Avanza Bank Holding

Governance roles

Reference: page 66. Listed in the ESRS content index at page 66 (p.77).

The Board of Directors of Avanza Bank Holding AB (publ) is described as "Avanza's highest executive body, setting the framework for the operations, appointing the CEO, and exercising oversight of the company's management" (p.66). At the end of 2025 the Board had nine members elected by the General Meeting, with no employee representatives or deputies, and none holding an executive position.

Composition and diversity (p.66): five men and four women, "a gender distribution of 56 per cent men and 44 per cent women". All members are independent of the company and its management under the Swedish Corporate Governance Code; six are also independent of the major shareholders.

Allocation of responsibility (pp.66-67):

• The Board "has the ultimate responsibility for governance, risk management and internal control related to Avanza's sustainability work", approves and monitors the climate transition plan, and determines the material sustainability matters.
• The Board's Risk, Capital and Audit Committee (RCAC) monitors sustainability reporting and prepares material matters for the Board.
• The CEO has overall responsibility for integrating sustainability into operations and has established a Sustainability Committee chaired by the Head of Sustainability.
• The Head of Sustainability reports to the Chief Financial Officer in Group Management (p.67).
• Risk Management and Compliance form the second line of defence; Internal Audit the third, reporting directly to the Board.

Board competence covers "financial markets, digital services, IT and cyber security, customer behavior, and regulations for financial institutions" (p.66), with sustainability expertise itemised at p.67.

Information provided to the administrative, management and supervisory bodies

Reference: page 67.

The Board, the CEO and the relevant committees "regularly receive information from relevant units such as Risk, Compliance, Sustainability, Cyber security, and HR regarding material impacts, risks and opportunities", covering "insights from Avanza's materiality assessment, stakeholders' views, as well as results from policies, actions, metrics and targets" (p.67).

Frequency and reporting lines (p.67):

• Each control function reports at least quarterly to the Board and the CEO.
• The Risk Management function "shall annually submit an assessment of the Avanza Group's sustainability risks to the Board", which is then fed into the double materiality assessment.
• Group Management members responsible for material matters report progress on targets, KPIs and action plans to the Sustainability Committee and the CEO.

Matters addressed in 2025: the report states the Board, CEO and committees "have addressed all material sustainability areas, with a particular focus on the Group's climate-related work", and prints a coverage table showing E1 Climate change, S1 Own workforce, S4 Customers and end-users and G1 Business conduct each addressed by the Sustainability Committee, the CEO, the RCAC and the Board (p.67).

The RCAC also considers sustainability within the ICAAP and ORSA, "where various climate scenarios are evaluated in relation to Avanza's income statement and balance sheet" (p.67).

Integration of sustainability performance in incentive schemes

Reference: pages 67-68.

Avanza's disclosure is short and is a partial negative. "Avanza applies fixed remuneration as a general rule", with the exception of "a few employees within Corporate Finance and Brokerage who also have the possibility of receiving variable remuneration"; decisions on variable remuneration are made by the CEO or the Board (pp.67-68).

On the ESRS question of whether sustainability performance is linked to incentives, the company states plainly:

"Within Avanza, sustainability targets are integrated into the overall Group targets and thus influence the performance evaluation in the same way as other targets during salary reviews. Avanza evaluates the company's sustainability-related results at an aggregate level; specific sustainability-related targets and results are not linked to variable remuneration." (p.68)

Avanza also "offers participation in warrant programmes, providing an opportunity for all permanent employees to become shareholders in the company" (p.68). No percentage of variable remuneration tied to sustainability or climate targets is disclosed, because on the company's own account none is.

Statement on due diligence

Reference: page 68.

Avanza reports due diligence through the ESRS 2 mapping table rather than as narrative, stating that "the reporting of Avanza's work with due diligence is integrated into the Sustainability Report" (p.68). The table maps each of the five core aspects to the disclosures that carry them:

• (a) Embedding in governance, strategy and business model - ESRS 2 GOV-2 p.67, GOV-3 p.67, SBM-3 p.72.
• (b) Engaging with affected stakeholders - SBM-2 p.71, IRO-1 p.76.
• (c) Identifying and assessing negative impacts - IRO-1 p.76, SBM-3 p.72.
• (d) Taking action - "Actions related to climate impact, own workforce, supplier assessments, and screening of customers to prevent financial crime" (E1-3 p.86, S1-4 p.100, S4 MDR-A p.110, G1-2 p.114).
• (e) Tracking effectiveness and communicating - E1-6 p.89, S1-6 p.103, S1-8-11 pp.103-104, S1-13-17 pp.104-105, S4 MDR-M p.111, G1-2-4 pp.114-116.

The company declares one limitation against its own process: "The due diligence process extends only to those suppliers with which Avanza has direct contracts, which limits the scope related to the value chain" (p.68). This is consistent with BP-1, where the 2025 value chain is "limited to direct customers and direct suppliers, based on the option for a phased-in disclosure of value chain information" (p.64).

Risk management and internal controls over sustainability reporting

Reference: page 68.

"Avanza's established framework for governance, risk management and internal control also applies to sustainability reporting", with processes that "involve reviewing the completeness, reliability, and accuracy of the information" and that "encompass all departments that contribute data and information to the report" (p.68). All data is reconciled centrally before publication.

Risks identified for the reporting process itself (p.68):

• "Risk of incorrect reporting of sustainability data ... This may result from poor data quality, manual entry without validation, or other deficiencies in internal controls."
• "Risk that reported data is inconsistent between reporting periods ... due to changes in methodologies or definitions between periods without sufficient documentation, as well as poor version control or lack of supporting evidence."

High-priority risks are defined as "those that could lead to material misstatements, omissions, or non-compliance with regulations" (p.68).

Mitigations (p.68): a standardised internal and value chain data collection process; ESRS and sustainability reporting training for relevant personnel; specific controls and reconciliations performed both by data providers in the operations and by the controlling unit; and decentralised process ownership so that "area managers address potential deficiencies in the controls identified by the controlling unit". Results of risk assessments and internal controls are reported to Group Management and the RCAC as part of regular reporting.

Strategy, business model and value chain

Reference: pages 68-70.

Avanza is a Swedish digital savings and investment platform. It "offers over 80,000 investment opportunities, including more than 1,400 funds, of which 23 are from its own fund company", plus savings accounts, mortgages and occupational pension solutions (p.69). All employees are in Sweden at the head office in Stockholm; the number of employees during the reporting year was 722 (p.69). Customers are mainly private individuals, with a smaller share of corporate customers.

Value chain (p.70):

• Upstream - counterparties in the financial sector whose products are brokered on the platform, IT service providers, providers of market and ESG data, energy and technical equipment suppliers. "Based on cost analysis, Avanza has primarily identified IT suppliers and partners within the financial sector as material."
• Own operations - the workplace, platform operation and brokerage of own financial products.
• Downstream - customers' investments, and Avanza Fonder's investments. "Avanza's primary impact lies downstream."

