1,818", against a 1,000-company objective (page 165).

Own operations (base 2018). "-30% reduction in CO2 emissions per FTE on energy consumption (scope 1 and 2)"; "-30%... related to business travel by train and plane per FTE (scope 3)"; and "at least 35% of its purchases of goods and services outside the Credit Agricole group from suppliers with science-based Net Zero targets" (page 166). All three are reported as met (pages 166, 223). Next: "-50% per FTE by 2030 vs 2019".

Limits. All targets are intensity-based. No absolute GHG reduction target, no financed-emissions target beyond the Net Zero range (EUR 332 bn of EUR 2,380,000 million AuM), no SBTi validation.

Energy consumption and mix

Reference: page 170, table "Energy consumption and energy mix (E1-5-AR-34-T1)" (index entry E1-5 -> Metrics, page 152); Annex 1 datapoints E1-5-37, E1-5-38 and E1-5-40 to 43, page 226.

Amundi publishes the full ESRS E1-5 table for own operations, with rows for fuel from coal, oil, natural gas and other fossil sources; purchased fossil heat, steam and cooling; fossil electricity; total fossil consumption and share; nuclear consumption and share; the four renewable categories; total renewable and total energy consumption; and two share indicators.

Headline results. "Share of renewable sources in total energy consumption (%)": 73% at 31 December 2025 against 70% at 31 December 2024. "Share of green electricity (%) (voluntary)": 96% against 91% (page 170).

Restatement. The green electricity indicator was "initially reported at 79% in the Sustainability Report as of 31/12/2024" and recalculated "according to a refined methodology that retains only electricity consumption" (page 170).

Scope. France plus subsidiaries with more than 100 employees, "a coverage rate of 88% of staff", with extrapolation below that threshold (page 166).

Note: the MWh rows of this table did not extract reliably from the source PDF and should be read from page 170 of the report.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 166 and 171-172, table E1-6-AR-48-T1; index entry E1-6, page 152.

Intensity only. "Amundi has decided to publish its greenhouse gas (GHG) emissions according to the scope 1, 2 and 3 categories, and only in terms of intensity per full-time equivalent (FTE) rather than absolute value" (page 171). No absolute tonnage is published for any scope.

Composition. The 2025 footprint is 9.31 teqCO2/FTE: Procurement 85.7%, Business travel 7.4%, Energy 3.7%, CapEx 2.9%, Waste and other 0.2%. "The change observed in 2025 in the carbon footprint per FTE is primarily due to higher procurement spending and a methodological adjustment" (page 166).

Progress. "as of 31 December 2025, achieved a reduction in CO2 emissions per FTE of 66% for Scopes 1 and 2 (energy consumption) and 65% for business travel by train and plane (Scope 3) compared to 2018" (page 166), from 2018 bases of 1.00 and 2.10 tonnes CO2e per FTE (page 172).

Financed emissions excluded. "Amundi does not include third-party investments in its carbon footprint"; instead it "calculates the carbon intensity of the portfolios in the Net Zero range, which stands at 98 tonnes of CO2 equivalent per million euros of revenue as of 31/12/2025" (page 171). The auditors give an emphasis of matter on this (page 236).

Note: the numeric columns of the page 171 table did not extract reliably from the PDF.

Policies related to own workforce

Reference: pages 178-194 (index entry S1-1 -> 3.3.2 "Policies", page 152); Annex 1 datapoints S1-1-20 to 23 marked Material (page 230).

"Human resources policies... are structured around five themes deemed material: development of human capital; performance and remuneration; working environment; equity, diversity and inclusion; social dialogue and employee engagement" (page 175). They apply in France and abroad, "with the exception of associates... (approximately 30% owned)".

Human rights commitments. The Quality of Life and Working Conditions policy is "rooted in the universal values enshrined in the major national and international texts": the ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles, the OECD Guidelines, and "The Global Agreement applicable to all Credit Agricole subsidiaries... signed on 9 October 2023 with the UNI Global Union", which "includes commitments to respect human rights as well as specific measures on health, safety and quality of life at work" (page 185).

Harassment and discrimination. A dedicated policy covers "equality and non-discrimination, prevention of psychological and sexual harassment and respect for human rights, including in particular, equal treatment and freedom of association. Amundi does not use child labour, nor does it engage in human trafficking, and is committed to respecting international labour rights standards" (page 185).

