Assicurazioni Generali S.p.A.

Reference: pages 91-94 (content index p. 91; G1-specific version pp. 91, 94).

Generali "has adopted the traditional Italian corporate governance model with a tripartite organisational structure that does not provide for worker representation within its corporate bodies" (p. 91).

Composition (p. 92). Board of Directors: 46% female, 77% independent. Board of Statutory Auditors: 33.3% female, 100% independent, all non-executive. A Diversity policy for corporate bodies is in place.

Committees (p. 93). The Risk and Control Committee "periodically reviews sustainability reporting, also gathering the opinion of the auditing firm and the Board of Statutory Auditors". The Innovation, Social and Environmental Sustainability Committee examines the Sustainability Group Policy and "expresses an opinion on the methodology for reporting sustainability information".

Expertise. After self-declarations, "the Board of Directors has ascertained a widespread presence of these skills among the Directors"; a 2025 session covered sustainability regulation (p. 93).

Management (p. 94). The Group Management Committee is "responsible for ensuring the integration of sustainability along the value chain". A Group Chief Sustainability Officer reports to the Group CEO through the General Manager, with a formal escalation process running up to the Group CEO.

Reference: pages 94-95 (content index p. 94).

"The Board defines and approves the Group's strategy, which includes both financial and sustainability aspects, through the three-year strategic plan, and the outcomes of the double materiality assessment process, as well as internal policies" (p. 94). During the year "the Board, the relevant Board Committees and the Board of Statutory Auditors are informed by the Group's management about policies, actions, metrics and targets in terms of sustainability, also related to material impacts, risks and opportunities". Committee work reaches the Board "through a written report that summarises the information provided, the in-depth analyses carried out, the areas of attention that emerged, any positions of dissent or abstention and the related motivations".

What the Board examined in 2025 (p. 95): "the outcomes of the annual control process relating to the double materiality assessment process, the Generali Climate Transition Plan and the sustainability elements in the remuneration systems, with the support of the ISC, as well as the progress of the project on the management of climate change-related risk ... with the support of the RCC."

The 2025 DMA review was approved by the Board on 19 December 2025 (p. 78).

Reference: pages 95-96 (GOV-3 and GOV-3 - E1, content index p. 95).

"In accordance with regulatory requirements and best international market practices, no variable remuneration is envisaged for non-executive Directors and Statutory Auditors" (p. 95). The Group CEO is the sole executive director; the same structure applies to Group Management Committee members.

Weightings (p. 95). The Short Term Incentive is capped at 200% of fixed remuneration and linked to financial, economic and operational objectives "as well as non-financial/sustainability objectives, the latter accounting for 20% of the total". The Long Term Incentive share plan, also capped at 200% over a 7-year timeframe, uses relative TSR, Net Holding Cash Flow and "internal, measurable sustainability objectives, which also have a 20% weighting".

Climate weighting (E1 datapoint). "The weight of Sustainability Commitment objectives, related to climate considerations, is set at 10% for both components." Named priorities: STI "YoY growth of climate insurance solutions"; LTI "CO2 emissions reduction target from Group activities".

Achievement is scored on a five-point scale "where 1 represents not achieved (with a payout of 0% of the so-called baseline) and 5 represents far exceeded". Page 96 details the internal control process, including verification "that no conditions of malus, clawback and hedging exist".

Reference: page 96 (GOV-4 and the paragraph 30 datapoint, content index p. 96).

Due diligence is described as practices "to identify and assess, prevent, mitigate or remediate, and monitor the actual and potential negative impacts of their activities, as outlined in the OECD Guidelines for Multinational Enterprises", in five phases: identification and assessment, prevention, mitigation or remediation, monitoring of effectiveness, and procedures for reporting and managing concerns.

"The Group adopts the due diligence process with respect to the key segments of the value chain related to investment and insurance processes, own operations and the supply chain ... the Group discloses its framework for managing negative impacts deriving from investment and insurance activities related to climate change and biodiversity."

Mapping table (p. 96):

The mapping cites disclosures by name rather than page and covers only the environmental topics.

Reference: page 97 (content index p. 97).

Generali has "established a specific data quality model in relation to Sustainability Statement, under the supervision of the Group CFO, acting as the Dirigente Preposto". The DP "reports - at least annually, as well as whenever necessary - to the corporate bodies regarding the methods by which the management and control activities of the Sustainability Statement process are carried out and the results of the monitoring activities".

Risks named. They relate to "the correct interpretation and adoption of the Group's methodologies, compliance with the ESRS for the collection and calculation of sustainability indicators, completeness, appropriateness, integrity, and accuracy of data and estimation results, availability of data along the value chain, as well as the related traceability (audit trail)".

Instruments. Sustainability Reporting Playbooks define indicators, methodologies, scopes and data flows. Basic requirements apply to all companies, including "cascading attestations on data quality through the Integrated Confirmation Letter"; extended requirements apply to companies identified as significant.

Monitoring. Self-assessment covers company-level controls, procedures, key controls and the IT environment, and "dedicated verification activities are also conducted by independent third parties on a sample of processes and key controls".

Reference: pages 71-72 (content index p. 71).

"The Group is one of the largest global insurance and asset management providers. With more than 88 thousand employees worldwide, an extensive network of agents and a large customer base, it plays a leadership role in Europe and has an increasingly significant presence in Asia and America" (p. 71). The model rests on Life, Property & Casualty and Asset & Wealth Management.

Value chain (p. 71). Built around four "responsible roles" - Responsible Investor, Insurer, Employer and Corporate Citizen - and four segments: investment ("the allocation of the company's own financial assets ... and those of third parties"), insurance ("the provision of Life and P&C insurance policies through the distribution channel, including claims management"), own operations, and supply chain, "mainly characterised by data and service providers linked to the core business".

Sustainability was "formally introduced in 2004", entered strategy in 2021 and is now "one of the three strategic foundations of Lifetime Partner 27: Driving Excellence strategy". Strategic initiatives address "climate change (both climate change mitigation and climate change adaptation), demographic changes, and workforce transformation".