The company describes its chain as "characterised by a high degree of indirect impact ... the impact is more indirect compared to a traditional bank or insurance company that, to a greater extent, provides lending and investment products" (p.70).

SFDR-linked exclusions (p.69): "Avanza has analysed its revenue against sectors with significant sustainability impact and concludes that no direct revenue is generated from fossil fuels, chemical production, controversial weapons, or tobacco." Approximately 70 per cent of costs are personnel-related (p.70).

Interests and views of stakeholders

Reference: pages 71-72.

"Avanza's strategy and business model are based on active stakeholder engagement", and the dialogue "is central to Avanza's materiality assessment, and the results form the basis for defining the sustainability strategy and targets" (p.71). The stakeholder groups named are customers, employees, shareholders, suppliers, regulators and society at large.

Engagement methods (p.71):

• Customers - "Ongoing customer surveys, NPS measurements, customer service, savings profiles, and social media."
• Employees - employee surveys, internal forums and the work environment committee; pulse surveys three times a year (p.72).
• Shareholders - quarterly reports, annual general meetings and investor meetings.
• Suppliers - "Procurement processes, Code of Conduct, and supplier dialogues"; the report puts the supplier count at around 400 (p.72).
• Regulators - formal reporting and ongoing regulatory dialogue.

The overview table at p.72 sets each group's prioritised sustainability matters against the engagement method, for example customers prioritising "Decision support, such as analyses, tools, and support for sustainable choices", fees, user-friendliness, cyber security and financial return.

Results "are compiled, analysed, and presented to Group Management and the Board of Directors" (p.71). On the 2025 outcome the company states: "The Group has gathered input from this year's stakeholder dialogues, which have confirmed Avanza's already adopted strategy" (p.71).

Material impacts, risks and opportunities

Reference: pages 72-75.

The double materiality assessment "resulted in the following matters being considered material: Climate change (E1), Own workforce (S1), Consumers and end-users (S4), and Business conduct (G1)" (p.72). The full material IRO table is printed at pp.74-75 with 19 typed rows across the four topics, each carrying its type, materiality and value chain location.

Effect on strategy and business model (p.72): "The impacts, risks and opportunities (IROs) identified are not assessed to entail any material financial risks that justify major changes to the strategy, business model, or value chain." They are managed through three focus areas: Sustainable Investments, Savings for Millions, and Sustainable and Responsible Organisation.

Time profile (p.72): "In the short term, no significant effects on financial position, financial performance, or cash flow are expected in relation to the identified sustainability risks. In the medium and long term, Avanza anticipates that risks related to social and environmental sustainability may increase."

Resilience (p.73): "Avanza's strategy and business model are resilient to material sustainability impacts, risks, and opportunities, in accordance with ESRS 2 SBM-3." Resilience is tested through ICAAP and ORSA climate scenarios: "The stress tests show that direct exposure to physical risks due to climate change is very limited", while transition risk arises because "earnings are partly linked to the value of customers' investments and their trading activity". "In all scenarios, the stress tests show a very limited effect."

Change on the prior year (p.73): "Avanza reports the same material matters as the previous year, as the 2024 report was inspired by the ESRS standards, even though Avanza reported in line with GRI. This year's reporting is more granular."

Process to identify and assess material IROs

Reference: page 76.

"An initial double materiality assessment was carried out in 2023 and was most recently updated in 2025" and "will be revised annually" (p.76). Avanza "has applied the methodologies set out in ESRS 1" in four steps: understanding, identification, assessment, and results/reporting scope.

01 Understanding (p.76) - the business model and value chain are mapped, followed by "a general screening of relevant activities, geographies, and products, taking into account factors with potentially high sustainability impact based on previous analyses and adopted exclusion criteria".

02 Identification (p.76) - "The identification of IROs is based on the list provided in ESRS 1 AR 16. In addition, Avanza has added certain entity-specific disclosures that are not covered by the ESRS list of sustainability matters." Four entity-specific matters follow: financial literacy, financial inclusion, cyber security and financial crime (pp.74-75).

03 Assessment (p.76) - a five-point scale for scale, scope, remediability and likelihood; for positive impacts "only scale and scope are taken into account". On human rights, "the severity is given greater weight than likelihood". Financial materiality uses a harmonised five-point scale, assessed "in collaboration between the Finance and Risk Management functions".

04 Decision (p.76) - results "are approved by the Sustainability Committee, Group Management, and the RCAC ... before being adopted by the Boards of Directors of Avanza Bank Holding and Avanza Bank AB".

Data sources include "industry-specific materiality matrices from SASB ..., MSCI ..., and S&P". The company notes a data-quality gradient: own-workforce data is primary, whereas "the documentation for assessing impacts on, for instance, biodiversity is subject to a higher degree of assumptions" (p.76). Outcome: "No new areas have been added or removed compared to the previous version" (p.76).

Disclosure requirements covered

Reference: page 77.

Avanza prints a real ESRS content index headed "Index and overview of disclosures" at p.77, listing each disclosure requirement against a page number, followed by the "List of datapoints in cross-cutting and topical standards that derive from other EU legislation" at pp.78-81, which marks each datapoint as a page reference, "Non-material" or "Phase-in".

What the index covers (p.77): ESRS 2 BP-1 to IRO-2 (pp.64-77); ESRS E1 with IRO-1, E1-1, SBM-3 and E1-2 to E1-6 (pp.83-89) plus the entity-specific "Climate impact of savings capital on the platform" (pp.87, 89); ESRS S1 with SBM-2, SBM-3 and S1-1 to S1-17 excluding S1-7 and S1-12 (pp.98-105) plus entity-specific financial literacy and financial inclusion (p.108); ESRS S4 with SBM-3 (p.109) and MDR Policies, Actions, Targets, Metrics (pp.110-111) rather than any numbered S4 disclosure requirement; ESRS G1 with IRO-1, GOV-1 and G1-1 to G1-4 (pp.113-115) plus entity-specific financial crime (p.117) and cyber security (p.119); and the EU Taxonomy.

Phase-in table (p.65). Avanza separately lists the requirements it has elected to phase in: E1-9 (2026), S1-7 (2026), S1-12 (2026), the S1-13 training-hours datapoint (2026), S4-2 (2026), and S4-1, S4-3, S4-4 and S4-5 (2027). The company states: "Avanza has chosen to phase-in all disclosure requirements relating to ESRS S4, but provides a high-level report on the policies, actions, metrics, and targets associated with the area" (p.65).

Materiality of information was determined "in accordance with ESRS 1, Chapter 3.2 Material matters and materiality of information" (p.77).

Transition plan for climate change mitigation

Reference: pages 84-85.