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 193-194 (index entry S1-2 -> 3.3.2.5 "Social dialogue and employee engagement", page 152).

"The company respects freedom of association and therefore considers the exercise of trade union rights, staff representation and collective bargaining to be a fundamental right" (page 193). The policy "covers all entities, in France and abroad".

Structures. In France, a Social and Economic Committee, a Health, Safety and Working Conditions Committee, and specialised commissions. "These bodies are made up of employee representatives who are elected for four years in workplace elections... one of the employee representatives is appointed by the Social and Economic Committee to sit on the Amundi Board of Directors. On average, more than sixty meetings are held each year" (page 193).

2025 activity. Agreements signed included the annual pay negotiation of 13 January 2025, the extension of the youth-integration and end-of-career agreement on 26 June 2025, and a three-year incentive agreement. Recurring consultations covered social policy and the economic and financial situation, "including for the first year Amundi's sustainability strategy" (pages 193-194).

Direct listening. An annual anonymous survey run by an independent firm: "In 2025... The participation rate was 82%. More specifically, Amundi's recommendation score was 83%" (page 194).

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: pages 185-186 and 220 (index entry S1-3 -> 3.3.2.3, page 152); Annex 1 routes S1-3-32 c) to section 3.5.2.8 "Protection of whistleblowers", marked Material (page 230).

Whistleblowing. "Amundi employees can activate an internal whistleblowing system if they witness or are victims of serious acts or acts contrary to the Code of Conduct" (page 185). The platform "is secure and accessible 24/7... and is open to all third parties. This platform guarantees the total confidentiality of the information reported as well as the identity of the whistleblower via data encryption" (page 220). It ensures "anonymity when this option is chosen by the whistleblower, confidentiality of processing, processing of the report within seven working days" (page 220).

Harassment remediation. The policy provides for "immediate response to reported harassment or discrimination, by conducting internal investigations and taking corrective measures and, where appropriate, proportionate penalties" (page 185).

Support. "a Psychosocial Risks Monitoring Committee meets quarterly to detect collective risks and a Sensitive Situations Monitoring Committee meets monthly to process reports and define appropriate action plans" (page 185). Outcomes appear under S1-17: five discrimination incidents and two channel complaints in 2025 (page 202).

Taking action on material impacts on own workforce

Reference: pages 178-194 (index entry S1-4 -> 3.3.2 "Policies", page 152).

"In 2025, Amundi did not identify any negative material impacts on its own staff" (page 177), so S1 actions target the four positive impacts, five risks and three opportunities in its IRO table (page 176).

Skills and mobility. "In 2025, Amundi recorded 243 mobilities between business lines and 34 mobilities between countries" (page 179). Internal Mobility Days "brought together more than 1,000 employees worldwide" (page 178). "three specific e-learning courses were created and rolled out in France and internationally on ESG, Responsible Investment and climate issues" (page 179).

Management. "In 2025, over 300 managers were trained in France as part of the Amundi Management Spirit programme" (page 180), supported by a nine-sheet Manager toolkit and a team rituals guide.

Talent. Amundi Tomorrow identifies talent through Early Years, Novamundi and Future Leaders groups; its "150 members... are invited to Paris twice over a period of two years" (page 181).

Health. In France in 2025: first aid sessions, a flu campaign reaching "more than 500 employees", and nine workshops under "Acting daily for our mental health" (page 187).

Value sharing. A Q3 2025 capital increase at a 30% discount: "More than 2,500 employees, present in 15 countries, have subscribed", taking employee share ownership to 2.4% of capital (page 184).

Targets related to own workforce

Reference: pages 189, 192 and 195 (index entry S1-5 -> 3.3.2 "Policies", page 152).

Amundi sets no numerical target for most S1 metrics. "The targets of the HR department are defined by the continuous improvement of the metrics presented below" (page 195).

Gender representation targets, with 2025 outcomes (page 189):

• Board of Directors: "as far as possible, a target of parity" - reached at 50/50 excluding the employee-elected director since May 2025 (page 137);
• Executive Committee: "a target of 30% women in its Executive Committee by 2025. This figure stood at 39.1% at the end of December 2025";
• Senior Leadership Team: "a target of 35% in 2025 for the Senior Leadership Team. This reached 37.1% at the end of December 2025".

Amundi adds it "is on track to comply with Article 14 of the French 'Rixain' law... The target is 30% from 1 March 2026 and 40% as of 1 March 2029" (page 189).