Appendix B datapoints (p. 99). Fossil fuel, chemicals, controversial weapons and tobacco involvement are all marked "Not material (*)", i.e. not applicable.

Reference: pages 73-74 (SBM-2 and the S1- and S4-specific versions, content index p. 100).

"Dialogue and active engagement with stakeholders are essential for the Group's sustainable success and long-term value creation" (p. 73). Seven categories are mapped to channels: agents and distributors, contractual partners, clients, employees, financial community, community and the environment. Clients are "Engaged through brand surveys and surveys to monitor satisfaction levels, market research, dialogue with consumer associations"; the community "through multi-stakeholder meetings, meetings with representatives of NGOs, institutions and civil society associations ... and contributing to public consultations" (p. 74).

Own workforce (p. 74). Employees are engaged "through global surveys, individual performance assessment interviews, meetings with trade unions and workers' representatives (also through the European Works Council)". Survey results "provide valuable insights into areas for improvement and strengths, directly influencing company policies and strategic initiatives".

Link to the DMA (p. 74). "The opinions and interests of Generali's stakeholders were also considered as part of the double materiality assessment process performed in 2024, which involved both internal and external stakeholders of the Group." Results including that feedback "were shared with the Innovation and Sustainability Committee and subsequently approved by the Board of Directors".

Reference: pages 75-77 (SBM-3 and its E1-, S1- and S4-specific versions, content index pp. 100-101).

Twenty material IROs are tabulated by value chain segment. Three topics are both material and strategic: "climate change, demographic changes and workforce transformation" (p. 75).

Investment (p. 75). E1: a negative impact "generated by Generali's investment activities, considering the exposure of the investment portfolio to highly emissive sectors", transition risk, a positive adaptation impact from "capital allocation in economic activities that contribute to climate change adaptation", and physical risk. E4: a potential negative impact from exposure "to sectors that contribute to the loss of biodiversity".

Insurance (pp. 75-76). The same four E1 items for underwriting, including a positive impact "due to the extension of NAT CAT coverage and insurance products for climate adaptation"; one E4 negative impact; and four S4 items - a positive impact and a "Potential financial opportunity" on demographic changes (an entity-specific sub-topic), plus a personal-data risk and a risk "linked to customer protection".

Own operations (p. 76). S1: a positive impact from DEI, training and flexible working, and a financial opportunity from talent attraction and retention. G1: positive impacts on corporate culture, corruption and bribery, and protection of whistle-blowers. Supply chain: G1, a positive impact from favouring counterparts "that excel in ESG practices".

Reference: pages 78-90 (general process p. 78; topic-specific E1 p. 82, E2 and E3 p. 88, E4 and E5 p. 89, G1 p. 90).

"Generali performs a double materiality assessment every three years, in line with its strategic planning, and carries out an annual review in the other years" (p. 78). The first was carried out in 2024.

2025 annual review (p. 78). "Based on the analyses carried out as part of 2025 annual review process, the Group confirms the impacts, risks and opportunities identified in 2024." Results went to the Innovation and Sustainability Committee "and subsequently to the Board of Directors of the Parent Company, which approved them on 19 December 2025".

Method (pp. 78-80). Four phases - methodology tuning, pre-assessment, feedback collection, final validation - covering all ESRS sub-topics plus entity-specific topics across the four value chain segments, over three time horizons weighted "giving greater value to the medium-term perspective (60%), followed by the long-term (30%) and short-term (10%)". Both dimensions "were assessed on a scale from 1 (minimum) to 5 (maximum) ... with a materiality threshold set at 4 (significant)" (p. 79).

Topic processes. Climate (p. 82) uses the carbon footprint by segment, sector exposure weighted by portfolio or spending, and the Group ORSA. Pollution, water, biodiversity and resource use (pp. 88-90) rely on ENCORE sector data and WWF Risk Filter country screens.

Reference: pages 98-105 ("Disclosure requirements covered in the Sustainability Statement", content index p. 98).

Generali prints a full ESRS content index. "The following table serves as a content index for all disclosure requirements, whether material or mandatory, that have been considered in the preparation of the Sustainability Statement ... it also includes the datapoints derived from other EU legislative acts listed in Appendix B of the ESRS 2 standard" (p. 98). It runs pp. 99-105 in two columns with SFDR, Pillar 3, Benchmark Regulation and EU Climate Law cross-references, and four footnotes (p. 105): "() Not applicable. () Entity-specific. () Disclosure Requirement subject to phase-in provision. (****) ... Group emission intensity is not reported."

Listed with page references: BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, IRO-2; E1-2, E1-3, E1-4 (entity-specific) and E1-6; E4-2 and E4-3 (entity-specific); S1-1 to S1-6, S1-8, S1-9, S1-11 to S1-17; S4-1 and S4-4; G1-1 to G1-4.

Marked "Not material": the E1-5, E1-7, E2-4, E3-1, E3-4, E5-5, S2-1, S2-4, S3-1 and S3-4 datapoints. E1-9 and S1-14 paragraph 88(e) carry the phase-in flag.

Two sub-topic carve-outs are explained (p. 98): adequate wages is non-material, and "a specific analysis was performed on payment practices towards SMEs, concluding that the sub-topic payment practices is not material".

Reference: page 116 (the E1-1 paragraph 14 and 16(g) datapoints are both indexed to p. 116).

"In 2025, Generali adopted its inaugural Climate Transition Plan, approved by the Board of Directors of the Parent Company, implemented by Group and local competent functions, and periodically updated. The plan is fully embedded in the Lifetime Partner 27: Driving Excellence strategy."

Scope. It "encompasses investment and underwriting activities, as well as own operations, and excludes banking and agricultural activities". Content. It "defines the commitments, levers, resources and governance mechanisms through which Generali supports a transition towards a net-zero greenhouse gas emissions economy and commits to becoming a net-zero company by 2050 ... it sets science-based interim targets for 2030, which are defined on pathways compatible with limiting global warming to 1.5°C".