Avanza "has adopted a Transition Plan to guide the Group in its work towards achieving climate neutrality through a net-zero strategy by 2045 at the latest. The Transition Plan is supported by the Group's science-based targets, which have been approved by the SBTi" (p.84).

Three main areas (p.84): supporting customers in the transition through sustainable investment alternatives, education and decision support; responsible investments, where Avanza Fonder works through "selecting in companies that promote sustainable development, selecting out investments with high sustainability risks, and influencing through active ownership"; and reducing climate impact in own operations and the supply chain.

Scope-level operationalisation (p.84): "Scope 1: Avanza has no emissions related to Scope 1." Scope 2: 100 per cent renewable electricity and a 50 per cent absolute reduction. Scope 3 category 1: a 50 per cent reduction "through systematic follow-up and clearly defined sustainability requirements for suppliers". Scope 3 category 15: integration of climate perspectives in fund management, with liquidity management "prioritizing green and sustainability-linked instruments".

Paris alignment (p.84): "Avanza has joined the Business Ambition for 1.5 °C and the Group's climate targets have been approved by the SBTi." The long-term net-zero goal "means an emission reduction of at least 90 per cent, followed by the neutralisation of any remaining hard-to-abate emissions".

Approval (p.84): "The Transition Plan was developed in 2025 and will be integrated into the Group's overall business strategy. The plan has been adopted by the Group Management and the Board of Directors of Avanza Bank Holding AB (publ)."

Investments (p.85): "Avanza has not yet quantified the investments required to implement key measures." Locked-in emissions (p.85): a qualitative assessment found that "No identified assets have been assessed to give rise to material locked-in greenhouse gas emissions", helped by the fact that "Avanza does not engage in corporate lending". Avanza "is not excluded from the EU benchmarks for Paris Agreement alignment" (p.85).

Progress (p.84): "2025 is the first year Avanza is applying the Transition Plan, which is why there are no values to compare progress against according to the requirements in ESRS E1-1."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 as reported in the E1 chapter (page 83) and from the E1 SBM-3 subsection (pages 85-86) of the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical and transition split (p.83). "The physical risks are based on NGFS and cover both acute and chronic climate-related risks. Avanza has also assessed transition risks based on the savings capital's sector exposure, where analyzed transition risks include regulatory changes, political decisions, and market development."

Methodology (pp.83, 85). Physical risk mapping uses NGFS scenarios and PACTA data, "where the geographical scope of the savings capital and its exposure to extreme weather, based on a Swedish context, form the foundation". PACTA is used "to identify the sectors that have a high climate impact"; only 3.5 per cent of savings capital sits in those sectors, "all sectors are likely exposed to climate-related risks in the long term" (p.85).

Scenarios (p.85). Three NGFS-inspired scenarios from the Conceptual Note on Short-term Climate Scenarios (2023): "Highway to Paris", "Sudden Wake-up" and "Low Policy Ambition". "Low Policy Ambition" is identified as the high-emission and most adverse case; "Highway to Paris" as the Paris-aligned and most favourable case. No global average temperature projection is stated for any scenario, so the ESRS ¶17(a)(iii) datapoint is not met.

Time horizons (pp.64, 83). Avanza departs from the standard ESRS horizons and uses its own climate-scenario horizons: short 2025-2027, medium 2028-2030, long 2031-2035.

Scope and assumptions (p.85). The analysis covers Avanza Bank and Avanza Pension; "risks that may affect Avanza Fonder are not included in this analysis". Assumptions concern "macroeconomic trends such as inflation and interest rates, the energy mix, and consumer behavior". The analysis is run annually within ICAAP and ORSA.

Climate-specific risk identification and scenario analysis is also presented under ESRS 2 IRO-1 and the E1 chapter's own IRO-1 heading.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 as reported in the E1 chapter (pages 85-86) and from the Group-level SBM-3 resilience statement (page 73) of the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results (pp.73, 85-86). "Scenario analyses and stress tests performed show good resilience in the short and medium term. In the long term, the savings capital is largely exposed to climate-related risks, and the climate's development may therefore have a palpable impact on Avanza's earning capacity" (p.85). The headline outcome is stated at p.86: "Despite conservative assumptions regarding net inflow, credit growth, and cost development, Avanza remains profitable and grows across all scenarios and time horizons." At Group level: "the assessment, based on analysis and stress testing, is that the direct impact from climate change will be limited" (p.73).

Areas of uncertainty (p.85). "The biggest uncertainties in the resilience analysis relate to inflation assumptions in relation to uncertainty about the oil price, assumptions about future interest rates, and stock market development, all of which play a role in how the scenarios evolve. Further limitations are linked to the exclusion of tipping points, uncertainty about political decisions, and methodological limitations regarding the use of damage functions."

Capacity to adjust (pp.73, 86). Resilience is attributed to "the digital business model, Avanza's customer focus, and its rapid adaptability" and "an internal capacity for innovation, enabling swift adaptation of the platform and offering" (p.73). Concrete adaptation levers are named for collateral: "Increased volatility in underlying securities results in the loan-to-value (LTV) ratio being reviewed and potentially lowered for individual issuers", and mortgage collateral is captured "in the annual revaluation" (p.86).

Refresh (pp.85-86). "Avanza conducts the climate scenario analysis annually within the framework of ICAAP and ORSA" and "continuously evaluates the results of the resilience analysis and compares the outcomes across the different time horizons with current exposure and external events".

Scope limitation. The resilience analysis "was performed for Avanza Bank and Pension", so Avanza Fonder is excluded (p.85).

Policies related to climate change mitigation and adaptation

Reference: page 86.

Avanza discloses a single climate policy instrument: "Avanza has adopted a Sustainability and Environmental Policy that addresses climate change mitigation, energy efficiency, and sustainable investments" (p.86).

Scope and IROs addressed (p.86). "The policy contributes to addressing Avanza's climate-related impacts, risks, and opportunities linked to the Group's Scope 2 and Scope 3 related emissions. The policy aims to reduce climate impact and Avanza's exposure to financial climate-related risks. It covers the entire value chain and ensures a structured approach to managing emissions arising from procurement, own operations, and downstream through our investments."

Accountability (p.86). "The responsibility for implementing the policy is decentralized to each company within the Group, where the CEO has the ultimate responsibility for the policy's implementation." Internal control functions, "such as the risk management function, are responsible for follow-up and control of sustainability risks and report to the Board of Directors and the CEO".

Supporting documents (p.86). The policy "is supplemented by several other governing documents that integrate sustainability aspects, including the Instruction for Responsible Investments and Guidelines on Liquidity and Market Risk Management". The Board establishes the policy and monitors the Group's climate transition plan (p.66).

Availability (p.86). "Avanza's Sustainability and Environmental Policy is available on avanza.se/ir."