Other commitments. Talent pool: a "goal of reaching 50% international profiles and 50% French profiles. At the end of 2025, international profiles represented 46%" (page 192). Youth: "an overall recruitment commitment of 40% of young people over the duration of the agreement" (page 178). Disability: 39 hires over 2023-2025 "versus a target of 13" (page 192).

Gap. No targets for health and safety, training, pay gap, turnover or wages, and no worker involvement in target setting is described.

Characteristics of the undertaking's employees

Reference: pages 195-197, tables S1-6-AR-55-T1 to T3 and S1-6-50-c (index entry S1-6 -> 3.3.2.1, page 152).

Headcount and gender. 5,329 FTE at 31 December 2025 against 5,626 a year earlier: women 2,158 (40%) against 2,296 (41%); men 3,171 (60%) against 3,331 (59%). "taking inactive employees into account, the number of women stands at 2,345 (42%) and the number of men stands at 3,241 (58%), for a total of 5,586 FTEs" (page 195).

By region. Europe 4,811 FTE (90%), of which France 2,917 (55%); Asia-Oceania 480 (9%); North America 23, down from 446 (8%); Central and South America 6; Near and Middle East 9 (pages 195-196). The North America fall reflects "the sale of our US entities (-446 FTEs) following the partnership with Victory Capital, finalised on 1 April 2025" (page 177).

By contract type. Permanent 5,281 FTE (2,139 women, 3,142 men); fixed-term 48 (19 women, 29 men); employees with non-guaranteed hours: none in either year (page 196).

Turnover. 296 leavers in 2025 against 220; ESRS-formula turnover 5.3% against 4.5%; 155 resignations from permanent contracts against 137, a 2.9% resignation rate (France 1.3%, Europe excluding France 3.7%, Asia 7.8%). Amundi restated the prior year: "The 2024 figure is corrected in the table above and shows the 2024 turnover rate calculated according to the ESRS formula" (page 197).

"the under 30 age group accounted for 34% of new hires" (page 177).

Collective bargaining coverage and social dialogue

Reference: pages 197-198, table S1-8-AR-70-T1 (index entry S1-8 -> 3.3.2.5, page 152).

Amundi publishes the ESRS banded coverage table, listing countries against the bands 0-19%, 20-39%, 40-59%, 60-79% and 80-100% for three measures: employees covered by collective agreements in the EEA (S1-8-60-b), outside the EEA (S1-8-60-c), and employees covered by employee representatives in the EEA (S1-8-63-a). EEA countries named include Germany, Austria, Belgium, Spain, France, Italy, Luxembourg, the Netherlands, Sweden, Finland, Ireland, Bulgaria, Hungary, Poland, Romania, Slovakia and the Czech Republic; outside it, Chile, Mexico, the UAE, Malaysia, Taiwan, Hong Kong, Singapore, Switzerland, China, Japan, the UK and the US (page 197).

Group-wide floor. "All Amundi Group employees are covered by the Global Agreement signed on 9 October 2023. Amundi promotes social dialogue in all its entities as stated in Article 2 of the aforementioned Global Agreement" (page 198).

Engagement (voluntary). Employee shareholders 60% against 64% in 2024; Amundi recommendation score 83% against 84%, from "the annual survey of all employees conducted by Willis Towers Watson in December 2025" (page 198).

Note: the country-to-band allocations did not extract reliably from the PDF and should be read from page 197.

Diversity metrics

Reference: page 199 (index entry S1-9 -> 3.3.2.4 "Equality, diversity and inclusion (ED&I)", page 152).

Top management (S1-9-66-a). Executive Committee: 18 women (39.1%) and 28 men (60.9%) at 31 December 2025, against 19 women (38.8%) and 30 men (61.2%) a year earlier (pages 139, 199).

Age distribution (S1-9-66-b). Under 25: 46 (54 in 2024); 25-30: 401 (432); 30-35: 608 (625); 35-40: 678 (669); 40-45: 807 (876); 45-50: 892 (952); 50-55: 972 (984); 55-60: 607 (646); 60-65: 288 (329); over 65: 30 (51). The indicator "covers 99.9% of employees" (page 199). Average age: 45.1 against 45.2.

Other voluntary indicators (page 199): 69 nationalities in France against 62; under-30s among permanent hires 34.0% against 34.4%; 1,476 young people recruited and trained (1,426); 925 interns, work-study staff and summer jobs (898); 150 work-study staff (170); women in the talent pool 49.3% against 43%; women in executive positions (Senior Leadership Team including Comex and GMC) 37.1% against 33.7%.