Stated limitations. "Generali believes that accurately quantifying the contribution of each lever to GHG emissions reduction targets and the related resource allocations ... is a process currently characterised by considerable complexity." Footnote 72: the plan "does not include all the information required by paragraphs 14-16 of ESRS E1-1, as such information is currently not available".

Paragraph 16(g). Generali "is included in the applicable EU Paris-aligned Benchmarks ... it does not retain material locked-in GHG emissions from key assets or products".

Back-filled from ESRS 2 IRO-1 "Process to identify and assess climate-related impacts, risks and opportunities", where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 82-88.

Risk classification (¶15). "physical risk due to the variation in frequency and severity of climate-related natural events; transition risk due to the variation in costs and revenues deriving from the transition to a green economy ...; litigation risk due to higher costs deriving from legal cases and controversies" (p. 82).

Methodology (¶16). The proprietary Clim@risk methodology runs through an internal tool, Aeolus, over the general account and unit-linked investment portfolios, the Motor and Fire and other property damage P&C lines plus D&O policies, and the Life book.

Scenarios (¶17(a)). NGFS Phase V for transition and litigation risk: Net-Zero 2050, "consistent with ... limiting global warming to 1.5°C"; Delayed Transition, "around 2°C"; Fragmented World, "a little limitation of global warming". For physical risk, IPCC CMIP6 pathways "SSP1-2.6, SSP2-4.5 and SSP5-8.5" (p. 83). Both a high-emission and a 1.5°C-aligned scenario are used.

Assumptions and timing (¶17(c)-(d)). Carbon cost, electricity demand, energy mix and transport energy at country level. Analyses "do not consider the impacts of future managerial and business actions" (p. 84).

Back-filled from ESRS 2 SBM-3 and the resilience analysis within ESRS 2 IRO-1. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 77, 84-88.

Resilience statement (¶19(a)). "The resilience of the Group's business model in relation to material IROs is confirmed ... the Group's resilience has also been assessed through scenario analysis applied to investments (including real estate for own use), P&C underwriting and Life underwriting" (p. 77). "medium- and long-term analyses are classified as resilience analyses, aimed at evaluating the organization's ability to maintain operational continuity ... even under adverse scenarios" (p. 84).

Results (p. 85). "transition risk is relatively limited"; "physical risk is material, confirming that the increasing volatility and severity of extreme climate events can significantly impact both the investment and underwriting portfolios"; litigation risk is limited. Quantified for the general account portfolio at 2050: transition risk "less than 2%", physical risk 6% under Delayed Transition and "lower than 10%" under Fragmented World (pp. 86-87).

Uncertainty (¶19(b), p. 85). Impacts "may be subject to change and may not be comparable year on year".

Capacity to adapt (¶19(c), p. 88). "Climate change risk management is integrated into decision-making processes through the definition of a specific framework, including limits and remedial actions."

Reference: pages 116, 117, 124, 127. The content index flags E1-2 as "(**) Entity-specific" (p. 101).

Sustainability Group Policy (p. 116). Sets the climate ambition "to contribute to keeping global warming well below 2°C (WB2D), and possibly as close as 1.5°C by the end of the century ... throughout the Group's value chain, with a particular focus on investment and underwriting activities, as well as its own operations".

Investment (p. 117). The Investment Governance Group Policy "defines the governance of the investment process for the insurance portfolios and the related methods for integrating material sustainability factors, including environmental factors linked to climate change". The Integration of Sustainability into Investments and Active Ownership Group Guideline covers "the methods for integrating sustainability factors into the decision-making process for proprietary investments". A limitation is stated: the Group "has identified and disclosed its strategic objectives and its metrics by referring to both mitigation and adaptation in a conjoined manner".

Asset managers (pp. 123-124). Infranity's policy aims at "aligning the climate trajectory of the managed portfolios with the objectives of the Paris Agreement".

Underwriting (p. 127). The Responsible Underwriting Group Guideline integrates climate considerations into P&C underwriting "with the goal of reducing underwriting of risks belonging to sensitive sectors".

Reference: pages 117-120, 127-131. The content index flags E1-3 as "(**) Entity-specific" (p. 101).

Investment exclusions (p. 118). "New investments are prohibited and gradual divestment is required from listed companies operating in sectors and activities with a significant negative impact on climate change" - thermal coal "to achieve the coal phase-out by 2030 for OECD countries and by 2040 for the rest of the world"; unconventional oil and gas on "exposure to tar sands, hydraulic fracturing, and ... the Arctic Circle"; and conventional oil and gas companies with inadequate transition plans.

Engagement and voting (pp. 119-120). In 2025 Generali "engaged 26 invested companies on climate-related matters ... both individually (14) and collectively (12)", and "in 66 shareholders' meetings of 50 investee companies, Generali voted on 81 climate change resolutions ... 85.7% in favour, 12.7% abstentions, and 1.6% against."

Underwriting (pp. 127-128). Thermal coal phase-out "by 2030 for clients operating in OECD countries and by 2038 for clients in the rest of the world"; since "1 January 2025" no new covers for midstream/downstream assets of customers without solid emission-reduction commitments. Residual coal exposure is "less than 0.1% of the premiums".

Adaptation (p. 130). "in 2025 Generali established the Group Climate Hub: a center of excellence designed to coordinate and accelerate climate initiatives", with first outcomes "expected during 2026".

Reference: pages 115, 119, 129-130. The content index flags E1-4 and the GHG reduction targets datapoint as "(**) Entity-specific" (pp. 101-102).

Own operations (p. 115). "an emission reduction target on all Scopes from own operations by 35% compared to 2019 (baseline 149,684 tCO2e) by the end of 2025 - target overachieved - and by 60% compared to 2019 baseline by the end of 2030, as well as to achieve net-zero emissions by 2035". Own-operations Scope 1, 2 and 3 were 77,036 tCO2e in 2025 (2024: 82,005).