No separate climate adaptation policy is disclosed; adaptation is handled through the ICAAP and ORSA scenario work rather than a dedicated instrument (pp.85-86).

Actions and resources in relation to climate change policies

Reference: pages 86-87.

Scope 2 (p.86). Emissions arise from electricity, district heating and district cooling for the Stockholm office. "Avanza purchases 100 per cent fossil-free electricity, which is verified by Guarantees of Origin", so residual emissions are "primarily linked to the purchase of district heating and district cooling". "Energy efficiency measures related to ventilation and heating were implemented in the office property during the year, but the results from these have not yet been quantifiable."

Scope 3 category 1 (p.86). During the year Avanza "further developed its process for assessing and following up on suppliers based on ESG requirements", applied "regardless of geographical location", with annual follow-up focused on high-risk suppliers. "The measures to reduce emissions linked to Scope 3 Category 1 have not yet been quantified but will be analyzed in the coming years, based on the inventory conducted during 2025."

Scope 3 category 15 (pp.86-87). This is where the impact sits: "Avanza's largest impact occurs through the Group's financed emissions, where Avanza Fonder accounts for about 95 per cent of the financed emissions and the Group's total emissions." 2025 actions include Avanza Fonder joining Climate Action 100+ and expanding "structured engagement work through dialogues with companies that lack science-based climate targets"; group-wide exclusion criteria covering "companies that derive more than 5 per cent of their revenue from fossil fuels", tobacco, and confirmed breaches of the UN Global Compact; and Paris-Aligned Benchmarks (PAB) for its foreign index funds (p.84). Of the 23 funds managed, "19 funds are classified as Article 8 ... Two of the funds are classified as Article 9" (p.86). "During 2025, 69 per cent of the funds adopted SBT goals" (p.87). Sustainability-linked instruments were 16 per cent of the treasury portfolio at period end (p.87).

Platform (p.87). Focus areas are sustainable investment alternatives, decision support and education; during the year "the focus has been on mapping the climate impact of the savings capital on the platform by measuring the carbon intensity for stocks, funds, and ETFs". Fund companies on the platform "must have signed the Principles for Responsible Investments (PRI)"; 91.0 per cent of fund companies and 99.8 per cent of AUM were covered in 2025.

Resources (p.87). "None of the measures that have been adopted or are planned are expected to generate significant operating expenses and/or capital expenditures."

Targets related to climate change mitigation and adaptation

Reference: pages 88-89.

Headline target table (p.88), base year 2025, target year 2035: total GHG reduction -4,481,004 tCO2e (-50 per cent), of which Scope 2 -12 tCO2e (-50 per cent) and Scope 3 -4,480,992 tCO2e (-50 per cent). No Scope 1 target is set because Avanza reports no Scope 1 emissions.

Scope 2 (p.88). Targets to buy 100 per cent renewable electricity and cut energy-related emissions "by 50 per cent between 2021 and 2030 ... set according to SBTi", supplemented by a reduction "from the 2025 level of 23 tCO2e by 50 per cent by 2035 and 90 per cent by 2045". "Avanza achieved the target of purchasing 100 per cent fossil-free electricity in 2021 and has maintained the same level since then."

Scope 3 category 1 (p.88). "Avanza intends to reduce emissions by 50 per cent by 2035 ... with a base year of 2025 at 3130 tCO2e." Software and information systems "account for just over 50 per cent of the emissions".

Scope 3 category 15 (p.89). Avanza Fonder's existing target that 65 per cent of underlying holdings hold SBTi-approved targets by end-2027 (75 per cent by 2030, 100 per cent by 2040) remains, supplemented by a WACI reduction of 50 per cent by 2035 from the 2025 base. "During 2025, 69 per cent of Avanza Fonder's holdings had adopted SBTs, which means that the Group has reached its sub-target."

Platform (p.89). A target to cut the weighted average carbon intensity of savings capital by 50 per cent over 2025-2035.

Sub-targets and pathway (p.88). "The projected emission pathways for both relative and absolute reductions have sub-targets of a 25 per cent reduction by 2030." Avanza states a gap openly: "Avanza has not yet mapped sector-specific emission pathways and their related emission trajectories but is instead based on Sweden's national commitment to achieve net zero by 2045."

Stakeholder involvement (p.88). "The process has not involved direct consultations with affected stakeholders, but consideration has been given to the interests of stakeholders as well as the political ambitions formulated at the national and EU level."

Energy consumption and mix

Reference: page 89.

Avanza "reports only the energy used for the office in Stockholm, which falls under Scope 2 ... expressed in MWh and refer to final energy consumption. Avanza does not produce any energy" (p.89).

Energy mix table, 2025 (p.89), base year 2025 with no comparative:

• Total energy consumption, own operations: 801 MWh
• From renewable sources: 656 MWh (82 per cent)
• From nuclear sources: 54 MWh (7 per cent)
• From fossil sources: 91 MWh (11 per cent)
• Of which purchased or acquired electricity, heat, steam and cooling from renewable sources: 89 per cent
• Self-generated non-fuel renewable energy: 0 per cent

Composition (p.89). "Avanza purchases 100 per cent renewable electricity in the form of hydropower, which is verified via origin certificates issued by the supplier." Residual emissions arise from district heating and cooling: "73 per cent of the purchased district heating is produced from renewable sources such as solid biofuels and bio-oils, residual waste of renewable origin, and energy from sea and wastewater. Fossil energy constitutes 17 per cent ... Of the purchased energy, 52 per cent is recovered."

Sector classification (p.89). "Avanza operates under NACE Code 64990, 'Other financial service activities, except insurance and pension funding, n.e.c.' The Group thus does not fall under sectors A-H, which are classified as high-emission sectors." The high climate impact sector disaggregation of ESRS E1-5 paragraph 38 therefore does not apply.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 89-91.

Emissions table, 2025 (p.90), 2025 set as base year with no comparatives:

Category 15 splits into Avanza Fonder (Scope 1-2 249,287; Scope 3 8,398,868; Scope 1-3 8,648,155) and the Treasury portfolio (Scope 1-2 4,312; Scope 3 306,376; Scope 1-3 310,688) (p.90). Categories 2 to 14 "have not been assessed as material" (p.91). Financed emissions are 99.97 per cent of the footprint on these figures.

Intensity (p.91). GHG intensity per net revenue is 0.002 tCO2e/SEK on both a location-based and market-based basis, against net revenue of SEK 4,495 million.

Methodology (pp.90-91). Scope 2 uses emission factors from Fortum and Stockholm Exergi, a Heat Market Committee method agreed in 2024 and a Stockholm Exergi EPD valid 2022-2027. Category 1 is spend-based using the Swedish National Agency for Public Procurement's 2024 climate indicators. Category 15 follows PCAF; "approximately 40% of the financed emissions consists of reported data and 60% is estimated data", and the PCAF score for the bond portfolio is assessed at 3 (pp.91, 93).