Board. Reported under GOV-1: 6 women and 6 men counted for the statutory ratio at 31 December 2025 (50.0% each) against 7 and 5, with an average ratio of women to men of 0.71 against 0.74 (page 139).

Women make up 52% of succession plans for key positions (page 190), and Amundi reports "a presence in 34 countries and 69 nationalities in France" (page 192).

Adequate wages

Reference: page 200, tables S1-10-69 and S1-10-70 (index entry S1-10 -> 3.3.2.2 "Performance and remuneration", page 152).

Result. 100.00% of active employees are reported as receiving an adequate wage in both reporting years, and the S1-10-70 table states plainly: "All employees of Amundi receive a decent salary" (page 200). The table covers "all active employees on permanent and fixed-term contracts (including executive corporate officers, excluding board members), expressed as individuals (headcount)".

Benchmark used. "Adequate wage: in the absence of a legal definition, Amundi has adopted the definition of the Fair Wage Network, an internationally recognised external body. The adequate wage used corresponds to the adequate wage for a family of two adults and a number of children corresponding to the country's fertility rate, adjusted for the number of employees in the household" (page 200). Salary is "the theoretical gross annual salary paid over the year", adjusted to full-time equivalent for part-timers and mid-year joiners.

Supporting statements. Amundi "is fully in line with the Global Agreement signed on 9 October 2023, which provides for compensation and benefits that ensure the people concerned and their families an appropriate standard of living under fair conditions" (page 184). In France a purchasing-power policy "benefited more than 88% of employees whose fixed compensation is less than or equal to EUR 50,000" (page 183).

Social protection

Reference: page 186 (index entry S1-11 -> 3.3.2.3 "Working environment", page 152).

Social protection is one of Amundi's material S1 positive impacts: "Positive impact on employees where social protection practices are better than the legal minimum", in own operations, addressed by the Working Environment / Quality of Life and Working Conditions policy (pages 146, 176).

What is disclosed. "In addition to health and personal protection for each employee and their families, Amundi offers a range of services aimed at preserving the health of its employees. In France, the compulsory collective supplementary social protection comes under this framework. This consists of health protection, complementary health insurance and a pension" (page 186).

Above the legal floor. "Since 2018, the cap on cover imposed by the legislation on responsible contracts has led to an increase in out-of-pocket expenses for beneficiaries... it has decided to put in place two higher levels of cover. In addition, on 1 February 2024, Amundi increased the share it pays of complementary health insurance (basic scheme) from 60% to 65% and decided to expand the scope of alternative medicines eligible for reimbursement" (page 186).

Gap. No percentage-of-workforce coverage figure is given for the ESRS social protection categories; the disclosure is qualitative and largely France-specific.

Persons with disabilities

Reference: page 192, with the voluntary metric on page 200 (index entry S1-12 -> 3.3.2.4, page 152).

Metric. "Number of people with disabilities hired or integrated - France": 12 in 2025 against 11 in 2024, covering "all hires on permanent and fixed-term contracts... Beneficiaries of the Obligation to Employ Disabled Workers (BOETH), as defined by law" (page 200).

Population and rate. "In France, Amundi had 127 employees with disabilities in 2025... Our employment rate continues to increase, alongside the growth of our workforce. It reached nearly 4.23% in 2025." "Around 7.3% of its students recruited on a work-study basis in 2025 were disabled" (page 192).

Against the group agreement. "The 2023-2025 period, covered by the 7th Credit Agricole S.A. Group agreement, enabled Amundi to achieve a total number of hires of people with disabilities that significantly exceeded the targets... 39 versus a target of 13 (as of 1 October 2025)" (page 192). The 8th agreement covers 2026-2028 (page 188).

Actions. Four pillars: "recruitment, maintaining employment, using the sheltered sector and raising employee awareness". 2025 work included the "Parlons Handicap" programme, the mandatory "Inclusive Manager" course taken by 98 managers, and the 5th DuoDay. Sheltered-sector procurement runs at "over EUR 500,000 per year" (page 192).

Scope limit. All figures are France only; no group-wide disability employment rate is given.

Training and skills development metrics

Reference: page 200 (index entry S1-13 -> 3.3.2.1 "Development of human capital", page 152).