Investment (p. 119). Corporate portfolio carbon intensity (EVIC) 73 tCO2e/€ mln invested (2024: 89), target -60% over 2019-2030 from 182 (2019). GRE real estate 23.9 KgCO2e/m2 (2024: 33.5), target -60% from 61.2. Climate solutions investments € 35.3 bn (2024: € 26.7 bn), target "Increase of € 12 bln" 2025-2027. Targets are "positioned at the upper end of the range provided by the NZAOA protocol".

Insurance (pp. 129-130). Climate insurance solutions premiums € 2,223 mln (2024: € 1,821 mln), target "+8-10% CAGR" 2024-2027. Personal motor emission intensity 0.26 ktCO2e/€ mln (2024: 0.30), target -30% over 2021-2030 from 0.35. Global Corporate & Commercial 0.18 (2024: 0.20), target -40% from 0.27.

Scope exclusions (p. 116). Employee commuting and government bonds. No adaptation target yet: the Group "is developing metrics and targets to verify the effectiveness of its actions on climate adaptation" (p. 131).

Reference: pages 113-115 (E1-6 and the paragraph 44 datapoint, both indexed to p. 113).

Group GHG inventory (p. 113), tCO2e:

Scope 3 category 15 (investments) dominates at 20,716,115 tCO2e; employee commuting is 39,580, fuel and energy-related activities 24,329, purchased goods and services 16,740 and business travel 11,971. Scope 1 from regulated emission trading schemes is 0%.

Method and quality (pp. 113-115). Emissions follow "the principles of the GHG Protocol - Corporate Accounting and Reporting Standard and ... those of the PCAF". Own-operations coverage is 79.9% measured, 20.1% extrapolated. Data quality is disclosed plainly: "0.5% (0.4% at 31 December 2024) of Scope 3 emissions are calculated using primary data". Insurance-portfolio emissions are excluded "as they are not covered by the categories defined by the sustainability reporting standard". Scope 1 biogenic emissions were 118 tCO2e.

Intensity. "In accordance with the provisions of Appendix E of ESRS 1, Group emission intensity is not reported as it is deemed not representative of Group-wide performance" (p. 115).

Reference: pages 132, 136, 138. The content index flags E4-2 as "(**) Entity-specific" (p. 103).

"The disclosure adopts an entity-specific approach through the description of policies, actions, and metrics in place, in order to reflect the peculiarities of its business" (p. 131).

Asset Owner (p. 132). "The Investment Governance Group Policy and the Integration of Sustainability into Investments and Active Ownership Group Guideline outline the methodologies for integrating sustainability factors into the decision-making process of the proprietary investments, including considerations related to biodiversity."

Asset Managers (p. 136). Infranity's Sustainable Investment Policy commits it to "fight climate change and support resilient, inclusive and sustainable economies, notably through the rational use of resources, biodiversity protection, mitigation of pollution". Sycomore AM operates a Natural Capital Strategy and an ESG Integration Policy; Sosteneo an Investment Sustainability Policy.

Responsible insurer (p. 138). "the Group has specifically identified so-called sensitive sectors toward biodiversity, such as mining, hydrocarbon mining, fishing and livestock, and large dams for hydropower plants."

Appendix B datapoints (p. 104). The E4-2 paragraph 24(b), (c) and (d) datapoints - sustainable land or agriculture practices, sustainable oceans or seas practices, and policies to address deforestation - are each marked "Not material".

Reference: pages 132-133, 137-138. The content index flags E4-3 as "(**) Entity-specific" (p. 103).

Exclusions (p. 132). For corporate issuers, "New investments are prohibited, and gradual divestment from issuers responsible for serious environmental abuses, including the destruction of natural capital and damage to the biodiversity of the territory, is required." For sovereign issuers the analysis "also includes the deforestation of the territory". Funds are screened for "an exclusion policy for companies accused of major environmental controversies".

Engagement and voting (pp. 132-133). Priorities come from "an annual screening of the Group's portfolios, conducted using data from MSCI, to identify issuers involved in material environmental controversies that could have an impact on biodiversity", plus the Nature Action 100 and PRI Spring lists. In 2025 "the Group directly engaged with 22 of the most significant companies in its portfolios ... through 5 individual dialogues and 17 collective initiatives", largely in consumer staples.

Asset managers (pp. 137-138). Infranity excludes "pesticides, chemicals, plastics, agricultural materials related to deforestation, palm oil production, GMOs, mining and conventional and unconventional fossil fuels sectors".

Underwriting (p. 138). For sensitive sectors the Group "has adopted a local escalation process ... aimed at limiting their subscription as much as possible".

Reference: pages 140-142 (S1-1 and the paragraph 20, 21 and 23 datapoints, indexed to pp. 140 and 152).

"Generali is committed to respect and promote all human rights as defined in the United Nations International Bill of Human Rights and in the International Labour Organization (ILO)" (p. 140). The Human Rights Public Statement sets out "a due diligence process to identify, assess, prevent, mitigate or remediate, and monitor any potential direct and indirect adverse impacts on human rights, in accordance with the United Nations Guiding Principles on Business and Human Rights".

The named instruments (pp. 140-142): the Group Code of Conduct; the Reporting Concerns and Anti-Retaliation Group Guideline; the DEI Group Guideline, which "emphasizes the Group's rejection of any form of irregular or work exploitation, as well as any kind of forced or compulsory and child labour"; the European Social Charter, covering "the rights of freedom of association, the establishment of workers' representations and their functions"; the EWC Agreement of 1997; and the Group Remuneration Internal Policy.

Health and safety policy datapoint (p. 152). "The responsibility related to the definition and implementation of health and safety management systems to prevent work-related accidents is demanded to the companies, in accordance with the respective local regulation." The paragraph 22 datapoint on preventing trafficking in human beings is marked "Not material" (p. 104).

Reference: pages 144-145 (S1-2, indexed to p. 144).