Limitations disclosed (pp.91-92). "The high proportion of Scope 3 data based on estimates and statistical models means that the outcomes may exhibit higher volatility or necessitate restatements for previous years." Biogenic emissions from district heating are not yet quantified by the supplier and are "expected to be able to publish data from 2026 onwards" (p.91).

Policies related to own workforce

Reference: page 99.

Avanza lists six governing documents covering employees and consultants (p.99): the Sustainability and environmental policy, Instruction on diversity and inclusion, Instruction on anti-discrimination and harassment, Instruction on occupational health and safety, Remuneration policy and Code of Conduct. "The Head of HR is responsible for ensuring that these guidelines are implemented and complied with in the operation, where the Board of Directors and the CEO hold the ultimate responsibility."

International instruments (pp.98-99). "Through these governing documents, Avanza supports the UN Guiding Principles on Business and Human Rights, the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises."

Discrimination grounds (p.99). The documents "encompass all statutory grounds for discrimination ... regardless of sex, transgender identity or expression, ethnic origin, religion or belief, functional impairment, sexual orientation, or age. The absence of reasonable accommodation measures for persons with disabilities is also considered a form of discrimination."

Two stated limitations, both reasoned (pp.99-100).

• "Avanza has no special commitments regarding positive discrimination for individuals from particularly vulnerable groups, as Swedish legislation limits this."
• "Avanza has no specific policy for slavery or forced labour as Swedish legislation explicitly prohibits all forms of forced labour and slavery. These principles are integrated into existing policies, such as Avanza's Code of Conduct and Policy on Equal Treatment."

Availability (p.99). "All policy documents are available on Avanza's intranet, and those that are public are also available on Avanza's external website." The remuneration policy "does not apply to non-employees as these are not paid by Avanza. Other policies cover both employees and non-employees" (p.99).

Processes for engaging with own workforce

Reference: page 100.

"Avanza safeguards the interests of its employees through an open and continuous dialogue at multiple levels of the organization", combining "structured employee surveys and employee dialogues (or performance reviews), as well as ... informal channels", plus information meetings at departmental and company level (p.100).

Accountability (p.100). "The Head of HR has the operational responsibility for ensuring that these contacts take place and that the results from them are considered in Avanza's decisions. In strategic matters, relevant departmental managers are also involved to ensure that the employee perspective is integrated into high-level decisions."

Frequency (pp.98, 102). Pulse surveys are run three times a year with a response rate "around 90 per cent for several years", alongside annual performance reviews, mid-year follow-ups and goal-setting meetings (p.72). A concrete mechanism is named: "Avanza's four-month planning, where employees actively participate in formulating targets and action plans within their respective areas" (p.98).

Workers' representatives (p.100). "Avanza operates solely in the Swedish market and therefore does not have a global framework agreement with workers' representatives." Systematic occupational health and safety work is conducted "in close cooperation with Avanza's Work Environment Committee", which has representatives from both employer and employees (pp.98, 100).

Underrepresented groups (p.100). "Avanza also works proactively to understand the perspectives of underrepresented employees as a step towards creating a more gender-equal workplace. This primarily concerns employee surveys with the aim of retaining, developing, and attracting more women to Avanza."

Effectiveness (p.100). "The effectiveness of the contact with employees is evaluated through employee surveys."

Processes to remediate negative impacts and channels to raise concerns

Reference: page 100.

Channels (p.100). "Relevant channels for capturing negative impacts/consequences include both direct dialogue with the manager or HR and a whistleblower system. Avanza ensures access to these channels through regular information on the intranet, in training sessions, and during the onboarding process for new hires."

Follow-up (p.100). "All incoming cases are systematically monitored and followed up on to ensure promptness, and the channels' function is continuously evaluated, partly through employee surveys. Avanza conducts evaluations to ensure that employees are aware of the tools available and that they have confidence in them."

Whistleblowing mechanics (cross-referenced to G1-1, p.114). Reports may be made to the immediate manager, or "both openly and anonymously via an external whistleblowing system where the information is encrypted". Everyone at Avanza, "including employees and consultants", may submit a case. The Chief Compliance Officer receives reports; where reporting to Compliance is not appropriate, reports may go to HR, the CEO or the Chairman of the Board. Three (1) potential breaches were reported via the system during the year (p.114). Protection follows Directive (EU) 2019/1937, with confidentiality, encryption, anonymity and protection against retaliation (p.114).

Support and remediation (pp.100-101). "Avanza offers comprehensive support for ill health or work injury. Insurance coverage for employees includes rehabilitation insurance, counseling support, and access to occupational health care." Remediation "may include a range of measures, such as rehabilitation, supportive counselling, or, in serious cases, financial compensation", with follow-up "in dialogue with the affected individual" (p.101).

Stated limitation (p.100). "Avanza does not have specific policies linked to compensation and remediation for negative impacts. Swedish labour legislation is strictly followed when deciding on compensation for affected parties."

Taking action on material impacts on own workforce

Reference: pages 100-101.

Actions cover "all employees, including consultants" and are "of an ongoing and recurring nature, meaning they are evaluated continuously on an annual basis" (p.100).

Good working conditions (p.100). The Occupational Health and Safety Committee, with employer and employee representatives, "meets regularly to make decisions on new measures based on completed risk assessments". Risk assessments cover "both the physical and social work environment ... safety inspections, ergonomic reviews, and measurements of air quality". Action plans target discriminatory treatment and harassment, with "a low sickness absence rate of under 3 per cent" as the goal.

Fair remuneration (p.100). "A thorough and annual salary audit is conducted to analyse pay gaps. If differences are discovered that are not based on objective grounds, they are carefully investigated before salary adjustments are approved." Position evaluations are used for new hires and internal mobility.

Competence development (p.101). "In 2025, a comprehensive learning strategy was developed, including training programmes in Avanza's own areas of expertise, as well as in leadership and personal development", with individual development plans set at annual performance reviews and leadership programmes "tailored to different management levels".

Equal treatment (p.101). During 2025 "personal letters have been replaced with competence-based selection questions in the recruitment system", reference checks were made "digital and structured", and Avanza participated in WEday (Women Engineering Day) and IGEday (Introduce a Girl to Engineering Day) to broaden the IT and tech candidate base.

Health (p.101). A wellness allowance, a sports club, parental benefits, crisis management assistance and sickness and rehabilitation insurance. "Avanza has not had any incidents that required external remediation during the reporting year."

Resources (p.101). "None of the actions require significant operating expenditures or capital expenditures to implement", though budget is allocated for training, technology and systems, and dedicated HR and Compliance teams handle employment law, occupational health and safety and ethics.

Targets related to own workforce

Reference: pages 102-103.