Performance and career development reviews (S1-13-83-a). 5,027 workers participated in 2025 against 4,894 in 2024, representing 92.8% against 95.5%. The indicator "covers active workers on permanent and fixed-term contracts and does not include entities sold or in the process of being sold" (page 200).

Average training hours (S1-13-83-b). 21.6 hours in 2025 against 18.1; women 23 against 18.8; men 20.2 against 17.6. The indicator "covers active and inactive workers... It includes all types of training, including in-person, e-learning and regulatory training" (page 200).

Regulatory training (voluntary). Percentage of persons trained: 100% in both years, covering "all workers, including non-permanent workers" (page 200).

Underlying provision (pages 178-182). The Amundi Learn offer with an annually drafted skills development plan; the Phileas platform; eCampus for regulatory training; LinkedIn Learning rolled out at end-2024; and the Responsible Investment Training programme with "a common set of compulsory training units". Two annual one-to-ones run: the career development appraisal, whose "main objective is to maintain employability and adaptability", and the annual performance review.

Both training metrics improved while the review participation rate fell 2.7 percentage points. No target is set for either.

Health and safety metrics

Reference: page 201 (index entry S1-14 -> 3.3.2.3, page 152); Annex 1 datapoints S1-14-88 b), c) and e) marked Material and routed to section 3.3.3 (page 230).

Coverage (S1-14-88-a). "Employees covered by a health and safety management system": 95.6% at 31 December 2025 against 94.1% a year earlier. The system is "a structured framework aimed at ensuring the health and safety of employees, by integrating processes and practices designed to identify, assess and control occupational risks", introduced in Europe by Directive 89/391 (page 201).

Fatalities (S1-14-88-b). 0 in 2025 and 0 in 2024.

Work-related accidents (S1-14-88-c). 10 in 2025 against 5 in 2024 - a doubling, on a workforce that fell by 396 FTE (page 201).

Absence (voluntary). Rate of absence for illness in France: 1.3% against 1.5%.

Governance. Amundi Care, a quarterly Psychosocial Risks Monitoring Committee, a monthly Sensitive Situations Monitoring Committee, an Occupational Health and Prevention Department of three nurses and one social worker, and an annually updated DUERP (pages 184-186).

Gap. Days lost to injuries, accidents, fatalities or illness (S1-14-88-e) is not published although Annex 1 marks it material. Non-employees are excluded from the whole S1 metrics section (page 195).

Work-life balance metrics

Reference: pages 186-187 and 190 (index entry S1-15 -> 3.3.2.3 "Working environment", page 152).

Amundi addresses S1-15 through its Quality of Life and Working Conditions policy rather than through a metrics table. No percentage of employees entitled to family-related leave, and no percentage that took it, is published - the two quantitative datapoints ESRS S1-15 asks for.

Entitlements (page 190):

• "minimum 16-week maternity leave allowing every woman since 2020, in all Amundi locations, to combine their career with motherhood";
• "in France, since 1 July 2022, paid paternity leave of 28 calendar days", extended "in 2024, the roll-out of this 28-calendar-day paid paternity/co-parental leave to all entities worldwide";
• three extra days of leave a year for a hospitalised child and donation of days in the event of serious illness.

Working time. The 2022 agreement supports "a better work/life balance, including by strengthening the right to disconnect after working hours in the context of working from home". Amundi "goes beyond what is required by legislation in a number of areas by acting on: the organisation of work: meetings that comply with the team's working hours, defined planning ahead of time" (page 187).

Carers. A "pilot part-time scheme for caregiving employees launched in 2025 until the end of 2026 allowing 10 employees to work 80% while being paid 100% for a maximum of three months" (page 187).

Compensation metrics (pay gap and total compensation)

Reference: pages 201-202 (index entry S1-16 -> 3.3.2.2, page 152); Annex 1 marks S1-16-97 a) and b) Material, routed to section 3.3.3 (page 231).

Gender pay gap (S1-16-97-a). 25.3% at 31 December 2025 against 26.5% a year earlier. Amundi defines it as "the gap between women's average total annual pay compared to men's average total annual pay, regardless of location or job type" (pages 201-202).

CEO pay ratio (S1-16-97-b). "Ratio of the annual total compensation of the highest paid person to the median annual total compensation of all employees": 26.5 in 2025 against 28.5. It uses fixed, individual variable and collective variable compensation, adjusts part-timers to full-time equivalent, and "The median annual total remuneration of all employees excludes the highest paid person" (page 202).