"Among the diverse approaches for active and recurring employees listening, the Group leverages dedicated surveys, such as the Global Engagement Survey and the Global Pulse Survey. Additionally, in the European context, Generali ensures employees engagement through their designated representatives in the EWC" (p. 144). Both surveys are "open to all employees of the consolidated Group companies".

2025 participation. "In 2025, the third edition of the Global Pulse Survey was conducted, achieving a record response rate ... with approximately 69,000 respondents out of more than 77,300 employees invited to participate." It "has been translated into 25 languages", and "The perspectives of particularly vulnerable workers are addressed and equally considered".

Workers' representatives (p. 145). "The only employee representation body at European level within the Group is the EWC." Dialogue runs "quarterly within the Select Committee and once a year with all Committee members in plenary session". The Committee "can express an opinion regarding transnational measures with significant impacts on employees", and those opinions "may be taken into consideration during the Group's decision-making process".

Results feed action: they "reaffirmed the work priorities identified in the 2024 Global Engagement Survey ... supported by more than 400 engagement initiatives active across the Group".

Reference: page 158 (S1-3 and the paragraph 32(c) grievance mechanism datapoint, both indexed to p. 158).

"The Group provides its employees with different options to report potential, alleged or even feared violations to be investigated. Employees and other reporters can use the Generali Group Whistleblowing Helpline (generali.whispli.com/speakup) available on the intranets and on the Group corporate web sites" (p. 158), governed by the Reporting Concerns and Anti-Retaliation Group Guideline.

"Reports on issues related to the workforce can also be conveyed through EWC representatives, as provided by the European Social Charter ... Violations - or alleged violation - may be brought to the attention of the Management during ordinary or extraordinary annual meetings with the EWC, as well as in regular correspondence or in dedicated meetings."

Handling (p. 163). Reports "are analysed, evaluated and managed by independent internal specialists from the Compliance function", escalating to Group Compliance "if a conflict of interest arises". Where substantiated, Compliance "proposes remedial actions (e.g., training session, communication initiative, organizational or procedural change, adoption of a first or second line control)".

Anti-retaliation (p. 164). Retaliation "is an unlawful behaviour and, if it occurs, must be severely punished".

No measured level of employee awareness of, or trust in, the channels is disclosed.

Reference: pages 145-157 (S1-4 is indexed as "p. 145 - 157").

Actions sit under the four GPeople27 priorities: Distinctive Culture, Skills Leadership, Talent Attraction and Development, Future-Ready Organization (p. 139).

Social dialogue (pp. 145-146). "dialogue with the EWC led to the signing, on 17 December 2025, of a Joint Declaration on technological transformation, digitalization, and Artificial Intelligence, applicable to all Group entities across the territories within the EEA", covering "training programs aimed at upskilling and reskilling our people ... as well as the management and control of risks arising from AI applications".

Diversity and inclusion (pp. 148-150). The third Elevate programme for women managers concluded in December 2025. "approximately 160 actions were implemented locally" on gender and "about 50 locally launched actions" on generational diversity.

Health and well-being (p. 152). Four families of initiatives - mental well-being, physical health, physical activity, and training on ergonomics and safe driving - "were made available to more than 80% of the Group's employees".

Training (p. 153). We LEARN offers "more than 250 customised digital courses translated into over 18 languages"; "the total amount of financial resources allocated increased to € 74.0 million ... (€ 62.5 million at 31 December 2024)".

Ways of working (p. 157). The hybrid model was refreshed with "7 Golden Rules".

Reference: pages 144 and 153 (S1-5 is indexed to both).

Two entity-specific own-workforce targets sit within the Lifetime Partner 27: Driving Excellence strategy.

Engagement rate (p. 144). 85% at 31/12/2025 (2024: 83%), target "Engagement rate above or equal to the market benchmark" for 2025-2027, no baseline stated. "In the 2025 Global Pulse Survey the Group engagement rate reached 85% of favourable responses, the highest figure on record since tracking began." The benchmark is "the European HQ Financial Services Norm by Willis Towers Watson".

Upskilling index (p. 153). 31% at 31/12/2025 (2024: N/A), target "Upskilling index ≥ 90%" for 2025-2027, no baseline stated. The index "indicates the percentage of the targeted Group's population that has successfully completed their upskilling journey during the strategic cycle 2025-2027", built from three equally weighted components: "Culture, Customer & Sustainability (33%), AI, GenAI & Operational Model (33%) and Core Competencies (Technical & Functional Excellence) (33%)".

Worker involvement. Stated plainly and negatively for both: "The identification of the target, the monitoring of the results obtained, and the identification of potential target improvements do not involve the participation of employees or their representatives. Employees and/or their representatives are recipients of a communication plan regarding the defined targets" (pp. 144, 153).

Reference: pages 142-144 (S1-6, indexed to p. 142).

Head count by gender at 31/12/2025 (p. 143): male 42,247 (2024: 41,545); female 45,999 (45,304); other 2 (2); not reported 1 (0); total 88,249 (86,851).

Countries with at least 50 employees representing 10% or more of the total (p. 143): Italy 19,057 (18,733), Germany 11,211 (11,388), France 10,378 (9,991).

By region (p. 143): Europe 68,927 (68,310); Asia Pacific & Middle East 14,652 (13,787); Latin America 3,218 (3,314); North America 1,452 (1,440). "The geographical distribution of employees highlighted Generali's strong presence in Europe with 78.1% of total."

Contract type (p. 143): "The majority of employees (94.0%) had a permanent contract ... At the same time, the minority of employees (6.0% of the total) had temporary contracts, a situation that particularly arose in businesses subject to seasonality or project-based needs."

Turnover (p. 144): 12,783 employees left the Group in 2025 (2024: 12,597), a turnover rate of 14.5%, unchanged year on year.

Figures are head count and match the "more than 88 thousand employees worldwide" cited in the business model (p. 71). No reconciliation to the financial statements is given here.

Reference: pages 145-147 (S1-8, indexed to p. 145).