Avanza publishes eight own-workforce targets with 2025 outcomes, 2025 and 2030 target levels, a 2024 base year, a trend, scope, governing policy and measurement method (p.102).

*The share of the underrepresented gender is to amount to at least 40 per cent.

Target setting (p.102). "The targets are formulated in consultation with employees through annual performance reviews", supported by pulse surveys three times a year with a response rate "around 90 per cent". "Avanza has formulated its targets based on the trends observed in the financial industry as a whole ... but sets targets based on the organization's own conditions rather than national or EU-related goals."

The one target moving the wrong way (p.103). "The gender distribution within executive management is currently imbalanced, with an overrepresentation of men. In future appointments, including any vacancies, gender equality is taken into account to achieve a more balanced gender distribution over time." Equal pay is reported against an external benchmark: an index of 99, "above the industry average of 95" (p.103).

Characteristics of the undertaking's employees

Reference: page 103.

"During the 2025 reporting period, the number of employees (FTE) increased by 43 people, from 679 employees at year-end 2024 to 722 employees at year-end 2025. All staff in own workforce operates out of the head office in Stockholm, Sweden. Avanza has no employees in other countries" (p.103).

Headcount and gender (p.103):

• Employees at end of reporting period, headcount: 828 (2024 not reported)
• Employees at end of reporting period, FTE: 722 (2024: 679)
• Women 38 per cent / men 62 per cent (unchanged from 2024)

Contract type (p.103):

• Permanent employees: 710 (2024: 673)
• Temporary employees: 12 (2024: 6), 64 per cent women / 36 per cent men (2024: 33/67)
• Non-guaranteed hours employees: 40 (2024: 119)

Turnover (p.103):

• Number of persons who left during the reporting period: 66 (2024: 70)
• Staff turnover: 9 per cent (2024: 11 per cent)

The single-country, single-site profile means no country breakdown is required beyond Sweden. Own workforce is defined in SBM-3 as "employees and self-employed individuals ... permanent employees and hired consultants" (p.98); the consultant population is covered by S1-7, which Avanza has phased in to 2026 (p.65).

Collective bargaining coverage and social dialogue

Reference: page 103.

Avanza reports a nil return and explains it. "Avanza supports the employees' right to unionise and collectively bargain. At the same time, there is a belief in the ability and involvement of the individual, and Avanza has chosen not to sign collective agreements. Zero per cent (0%) of Avanza's employees are covered by collective bargaining agreements" (p.103).

Consequence acknowledged (p.103). "Given this context, it also means that there is no formal trade union representation. Dialogue with employees primarily takes place directly via managers, HR, and employee surveys."

Compensating arrangements (p.103). "Within the HR unit, there is high competence and experience in labour law and union negotiations, along with sophisticated procedures and processes to comply with current laws. Avanza continuously monitors the terms of relevant collective agreements to ensure that comparable terms are offered." The same commitment is repeated under S1-4: "Avanza continuously monitors the terms of relevant collective agreements to ensure that employees are offered competitive and fair terms" (p.100).

European Works Council (p.103). "As Avanza only operates in Sweden, there are no agreements regarding the establishment of European Works Councils."

Since all 722 employees are in Sweden at one site (p.103), the country and region breakdown required where coverage differs across the EEA does not arise: coverage is nil throughout.

Diversity metrics

Reference: page 104.

Gender distribution in executive management (p.104):

• Men: 6 (67 per cent) in 2025, against 4 (45 per cent) in 2024
• Women: 3 (33 per cent) in 2025, against 5 (55 per cent) in 2024

This is the one own-workforce target Avanza marks with a negative trend against its own goal of at least 40 per cent for the underrepresented gender (p.102).

Gender distribution among managers with staff responsibility (p.104):

• Female managers: 47 (46 per cent) in 2025, against 45 (52 per cent) in 2024
• Male managers: 56 (54 per cent) in 2025, against 42 (48 per cent) in 2024

Age distribution of employees (p.104):

• Under 30: 109 (15 per cent), against 115 (17 per cent) in 2024
• 30 to 50: 523 (73 per cent), against 486 (72 per cent) in 2024
• Over 50: 89 (12 per cent), against 76 (11 per cent) in 2024

Group-wide gender split is 38 per cent women and 62 per cent men (p.103). Board gender distribution is reported separately under GOV-1 at 56 per cent men and 44 per cent women (p.66). The company links the picture to a structural cause it names openly: "An indirect potential impact has been identified linked to the difficulty in recruiting women into IT, which is rooted in structural factors" (p.99).

Adequate wages

Reference: page 104.

Avanza reports full coverage and states the benchmark it used, which matters because Sweden has no statutory minimum wage and Avanza has no collective agreements (p.103).

"Although Sweden does not have a statutory minimum wage, Avanza ensures that all employees receive an adequate wage at least in line with reference wages based on the Financial Sector Union's wage statistics and Statistics Sweden's (SCB) wage statistics for Swedish median wages. 100% of Avanza's employees had a wage exceeding this level in 2025." (p.104)

Process (p.104). "Avanza continuously works to ensure adequate wages, including through position evaluations used in connection with new hires and internal mobility. HR is involved to ensure a fair, equal, and quality-assured payroll process."

The same process is described under S1-4, where annual salary audits analyse pay gaps and "if differences are discovered that are not based on objective grounds, they are carefully investigated before salary adjustments are approved" (p.100). The related equal pay index target stood at 99 against a target of 100 (p.102).

Because all employees are in Sweden (p.103), no country-level breakdown of employees paid below an adequate wage arises.

Social protection

Reference: page 104.

"Avanza ensures that all full-time employees on a monthly salary are covered by comprehensive social protection to minimise the risks of income loss during major life events. The protection consists partly of the Swedish social security system and partly of supplementary benefits offered to our employees" (p.104).

Coverage by event (p.104):

• Sickness - "Basic protection is provided by the Swedish social security system and reinforced by the company's own sickness benefits"
• Unemployment - "Protection is provided via the national unemployment insurance system"
• Work-related injuries - "Coverage is offered through the Swedish occupational injury insurance in combination with the Group's insurance solutions"
• Parental leave - "Covered by parental benefits within the social security system, complemented by the Group's parental policy and top-up pay"
• Pension - "Protection is provided by the public pension system and reinforced with occupational pension via Avanza"

Conclusion on gaps (p.104). "Since all of Avanza's full-time employees are based in Sweden, and the Swedish system together with Avanza's benefits covers all mentioned life events, there are no countries or types of employees where social protection is missing."

This is a nil return on the ESRS gap datapoint rather than an absence of disclosure. The scope stated is full-time employees on a monthly salary; the report does not separately address the 12 temporary employees or the 40 non-guaranteed hours employees reported at p.103.

Training and skills development metrics

Reference: page 104.