Voluntary indicators (page 201): equal pay index in France 86.0/100 in both years; average collective variable compensation in France EUR 11K against EUR 10.4K; average annual gross basic salaries in France - men EUR 88.7K (EUR 86.5K), women EUR 76.8K (EUR 75.0K), total EUR 83.7K (EUR 81.7K); and 20% of the long-term compensation of 200 senior executives indexed to Responsible Investment objectives.

Context. "specific budgets intended to reduce unfair pay gaps. In 2025, this budget was used to reduce pay gaps in both individual variable compensation and fixed compensation" (page 183).

Incidents, complaints and severe human rights impacts

Reference: page 202 (index entry S1-17 -> 3.3.2.3, page 152); Annex 1 marks S1-17-103 a) and S1-17-104 a) Material (page 231).

Work-related incidents and complaints (page 202):

• Incidents of discrimination (S1-17-103-a): 5 in 2025 and 5 in 2024;
• Complaints made through channels to express concerns (S1-17-103-b): 2 in 2025 against 0;
• Complaints filed with National Contact Points: 0 in both years;
• Fines, penalties and compensation for violations regarding social and human rights factors (S1-17-103-c): EUR 0K in both years.

Severe human rights incidents (page 202): severe human rights issues and own workforce incidents (S1-17-104-a) 0 in both years; of which cases of non-compliance with the UNGPs and OECD Guidelines 0; associated fines and compensation (S1-17-104-b) EUR 0K.

Amundi's statement. "Amundi has not identified the presence of serious human rights incidents. Serious human rights incidents can be defined as non-compliance with the United Nations Guiding Principles on Business and Human Rights, the International Labour Organisation Declaration on Fundamental Principles and Rights at Work or the OECD Guiding Principles" (page 202).

Reading the numbers. Five discrimination incidents in each of the last two years sit alongside zero severe incidents, so those cases fell below the threshold Amundi defines. No breakdown by ground, outcome or remediation is given.

Policies related to consumers and end-users

Reference: pages 206 and 212 (index entry S4-1 -> 3.4.1.7, page 152); Annex 1 routes S4-1-16 and S4-1-17 to sections 3.4.1.6 to 3.4.4, both Material (page 232).

Regulatory frame. Obligations "stem from international (e.g. Dodd Frank Act), European (e.g. MiFID II Directives, AIFMD, UCITSD, DORA, GDPR, etc.) and national regulations..., regulations (e.g. SFDR, etc.) or internal frameworks" (page 206).

Human rights (S4-1-17). "Amundi is committed to respecting human rights when promoting its offering (standards frameworks: United Nations Guiding Principles on Business and Human Rights; OECD Guiding Principles)" (page 206).

Internal framework. "the Group has set up a dedicated body of standards for customer protection and a framework of standards for information system security... They apply to all entities on topics such as financial savings, the claims system or the prevention of cyber attacks." An Ethics Charter common to the Credit Agricole group was adopted in 2017 (page 206).

Client protection. Amundi "ensures that information about the products offered to clients and Undertakings for Collective Investment (UCI) unitholders is clear, transparent and not misleading"; and "refrains from placing the interests of a group of clients... ahead of those of another group". Personal data rests on four pillars: "'Governance', 'Regulatory Framework', 'Training' and 'Control'" (page 206).

Processes for engaging with consumers and end-users about impacts

Reference: page 205 (index entry S4-2 -> 3.4.1.3, page 152).

"The Amundi Group takes into account the interests and viewpoints of its clients and end users through several systems: a listening and monitoring system...; an institutional and corporate 'client journey'..., including the collection of information on sustainability preferences through a suitability questionnaire; measurement of customer satisfaction using the Customer Recommendation Index (IRC)...; complaints management" (page 205).

Sustainability preferences. "Since the end of 2023, the investment objectives questionnaire includes questions regarding the sustainability preferences of institutional investors and corporate clients." "In 2025, new features were put in place to check that clients' objectives and preferences match the characteristics of the open-ended funds they hold. An initial control campaign... identified areas for improvement to be addressed in future periods" (page 208).

Listening in 2025 (pages 207-209). A Global Advisory Board meeting three times a year since 2016; a panel survey of individual investors in France and, for the first time, Germany, Austria, Spain and Italy; "the annual Amundi CREATE survey... in which over 150 pension funds representing nearly EUR 3 trillion in assets were questioned"; and the Amundi World Investment Forum, with "more than 1,000 participants, including over 800 clients".