"68.0% of the Group's total employees are covered by collective agreements, with a percentage rising to 88.1% in the EEA. In France and Italy, coverage is almost total, while in Germany it stands at 82.4%. In these countries, workers' representation covers nearly all employees. Outside Europe, the Asia Pacific & Middle East region records a low rate of collective bargaining coverage, which is nevertheless in line with coverage rates generally present in this geographical area across all sectors" (pp. 145-146).

The banded table at p. 146 places France, Germany and Italy in the 80-100% band for both EEA collective bargaining coverage and workplace representation, and the Asia Pacific & Middle East region in the 0-19% band for non-EEA coverage.

Framework (p. 145). "Aspects such as the recognition of fundamental workers' rights, collective bargaining, social dialogue, and freedom of association are referenced in the Group Code of Conduct, which applies to employees in all countries where the Group operates." The European Social Charter "defines respect for trade union rights and the exercise of related functions, and it promotes, through social dialogue, the socially responsible management of any impacts on people resulting from corporate restructuring".

Local companies "allocate the appropriate financial resources to meet what has been agreed upon in collective bargaining" (p. 147).

Reference: pages 148-149 (S1-9, indexed to p. 148).

Gender diversity in top management (p. 148): number of women in strategic positions 605 (2024: 647); percentage of women in strategic positions 40.7% (2024: 38.6%). "Strategic positions are defined as those within the Group Management Committee (GMC), the Generali Leadership Group (GLG), and their direct reports. The data source is Orion, a Group's IT system." The share rose while the absolute number fell, so the denominator contracted year on year.

Distribution of employees by age group (p. 148), head count: under 30 years old 11,718 (2024: 11,303); between 30 and 50 years old 50,798 (50,437); over 50 years old 25,733 (25,111); total 88,249 (86,851). "Employees who left the Group during 2025 are not included in the count."

Generali frames diversity around "two main areas: gender diversity and generational diversity" and "focuses particularly on the theme of having four different generations currently working together".

Board-level gender diversity is reported separately under GOV-1: 46% female on the Board of Directors and 33.3% on the Board of Statutory Auditors (p. 92). The age-group split is not given for top management.

Reference: page 147 (S1-11, indexed to p. 145).

"All Group employees are covered by social protection schemes for events which include sickness, unemployment, employment injury and acquired disability, parental leave, and retirement, except for a few very limited cases aligned with the specificities of the respective country" (p. 147).

The exceptions are named country by country (p. 147):

• unemployment coverage "is not available in India, French Polynesia, Peru and Singapore";
• parental leave - "immaterial cases where coverage is not provided in specific situations: parental leave among temporary employees in the United States, as well as all employees in French Polynesia";
• retirement - "retirement coverage for temporary employees in Japan and for non-citizen employees in Singapore".

"For areas not yet covered, the Group is committed to carefully monitoring potential needs and opportunities for coverage improvement, ensuring continuous alignment with the highest standards, market best practices and specific contexts, and requirements of each country."

The disclosure is qualitative and country-specific rather than quantified: no percentage of employees not covered by each major life event is given, and the gaps are described as "very limited" and "immaterial" without a supporting head count.

Reference: pages 149-150 (S1-12, indexed to p. 149).

"At 31 December 2025, employees with disabilities amounted to 2,686, representing 3.0% of the overall workforce" (p. 149), unchanged from 3.0% at 31 December 2024.

Basis of preparation (p. 149). "In calculating this indicator, the number of employees with disabilities is defined in accordance with the definition of disability established by local national laws. Therefore, the disclosure of this information in certain countries where the Group operates may be subject to legal restrictions or limitations on data collection (e.g., the United States). The percentage is based on the employees' head count out of the total Group workforce."

Associated actions (pp. 149-150). "every year, on International Day of Persons with Disabilities, Generali runs the Disability Week initiative"; in 2025 the event was designed for the DEI Community of Practice and the Group's Employee Resource Groups. The "Overcome our biases to shape an inclusive culture" programme, launched in 2024, "saw the participation of over 2,500 employees", with a second chapter, Inclusion in Action, in 2025. The Accessibility Manifesto dates from 2022.

The figure is Group-level only, with no breakdown by gender or country.

Reference: pages 153-154 (S1-13, indexed to p. 153).

Average number of training hours per employee (p. 154):

"The calculation of the indicator excludes inactive employees, while including those who joined during the year, and it also considers business and local context peculiarities."

"During 2025, the total amount of financial resources allocated increased to € 74.0 million compared to the previous fiscal year (€ 62.5 million at 31 December 2024). In the same period, an average of 36.5 hours of training per employee was recorded" (p. 153).

Programme. We LEARN has run since 2019 with "more than 250 customised digital courses translated into over 18 languages", "a network of more than 500 internal experts", and We LEARN Champions "distributed across more than 45 countries and all BUs".

The percentage of employees participating in regular performance and career development reviews is not disclosed.

Reference: page 152 (S1-14 and the paragraph 88(b) and (c) datapoints, both indexed to p. 152).

Health and safety at the workplace (p. 152):

The rate "is calculated as the number of recordable work-related accidents divided by the total number of hours worked by employees and multiplied by 1,000,000".

Context (p. 152). "The number of recordable work-related accidents is particularly influenced by both specific business lines where the Group operates, such as caregiving sector, and accidents occurred during commuting to and from work ... Cases related to commuting accidents, which in several countries account for the majority of recorded accidents, amounted to 176 and represented 27.1% of the total recorded accidents."

Phased-in datapoint. Paragraph 88(e), "Number of days lost to injuries, accidents, fatalities or illness", is marked "Not material (***)" - subject to a phase-in provision (pp. 104-105) - so lost days are not reported. Cases of recordable work-related ill health are not separately quantified.

Reference: pages 156-157 (S1-15, indexed to p. 156).