Metrics reported (p.104):

• Percentage of employees who participated in regular performance and career development reviews: 89 per cent (2024: 89 per cent)
• Number of performance and career development reviews: 606 (2024: 564)
• Proportion of women among those who participated: 32 per cent (2024 not reported)
• Proportion of men among those who participated: 68 per cent (2024 not reported)

Declared partial phase-in (p.104). Avanza states plainly why the training-hours half of S1-13 is absent: "Current system limitations do not support the tracking of training hours or gender distribution; consequently, this disclosure will be phased in." The phased-in disclosures table confirms it, naming "S1-13 Average number of training hours per employee, broken down by gender" with a phase-in financial reporting year of 2026 (p.65). Avanza therefore reports the review-participation limb of S1-13 and defers the training-hours limb, which is why S1-13 appears in the content index at page 104 (p.77) and in the phase-in table at the same time.

Underlying activity (p.101). "In 2025, a comprehensive learning strategy was developed, including training programmes in Avanza's own areas of expertise, as well as in leadership and personal development. Training programmes and digital learning platforms are offered to all employees, along with specific onboarding programmes for new hires. Individual development plans are drawn up during the annual performance reviews." Leadership modules cover "employment law, occupational health and safety, competence based interviews, countering discrimination and harassment, salary and performance reviews".

Health and safety metrics

Reference: page 104.

Metrics reported (p.104):

• Employees covered by the company's health, safety and environment management system based on legal requirements or recognised standards: 100 per cent (2024: 100 per cent)
• Work-related fatalities among own workforce: 0 (2024: 0)
• Work-related accidents among own workforce: 1 (2024: 0)
• Frequency of work-related accidents: 0
• Documented cases of work-related illness subject to legal restrictions on data collection: 0 (2024: 0)
• Days lost to work-related injuries and fatalities: 0 (2024: 0)

Narrative on the single accident (p.104). "During the year, one work-related accident was reported, in the form of an incident that occurred during the commute to or from work. Beyond this, no further work-related accidents or serious incidents have been reported."

Management system (p.99). "Avanza's occupational health and safety policy governs the work to prevent work-related ill health and accidents ... Avanza conducts active and systematic occupational health and safety work to ensure a sound and safe workplace for all employees ... Clear routines are in place to handle deviations and incidents, including discriminatory treatment and harassment."

The related sick leave target is reported under S1-5 at 2.0 per cent against a target of under 3 per cent, improving from 2.4 per cent in 2024 (p.102). No fatalities among other workers on Avanza's sites are reported; the company has one office and no site operations beyond it (p.103).

Work-life balance metrics

Reference: page 104.

Metrics reported (p.104):

• Proportion of employees entitled to leave for family reasons: 100 per cent (2024: 100 per cent)
• Percentage of those who have taken family-related leave: 30 per cent (2024 not reported)
• Of which women: 29 per cent
• Of which men: 31 per cent

Scope of the entitlement (p.104). "100 per cent of Avanza's employees are entitled to family-related leave. This includes the right to parental leave (including pregnancy benefit, parental benefit, and temporary parental benefit), leave for care of a sick child (VAB), and leave due to the death of a close relative, in accordance with Swedish legislation."

Stated ambition (p.104). "Avanza works continuously to encourage an equal take-up of leave to further promote work-life balance for all employees." The 2025 figures show near-parity in take-up, with 31 per cent of men and 29 per cent of women taking family-related leave.

Supporting benefits are described under S1-4, where the company offers "comprehensive parental benefits, crisis management assistance, and sickness and rehabilitation insurance" alongside a wellness allowance (p.101). Social protection for parental leave is reported under S1-11 as "parental benefits within the social security system, complemented by the Group's parental policy and top-up pay" (p.104). Because all employees are in Sweden, the entitlement rests on a single national framework.

Compensation metrics (pay gap and total compensation)

Reference: pages 104-105.

Unadjusted gender pay gap (p.104). Women's salary as a share of men's salary: 91 per cent in 2025, against 95 per cent in 2024. The gap therefore widened by four percentage points year on year.

Explanation given (p.104). "The pay ratio is primarily due to an uneven gender distribution within certain specialist and leading roles that generally have higher salary levels and where men are currently overrepresented. Avanza is actively working to address this imbalance through targeted initiatives to increase the proportion of women in these positions, including via competence-based recruitment. Avanza conducts annual salary mappings to identify, analyse, and remedy any unsubstantiated pay differences."

Total compensation ratio (p.105). CEO compared with the median salary at Avanza Group: 12 in 2025, against 13 in 2024. "The ratio also reflects differences in responsibility within the organisation, where the highest-paid individual has the ultimate responsibility for the entire business. The ratio is considered reasonable in relation to Avanza's size and industry."

The unadjusted gap should be read against the equal pay index reported under S1-5, which measures pay for equal work rather than across the whole population and stood at 99 against a target of 100, up from 98 in 2024 and "above the industry average of 95" (pp.102-103). The two figures measure different things and Avanza reports both.

Incidents, complaints and severe human rights impacts

Reference: page 105.

Metrics reported, all nil (p.105):

Definition applied (p.105). "The disclosure regarding the number of incidents of discrimination or victimisation comprises of cases confirmed following a legal and factual analysis. The definition of discrimination is based on the statutory grounds set out in the Swedish Discrimination Act. No such incidents were confirmed during the year."

The nil return is qualified by the word "confirmed": the S1-5 target table separately reports zero submitted harassment cases against the zero-tolerance target (p.102), and under S1-4 the company states "Avanza has not had any incidents that required external remediation during the reporting year" (p.101). The whistleblowing system, which is open to employees and consultants, received three potential breaches during the year, against one in 2024 (p.114); those are reported under G1-1 rather than as confirmed S1-17 incidents.

Business conduct policies and corporate culture

Reference: page 114.

Policy set (p.114). "Avanza has several policies to promote good business ethics and corporate culture ... the Group has established a Code of Conduct. In the Code of Conduct, adopted by the Board of Directors, all employees are encouraged to report behaviour they deem could be unethical or illegal. Furthermore, Avanza has adopted an instruction on whistleblowing and a policy on bribery." The Code "is appended to every contract" with suppliers, "where the parties are requested to both review and sign", and is "updated annually and communicated to all employees".

Accountability (p.114). "Legal is responsible for corporate governance and develops internal rules. Compliance, the second line of defence, monitors and provides advice and support on the licensed operations. The CEO and the Board of Directors are ultimately responsible."

Whistleblowing (p.114). Reports may go to the immediate manager or, "both openly and anonymously via an external whistleblowing system where the information is encrypted". "Everyone at Avanza, including employees and consultants, can submit a case." The Chief Compliance Officer receives reports; where Compliance is not appropriate, reports may go to HR, the CEO or the Chairman of the Board. "During the year, 3 (1) potential breaches were reported via this system." Investigation follows a defined process in which "an initial assessment of the information is made by the CCO", and the Board "annually receives a report on the number of cases and their subject areas".