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 205 (index entry S4-5 -> 3.4.1.5 "Indicators and targets", page 152).

Amundi sets no numerical S4 target: "Amundi monitors the effectiveness of the actions implemented, for example, through measures of client satisfaction and compliance checks with regulations. The objective is to act in the best interest of its clients. Amundi does not have any targets other than this objective" (page 205).

Effectiveness is tracked instead:

• Institutional IRC. "In 2025, 81 clients responded to the satisfaction survey... The institutional investors IRC remained solid at 40, up 5 points compared to the previous year. In addition, 84% of respondents rate their experience with Amundi as very good or excellent" (page 209).
• Wealth and asset managers. "IRC campaigns were conducted with retail banks in three countries in 2025. More than 9,000 client advisors... were surveyed" (page 209).
• Complaints. "The monitoring of complaints feeds General Management's indicator dashboard" (page 210).
• Cyber controls. Vulnerability scans, penetration tests, "Red Team" tests and "Bug Bounty" campaigns, plus cyber insurance (page 212).

Assessment. This satisfies the MDR-T fallback of tracking effectiveness absent a target, but no measurable, time-bound S4 target exists.

Business conduct policies and corporate culture

Reference: pages 216-221 (index entry G1-1 -> 3.5.2.5 to 3.5.2.10, page 152); Annex 1 marks G1-1-10 b) (UN Convention against Corruption) and G1-1-10 d) Material (page 233).

Policy set. "The Group has implemented an integrated and independent control system... based on a set of key policies: Ethics Charter; Code of Conduct; conflicts of interest prevention and management policy; anti-corruption policy; financial crime prevention system; prevention of market abuse" (page 216). The Code of Conduct, "published for the first time in 2019... is updated annually and is available on the company's corporate website" (page 189). The anti-corruption policy "complies with the United Nations Convention against Corruption" (page 219).

Governance. Compliance is "monitored by the Group's highest bodies: Amundi's Board of Directors via its specialised committees..., as well as the General Management Committee..., the Internal Control Committee..., the Compliance Committee, the Fraud and Corruption Committee and the Whistleblower Management Committee" (page 216).

Culture. Ethics themes "are reviewed quarterly by the Risk Committee of Amundi's Board of Directors"; "New hires must read the Ethics Charter and the Code of Conduct when they take up their position" (page 217). Training completion (voluntary): "Business ethics" 98.9% in 2025 against 95.8%; "Ethics and You quiz" 98.6% against 91.7% (page 217).

Management of relationships with suppliers

Reference: pages 222-223 (index entry G1-2 -> 3.5.3, page 152).

Policy. The "'Supplier Relationships (G1-2) and Payment Practices (G1-6)' policy... is part of the Amundi Group's Ethics Charter and is based on commitments including the United Nations Global Compact, the Diversity Charter and the Charter for Responsible Supplier Relations", relating to "respect for human rights and compliance with labour regulations, the fight against all forms of discrimination... environmental protection and business ethics" (page 222).

IROs. Three, "formulated in the form of two risks and a negative impact", covering non-responsible purchasing practices "particularly in terms of payment deadlines" and liability for "an environmental, social or ethical breach... on the part of its suppliers", identified "using the AFNOR risk map, based on ISO 31000..., ISO 20400... and ISO 26000" (page 222).

Screening. "The weighting of CSR in the multi-criteria analysis grids of short list offers increased from 15% to 35% in 2022", and "At the end of 2025, 97% of Ecovadis-rated Amundi suppliers had a score above 35" (page 223).

Results. The 35% science-based-target sourcing goal was met; EUR 0.6 million went to EA/ESAT sheltered-sector companies; and "For the first time in 2025, Amundi was included in the A 'Supplier Engagement Assessment' list of the Carbon Disclosure Project" (page 223).

Prevention and detection of corruption and bribery

Reference: pages 218-219 (index entry G1-3 -> 3.5.2.5 and 3.5.2.7, page 152).

Certification. "In July 2017... the Amundi Group [was] awarded ISO 37001 certification for its anti-corruption management system. This certification was recently renewed in 2025 and is renewed every three years" (page 219).