Family-related leave (p. 157). "Nearly all the Group employees, corresponding to 99.9%, are entitled to take family-related leave, with a substantial balance between women and men, while the overall percentage of those who took family-related leave is 9.5%. The small portion of the population that is not entitled ... mainly includes limited cases of employees with permanent contracts, whose rights accrue upon the conclusion of their probation periods." Entitlement was 99.9% in 2025 (2024: 99.3%), male 99.9% (99.5%) and female 99.9% (99.1%).

Policy basis (p. 156). "The principle of promoting work-life balance is outlined in the DEI Group Guideline and it is primarily realized through the recognition of benefits provided by laws, national collective agreements, corporate supplementary agreements and local regulations. Among the various measures that facilitate flexible working arrangements, paid leave is provided, such as, for pregnancy, breastfeeding for new mothers, marriage leave, maternity/paternity leave, child illness and care-giver assistance for disabled family members."

The 2023 Joint Declaration signed with the EWC "further guarantees the promotion of the right to disconnect, work-life balance, well-being and compliance with the contractual working hours limit".

Effectiveness (p. 157). Global Pulse Survey 2025 showed "an average favourability of 90%" on hybrid working questions.

Reference: page 151 (S1-16 and the paragraph 97(a) and (b) datapoints, all indexed to p. 151).

"At 31 December 2025, the gender pay gap is 26.9% (28.4% at 31 December 2024) and the total remuneration ratio is 219:1 (187:1 at 31 December 2024)". Footnote 101: "The metrics refer to companies with more than 50 employees (headcount) and represent 98% of the Group's total workforce."

Definitions used. "The gender pay gap is defined as the difference in average hourly pay levels between male and female employees, expressed as percentage of the average hourly pay level of male employees. The total remuneration ratio is defined as the ratio of the highest-paid individual to the median annual total remuneration of all employees, excluding the highest-paid individual."

The Group's own qualification. "these metrics do not fully reflect internal pay equity, as they consider all Group consolidated companies as a single unit and compare remuneration across different countries and types of business ... if the analysis of the total remuneration ratio were focused on the main countries in Europe, the indicator would show a substantial reduction of more than 25%."

Equal pay work. "At the end of the 2022-2024 strategic cycle, Generali achieved the closure of the Equal Pay Gap." EU Pay Transparency Directive compliance is "expected in 2026 and 2027".

Note the divergence: the pay gap narrowed while the total remuneration ratio widened from 187:1 to 219:1.

Reference: page 158 (S1-17 and the paragraph 103(a) datapoint, both indexed to p. 158).

Incidents and complaints (p. 158): number of incidents of discrimination 24 (2024: 25); number of complaints filed 98 (2024: 93). "The number refers to reports, including those from previous periods, that resulted substantiated in the reporting period." On complaints: "No reports were made to the national contact points for multinational enterprises of the OECD and published in the dedicated OECD database."

Complaints reach the Group through the Generali Group Whistleblowing Helpline and through EWC representatives under the European Social Charter.

Outcomes (p. 164). Across all report types, "At 31 December 2025, 233 reports were closed, including those relating to previous periods (208 at 31 December 2024). Of these, 86 (84 at 31 December 2024) resulted as substantiated - 24 (25 at 31 December 2024) about discrimination, harassment and retaliation - and led to dismissal or termination of the employment contract, warnings and other remedial measures." The 2025 measures were 16 dismissals or terminations, 42 warnings and 22 other, 80 in total.

The paragraph 104(a) datapoint on non-respect of the UN Guiding Principles and OECD guidelines is marked "Not material" (p. 104). No fines, penalties or compensation for damages are quantified.

Reference: pages 158-161 (S4-1 is indexed as "p. 158, 160, 161"; the paragraph 16 and 17 datapoints to p. 158).

Two material S4 sub-topics are addressed: information-related impacts for consumers and end-users (privacy and access to quality information) and the entity-specific sub-topic demographic changes (p. 76).

Privacy (p. 158). "The principles relating to the processing of personal data are identified and detailed in the Personal Data Protection Group Policy, which, although based on the principles of the General Data Protection Regulation (GDPR), also establishes their application to all Group companies outside the European Union", aligning with "the Global Compact and the United Nations Guiding Principles on Business and Human Rights, which promote sustainable practices and recognize privacy as a fundamental right".

Access to quality information (p. 160). "Generali has adopted the Product Oversight and Governance Group Policy (POG), that outlines, among others, the principles and guidelines to mitigate the risk of non-compliance with relevant regulations. It defines the commitment to ensuring that the distribution network maintains all necessary documentation for the insurance products intermediated, which must be clear, precise, and updated."

Demographic changes (p. 161). "The Life Underwriting and Reserving Group Policy includes guidelines for the development of products with social value ... with particular reference to demographic changes."

Reference: pages 158-161 (S4-4 is indexed as "p. 158, 160, 161").

Privacy risk management (pp. 158-159). The Group runs "a risk management process related to the processing of personal data that makes it possible to identify the risk itself and assess it, mitigate its impact and monitor it over time", on three lines of defence: operational functions "collect only the data that is strictly necessary, use tools such as pseudonymisation and encryption to protect it"; Compliance functions and Data Protection Officers "support and oversee the implementation of the policy"; and "the Internal Audit function, as a third line of defence, verifies the overall effectiveness of the control system".

Access to quality information (p. 160). "To ensure proper and transparent distribution, the Group outlines and updates the standards for distribution networks to enable them to fully and completely understand the characteristics of the products offered and related services, including the risks and costs (even implicit)." Effectiveness is monitored through product and distribution channel monitoring processes.

Demographic changes (p. 161). The Group is "leveraging the foundation of a dedicated Demographic Hub", focused on "the mostly underserved and therefore more vulnerable segments of the population, such as women, young people, the elderly, families, and migrants/refugees". New Business Premiums for those solutions were € 3,517 mln in 2025 (2024: € 3,205 mln).

Reference: pages 162-163 (G1-1 and the paragraph 10(b) and 10(d) datapoints, all indexed to p. 162).