Protection (p.114). "In accordance with the Whistleblowing Directive (EU) 2019/1937, established internal reporting channels are in place ... All employees are informed via internal training about their rights as whistleblowers, including protection against retaliation."

Functions at risk (p.114). "An internal risk analysis shows that the functions with the highest exposure to corruption and bribery risks are departments responsible for procurement and those that have direct contact with customers and business partners."

Training (p.114). "Avanza ensures recurring training on the Code of Conduct for all employees. All new employees undergo the training, which is repeated every three years."

Management of relationships with suppliers

Reference: pages 114-115.

Policy (p.114). "Avanza has a Third-party Policy, a Third-party Strategy, and a Supplier Code of Conduct aimed at, among other things, minimising risks and negative impacts on the environment and human rights in the supply chain." The Supplier Code of Conduct "covers the entire Group, with the procurement function having overall responsibility for its implementation". Selection integrates "social and environmental criteria such as working conditions, carbon footprint, and certifications ... through a structured counterparty assessment which includes a review of the supplier's sustainability work and risk profile". A stated limitation: "No explicit consideration is given to local or vulnerable suppliers."

Metrics (p.115). Two measures: "the share of new suppliers that undergo the internal procurement process and the share that meet the requirements in Avanza's Supplier Code of Conduct", screened "based on sustainability risks in the GRC-Watch system". The method "is subject to certain potential limitations regarding counterparties that do not undergo the procurement process".

Target and outcome, 2025 base year (p.115). The target is that 100 per cent of new suppliers signing agreements in the year undergo the procurement process and are evaluated against the Supplier Code of Conduct. The outcomes fall short and are reported as such:

• 90 per cent of new suppliers underwent the procurement process
• 68 per cent of new suppliers signed the Supplier Code of Conduct
• 13 per cent are assessed as meeting the Group's ESG requirements, "based either on the Group's own counterparty assessment or on the supplier having its own code of conduct that meets Avanza's requirements"

Action taken (p.115). "During the year, the transition to a digital portal increased the share of new suppliers reviewed based on Avanza's supplier requirements", and "Avanza introduced new system support and processes to increase the proportion of suppliers undergoing the procurement process."

Payment practices are not addressed in this disclosure; G1-6 is absent from the content index (p.77).

Prevention and detection of corruption and bribery

Reference: page 115.

Control system (p.115). "Avanza has established a control system with procedures to prevent, detect, and manage suspected cases of corruption and bribery. The system includes risk assessments, internal guidelines, and the whistleblowing function. The preventive work is based on a robust organisation with clear mandates, access control, communication regarding internal guidelines, and training initiatives. Systems for detecting suspected cases are primarily linked to controls regarding payments." A Decision and Attestation Order "is established with procedures to minimise the risk of undue influence".

Independence of investigators (p.115). "Investigations of corruption and bribery offences are led by the Compliance function, which is organisationally independent from the functions being scrutinised. Results from completed investigations are reported directly to the Board's Risk, Capital, and Audit Committee and to Management in accordance with established reporting procedures for whistleblowing."

Communication (p.115). "Avanza communicates its policies against corruption and bribery via internal training platforms, the intranet, and induction programmes. Business ethics policies are also made available to the public in both Swedish and English through Avanza's corporate website. Within the Avanza Group, it is mandatory for all employees to confirm knowledge of the business ethics policies."

Training (p.115). "All employees in risk-exposed departments must undergo mandatory training on anti-corruption and combating bribery every three years", covering "relevant legal requirements and internal guidelines", plus scenario-based training "provided to employees within identified high-risk functions". The reported coverage metric is 100 per cent of functions-at-risk covered by training programmes in both 2025 and 2024.

Outcome against target (p.115). "Avanza has a target that 90 per cent of all employees shall complete the training ... During 2025, 86 per cent of the employees in identified high-risk functions participated in the training." "All Board members and members of the Management Team undergo the same training as ordinary employees."

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are reported within the G1-2 and G1-3 disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; under the 2023 ESRS these targets fell under MDR-T.

Avanza discloses two measurable business conduct targets, both with 2025 outcomes that fall short.

1. Supplier screening (p.115). "Avanza has a target that 100 per cent of all new suppliers entering into agreements during the reporting year shall undergo the procurement process and be evaluated based on the requirements in the Supplier Code of Conduct. ... The target is compared against 2025 as the base year and is evaluated continuously." Outcome: 90 per cent underwent the procurement process, 68 per cent signed the Supplier Code of Conduct, and 13 per cent were assessed as meeting the Group's ESG requirements. "These results are monitored annually through internal audits and supplier surveys."

2. Anti-corruption training (p.115). "Avanza has a target that 90 per cent of all employees shall complete the training. The target covers the entire operation and is measured annually and compared with the previous year." Outcome: "During 2025, 86 per cent of the employees in identified high-risk functions participated in the training", against 100 per cent of functions-at-risk covered by training programmes.

Effectiveness tracking in the absence of further targets. Compliance "monitors and provides advice and support on the licensed operations" and reports regulatory compliance to the Board and the CEO, including "identified risks for or deficiencies in Avanza's regulatory compliance", with corporate culture matters "such as ethics, transparency, and sound business culture ... also discussed as needed" (pp.113-114). The Board "annually receives a report on the number of cases and their subject areas" from the whistleblowing system (p.114). The annual suitability assessment of the Board "includes questions concerning experience related to, among other things, the development of culture, as well as social, ethical, and professional standards" (p.114).

No target is set for incidents of corruption or bribery, which were nil in both years (p.116).

Incidents of corruption or bribery

Reference: pages 115-116.

Metrics reported, both nil (p.116):

Confirmation (p.116). "In the event of breaches, an investigation is conducted by Avanza's compliance function, and the results are reported directly to the Board's Risk, Capital and Audit Committee and to Group Management in accordance with established reporting procedures for whistleblowing and the handling of suspected bribery and corruption. During the year, no deviations, breaches, or incidents have been reported."

Basis of the metric, stated openly (p.116). "Avanza bases the metric on cases that have actually been reported and resulted in court rulings, where central assumptions are based on cases being identified through Avanza's whistleblowing system." That definition is narrower than the ESRS G1-4 requirement, which also asks for confirmed incidents that did not reach a conviction, and it should be read alongside G1-1, where "During the year, 3 (1) potential breaches were reported via this system" (p.114). The report does not state the subject matter or outcome of those three reports.

Independence (pp.115-116). "Investigations of corruption and bribery offences are led by the Compliance function, which is organisationally independent from the functions being scrutinised. Furthermore, the Compliance function is responsible for monitoring and following up on incidents that have led to criminal proceedings in accordance with judicial decisions, regardless of whether they are reported internally or via an external third party."