Structure. "an Anti-Corruption Officer is appointed in each entity... responsible for overseeing the anti-corruption compliance programme and the annual Management Review" (page 218). Supervision rests on the Code of Conduct, a Group procedure and Control Plan, annual Compliance oversight by questionnaire, "the mapping of corruption risks deployed in all entities", and third-party assessment via "a 'know your supplier' process" (pages 218-219).

Investigation. "All cases of corruption are investigated by the compliance departments, which may draw on other expertise (audit, risks, human resources, etc.)... The cases and measures taken are presented to the entities' compliance and internal control committees" (page 219), with monitoring reported to the Fraud and Corruption Prevention Coordination Committee twice a year.

Training coverage (G1-3-21-b). Anti-corruption General Module 98.3% in 2025 against 91.5%; "Combating corruption - Most exposed business lines" 94.7% against 86.5% (page 219).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered DR. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Stated targets. One qualitative target for corruption, three quantified for payment practices:

• "In terms of targets, the fight against corruption within the Amundi Group is based on a zero-tolerance policy and the implementation of effective measures" (page 219);
• average supplier payment period: "Target: Remain below 40 days for France", reported at 29 days in 2025;
• invoices paid on time: "Aim of 100% over a three-year horizon (at the end of the 2027 financial year)";
• late-payment proceedings: "Aim of 0 over a two-year horizon (at the end of the 2026 financial year)" (page 224).

Effectiveness tracked in the absence of targets. For the other themes Amundi tracks effectiveness rather than setting outcome targets, MDR-T's other limb: "The indicators for the deployment and effectiveness of the systems for preventing conflicts of interest are the responsibility of each entity" (page 218); "The deployment and effectiveness metrics of the market abuse prevention system fall under each entity" (page 221). Ethics and anti-corruption training completion rates are reported (pages 217, 219).

Limit. No ethics, conflicts of interest, market abuse or whistleblowing measure carries a dated, measurable outcome target.

Incidents of corruption or bribery

Reference: page 219, table G1-4-24-a (index entry G1-4 -> 3.5.2.7, page 152); Annex 1 marks G1-4-24 a) and b) Material (page 233).

Result. Convictions for breaches of anti-corruption and anti-bribery laws: 0 in 2025 and 0 in 2024. Amount of associated fines: EUR 0K in both years. "Amundi compiles an annual report on the number of convictions for breaches of anti-corruption and anti-bribery laws and the associated fines" (page 219).

Handling of cases. "Illegal behaviour or behaviour contrary to the Code of Conduct is identified through controls, customer or third-party complaints; internal or external reports must be made directly, or via the reporting platform... If, at the end of the investigation, the behaviour is confirmed to be illegal or contrary to the Code of Conduct, appropriate disciplinary or corrective measures are put in place" (page 218). Reporting reaches the management bodies through the Fraud and Corruption Prevention Coordination Committee (page 219).

Reading the disclosure. Amundi reports the two datapoints Annex 1 marks material - convictions and fines. It does not report the number of confirmed incidents of corruption or bribery, incidents leading to dismissal or discipline of its own workers, or incidents relating to contracts with business partners, which ESRS G1-4 also asks for.

Payment practices

Reference: page 224 (index entry G1-6 -> 3.5.3, page 152).

Scope. "For 'Total', the scope covered includes entities in France and the main international entities (Italy, Ireland and Luxembourg). For 'SMEs', the scope covers France only" (page 224).

Average payment time (G1-6-33-a). Total 29 calendar days in 2025 against 24 in 2024; SMEs (France only) 32 days against 22. Amundi discloses a methodology change: "The method for calculating SMEs' payment terms has been revised to take calendar days rather than business days into account. The average payment term for SMEs would have been 30.92 days in 2024, taking calendar days into account" (page 224).

Invoices paid within standard times (G1-6-33-b). Total: 91% by amount and 93% by number in 2025, against 93% and 88% in 2024. SMEs: 90% and 91%, against 92% and 90%. The 93% is corroborated in the action plan: "In 2025, the rate of invoices paid on time was 93%, by number of invoices" (page 223).

Legal proceedings (G1-6-33-c). 0 in 2025 and 0 in 2024.

Terms. "Amundi applies the legal payment terms in force in France, with a maximum period of 60 days from the invoice date, without distinction between supplier categories, whether SMEs or other types of companies" (page 223).

Direction of travel. Payment speed deteriorated on both measures, and the share paid on time by amount fell from 93% to 91%, while the share by number rose from 88% to 93%.