Group Code of Conduct (p. 162). It "constitutes the foundation of the Group's cultural identity and defines the fundamental rules to be adopted", covering "fair conduct of business, sustainability, work environment, diversity, equity and inclusion, personal information and privacy, fair competition and antitrust, conflicts of interest, anti-bribery and anti-corruption, anti-money laundering, counter terrorist financing and international sanctions". It "rejects any form of violation of human rights", binds all employees and "third parties (consultants, suppliers, agents, etc.) who act on its behalf", and was approved by the Board of the Parent Company.

UN Convention against Corruption datapoint (p. 162). The Anti-Bribery and Anti-Corruption Group Policy "has been drafted in line with ... the United Nations Convention against Corruption, the OECD Convention on Combating Bribery of Foreign Public Officials, and Wolfsberg Group's ABC Compliance Program guidelines".

Protection of whistle-blowers datapoint (p. 162). The Reporting Concerns and Anti-Retaliation Group Guideline describes "the anti-retaliation policy for safeguarding people who report".

Culture in practice (p. 163). "The provision of annual training programs on the Code of Conduct aims to promote full awareness of its provisions, encourage the reporting of violations."

Reference: pages 165-166 (G1-2, indexed to p. 165).

"The Group has long adopted a series of internal rules that define how the impacts, risks, and opportunities related to its suppliers should be addressed and managed. The purpose is to ensure integrity through the entire supply chain with respect to key principles that include human and labour rights, anti-corruption, and the environment" (p. 165).

Instruments (p. 163). The Ethical Code for Suppliers sets out "correctness and honesty, transparency and impartiality, prevention of conflicts of interest, fair competition, confidentiality, workers protection, and environmental protection".

Supplier ESG assessment (p. 165). "The ESG assessment of suppliers is under responsibility of Group companies that implement the One Procurement Group Guideline and it is performed at local level by dedicated teams. Starting from mid-2025 the ESG assessment has been extended to purchases exceeding € 200,000. It weighs 5% in the tender award criteria." It is "carried out by an independent external certifying provider, based on a supplier's self-declaration", covers human rights and labour, health and safety, environmental protection and supply chain responsibility (p. 166), and returns "compliant, non-compliant, or in progress".

From 2026 the Group "will introduce ... evaluations through carbon scorecards and carbon footprint" (p. 166). No count or percentage of suppliers assessed, and no outcome distribution, is disclosed.

Reference: pages 164-165 (G1-3, indexed to p. 164).

"The Group is firmly committed to fight against corruption and adhere to relevant international and national regulations, adopting a zero-tolerance approach towards the risks of corruption, bribery and abuse of power. It has issued the Anti-Bribery and Anti-Corruption (ABC) Group Policy ... which, supported by operational guidelines, defines approaches, processes and any additional measures aimed at such prevention" (p. 164).

Detection (p. 165). "The Group adopts specific procedures and a reporting channel, the Generali Group Whistleblowing Helpline ... in order to prevent, identify and manage cases of potential violations ... including cases of corruption. It has also defined a set of risks and compliance controls." Reports are handled by "independent internal specialists from the Compliance function" (p. 163).

Functions at risk (p. 165). "Functions exposed to relationships with third parties are considered the highest-risk functions for corruption ... more likely to engage in ... relationships with public administrations, public officials, or politically exposed persons."

Training (pp. 164-165). Board and Statutory Auditors "receive periodic induction training, organised by the Group Chief Anti-Financial Crime Officer function". For employees, "100% of high-risk functions are subjected to training programs", through the "Be aware of Anti-Bribery and Corruption" module on We LEARN.

Back-filled from the business conduct chapter (pages 163-166), where effectiveness is tracked in the absence of a numeric target. The statement was prepared under the 2023 ESRS (Delegated Regulation 2023/2772/EU, p. 70), under which business conduct targets fell within the Minimum Disclosure Requirement on targets rather than a standalone G1-3.

Reference: pages 98, 163-166.

No numeric business conduct target. Group targets are set only for climate, own workforce and consumers and end-users (pp. 115, 119, 129-130, 144, 153, 161). None is set for corporate culture, protection of whistle-blowers, corruption and bribery or management of relationships with suppliers. The content index introduction says only that "Minimum disclosure requirements (MDRs) about policies, actions, metrics, and targets are detailed in the chapters related to each material topic" (p. 98).

Effectiveness is tracked and quantified. Whistleblowing reports totalled 222 in 2025 against 187 in 2024. "At 31 December 2025, 233 reports were closed ... Of these, 86 ... resulted as substantiated", leading to 16 dismissals or terminations, 42 warnings and 22 other measures (p. 164). "in line with the prior period, 100% of high-risk functions are subjected to training programs" (p. 165), and convictions and fines were nil in both years. Supplier ESG performance is rated "compliant, non-compliant, or in progress" by an external certifier, weighted at "5% in the tender award criteria" (p. 165).

Reference: pages 164-165 (G1-4 and the paragraph 24(a) and 24(b) datapoints, indexed to pp. 164 and 165).

Incidents of corruption or bribery (p. 165): number of convictions for violation of anti-corruption and anti-bribery laws 0 in 2025 and 0 in 2024; amount of fines € 0 million in both years.

The basis is stated: "The evidence can be found in the Group process aimed at identifying and collecting operational events that generate direct economic losses, due, for example, to non-compliance with regulatory provisions regarding the management of gifts and entertainment or accurate and transparent recording of payments, as well as non-compliance with regulatory provisions related to the formal assignment of clear responsibilities and the implementation of internal procedures to prevent corruption and bribery practices."

Related report volumes (p. 164). The whistleblowing table shows 22 internal fraud reports (2024: 20) and 4 external fraud reports (2024: 9) among 222 received in 2025. Of 233 reports closed, 86 were substantiated, leading to 16 dismissals or terminations, 42 warnings and 22 other measures.

The disclosure gives convictions and fines but does not separately report the number of confirmed incidents of corruption or bribery, the number in which employees were dismissed or disciplined for it, or the number relating to contracts with business partners; outcomes are aggregated across all substantiated report types.